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PAGE 11 <br />APPROACH <br />PAGE 11 KENNEDY SCHOOL SFTS <br />CULTURAL RESOURCES <br />The potential area for improvement does not intersect <br />any historic districts, but does include or run adjacent <br />to several potential historic resources, including two <br />National Register of Historic Places (NRHP) listed <br />properties. Historic Property and/or archaeological <br />investigation by a Qualified Professional Historian will <br />likely be required. The level of impacts will largely be <br />dependent on the exact sidewalks and curb ramps <br />chosen for improvement, and their proximity to <br />any cultural resources discovered during the field <br />investigation. Improvements immediately adjacent to <br />a NRHP eligible or listed property would generally lead <br />to greater impacts, particularly if Right-of-Way (ROW) <br />is required or the improvements change the visual <br />environment. Despite this, it is likely that the project <br />can be designed in such a way to remain eligible for <br />the INDOT Minor Projects Programmatic Agreement. <br />THREATENED & ENDANGERED SPECIES <br />Habitat for endangered species will likely be scarce <br />throughout the project area. However, individual trees <br />do exist within residential lawns within the area for <br />proposed improvement. If any of these trees need to <br />be cleared, the potential impacts to endangered bat <br />species will need to be evaluated, and the resulting <br />Avoidance and Minimization Measures may result in a <br />higher level of CE being required. <br />SOLE SOURCE AQUIFER <br />The project is located in the St. Joseph Sole Source <br />Aquifer (SSA) area. Due to the level of expected <br />excavation, no impacts to the SSA are expected. <br />However, coordination with the EPA will likely be <br />required. <br />ENVIRONMENTAL JUSTICE <br />The proposed project area contains populations <br />of concern for Environmental Justice. If 0.5 acre or <br />more of ROW acquisition is required for the project, <br />a full analysis of impacts to these populations will be <br />required. If it is determined that there will be an undue <br />level of impacts to the populations, a CE Level 4 will be <br />required. Given the scope this would be unlikely, but <br />should be considered during project design. <br />SECTION 4(F) IMPACTS <br />The project area centers around Kennedy Park, a large <br />recreational area with walking trails, baseball and <br />basketball facilities, open fields, and a water park. <br />Additionally, the park is adjacent to the Kennedy <br />Academy, which contains a school playground. The <br />project area also includes the Martin Luther King <br />Jr. Community Center, which hosts open recreation <br />time on weekdays. All of these may possibly qualify <br />as Section 4(f) resources. If ROW is required from any <br />of these potential resources, that would constitute <br />a use of the resource, and could increase the level <br />of CE required for the project. With the proposed <br />scope and potential for improvement to these <br />resources, it is possible that the project could qualify <br />for an exemption from the Section 4(f) requirements. <br />Coordination with both INDOT and the resource <br />owners should be initiated as soon as possible to <br />determine the appropriate Section 4(f) measures. <br />ENVIRONMENTAL <br />With the use of federal funds, a NEPA document <br />will be required for the project. A key to keeping <br />this document and project on schedule will be <br />determining the locations for sidewalk/curb ramp <br />improvement. Coordination with INDOT and other <br />necessary parties over potential impact levels cannot <br />begin until an exact project area is laid out. Once <br />the project area is fully delineated, we will initiate <br />the necessary coordination to determine CE level, <br />and begin preparing the NEPA document. If further <br />investigation for Cultural Resources is required, we <br />will contact a qualified subconsultant to perform that <br />work. No federal permits are expected. A Construction <br />Stormwater General Permit may be required if more <br />than 1 acre of soil disturbance is expected. <br />RIGHT-OF-WAY <br />The amount of ROW acquisition required to construct <br />the project will be the primary determining factor <br />for the level of Environmental Document required. <br />If any is required, the project will not be eligible for <br />the Programmatic Categorical Exclusion (PCE). If the <br />amount of acquisition required is less than 0.5 acre, <br />the project will require a CE Level 1. Any more, and <br />a CE Level 2 or greater will be necessary. Given the <br />extensive potential area for improvement, this 0.5 <br />acre threshold could be passed fairly easily if enough <br />of the work takes place in areas where space within <br />existing ROW is limited. If it is believed that ROW <br />acquisition will be necessary, the expected amount <br />should be delineated early in the project process, to <br />properly determine the required path forward. <br />ENVIRONMENTAL