HUD FORM 4128

For The Proposed

ROSEWOOD TERRACE APARTMENTS 8810 AND 8850 SE OTTY ROAD

HAPPY VALLEY, CLACKAMAS COUNTY, OREGON 97086

Prepared for

PEDCOR INVESTMENTS, A LIMITED LIABILITY COMPANY

770 3RD AVENUE SW CARMEL, INDIANA 46032

And

PR MORTGAGE & INVESTMENTS,

U.S. DEPT OF HOUSING & URBAN DEVELOPMENT

Prepared by

Arkose Environmental, Inc. P.O. Box 560975

The Colony, Texas 75056 Telephone (214) 682-4582

www.arkoseinc.com

AEI PROJECT NO.: 16-203

Inspection Date: September 14, 2016

Report Date: October 10, 2016

CONTENTS

SECTION ONE: HUD FORM 4128

SECTION TWO: FIELD NOTES CHECKLIST

SECTION THREE: AGENCY CORRESPONDENCES

SECTION FOUR: HUD NOISE WORKSHEETS

SECTION FIVE: FIGURES

SECTION ONE:

HUD FORM 4128

Environmental Assessment U.S. Department of Housing 1. Project Number:

and Compliance Findings and Urban Development HUD Program:

for the Related Laws 2. Date Received:

Findings and Recommendations are to be prepared after the environmental analysis is completed. Complete items 1 through 15 as appropriate for all projects. For projects requiring an environmental assessment, also complete parts A and B. For projects categorically excluded under 24 CFR 50.20, Complete Part A. Attach notes and source documentation that support the findings.

3. Project Name and Location (Street, City, County, State): 4. Applicant Name, Address (Street, City, ST, Zip Code), Phone:

Rosewood Terrace Apartments Pedcor Investments, A Limited Liability Company8810 & 8850 SE Otty Road 770 3rd Avenue SWHappy Valley, Clackamas County, Oregon 97086 Carmel, Indiana 46032

(317) 218-2668

5. Multifamily Elderly Other 6. Number of: dwelling units 231 ; 7. Displacement: No Yes

buildings 1 Stories 4 & 5 Acres 5.29 (Explain)

8. New Construction Rehabilitation Other 10. Planning Findings: Is the project in compliance or conformance withthe following plans?

(Explain)

Local Zoning: Yes No Not Applicable 9. Has an Environmental Report (Federal, State, or local) been used

in completing this form? No Yes (If Yes, Identify) Coastal Zone: Yes No Not Applicable

The Phase I ESA was completed by Arkose Environmental, Inc. Explain any “No” answer:

Air Quality (SIP): Yes No Not Applicable

Are there any unresolved conflicts concerning the use of the site?

No Yes (explain): 11. Environmental Finding: (Check one)

Categorical Exclusion is made in accordance with § 50.20 or

Environmental Assessment and Finding of No Significant Impact (FONSI) is made in accordance with § 50.33 or

Environmental Assessment and a Finding of Significant Impact is made, and an Environmental Impact Statement is required inaccordance with §§ 50.33 (d) and § 50.41.

Project is recommended for approval (list any conditions Project is recommended for rejection (state reasons): and requirements):

Based on the previous subsurface and soil vapor investigation and DEQ no further action determinations for the Property, Arkose Environmental, Inc. (AEI) does not recommend further subsurface or soil vapor investigation of the Property at this time.

12. Preparer: (Signature) Date: 10-10-2016 13. Supervisor: (Signature) Date:

14. Comments by Environmental Clearance Officer:(Required for projects over 200 lots/units)

ECO: (Signature) Date:

15. Comments (if any) by HUD Approving Official:

HUD Approving Official: (Signature) Date:

form HUD-4128 (10/28/96) 24 CFR Part 50

221 (d)(4)

Part A: Compliance Findings for § 50.4 Related Laws and Authorities

Project is § 50.4 Laws and In Compliance Source Documentation and Requirements for Approval

Authorities Yes No

16. Coastal Barrier Resources

X According to the USFWS John H. Chafee Coastal Barrier Resources System Habitat and Resource Conservation database, the Property is not located within an area designated as a coastal barrier area.

17. Floodplain Management

(24 CFR Part 55)

X According to the Federal Emergency Management Agency's (FEMA) Flood Insurance Rate Map (FIRM), Clackamas County, Oregon and Incorporated Areas, Map Number 41005C0029D, Panel Number 29 of 1175, effective June 17, 2008, the Property is depicted as Zone X (unshaded). Zone X (unshaded) has been determined to include areas outside the 0.2% annual chance flood (outside 100 and 500-year floodplain).

18. Historic Preservation

(36 CFR Part 800)

X AEI reviewed the National Register of Historic Places to determine if the Property or adjoining properties were listed as historical sites. No listings were noted within a ½-mile radius of the Property. AEI also reviewed the EDR NEPACheck report, which stated that no historic sites were found on or within a ½-mile radius of the Property. The Bell Station Store, located at 9300 SE Bell Avenue is listed within the National Register of Historic Places. This building, reportedly constructed in 1900, is located between ½ and 1 mile northwest of the Property (approximately 5,244 feet). Based on the distance of the Bell Station Store from the Property and the more recent development located between the Property and the identified historic site, it is AEI’s opinion that the proposed apartment complex does not affect the listed historic site.

An information request letter, dated December 18, 2015, was submitted to the Oregon Heritage Division State Historic Preservation Office (SHPO) of the Oregon Park and Recreation Department. AEI received a response from SHPO on January 11, 2016 (SHPO Case No. 15-1998) stating “The project area lies within an area generally perceived to have a high probability for possessing archaeological sites and/or buried human remains. In the absence of sufficient knowledge to predict the location of cultural resources within the project area, extreme caution is recommended during project related ground disturbing activities. Under state law (ORS 358.905 and ORS 97.74) archaeological sites, objects and human remains are protected on both state public and private lands in Oregon. If archaeological objects or sites are discovered during construction, all activities should cease immediately until a professional archaeologist can evaluate the discovery.” AEI also received a letter response from the SHPO on January 22, 2016 (SHPO Case No. 15-1998) requesting further evaluation for eligibility for listing in the National Register. On April 4, 2016, Historical Research Associates, Inc. (HRA) submitted Section 106 Documentation for the property located at 8810-8850 SE Otty Road, Happy Valley (SHPO Case No. 15-1998). HRA surveyed the property at the reconnaissance-level, and reviewed historic maps and records, including GLOS, Metsker Maps, as well the Clackamas County Tax Assessor website to obtain information regarding the history and use of the property. HRA recommended a finding of no historic properties affected, as the buildings and structures on the parcel are recommended not eligible for listing on the National Register of Historic Places. SHPO responded to HRA’s Section 106 Documentation on May 2, 2016 stating, “We have reviewed the materials submitted on the project referenced above, and we concur with the determination that the property is not eligible for listing in the National Register of Historic Places. We also concur that there will be no historic properties affected for this undertaking. This letter refers to aboveground historic resources only. Comments pursuant to a review for archaeological resources have been sent separately (above referenced SHPO Case No. 15-1998 letter dated January 11, 2016). This concludes the requirement for consultation with our office under Section 106 of the National Historic Preservation Act (per 36 CFR Part 800) for above-ground historic properties.”

An information request letter, dated December 18, 2015 was submitted to the following Tribal Historic Preservation Offices (THPOs): Confederated Tribes of the Warm Springs Reservation, the Confederated Tribes of the Grand Ronde Indian Community of Oregon and the Confederated Tribes of Siltetz Indians. A follow-up/second submittal letter was submitted to THPO offices on September 25, 2016. AEI had not received responses from any of the THPO offices at the time this report was completed.

19. Noise Abatement X HUD Noise Worksheets completed by Arkose Environmental, Inc.

(24 CFR Part 51 Subpart B)

20. Hazardous Operations (24 CFR Part 51 Subpart C)

X Site observations, regulatory review and Phase I Environmental Site Assessment performed by AEI.

Project is § 50.4 Laws and In Compliance Source Documentation and Requirements for Approval

Authorities Yes No

21. Airport Hazards

(24 CFR Part 51 Subpart D)

X The closest civil airport is Portland International Airport located 9.50 miles north-northwest. The Portland International Airport has noise contours with landing and takeoff glide paths available for review. Also pilots must abide to existing noise abatement measures. No military airports were located within 15 miles of the Property. AEI determined that the Property is not located within the landing and takeoff glide paths and was outside the 65 dbl noise contours.

22. Protection of Wetlands

(E.O. 11990)

X Based upon information depicted on the National Wetlands Inventory Map (NWI) obtained from the United States Fish and Wildlife Service (USFWS) online, dated September 26, 2016, the “Gladstone, Oregon” quadrangle topographic map, aerial photographs and observations made during the site visit, the Property does not appear to contain potential jurisdictional wetlands including waters of the U.S. as defined and regulated by federal authority under 33 CFR Parts 320-330.

The proposed development will not cross any waters of the U.S. that are regulated by the Army Corps of Engineers (COE). In addition, the proposed project site does not impact any present, proposed, or potential unit of the national Wild and Scenic Rivers Systems.

The Property does not utilize or substantially impair the purpose of any publicly owned land from a public park, recreational area, wildlife and waterfowl refuge lands or historical sites of national, state or local significance as determined by the federal, state, or local officials having jurisdiction thereof.

23. Toxic Chemicals and Radio- active Materials (§ 50.3(j))

X

Regulatory Review and Environmental Site Assessment

24. Other § 50.4 authorities (e.g., endangered species, sole source aquifers, farmlands protection, flood insurance, environmental justice)

X As part of this assessment AEI conducted a search of the USFWS database for the presence of endangered or threatened species within a critical habitat as defined in 50 CFR Part 226. AEI also reviewed an EDR NEPACheck report, which states that no natural areas, (i.e. designated wilderness areas; designated wildlife preserves, sanctuaries and refuges; wild and scenic rivers; threatened or endangered wildlife and critical habitat), were identified on the Property or immediate adjoining properties. Additionally, AEI generated a FWS Trust Resource report for Woodland Crossing Phase II Apartments using the U.S. Fish & Wildlife Service (USFWS) Information Planning and Conservation (IPaC) System online tool. IPaC generates a project site specific report of Threatened & Endangered Species Critical Habitats, Refuges and Wetlands. According to the site specific Trust Resources report, there are no critical habitat, not refuges and no wetlands within the project area.

Based on review of the USFWS threatened and endangered species list, visual observations, the USFWS Trust Resources report, the USFWS Official Species List, the existing development, lack of critical on-site habitat and lack of evidence for the listed species, it is highly unlikely the Property serves as a habitat for endangered species. An information request letter, dated December 18, 2015, was submitted to the Oregon Fish and Wildlife Office in Portland, Oregon and a follow-up/second submittal letter was submitted on September 25, 2016. AEI received a response from Kevin J. Maurice, Wildlife Biologist with the USFWS stating, “There is no mechanism to concur with a no effect determination by the Service. As the designated agent for HUD you have made a determination as an environmental professional based on best available information which resulted in a no effect to listed species determination. In your letter (page 3) you point out the IPaC tool indicated there is no designated critical habitat present as well. You have availed yourself of the sec. 7 process. Document your logic train as to how you developed that no effects determination and the supporting documents used and retain that on file to be able to produce it to defend your determination if there is a 3rd party challenge. The site for the proposed action is an already highly disturbed site in a very urban and light industrial area that does not provide habitat for the listed species listed in the generic county species list.” No further action is recommended.

The Property is not located in the area of a sole source aquifer (SSA). EPA Region 10 Sole Source database was reviewed to confirm that proposed construction on the Property would not impact a sole source aquifer.

The Property is currently developed with industrial/commercial buildings. It is not presently being farmed, is located within an area committed to urban development and is mapped as urban land on the 2010 U.S. Census Urbanized Areas Reference Map for Portland, Oregon; therefore, the Property qualifies as an exemption from the Farmland Protection Policy Act (FPPA Manual Part 523.10(B)(ii)).

24. Other § 50.4 authorities (e.g., endangered species, sole source aquifers, farmlands protection, flood insurance, environmental justice); Continued

The Property is located in Zone X on the National Flood Insurance Program (NFIP) map. Zone X is not considered a Special Flood Hazard Area (SFHA); therefore, it is not mandatory for the owner to purchase and maintain flood insurance protection as a condition of approval of any HUD financial assistance for proposed property acquisition, rehabilitation, conversion, repair or construction.

The Property does not appear to be located in a predominantly minority and/or low-income neighborhood. Additionally, the Property neighborhood does not suffer from disproportionately adverse environmental effects on minority and low-income populations relative to the community-at-large.

No other issues were identified.

Part B: Environmental/Program Factors:

Anticipated Factors Impact/Deficiencies Source Documentation and Requirements for Approval

None Minor Major

25. Unique natural features and areas

X Visual observations, EDR NEPACheck report, USGStopographic map, and aerial photographs

26. Site suitability, access, X compatibility with Visual observations surrounding development 27. Soil stability, erosion, X Visual observations and drainage 28. Nuisances and hazards X Visual observations (natural and built)

29. Water supply/sanitary sewers

X Potable water to the Property is supplied through Sunrise Water Authority. Sunrise Water Authority (SWA) has an Intergovernmental Agreement (IGA) with the City of Happy Valley. SWA obtains surface water from the Clackamas River. According to the 2016 Drinking Water Quality Report, the drinking water meets or exceeds current state and Federal drinking water quality standards, including copper and lead.

Currently, sanitary wastewater disposal is provided through the Clackamas County Services District 1 (CCSD#1) municipal wastewater system. CCSD#1 has an Intergovernmental Agreement (IGA) with the City of Happy Valley.

30. Solid waste disposal X Solid waste disposal is provided through the Sunset Garbage Collection Company.

Currently Sunsets collects the waste once a week (Thursday) for off-site disposal. 31. Schools, parks, recreation, X Visual observations and City of Happy Valley and social services 32. Emergency health care, X Visual observations and City of Happy Valley fire and police services 33. Commercial/retail and X Visual observations and City of Happy Valley transportation 34. Other X No other concerns were identified during the property reconnaissance

SECTION TWO:

FIELD NOTES CHECKLIST

Field Notes Checklist Project Number:

Project Name: Proposed Rosewood Terrace Apartments Location: (street, city, county/state, & zip code)

Northeast corner of Laurel View Drive and George W. Lilies Parkway, Happy Valley, Clackamas County, Oregon 97086 Number of Dwelling Units: 231 Project site is in a location described as:

Central city Suburban

New construction Infill urban development In developing rural area

Rehabilitation: (Refinance) In undeveloped area

Note to Reader: An Environmental Assessment (EA) is a concise public document that a Federal agency must prepare in order to comply with the National Environmental Policy Act (NEPA) and the related Federal environmental laws and authorities. The EA must support decision making process and provide a clear rationale, justification, and documentation for ratings assigned. Instructions It is recommended that this checklist be used by HUD staff who prepare the Environmental Assessment (EA; form HUD-4128). It will constitute full documentation for many factors on the EA, and partial documentation for others. It will avoid narrative reports and expedite the environmental review process. This checklist, which is a slightly revised version of Appendix C of Handbook 1390.2, should be used pending revision of Handbook 1390.2.

The number for each checksheet topic is the number that appears on form HUD-4128. Also, each checklist title/heading is followed by a reference to where the topic appears in the current Handbook 1390.2. Before the site visit, review the Phase I and all background information submitted with the application (if applicable). During the site visit, the preparers of form HUD-4128 are to: (i) answer all relevant questions on this checklist; (ii) use the spaces provided for comments to include supplemental information as well as to record any recommended mitigation measures or requirements for project approval; (iii) key your answers to the relevant questions (using additional sheets of paper to provide more detailed information); and (iv) use the spaces provided for source documentation

to cite the information source used (e.g., title of a technical report, map, or special study; site inspection/field observation; name and location of the qualified data source(s) that provided the information, for example, the local planning agency, the local housing and/or community development agency, the State environmental protection agency, the State Historic Preservation Officer, or other qualified data source.) Preparers are to obtain and use, as appropriate, any environmental report (Federal, State, or local) that may have already been prepared for the property or area in which the property is located. Several different types of maps will be useful in completing the review, such as the project plan or plot map, a location map showing major features and facilities in the vicinity, the USGS topographic map and FEMA flood map for the site area, and zoning/land use maps. Many of the conditions can and should be recorded directly on the project plan. Distances to major features and facilities (e.g., schools and fire stations) and a description of the surrounding area are examples. The plan can then be referenced as “source documentation” on form HUD-4128.

9. Environmental Report

List the Federal, State, or local agencies contacted to obtain their existing environmental reports and other data for the HUD environmental review for the proposed project: A database which meets current ASTM standards of Federal and State agencies was compiled by EDR and a NEPACheck report was provided by EDR. List the major reports obtained: (attach the report(s) or otherwise list the title, author, and publication date) Arkose Environmental, Inc., Phase I ESA for the Property (AEI Project No. 16-203), October 10, 2016, Arkose Environmental, Inc., Phase I ESA for the Property (AEI Project No. 15-265), January 13, 2016, Arkose Environmental, Inc., Limited Phase II Investigation (AEI Project No. 16-133), February 15, 2016, PBS Engineering and Environmental, Letter Requesting Regulatory Closure, June 28, 2016, PBS Engineering and Environmental, Underground Storage Tank Decommissioning Report for 8810 SE Otty Road, Happy Valley, OR 97086 (LUST File No. 03-16-0340, PBS Project No.: 22445.001), April 2016, PBS Engineering and Environmental, Pre-Demolition Asbestos and Lead Paint Survey Report for 8810 SE Otty Road, Happy Valley, OR 97086 (PBS Project No.: 25012.000), April 2016

221(d)4

10. Planning Findings Is the project in compliance or conformance with the local zoning?

Yes No Not Applicable (If no or not applicable, explain) Information reviewed on the City of Happy Valley website

11. Is the project located within a coastal management zone (CZM)? Yes No Not Applicable

12. If your answer is YES, the State Coastal Zone Management (CZM) Agency must make a finding that the project is consistent with

the approved State CZM program

13. Is the State’s finding attached to this checksheet? Yes No

14. Is the project in compliance with the air quality State Implementation Plan (SIP)?

Yes No Not Applicable Comments: The Portland area, including Clackamas County, is currently classified by the U.S. EPA as an “Attainment” area for the ozone National Ambient Air Quality Standard. An attainment area meets the national primary or secondary ambient air quality standard. The two primary precursors to ozone formation are volatile organic compounds (VOCs) and nitrogen oxides (NOx). A general conformity analysis may be required when a project results in an emissions increase of 100 tons per year or greater for either VOCs or NOx. Because the emissions from the proposed Rosewood Terrace Apartments development are expected to be below these thresholds, it is not anticipated to impact the state implementation plan.

Source documentation: U.S. EPA Region 10, Approved Air Quality Implementation Plans in Region 10: https://www.epa.gov/air-quality-implementation-plans/approved-air-quality-implementation-plans-region-10, Oregon Department of Environmental Quality Air Quality Division: http://www.oregon.gov/DEQ/AQ/pages/index.aspx, Oregon Department of Environmental Quality (DEQ) Air Quality Division, Portland Area Carbon Monoxide Maintenance Plan, State Implementation Plan, Volume 2, Section 4.58, December 10, 2004, Oregon Department of Environmental Quality (DEQ), Portland-Vancouver Air Quality Maintenance Area (Oregon Portion) and Salem-keizer Area Ozone Maintenance Plan, adopted by the Environmental Quality Commission February 22, 2007

15. Are there any unresolved conflicts concerning the use of the site?

Yes No

If your answer is YES, briefly explain:

16. Coastal Barrier Resources Is the project located within a coastal barrier designated on a current FEMA flood map or Department of Interior coastal barrier resources map?

Yes No

If your answer is YES, the law prohibits Federal funding of projects in designated coastal barriers.

17. Flood Management (24 CFR Part 55) (see CF 3 and 4 of Handbook 1390.2) Is the project located within a floodplain designated on a current FEMA flood map?

Yes No Identify FEMA flood map used to make this finding:

Community Name and Number: Clackamas County, Oregon and Incorporated Areas Map Number 41005C0029D

Map Panel Number and Date of Map Panel: Panel Number 29 of 1175, effective June 17, 2008

If your answer is YES, use § 55.12 and the floodplain management

Decision making process (§ 55.20) to comply with 24 CFR Part 55.

Comments: According to the Federal Emergency Management Agency's Flood Insurance Rate Map (FIRM), Clackamas County, Oregon and Incorporated Areas, Map Number 41005C0029D, Panel Number 29 of 1175, effective June 17, 2008 the Property is depicted as Zone X (unshaded). This area which includes the proposed apartment building, includes areas determined to be outside the 0.2% annual chance floodplain and areas outside future conditions 1% annual floodplain (outside the 100 and 500-year floodplain).

Source documentation: (attach § 55.20 analysis)

FIRM Clackamas County, Oregon and Incorporated Areas, Map Number 41005C0029D, Panel Number 29 of 1175, effective June 17, 2008

18. Historic Preservation (see CF 2 of Handbook 1390.2)

Has the SHPO been notified of the project and requested to provide comments? Yes No

Is the property listed on or eligible for listing on the National Register of Historic Places? Yes No

Is the property located within or directly adjacent to an historic district? Yes No

Does the property’s area of potential effects include an historic district or property? Yes No

If your answer is YES to any of the above questions, consult with the State Historic Preservation Officer (SHPO) and comply with 36 CFR part 800.

Has the SHPO been or is being advised of HUD’s finding? Yes No

Comments: AEI reviewed the National Register of Historic Places to determine if the Property or adjoining properties were listed as historical sites. No listings were noted within a ½-mile radius of the Property. AEI also reviewed the EDR NEPACheck report, which stated that no historic sites were found on or within a ½-mile radius of the Property. The Bell Station Store, located at 9300 SE Bell Avenue is listed within the National Register of Historic Places. This building, reportedly constructed in 1900, is located between ½ and 1 mile northwest of the Property (approximately 5,244 feet). Based on the distance of the Bell Station Store from the Property and the more recent development located between the Property and the identified historic site, it is AEI’s opinion that the proposed apartment complex does not affect the listed historic site.

An information request letter, dated December 18, 2015, was submitted to the Oregon Heritage Division State Historic Preservation Office (SHPO) of the Oregon Park and Recreation Department. AEI received a response from SHPO on January 11, 2016 (SHPO Case No. 15-1998) stating “The project area lies within an area generally perceived to have a high probability for possessing archaeological sites and/or buried human remains. In the absence of sufficient knowledge to predict the location of cultural resources within the project area, extreme caution is recommended during project related ground disturbing activities. Under state law (ORS 358.905 and ORS 97.74) archaeological sites, objects and human remains are protected on both state public and private lands in Oregon. If archaeological objects or sites are discovered during construction, all activities should cease immediately until a professional archaeologist can evaluate the discovery.” AEI also received a letter response from the SHPO on January 22, 2016 (SHPO Case No. 15-1998) requesting further evaluation for eligibility for listing in the National Register. On April 4, 2016, Historical Research Associates, Inc. (HRA) submitted Section 106 Documentation for the property located at 8810-8850 SE Otty Road, Happy Valley (SHPO Case No. 15-1998). HRA surveyed the property at the reconnaissance-level, and reviewed historic maps and records, including GLOS, Metsker Maps, as well the Clackamas County Tax Assessor website to obtain information regarding the history and use of the property. HRA recommended a finding of no historic properties affected, as the buildings and structures on the parcel are recommended not eligible for listing on the National Register of Historic Places. SHPO responded to HRA’s Section 106 Documentation on May 2, 2016 stating, “We have reviewed the materials submitted on the project referenced above, and we concur with the determination that the property is not eligible for listing in the National Register of Historic Places. We also concur that there will be no historic properties affected for this undertaking. This letter refers to aboveground historic resources only. Comments pursuant to a review for archaeological resources have been sent separately (above referenced SHPO Case No. 15-1998 letter dated January 11, 2016). This concludes the requirement for consultation with our office under Section 106 of the National Historic Preservation Act (per 36 CFR Part 800) for above-ground historic properties.”

An information request letter, dated December 18, 2015 was submitted to the following Tribal Historic Preservation Offices (THPOs): Confederated Tribes of the Warm Springs Reservation, the Confederated Tribes of the Grand Ronde Indian Community of Oregon and the Confederated Tribes of Siltetz Indians. A follow-up/second submittal letter was submitted to THPO offices on September 25, 2016. AEI had not received responses from any of the THPO offices at the time this report was completed.

Source documentation: Copies of the correspondences are included in this report.

19. Noise Abatement (see CF 1 of Handbook 1390.2) Is the project located near a major noise source, i.e., civil airports (within 5 miles), military airfields (15 miles), major highways or busy roads (within 1000 feet), or railroads (within 3000 feet)?

Yes No

If your answer is YES, comply with 24 CFR 51, Subpart B which requires a noise assessment for proposed new construction. Use adopted DNL contours if the noise source is an airport.

Comments: AEI performed a noise survey using the HUD Noise Guidebook and HUD Exchange online DNL Calculator for the proposed Rosewood Terrace multifamily apartment complex in Happy Valley, Clackamas County, Oregon. No civil

airports are located within 5 miles of the Property and no military airports are located within 15 miles of the Property. Therefore, airport noise is considered non-applicable. The Property is located within 3,000 feet of the Tri Met Commuter Green line. The day/night noise level (DNL) for the railroad was calculated to be 55.6, which is considered acceptable (<65).

The Property is within 1,000 feet of U.S. Interstate Highway 205 (I-205) and SE Otty Road. AEI obtained 2015 traffic counts for I-205 from the Oregon Department of Transportation (DOT). Year 2015 traffic counts for SE Otty Road were obtained from Clackamas County Transportation and Engineering Division. The distance to the roadways were determined using the scaled Access and Water Supply Plan (Sheet No. C4.1, dated 8/25/16) completed by Cardno, which includes the proposed Rosewood Terrace development, and Google Earth Pro satellite image measurements. The noise value was calculated based on a 10 year projection. The projected value for traffic noise for both roadways (combined roadway DNL) was determined to be 74.6, which is normally unacceptable (65-75).

AEI calculated the combined value for the noise sources (automobiles and trains) to be 74.6 DNL, which is considered “normally unacceptable”. However, the proposed development could meet HUD’s recommended 45 DNL for interior noise levels with typical noise attenuation measures.

Source documentation: (attach NAG worksheets) Noise worksheets, HUD Noise Guidebook, HUD Exchange DNL Calculator, Oregon Department of Transportation, Clackamas County Transportation and Engineering Division, http://airnav.com/airports/, Access and Water Supply Plan (Sheet No. C4.1, dated 8/25/16) completed by Cardno, Google Earth Pro, http://trimet.org/max/

20. Hazardous Industrial Operations (see CF 5 of Handbook 1390.2) Are industrial facilities handling explosive or fire-prone materials such as liquid propane, gasoline or other storage tanks adjacent to or visible from the project site?

Yes No If your answer is YES, use HUD Hazards Guide and comply with 24 CFR Part 51, Subpart C.

Comments: Based on the site reconnaissance and a regulatory agency database review, industrial facilities handling explosive or fire-prone materials such as liquid propane, gasoline, or other storage tanks are currently on, adjacent to or visible from the Property. A 250-gallon aboveground waste oil tank (AST) was observed within the Spain's Complete Muffler Service facility (located on the Property) during AEI’s December 2015 site reconnaissance. The AST appeared to be in good condition and will be removed from the Property prior to development of the Rosewood Terrace apartment complex. Spain's Complete Muffler Service facility was not accessible during AEI’s reconnaissance on September 14, 2016; therefore, AEI was unable to determine if the AST is still located on-site. If the on-site AST is removed from the Property as planned, it will no longer present an explosive/flammable hazard concern in connection with the Property.

The north adjoining Miles Fiberglass and Composite facility reportedly stores resin and acetone in ASTs and steel drums. The AST sizes were not reported; however, the reported quantity of resin stored at the facility is 5,000-9,999 gallons and the reported quantity of acetone stored at the facility is 500-999 gallons. No ASTs are visible on the Miles Fiberglass and Composites site from the Property.

Acetone is typically used as a general solvent for cleaning purposes. According to DEQ Air Quality Division air permit records, the Miles Fiberglass and Composite facility uses four general processes to form resins into parts. Gelcoat Resin Application uses a spray gun to apply the colored finish coat to the molds before the fiber reinforcement is added. The gelcoat is a special resin used to form what will be the finish of the part. The Mechanical (Spray) Resin Application (SR-A) process uses a spray gun or other device to apply resin to parts. This process generally accounts for most of the resin use at the facility. In Manual Resin Application (MRA), the resin is applied directly to the fiber reinforcement either before or after it is applied to the part. In closed molding, the resin is placed or forced into a closed mold and allowed to cure. Once the resin has cured, the various parts are removed from their molds or forms and trimmed, repaired, assembled and prepared for shipping.

Source documentation: (attach ASD worksheets ) Site observations, EDR Radius Map Report and Oregon DEQ

21. Airport Hazards (see CF 5 of Handbook 1390.2) Is the project within 3,000 feet from the end of a runway at a civil airport?

Yes No Is the project within 2-1/2 miles from the end of a runway at a military airfield?

Yes No If your answer is YES to either of the above questions, comply with 24 CFR Part 51, Subpart D.

Comments: No civil airports are located within 5 miles of the Property and no military airports are located within 15 miles of the Property. The nearest civil airport, Portland International Airport (PDX), is located 8.3 nautical miles north and has noise contours with landing and takeoff glide paths available for review. Also pilots must abide to existing noise abatement measures. AEI determined that the Property is not located within the landing and takeoff glide paths and is outside the PDX 65 dbl noise contours.

Source documentation: Topographic map, EDR NEPA Check and http://www.aeroplanner.com

22. Protection of Wetlands (E.O. 11990) (see CF 3 and 4 of Handbook 1390.2) Are there drainage ways, streams, rivers, or coastlines on or near the site?

Yes No Are there ponds, marshes, bogs, swamps or other wetlands on or near the site?

Yes No

For projects proposing new construction and/or filling, the following applies: Is the project located within a wetland designated on a National Wetlands Inventory map of the Department of the Interior (DOI)?

Yes No

If your answer is YES, E.O. 11990, Protection of Wetlands, discourages Federal funding of new construction or filling in wetlands and compliance is required with the wetlands decision making process (§ 55.20 of 24 CFR Part 55. Use proposed Part 55 published in the Federal Register on January 1, 1990 for wetland procedures).

Comments: Based upon information depicted on the National Wetlands Inventory Map (NWI) obtained from the United States Fish and Wildlife Service (USFWS) online, dated September 26, 2016, the “Gladstone, Oregon” quadrangle topographic map, aerial photographs and observations made during the site visit, the Property does not appear to contain potential jurisdictional wetlands including waters of the U.S. as defined and regulated by federal authority under 33 CFR Parts 320-330.

The proposed development will not cross any waters of the U.S. that are regulated by the Army Corps of Engineers (COE). In addition, the proposed project site does not impact any present, proposed, or potential unit of the national Wild and Scenic Rivers Systems.

The Property does not utilize or substantially impair the purpose of any publicly owned land from a public park, recreational area, wildlife and waterfowl refuge lands or historical sites of national, state or local significance as determined by the federal, state, or local officials having jurisdiction thereof.

Source documentation: (attach § 55.20 analysis for new construction and/or filling) Site observations, USGS topographic maps, aerial photographs, and NWI Map.

23. Toxic Chemicals and Radioactive Materials (see CF 5 of Handbook 1390.2)

Has a Phase I (ASTM) Report been submitted and reviewed? Yes No

If your answer is NO, is a Phase I (ASTM) report needed?

Yes No Are there issues that require a special/specific Phase II report before completing the environmental assessment?

Yes No Is the project site near an industry disposing of chemicals or hazardous wastes?

Yes No Is the site listed on an EPA Superfund National Priorities or CERCLA, or equivalent State list?

Yes No Oregon DEQ Environmental Clean-up Site / Voluntary Clean-up Program (ECSE File #6109) Is the site located within 3,000 feet of a toxic or solid waste landfill site?

Yes No

Does the site have an underground storage tank? Yes No Heating oil tank decommissioned in place

If your answer is YES to any of the above questions, use current techniques by qualified professionals to undertake investigations determined necessary and comply with § 50.3(i).

Are there any unresolved concerns that could lead to HUD being determined to be a Potential Responsible Party (PRP)? Yes No

Comments: The Property, which is identified as Apte Property at 8810 and 8850 SE Otty Road by the DEQ, is registered as a VCP and ECSI site. Groundwater below the site contains arsenic and lead contamination at concentrations above DEQ drinking water RBCs but below RBCs for any other risk pathway. There is no current or reasonably likely future use of groundwater at the site or in the immediate vicinity of the site. On April 14, 2016, the Property owner entered into an agreement with DEQ for further site evaluation. On May 20, 2016, the DEQ issued Comfort Letter on Metals in Groundwater for the Proposed Rosewood Terrace Apartments at 8810 and 8850 SE Otty Road in Happy Valley, Oregon 97086 (ECSE File #6109). On June 28, 2016, PBS Engineering and Environmental submitted a letter requesting regulatory closure of the site related to elevated concentrations of metals in groundwater from temporary borings at the site. On October 4, 2016, the DEQ issued a no further action determination for the Property (ECSEI File #6109), stating the following: “DEQ has determined

that remedial action to address environmental contamination at the Proposed Rosewood Terrace Apartments is complete, and no further action is required.” and “Based on the available information, the Site is currently protective of public health and the environment. The Site requires no further action under the Oregon Environmental Cleanup Law, ORS 465.200 et seq. unless new or previously undisclosed information becomes available, or there are changes in site development or land and water uses, or more contamination is discovered. DEQ will update the Environmental Cleanup Site Information System (ECSI) database to reflect this decision.” Based on the remediation of the Property and the DEQ’s no further action determination, the VCP and ECSI registration of the Property is considered a controlled recognized environmental condition. Source documentation: (attach Phase I ASTM report) Arkose Environmental, Inc., Phase I ESA for the Property (AEI Project No. 16-203), October 10, 2016, Arkose Environmental, Inc., Phase I ESA for the Property (AEI Project No. 15-265), January 13, 2016, Arkose Environmental, Inc., Limited Phase II Investigation (AEI Project No. 16-133), February 15, 2016, PBS Engineering and Environmental, Letter Requesting Regulatory Closure, June 28, 2016, PBS Engineering and Environmental, Underground Storage Tank Decommissioning Report for 8810 SE Otty Road, Happy Valley, OR 97086 (LUST File No. 03-16-0340, PBS Project No.: 22445.001), April 2016, PBS Engineering and Environmental, DEQ No Further Action Determination Letter dated October 4, 2016

24. Other

a. Endangered Species (see EF 3.4 of Handbook 1390.2)

Has the Department of Interior list of Endangered Species and Critical Habitats been reviewed? Yes No

Is the project likely to affect any listed or proposed endangered or threatened species or critical habitats? Yes No

If your answer is YES, compliance is required with Section 7 of the Endangered Species Act, which mandates consultation with the Fish and Wildlife Service in order to preserve the species.

Comments: As part of this assessment AEI conducted a search of the USFWS database for the presence of endangered or threatened species within a critical habitat as defined in 50 CFR Part 226. AEI also reviewed an EDR NEPACheck report, which states that no natural areas, (i.e. designated wilderness areas; designated wildlife preserves, sanctuaries and refuges; wild and scenic rivers; threatened or endangered wildlife and critical habitat), were identified on the Property or immediate adjoining properties.

Additionally, AEI generated a FWS Trust Resource report for Woodland Crossing Phase II Apartments using the U.S. Fish & Wildlife Service (USFWS) Information Planning and Conservation (IPaC) System online tool. IPaC generates a project site specific report of Threatened & Endangered Species Critical Habitats, Refuges and Wetlands. According to the site specific Trust Resources report, there are no critical habitat, not refuges and no wetlands within the project area.

Based on review of the USFWS threatened and endangered species list, visual observations, the USFWS Trust Resources report, the USFWS Official Species List, the existing development, lack of critical on-site habitat and lack of evidence for the listed species, it is highly unlikely the Property serves as a habitat for endangered species. An information request letter, dated December 18, 2015, was submitted to the Oregon Fish and Wildlife Office in Portland, Oregon and a follow-up/second submittal letter was submitted on September 25, 2016. AEI received a response from Kevin J. Maurice, Wildlife Biologist with the USFWS stating, “There is no mechanism to concur with a no effect determination by the Service. As the designated agent for HUD you have made a determination as an environmental professional based on best available information which resulted in a no effect to listed species determination. In your letter (page 3) you point out the IPaC tool indicated there is no designated critical habitat present as well. You have availed yourself of the sec. 7 process. Document your logic train as to how you developed that no effects determination and the supporting documents used and retain that on file to be able to produce it to defend your determination if there is a 3rd party challenge. The site for the proposed action is an already highly disturbed site in a very urban and light industrial area that does not provide habitat for the listed species listed in the generic county species list.” No further action is recommended.

Source documentation: Site observations, IPaC System online tool, US Fish and Wildlife Service, and EDR NEPACheck. A copy of the USFWS correspondence is included in this report.

b. Sole Source aquifers

Will the proposed project affect a sole source or other aquifer? Yes No

Comments: The Property is not located in the area of a sole source aquifer. Source documentation: U.S. EPA Region 10 Water Protection Division (http://www.epa.gov/Region4/water/groundwater/r4ssa.html)

c. Farmlands Protection (see EF 3.3 of Handbook 1390.2)

If the site or area is presently being farmed, does the project conform with the Farmland Protection Policy Act and HUD policy memo?

Yes No N/A

If your answer is YES, compliance is required with 7 CFR Part 658, Department of Agriculture regulations implementing the Act.

Comments: The Property is currently developed with industrial/commercial buildings. It is not presently being farmed, is located within an area committed to urban development and is mapped as urban land on USGS topographic maps and the 2010 U.S. Census Urbanized Areas Reference Map for Portland, Oregon; therefore, the Property qualifies as an exemption from the Farmland Protection Policy Act (FPPA Manual Part 523.10(B)(ii)). Source documentation: 2010 U.S. Census Urbanized Areas Reference Map for Portland, Oregon and site observations, USGS “Gladstone, Oregon” quadrangle topographic map and aerial photographs

d. Flood Insurance

Is the building located or to be located within a Special Flood Hazard Area identified on a current Flood Insurance Rate Map (FIRM)?

Yes No

If your answer is YES, flood insurance protection is required for buildings located or to be located within a Special Flood Hazard Area as a condition of approval of the project. In addition, compliance with § 55.12 and the floodplain management decision making process (§ 55.20) is required (refer to item #17 above). Document the map used to determine Special Flood Hazard Area in above item #17 pertaining to community name and number, map panel number and date of map panel.

e. Environmental Justice Is the project located in a predominantly minority and low-income neighborhood?

Yes No

Does the project site or neighborhood suffer from disproportionately adverse environmental effects on minority and low-income populations relative to the community-at-large?

Yes No

If your answer is YES, compliance is required with E.O. 12898, Federal Actions to Address Environmental Justice.

Comments: Source documentation: Site observations

25. Unique Natural Features and Areas (see EF 3.2 of Handbook 1390.2) Is the site near natural features (i.e., bluffs or cliffs) or near public or private scenic areas?

Yes No

Are other natural resources visible on site or in vicinity? Will any such resources be adversely affected or will they adversely affect the project?

Yes No Comments:

26. Site Suitability, Access, and Compatibility with Surrounding Development (see EF 1.1 and 1.3 of Handbook 1390.2) Has the site been used as a dump, sanitary landfill or mine waste disposal area?

Yes No

Is there paved access to the site? Yes No

Are there other unusual conditions on site? Yes No

Is there indication of: Yes No Yes No distressed vegetation oil/chemical spills

waste material/containers abandoned machinery, cars,

soil staining, pools of liquid refrigerators, etc. loose/empty drums, barrels transformers, fill/vent pipes,

pipelines, drainage structures Transformers

Is the project compatible with surrounding area in terms of: Yes No Yes No

Land use Building type (low/high-rise)

Height, bulk, mass Building density

Will the project be unduly influenced by: Yes No Yes No

Building deterioration Transition of land uses

Postponed maintenance Incompatible land uses

Obsolete public facilities Inadequate off-street parking

Are there air pollution generators nearby which would adversely affect the site: Yes No Yes No

Heavy industry Large parking facilities

Incinerators (1000 or more cars)

Power generating plants Heavy travelled highway U.S. I-205

Oil refineries (6 or more lanes)

Cement plants Other ___________________

Comments: Six pole-mounted transformers were observed in the utility easement along SE Otty Road. The transformers are reportedly owned and operated by Portland General Electric (PGE). According to information reviewed on the PGE website, all of the transformers owned by PGE contain less than 50 ppm PCBs, and are not considered PCB units. They classify oil-filled electric equipment in accordance with applicable federal regulations (40 CFR Part 761). Equipment manufactured after January 1, 1980, is classified as non-PCB (less than 50 ppm). In the event of a future spill or release of dielectric fluid or other substances, PGE will meet or exceed all state and federal requirements in the areas of response, notification, clean-up, disposal, and documentation of the event. Any special or unique circumstance regarding future transformers at this location should be brought to the attention of PGE. Transformers do not represent evidence of a recognized environmental condition in connection with the Property.

Fluorescent light fixtures were observed throughout the structure. Based on the age of the structure, some ballasts within the fixtures may be PCB containing. If during demolition and/or renovation, labeling does not identify the ballasts as “Non-PCB” containing, the ballasts must be assumed to contain PCB levels above the Federal threshold of 1 lb. oil per device in the old fluorescent light ballasts until proven otherwise. Under the Toxic Substance Control Act (TSCA) 40 CFR 761, the EPA regulates PCB concentrations greater than 50 ppm. This is important because any PCB containing ballast must be disposed according to established guidelines. No evidence of damage or leakage was observed, therefore, the ballasts are not considered evidence of a recognized environmental condition.

No other exterior electrical equipment expected to contain PCBs was observed on or immediately adjacent to the Property during AEI’s reconnaissance.

The Property is located approximately 100 feet west of U.S. Interstate Highway 205.

Source documentation: Visual observations, Google Earth and Portland General Electric

27. Soil Stability, Erosion, and Drainage (see EF 1.2 of Handbook 1390.2)

Slopes: Not Applicable Steep Moderate Slight Is there evidence of slope erosion or unstable slope conditions on or near the site?

Yes No Is there evidence of ground subsidence, high water table, or other unusual conditions on the site?

Yes No Is there any visible evidence of soil problems (foundations cracking or settling, basement flooding, etc.) in the neighborhood of the site?

Yes No Have soil studies or borings been made for the project site or the area?

Yes No Unknown Do the soil studies or borings indicate marginal or unsatisfactory soil conditions?

Yes No Is there indication of cross-lot runoff, swales, drainage flows on the property?

Yes No Are there visual indications of filled ground?

Yes No

If your answer is YES, was a 79(g) report/analysis submitted? Yes No

Are there active rills and gullies on site? Yes No

If the site is not to be served by a municipal waste water disposal system, has a report of the soil conditions suitable for on-site septic systems been submitted?

Yes No N.A. Is a soils report (other than structural) needed?

Yes No Unknown Are structural borings or a dynamic soil analysis/geological study needed?

Yes No Unknown

Comments:

Source documentation

28. Nuisances and Hazards (see EF 1.3 and 1.4 of Handbook 1390.2)

Will the project be affected by natural hazards:

Yes No Yes No Faults, fracture Fire hazard materials

Cliffs, bluffs, crevices Wind/sand storm concerns

Slope-failures from rains Poisonous plants, insects, animals

Unprotected water bodies Hazardous terrain features

Will the project be affected by built hazards and nuisances:

Yes No Yes No Hazardous street Inadequate screened

Dangerous intersection drainage catchments

Through traffic Hazards in vacant lots

Inadequate separation of Chemical tank-car terminal pedestrian/vehicle traffic Other hazardous chemical storage

Children’s play areas located next to High-pressure gas or liquid petroleum freeway or other high traffic way transmission lines on site

Inadequate street lighting Overhead transmission lines

Quarries or other excavations Hazardous cargo transportation routes

Dumps/sanitary landfills or mining Oil or gas wells

Railroad crossing Industrial operations

Will the project be affected by nuisances: Yes No Yes No

Gas, smoke, fumes Unsightly land uses

Odors Front-lawn parking

Vibration Abandoned vehicle

Glare from parking area Vermin infestation

Vacant/boarded-up Industrial nuisances

buildings Other

Comments: According to the US Seismic Zones Map prepared by the U.S. Coast and Geodetic Survey, Clackamas County lies in Zone 3. The Property is located in an area threatened by three types of earthquakes. But there is currently significant uncertainty about exactly where, how often and how big future earthquakes will be. This uncertainty makes it difficult to rely on a traditional probability-based approach to hazard mapping, which would provide information about absolute levels of ground shaking to be expected and how often such levels might be reached. The three types of earthquakes are crustal earthquakes, Intraslab or Benioff earthquakes and great subduction earthquakes. In the area of the Property, the most common are crustal earthquakes, which occur at depths of 6-10 miles below the surface. The few moderate earthquakes that have originated in area have been this type of earthquake. Intraslab or Benioff earthquakes are the type that severely rocked the Puget Sound region in 1949 and again in 1965. Intraplate earthquakes occur within the remains of the ocean floor, which has been shoved (subducted) beneath North America. Great subduction earthquakes occur around the world in subduction zones, where continent-sized pieces of the earth's crust are shoved deep into the body of the earth. These earthquakes consistently are among the most powerful recorded, often having magnitudes of 8 to

9 on the moment magnitude scale. The Cascadia Subduction Zone, which has long been recognized off the coast of Oregon and Washington, has had no great subduction earthquakes during our short 200-year historical record. However, in the past five years, a variety of studies have found widespread evidence that these great events have occurred repeatedly in the past, most recently about 300 years ago in the latter part of the 17th century. The best evidence available suggests that these great earthquakes have occurred, on average, every 350 to 700 years, and there is reason to believe that they will continue to occur in the future. Provided structures conform to the NEHRP Recommended Seismic Provisions for New Building and Other Structures 2009 Edition (FEMA P-750) Uniform Building Codes, seismic activity should not present a concern to the Property.

The Property is located near the base of Mount Scott. According to the 1984 USGS Gladstone, Oregon 7.5-minute topographic map, the elevation of the Property ranges from approximately 250 feet above mean sea level (MSL) on the eastern portion of the site to approximately 210 feet MSL on the western portion of the Property. Soils on the Property have a light to moderate hazard of water erosion.

Source documentation Visual observation, US Seismic Zones Map prepared by the U.S. Coast and Geodetic Survey, USGS “Gladstone, Oregon” quadrangle topographic map, and United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Web Soil Survey for Clackamas County, Oregon

29. Water, Supply, Sanitary Sewers, and Solid Waste Disposal (see EF 2.1, 2.2, and 2.4 of Handbook 1390.2)

Is the site served by an adequate and acceptable:

water supply Yes No Municipal Private;

sanitary sewers and waste water disposal systems Yes No Municipal Private;

and trash collection and solid waste disposal Yes No Municipal Private.

If the water supply is non-municipal, has an acceptable “system” been approved by appropriate authorities and agencies? Yes No

If the sanitary sewers and waste water disposal systems are non-municipal, has an acceptable “system” been approved by appropriate authorities and agencies?

Yes No

Comments: Source documentation: City of Happy Valley

30. Schools, Parks, Recreation, and Social Services (see U/EF 4, 5, and 6 of Handbook 1390.2)

Will the local school system have the capability to service the potential school age children from the project? Yes No

Are parks and play spaces available on site or nearby? Yes No

Will social services be available on site or nearby for residents of the proposed project? Yes No

Comments : Source documentation City of Happy Valley and visual observation

31. Emergency Health Care, Fire and Police Services (see U/EF 7, 8, and 9 of Handbook 1390.2)

Are emergency health care providers located within reasonable proximity to the proposed project? Yes No Approximate response time: <5 min

Are police services located within reasonable proximity to the proposed project? Yes No Approximate response time: <5 min

Is fire fighting protection (X) municipal ( ) volunteer adequate and equipped to service the project?

Yes No Approximate/estimated response time: <5 min

Comments:

Source documentation City of Happy Valley and visual observations

32. Commercial/Retail and Transportation (see U/EF 10 and 11 of Handbook 1390.2)

Are commercial/retail shopping services nearby? Yes No

Is the project accessible to employment, shopping and services by public transportation or private vehicle?

Is adequate public transportation available from the project to these facilities? Yes No

Are the approaches to the project convenient, safe and attractive? Yes No

33. Conditions and Requirements for Approval: Are mitigation measures required?

Yes No If your answer is YES, list and describe:

Brief Description of the Project: The property is proposed for development of a 231unit multifamily residential apartment complex

Field Inspection on: 09/14/2016

By: Lui Barkkume

Signature

SECTION THREE:

AGENCY CORRESPONDENCES

Scanned by CamScanner

Department of Environmental Quality Northwest Region

800 NE Multnomah Street Suite 600 Kate Brown, Governor Portland, Oregon 97232

(800) 452-4011

May 20, 2016 Also sent by e-mail

Daniel Apte 10336 Loch Lomond Road, #239 Middletown, California 95461

RE: DEQ Comfort Letter on Metals in Groundwater Proposed Rosewood Terrace Apartments 8810 and 8850 SE Otty Road, Happy Valley, Oregon 97086 ECSI File# 6109

Dear Daniel Apte:

This letter provides the Oregon Department of Environmental Quality’s (DEQ) determination that existing concentrations of metals in groundwater are unlikely to pose an unacceptable risk at the above referenced property. Your attorney, Carson Bowler, requested this determination, which DEQ agreed to provide in the form of a “Comfort Letter” based on our limited review of site information.

The DEQ reviewed two documents prepared by Arkose Environmental, Inc. (AEI) in collaboration with PBS Engineering and Environmental (PBS) for the above referenced property: 1) Phase I Environmental Site Assessment, Proposed Rosewood Terrace Multifamily ApartmentComplex, 8810 & 8850 SE Otty Road, Happy Valley, Clackamas County, Oregon, 97086(January 13, 2016; Phase I Report); and 2) Limited Phase II Investigation, Proposed RosewoodTerrace Apartments, 8810 and 8850 SE Otty Road, Happy Valley, Clackamas County, Oregon,97086 (February 15, 2016; Phase II Report). This review is in general accordance with the CostRecovery Agreement that you entered into with the DEQ on April 15, 2016.

The property consists of two contiguous tracts totaling approximately 5.4 acres, currently owned by Daniel L. Apte. Tract 1, identified as Parcel ID# 00048647, is a 3.36 acre tract with two physical addresses; 8810 and 8830 SE Otty Road, and Tract 2, identified as Parcel ID # 00049101, is a 1.99 acre tract with a physical address of 8850 SE Otty Road. Spain’s Muffler Service has physical address of 8830 SE Otty Road and occupies the western half of a structure located in the northwest portion of the Property. The remaining portions of the property are occupied by Emerick Construction which has a physical address of 8850 SE Otty Road.

The Phase I Report identified the following recognized environmental conditions (RECs) in connection with the property that were subsequently evaluated in a Phase II investigation.

• A fill pipe located on the west site of the Emerick Construction office building, labeledoil, which appears to be associated with a heating oil tank. The lack of documentation onthe status of the suspected tank presents a recognized environmental condition.

Mr. Daniel Apte May 20, 2016 Page 2 of 3

• Spain’s Complete Muffler Service is located and has been operating on the property since 1985. The length of operation, observations of a waste oil tank, historical automotive activities, and the current and former use of the property present a recognized environmental condition.

• Emerick Construction Company had a leaking underground storage tank that was removed from the property. Petroleum products that produce vapors may have impacted the Spain’s Complete Muffler Service and Emerick Construction Company sites. The potential for vapors to occur in the subsurface below proposed structures presents a recognized environmental condition.

• A 250-gallon above ground storage tank (AST) was observed within the Spain’s Complete Muffler Service facility located on the property. The presence of an AST on the property presents an explosive/flammable hazard which is a recognized environmental hazard. If the AST is removed from the property prior to development as planned, explosive/flammable hazards will no longer present a concern.

The Phase II investigation was conducted to collect additional information with respect to the RECs identified in the Phase I Report. The assessment included installation of seven soil borings (SB-1, SB-2, SB-3, SB-4, SB-5, SB-6, and SB-7) to collect subsurface soil and/or groundwater samples for laboratory analysis. A total of ten soil samples and seven groundwater samples were collected. Four soil samples and one of the groundwater samples were placed on hold. Soil samples were analyzed for total petroleum hydrocarbons (TPH), including gasoline, diesel, and residual range organics. Diesel fuel constituents were detected in soil collected from soil boring SB-4 located near the suspected heating oil underground storage tank. The identified concentrations are below the DEQ cleanup levels for soil. Concentrations of TPH constituents in the remaining soil samples are below laboratory detection limits. Groundwater samples collected from SB-6 and SB-7 were analyzed for TPH. The constituents were below laboratory detection limits for TPH, including gasoline, diesel, and residual range organics. Groundwater samples collected from SB- 1, SB-2, SB-3, and SB-4 were analyzed for RCRA metals, volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs). RCRA metals including arsenic and lead were detected in groundwater samples collected from the property above the DEQ Residential Risk-Based Concentrations (RBCs) for Groundwater Ingestion. No VOCs or SVOCs were detected in any of the groundwater samples collected from the property during the Phase II investigation. The arsenic and lead concentrations in groundwater are summarized in the table below.

Metal

Oregon DEQ Urban Residential RBC

(µg/l)

Laboratory Results (µg/l)

SB-1 SB-2 SB-3 SB-4

Arsenic 0.21 <10 85.4 10.3 31.9

Lead 15 24.7 390 32.4 102 Soil gas collection was also attempted, but was unsuccessful due to the low-permeability of the soils. The suspected heating oil underground storage tank was investigated through soil probing

Mr. Daniel Apte May 20, 2016 Page 3 of 3 with fiberglass soil probes, probing of the fill port with Teflon tubing, and use of a magnetometer. It could not be determined during the Phase II investigation whether a heating oil underground storage tank (HOT) is present below the Emerick building. The HOT was found in a subsequent HOT assessment and decommissioning completed by PBS in April 2016. The decommissioning report and certification that the cleanup met DEQ requirements are filed under LUST file 03-16-0340. This file has been closed by DEQ. Based on our review of the Phase I Report and Phase II Report, DEQ concludes the following:

• Groundwater below the site contains arsenic and lead contamination at concentrations above DEQ drinking water RBCs but below RBCs for any other risk pathway.

• Shallow groundwater is present in low-permeability soils at depths ranging from 15 to 19 feet below ground surface.

• There is no current or reasonably likely future use of groundwater at the site or in the immediate vicinity of the site.

• Existing concentrations of metals in groundwater are unlikely to pose an unacceptable risk to human health or the environment.

These conclusions are based solely on our review of the Phase I Report and Phase II Report and should not be interpreted as a No Further Action determination for the property. Such a determination would require additional review of site conditions and further consultation with DEQ. In the event that contaminated soil or groundwater is encountered in the future, it must be handled and disposed of in accordance with local, state and federal regulations. Please do not hesitate to contact me with questions regarding this letter. Sincerely, Sarah A. Greenfield, P.E. Project Manager NWR Cleanup Section Oregon DEQ 503-229-5245 Cc: Carson Bowler, Schwabe, Williamson & Wyatt ECSI File# 6109

Department of Environmental Quality

Northwest Region

800 NE Multnomah Street Suite 600

Kate Brown, Governor Portland, Oregon 97232

(800) 452-4011

October 4, 2016 Also sent by e-mail

Daniel Apte

10336 Loch Lomond Road, #239

Middletown, California 95461

RE: No Further Action Determination

Proposed Rosewood Terrace Apartments

8810 and 8850 SE Otty Road, Happy Valley, Oregon 97086

ECSI File# 6109

Dear Mr. Apte:

The Oregon Department of Environmental Quality (DEQ) has completed a review of the available

information for the Proposed Rosewood Terrace Apartments located at 8810 and 8850 SE Otty Road in

Happy Valley, Oregon (Site). The property consists of two contiguous tracts totaling approximately 5.4

acres, currently owned by Daniel L. Apte. Tract 1 (Taxlot No.12E28CC00100) is a 3.36 acre tract with

two physical addresses; 8810 and 8830 SE Otty Road. Tract 2 (Taxlot No. 12E28CD01100) is a 1.99 acre

tract with a physical address of 8850 SE Otty Road. Spain’s Muffler Service has physical address of 8830

SE Otty Road and occupies the western half of a structure located in the northwest portion of the

Property. The remaining portions of the property are occupied by Emerick Construction which has a

physical address of 8850 SE Otty Road.

DEQ has determined that remedial action to address environmental contamination at the Proposed

Rosewood Terrace Apartments is complete, and no further action is required. This determination is based

on the DEQ regulations and the facts as we now understand them including, but not limited to the

following:

Spain’s Complete Muffler Service has been operating on the property since 1985 providing

automotive services. A vacant office building and various other structures located on the property

were most recently used by Emerick Construction. The property is zoned Station Community

Mixed Use (SCMU) which provides for multifamily development.

In 1989, two underground storage tanks were decommissioned and removed from the property by

Emerick Construction. Approximately 500 cubic yards of petroleum-contaminated soil was

removed. No groundwater was encountered. DEQ issued a No Further Action letter on April 18,

1990 and the case was closed under LUST File No.03-89-0180.

In March 2016, a heating oil underground storage tank (HOT) located near Emerick Construction

was decommissioned in-place and closed by DEQ under LUST File No. 03-16-0340.

A 250-gallon above ground storage tank (AST) is located at Spain’s Complete Muffler Service

facility. This AST will be removed prior to development of the property.

In January 2016, seven soil borings were advanced on the property (SB-1, SB-2, SB-3, SB-4, SB-5,

SB-6, and SB-7; see attached figure) to evaluate whether hazardous substances have impacted the

Property. Ten soil samples and seven groundwater samples were collected. Groundwater was

encountered in low-permeability soils at depths ranging from 15 to 19 feet below ground surface.

o Six soil samples were analyzed for total petroleum hydrocarbons (TPH), including gasoline,

diesel, and residual range organics. The remaining soil samples were placed on hold.

Concentrations of TPH constituents in soil were either below laboratory detection limits or

below DEQ’s most stringent risk-based concentrations (RBCs).

Mr. Daniel Apte

October 4, 2016

Page 2 of 2

o Six groundwater samples were analyzed. Groundwater samples collected from SB-6 and SB-

7 were analyzed for TPH, including gasoline, diesel, and residual range organics. The

constituents were below laboratory detection limits for TPH. Groundwater samples collected

from SB-1, SB-2, SB-3, and SB-4 were analyzed for Resource Conservation and Recovery

Act (RCRA) metals, volatile organic compounds (VOCs), and semi-volatile organic

compounds (SVOCs). No VOCs or SVOCs were detected in any of the groundwater samples.

Arsenic and lead were detected in groundwater at concentrations above DEQ RBCs for

ingestion in drinking water but below RBCs for any other exposure pathway. These

concentrations are likely related to elevated suspended solids generated during drilling.

Based on consideration of factors including quality, yield, lack of water wells and property use

restrictions already in place at the adjacent down-gradient property, there is no current or

reasonably likely future use of groundwater at the site or in the immediate vicinity of the site. As a

result, groundwater containing dissolved arsenic and lead is unlikely to pose unacceptable risks to

future residents or employees.

On August 18, 2016, DEQ issued a 30-day notice to the adjacent off-site property owner, notifying

them of potential groundwater contamination at the site and of DEQ’s proposal to issue an NFA

determination. No comments or inquiries were received during the specified comment period.

Based on the available information, the Site is currently protective of public health and the environment.

The Site requires no further action under the Oregon Environmental Cleanup Law, ORS 465.200 et seq.

unless new or previously undisclosed information becomes available, or there are changes in site

development or land and water uses, or more contamination is discovered. DEQ will update the

Environmental Cleanup Site Information System (ECSI) database to reflect this decision.

If any contaminated soil or groundwater is encountered in the future, it must be handled and disposed of

in accordance with local, state and federal regulations.

DEQ recommends keeping a copy of all of the documentation associated with this remedial action with

the permanent facility records. If you have any questions, please contact Sarah Greenfield at 503-229-

5245, or via email at greenfield.sarah@deq.state.or.us.

Sincerely,

Kevin Parrett, Manager

Northwest Region Cleanup Section

Attachments: Land Title Survey

Cc: Denis Terzian, PBS Engineering and Environmental (via e-mail)

Tom Shimota, Jones Lang LaSalle (via e-mail)

Carson Bowler, Schwabe, Williamson & Wyatt (via e-mail)

ECSI File# 6109

SB-1

SB-2

SB-3

SB-4SB-6

SB-7

SB-5

P.O. Box 560975, The Colony, Texas 75056

phone (214) 682-4582 fax (972) 668-3373 www.arkoseinc.com

December 23, 2015 Oregon Heritage Oregon Parks & Recreation Department 725 Summer St NE, Suite C Salem, Oregon 97301

(503) 986-0690 Re: Historical Review Proposed Rosewood Terrace Apartments

8810-8850 SE Otty Road Happy Valley, Clackamas County, Oregon 97086

AEI Project No. 15-265

To Whom It May Concern:

Pursuant to 36 CFR 800.4 Arkose Environmental, Inc. (AEI) is submitting this letter request to provide your office with the necessary information and our determination for the following proposed development with respect to historical and cultural properties know to be within the undertaking’s area of potential effects:

HUD PROGRAM:

HUD 221(d)(4) – New Construction for a multi-family apartment complex

LOCATION:

The Property is located at 8810 and 8850 SE Otty Road in Happy Valley, Oregon 46360 (the “Property”). The Property is specifically located on the south side of SE Otty Road approximately 180 feet west of US Highway 205. The approximate center of the Property is located 45.45040000 north latitude and -122.57360000 west longitude in the south-central portion of Happy Valley, Oregon.

LEGAL DESCRIPTION:

According to the Clackamas County Department of Assessment and Taxation online database, the Property consists of two contiguous tracts of land in the southwest ¼ of Section 28, Township 1 South, Range 2 East of the Willamette Meridian in Clackamas County, Oregon. Tract 1 was identified as a 3.36 acre (146,361.6 ft2) tract with two physical addresses. The addresses included 8810 and 8830 SE Otty Road. Tract 1 was identified as Parcel ID # 00048647 (Reference Parcel Number 12E28CC00100). Tract 2 was identified as a 1.99 acre (86,684.4 ft2) tract with a physical address of 8850 SE Otty Road. Tract 2 was identified as Parcel ID # 00049101 (Reference Number 12E28CD01100). According to information provided in the Clackamas County Department of Assessment and Taxation online database, the Property is currently owned by Daniel L. Apte as recorded in a Warranty Deed (2012-000924) dated January 10, 2012.

2

PRESENT CONDITION OF SITE:

The Property is irregular in shape and encompasses two tracts of land totaling 5.29 acres (233,046 ft2). The Property is developed with the operational Spain's Complete Muffler Service facility (8830 SE Otty Road) which occupies the western half of a Quonset type structure located on the northwest portion of the Property and Emerick Construction Company (8850 SE Otty Road) which uses the remaining portions of the Property for equipment storage. The Emerick Construction Company facility consist of a two-story office/storage building, a covered lean-to type structure that includes an enclosed garage, a wood working building attached to the aforementioned Quonset type building, the eastern half of the Quonset building used for storage, a detached storage building, open parking, fenced storage areas and vacant land.

According to the Clackamas County Comprehensive Zoning Plan obtained through the Clackamas County Planning Division's on-line database, the property is zoned SCMU (Station Community Mixed Use).

SITE VICINITY:

The vicinity of the Property can generally be described as mixed-use development. The Property is specifically located in a residentially and commercially developed area that is characterized by commercial retail facilities, manufacturing facilities, service companies, multifamily apartments, and a mobile home park. Adjoining the Property to the north is SE Otty Road with Miles Fiberglass and Composites (8855 SE Otty Road) beyond. Adjoining the Property to the south is a mobile home trailer park. Abutting the Property to the east is TriMet's Max Green Line Commuter train followed by US Interstate Highway 205 with Heritage Heights Townhomes beyond and adjoining the Property to the west is Wal-Mart (10000 SE 82 Avenue).

INFORMATION REFERENCES:

AEI reviewed the National Register of Historic Places to determine if the Property or adjoining properties were listed as historical sites. No listings were noted within a ½-mile radius of the Property. AEI also reviewed the EDR NEPACheck report, which stated that no historic sites were found on or within a ½-mile radius of the Property. The Bell Station Store, located at 9300 SE Bell Avenue was listed within the National Register of Historic Places. This building, reportedly constructed in 1900, is located between ½ and 1 mile northwest of the Property (approximately 5,244 feet). Based on the distance of the Bell Station Store from the Property and the more recent development located between the Property and the identified historic site, it is AEI’s opinion that the proposed apartment complex does not affect the listed historic site. Additionally, information request letters were submitted to the Tribal Historic Preservation Offices (THPOs). These offices included the Confederated Tribes of the Warm Springs Reservation, the Confederated Tribes of the Grand Ronde Indian Community of Oregon and the Confederated Tribes of Siltetz Indians.

In accordance with Section 106 of the National Historic Preservation Act of 1966 (16 USC 470) as amended, AEI is requesting a historical review of the subject property.

I have attached figures and photographs of the subject property area for your reference.

As per section 106 of the National Historic Preservation Act, AEI requests that the following statements be confirmed in regard to the above referenced site. 1) The subject property does or does not affect districts, sites, buildings, structures or objects listed, or

eligible for listing in the National Register of Historic Places.

2) This subject property does not affect Indian religious sites.

3

CONCLUSION

Based on our findings, AEI is of the opinion that, pursuant to 36CFR800.4(b), that the proposed apartment complex will not have any “Effect” that has not already been addressed during the construction of the complex. Your written confirmation and concurrence within 30 days of receipt will be deeply appreciated. Please forward your response to Mr. Michael Couture at the address shown below.

Arkose Environmental, Inc. P.O. Box 560975 The Colony, Texas 75056

Email: mikec@arkoseinc.com

If you have any questions or require additional information, please contact the undersigned at (214) 680-5658. Your assistance is appreciated.

Sincerely,

ARKOSE ENVIRONMENTAL, INC. ___________________________

Michael Couture, P.G., REM Senior Project Manager

Arkose Environmental, Rosewood Terrace Apartments

Dennis Griffin, Ph.D., RPA

State Archaeologist

(503) 986-0674

dennis.griffin@oregon.gov

8810-8850 SE Otty Road, Happy Valley, Clackamas County

Dear Mr. Couture:

RE: SHPO Case No. 15-1998

Demo and build

Our office recently received a request to review your application for the project referenced above. In checking our statewide archaeological database, it appears that there have been no previous surveys completed near the proposed project area. However, the project area lies within an area generally perceived to have a high probability for possessing archaeological sites and/or buried human remains. In the absence of sufficient knowledge to predict the location of cultural resources within the project area, extreme caution is recommended during project related ground disturbing activities. Under state law (ORS 358.905 and ORS 97.74) archaeological sites, objects and human remains are protected on both state public and private lands in Oregon. If archaeological objects or sites are discovered during construction, all activities should cease immediately until a professional archaeologist can evaluate the discovery. If you have not already done so, be sure to consult with all appropriate Indian tribes regarding your proposed project. If the project has a federal nexus (i.e., federal funding, permitting, or oversight) please coordinate with the appropriate lead federal agency representative regarding compliance with Section 106 of the National Historic Preservation Act (NHPA). If you have any questions about the above comments or would like additional information, please feel free to contact our office at your convenience. In order to help us track your project accurately, please reference the SHPO case number above in all correspondence. This letter refers to archaeological resources only. Comments pursuant to a review for above-ground historic resources will be sent separately.

Sincerely,

PO Box 560975

Mr. Michael Couture

The Colony, TX 75056

Arkose Environmental, Inc

January 11, 2016

Arkose Environmental, Rosewood Terrace Apartments

Jason Allen, M.A.

Historic Preservation Specialist

(503) 986-0579

jason.allen@oregon.gov

8810-8850 SE Otty Road, Happy Valley, Clackamas County

Dear Mr. Couture:

RE: SHPO Case No. 15-1998

Demo and build

Thank you for submitting materials related to the above-identified project. Unfortunately, with the information submitted, we cannot concur with your finding of "no effect." While it is true that there are no properties within or adjacent to the subject property that are listed in the National Register of Historic Places, as noted in your submission, Section 106 of the National Historic Preservation Act concerns itself both with properties listed in the National Register of Historic Places, and with those that are eligible for listing. A part of that process is determining whether any previously unidentified historic properties are present. Based on very limited map and photographic research, it appears that the subject parcel(s) include buildings that are 50 years old or older, and as such should be evaluated for eligibility for listing in the National Register. We request such evaluations as well as findings of effect based upon the findings on eligibility, as well as application of the criteria for adverse effect should any be found to be eligible.

Feel free to contact our office if you have questions around how to proceed.

Sincerely,

PO Box 560975

Mr. Michael Couture

The Colony, TX 75056

Arkose Environmental, Inc

January 22, 2016

April 4, 2016 Jason Allen Review & Compliance Coordinator Oregon State Historic Preservation Office 725 Summer Street NE, Suite C Salem, OR 97301-1266 RE: SHPO Case No. 15-1998 Arkose Environmental, Rosewood Terrace Apartments 8810-8850 SE Otty Road, Happy Valley, Clackamas County Dear Mr. Allen, On behalf of Arkose Environmental and the team here at HRA, please find the enclosed Section 106 Documentation for the property located at 8810-8850 SE Otty Road, Happy Valley. The property includes multiple buildings and structures, including a storage/garage building (built ca. 1955), multiple accessory/storage structures, and an office building. The proposed project includes the removal of all structures on the parcel. Partially funded by the U.S. Department of Housing and Urban Development (HUD), the project is therefore subject to Section 106 of the National Historic Preservation Act. Consultation with the Oregon State Historic Preservation Office (SHPO), dated January 22, 2016, resulted in a request that the project site be evaluated for the National Register of Historic Places. HRA surveyed the property at the reconnaissance-level, and reviewed historic maps and records, including GLOS, Metsker Maps, as well the Clackamas County Tax Assessor website to obtain information regarding the history and use of the property. HRA recommends a finding of no historic properties affected, as the buildings and structures on the parcel are recommended not eligible for listing on the National Register of Historic Places. Please find enclosed one (1) hard copy of the Section 106 Documentation Form, unbound, for your review. If you have any questions or concerns, please do not hesitate to contact me. Sincerely,

Natalie K. Perrin

OREGON INVENTORY OF HISTORIC PROPERTIESSECTION 106 DOCUMENTATION FORM

Individual Properties

Pg 1 106 Documentation: Individual Properties Rev. 09/13

Property Name: Street Address: City, County:

Project Name: Agency project #:

Agency: SHPO Case#:

Location Coordinates (to sixth decimal place):

Latitude: Longitude:

Is the property listed in the National Register of Historic Places?

YES – Individually NO YES – In a district

Insert photograph of resource here

Surveyor: Date Recorded:

National Register Findings:

Eligible: Individually As part of District NR Criteria: A B C D

Not Eligible: Irretrievable integrity loss Not 50 Years Fails to meet NR Criteria

Finding of Effect: No Effect No Adverse Effect Adverse Effect

State Historic Preservation Office Comments – Official Use Only:Eligibility: Concur Do Not Concur:

Effect: Concur Do Not Concur: RECEIVED STAMP

Signed _____________________________________________________ Date ______________________________

CONTACT INFORMATION STAMP

Comments:

8810 SE Otty Road Happy Valley, Clackamas

Arkrose Environmental, Rosewood Terrace Apts.

15-1998

45.451140 -122.573762

Office Building: North elevation.

Natalie Perrin, Carl Williams 03/18/2016

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Pg 2 106 Documentation: Individual Properties Rev. 09/13

Property Name: Street Address: City, County:

Original Use: Number of Associated Resources:

Architectural Classification / Resource Type: Owner: Private Local Government

State Federal

Window type and Materials: Exterior Surface Materials:

Primary:

Secondary:

Decorative: Roof Type and Materials:

Integrity:

Excellent Good Fair Poor

Construction Date: ( Circa)

Architect/Builder (if known):

Description of Property (including previous alterations & approximate dates):

Determination of Eligibility, Justification, and Sources (Use continuation sheets if necessary):

8810 SE Otty Road Happy Valley, Clackamas

4

BuildingUtilitarian

Multiple (wood, vinyl, aluminum)

Mutiple

1955

Unknown

The property is located in the southwest quarter of Section 28 in Township 1 South, Range 2 East. The propertyincludes multiple structures, including a storage/garage building, multiple accessory/storage structures, and anoffice building. The parcel is bounded to the north by SE Otty Road, to the west and south by adjacent parcels,and to the east by the East Side Light Rail and Interstate 205. The tax parcel (Clackamas County 00048647)includes 3.35 acres of land zoned as Station Community Mixed Use.

The storage/garage building (circa 1955), which abuts SE Otty Road on the parcel’s northern edge, currentlyfunctions as a muffler repair shop. The building is utilitarian in style with few distinguishing features. One-storyin height, the building has an L-shaped plan and concrete foundation. The main section of the building hasexposed concrete walls while an extension to the rear has corrugated metal cladding. The building features anelongated domed roof over the principal section, and a shed roof over the rear addition. The front (north) façadehas concrete walls supported on the exterior by concrete buttresses. The façade has three roll-up garage doorsand an entrance door. The east face features concrete walls and single entry door. The west face has concretewalls and no other features. (See continuation sheet)

The property was surveyed at the reconnaissance-level. HRA reviewed historic maps and records, includingGLOS, Metsker Maps, as well the Clackamas County Tax Assessor website to obtain information regarding thehistory and use of the property.

The Bureau of Land Management (BLM) records multiple property owners within Section 28 of Township 1South Range 2 East as early as 1862. The area was marked by a curved road that extended in a north-southorientation (BLM 1862). Subsequent historic maps indicate the property changed hands multiple times and wasused as farmland throughout the early to mid-1900s (Metsker 1937, 1951). Clackamas County tax records donot provide a definitive date for the construction of the large storage/garage building and northernmost sectionof the office building, however historic aerials indicate it was constructed between 1952 and 1960 (NETR 1952,1960). The construction of the garage and office in the 1950s was followed by the addition of the storage unitsbetween 1970 and 1990 (NETR 1970, 1994). The most significant change to the surrounding context came withthe construction of Interstate 205 in 1975, which divided the subject parcel. The central section of the officebuilding and small storage unit appear to date from the 1990s (NETR 1994, 2000).

(See continuation sheet)

Business

Concrete: Other/undefinedCorrugated MetalVertical Board

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Property Name: Street Address: City, County:

Description of project scope, and nature and extent of impacts:

Finding of Effect and justification:

8810 SE Otty Road Happy Valley, Clackamas

The proposed project includes the removal of all structures on the parcel. Partially funded by the U.S.Department of Housing and Urban Development (HUD), the project is therefore subject to Section 106 of theNational Historic Preservation Act. Consultation with the Oregon State Historic Preservation Office (SHPO)resulted in a request that structures on the current project site be evaluated for the National Register of HistoricPlaces.

HRA recommends a finding of no historic properties affected, as the buildings and structures (both individuallyand collectively) on the parcel are recommended not eligible for listing on the National Register of HistoricPlaces.

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8810 SE Otty Road Happy Valley, Clackamas

Office Building: Southeast oblique

Office Building: East elevation.

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Property Name: Street Address: City, County:

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8810 SE Otty Road Happy Valley, Clackamas

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Property Name: Street Address: City, County:

(Cont.)

NA 8810 SE Otty Road Happy Valley, Clackamas

The rear (south) face is marked by the shed-roof addition, which extends south off the western half of thebuilding. The rear face features three roll-up garage doors and multiple single door entrances. Theexposed concrete section of the rear face also includes exterior concrete buttresses.

The office structure, which abuts SE Otty Road to the north and parking lot to the east, is a combinationof buildings added onto each other over time. The building does not have a distinguishable architecturalstyle. The building features an irregular plan. It has a poured concrete foundation and both flat and shedroofs. The building features multiple cladding types, including board and batten, plywood panels, andbrick. The building also has multiple window types including fixed and operable wood, aluminum, andvinyl types. The front (north) section of the building is one-story in height and features board and battenand brick siding, as well as multiple window types. It has a flat roof and rectangular plan. The centralsection of the building is two-stories in height and marked by a plywood parapet. This section of thebuilding has a T-shaped plan and is clad with plywood paneling. The third section of the building extendsoff the central section’s southwest corner. It has an irregular-plan and is one-story in height. It is markedby multiple shed roofs and plywood-panel cladding, with aluminum windows.

Directly south of the office building, extending in a north-south orientation, is a series of accessorystructures joined by their side walls. The northernmost section is one-story in height with a wood post andpier support system. It is open to the west and enclosed to the north, south, and east. It has a shed roofclad with corrugated-metal panels, and has corrugated-metal siding. Its southern wall abuts the northernwall of the central storage building. The central storage building is 1.5-stories tall and is fully enclosed. Itfeatures a shed roof clad with corrugated-metal panels and has corrugated-metal siding. It features a roll-up garage door on its west face. Its southern wall abuts the northern wall of the southernmost building inthe grouping. The southernmost building is in ruin. The building is 1.5-stories tall with a shed roof that ispartially collapsed. The building is enclosed on its north, east, and south facades and open to the west.The building features corrugated-metal siding.

Situated south of the large shop/garage building is a small storage building. It has a rectangular plan, andside-gable roof clad with corrugated-metal panels. The front (east) face is marked by a modest roofoverhang that shelters the building's only entrance door. The north and south faces have aluminumwindows.

Description of Property

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Individual Properties Continuation Sheet

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Property Name: Street Address: City, County:

(Cont.)

8810 SE Otty Road Happy Valley, Clackamas

Under Criterion A, properties can be determined eligible for listing in the National Register of HistoricPlaces (NRHP) if they are associated with events that have made a significant contribution to the broadpatterns of our history. Neither the property collectively, nor the individual buildings and structures,appear to be related to any significant event or patterns of events (Criterion A). Therefore eligibility underCriterion A, either individually or as contributing to a district (none appears to be present), is notappropriate to the resource.

Under Criterion B, properties can be eligible to the NRHP if they are associated with the lives of personssignificant in our past, i.e., persons whose activities are demonstrably important within a local, state, ornational context. Properties eligible under Criterion B are supposed to be associated with the productivelife of an individual, and are often their primary home or business during the time when they achievedimportance. This commercial property is unlikely to be associated with the productive period of anindividual’s life, and therefore, eligibility under Criterion B does not appear to be appropriate to theresource.

Under Criterion C, properties can be eligible to the National Register of Historic Places if they embodythe distinctive characteristic of a type, period, or method of construction, or represent the works of amaster, or possess high artistic values, or represent a significant and distinguishable entity whosecomponents may lack individual distinction (i.e., are part of a district). The collection of buildings areutilitarian without any distinguishing or noteworthy features. Further, they do not represent the distinctivecharacteristic of a type, period, or method of construction, as they were expanded and constructedhaphazardly over time for specific needs. Therefore, eligibility under Criterion C is not appropriate to theresource.

Under Criterion D, properties may be eligible for the National Register if they have yielded, or may belikely to yield, information important in history. To be eligible under Criterion D, the property must have, orhave had, information to contribute to our understanding of human history and that information must beconsidered “important.” Most commonly applied to archaeological sites, buildings, structures, andobjects may be eligible under Criterion D if they are the principal source of information. The resourcesthat comprise the complex were built of common construction methods and well-known materials and areunlikely to answer important research questions or yield information about human history that can only beanswered by the actual physical material, design, construction methods, or interrelation of theseresources. As such, HRA recommends that the parcel's buildings and structures are not eligible underCriterion D.

Further, the property lacks integrity of materials, design, workmanship, feeling, setting, and association,and would be unlikely to convey significance under any criteria, should the property be eligible within asignificant historic context (of which, none appears to be present).

HRA recommends 8810 SE Otty Road not eligible to the National Register due to a failure to meet thecriteria for significance under any of the criteria for eligibility, and a loss of integrity.

Determination of Eligibility

OREGON INVENTORY OF HISTORIC PROPERTIESSECTION 106 DOCUMENTATION FORM

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Property Name: Street Address: City, County:

(Cont.)

NA 8810 SE Otty Road Home Valley, Clackamas

Bureau of Land Management (BLM)1852 Township 1 S Range 2 E Section 28. GLO Original Survey. Bureau of Land Management.Electronic document, http://www.glorecords.blm.gov/details/survey/default.aspx?dm_id=349806&sid=w2a5lac2.0zc&surveyDetailsTabIndex=1, accessed March 31, 2016.

1862 Township 1 S Range 2 E Section 28. GLO Survey. Bureau of Land Management. Electronicdocument, http://www.glorecords.blm.gov/details/survey/default.aspx?dm_id=349808&sid=w2a5lac2.0zc&surveyDetailsTabIndex=1, accessed March 31, 2016.

Clackamas County Tax Assessor2016 8810 SE Otty Road Happy Valley, OR. http://cmap.clackamas.us/map.jsp?x=7669974.5982778&y=657094.59955556&aerial=1&data=address,assessment,boundary,service,hazard, accessed March 31, 2016.

Metsker Map (Metsker)1937 Township 1 S Range 2 E Section 28. Clackamas County Atlas. Charles F. Metsker Map Co.Electronic document, http://www.historicmapworks.com/Map/US/841157/Page+010+++Township+1+S+++Range+2+E++W+M+++Milwaukie/Clackamas+County+1937/Oregon/, accessed March 31, 2016.

1951 Township 1 S Range 2 E Section 28. Clackamas County Atlas. Charles F. Metsker Map Co.Electronic document, http://www.historicmapworks.com/Map/US/1253127/Township+1+S+++Range+2+E/Clackamas+County+1951/Oregon/, accessed March 31, 2016.

1966 Township 1 S Range 2 E Section 28. Clackamas County Atlas. Charles F. Metsker Map Co.Electronic document, http://www.historicmapworks.com/Map/US/1314229/Page+015+++Township+1+S+++Range+1+E+++Wichita/Clackamas+County+1966/Oregon/, accessed March 31, 2016.

Nationwide Environmental Title Research (NETR)1952 Historic Aerial for Happy Valley. Oregon area. Electronic document, http://www.historicaerials.com, accessed March 31, 2016.

1960 Historic Aerial for Happy Valley. Oregon area. Electronic document, http://www.historicaerials.com, accessed March 31, 2016.

1970 Historic Aerial for Happy Valley. Oregon area. Electronic document, http://www.historicaerials.com, accessed March 31, 2016.

1994 Historic Aerial for Happy Valley. Oregon area. Electronic document, http://www.historicaerials.com, accessed March 31, 2016.

2012 Historic Aerial for Happy Valley. Oregon area. Electronic document, http://www.historicaerials.com, accessed March 31, 2016.

Bibliography

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8810 SE Otty Road Happy Valley, Clackamas

Office Building: West elevation.

Office Building: West elevation.

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8810 SE Otty Road Happy Valley, Clackamas

Garage Building: East and north elevations.

Garage Building: North and west elevations.

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8810 SE Otty Road Happy Valley, Clackamas

Garage Building: West and south elevations.

Garage Building: South and east elevations.

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8810 SE Otty Road Happy Valley, Clackamas

Storage buildings: West elevation.

Northernmost storage building: West elevation.

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8810 SE Otty Road Happy Valley, Clackamas

Center Storage Building: West elevation.

Southernmost storage building: West elevation.

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Storage Building: East and north elevations.

Storage Building: East and south elevations.

Arkose Environmental, Rosewood Terrace Apartments

Jason Allen, M.A.

Historic Preservation Specialist

(503) 986-0579

jason.allen@oregon.gov

8810-8850 SE Otty Road, Happy Valley, Clackamas County

Dear Mr. Couture:

RE: SHPO Case No. 15-1998

Demo and build

We have reviewed the materials submitted on the project referenced above, and we concur with the determination that the property is not eligible for listing in the National Register of Historic Places. We also concur that there will be no historic properties affected for this undertaking. This letter refers to above-ground historic resources only. Comments pursuant to a review for archaeological resources have been sent separately.

This concludes the requirement for consultation with our office under Section 106 of the National Historic Preservation Act (per 36 CFR Part 800) for above-ground historic properties. Local regulations, if any, still apply and review under local ordinances may be required. Please feel free to contact me if you have any questions, comments or need additional assistance.

Sincerely,

PO Box 560975

Mr. Michael Couture

The Colony, TX 75056

Arkose Environmental, Inc

May 2, 2016

P.O. Box 560975, The Colony, Texas 75056 phone (214) 682-4582 www.arkoseinc.com

September 25, 2016 Oregon Fish and Wildlife Office U.S. Fish and Wildlife Service 2600 Southeast 98th Avenue, Suite 100 Portland, Oregon 97266-1398 (503) 231-6179 Re: Threatened and Endangered Species Review – SECOND SUBMITTAL FOR PROJECT Proposed Rosewood Terrace Apartments

8810-8850 SE Otty Road Happy Valley, Clackamas County, Oregon 97086

AEI Project No. 16-203 To Whom It May Concern:

Arkose Environmental, Inc. (AEI) is performing a HUD investigation intended to identify potential for impact to threatened and endangered species at the above referenced location in Happy Valley, Clackamas County, Oregon.

HUD PROGRAM:

HUD 221(d)(4) – New Construction for a multi-family apartment complex

LOCATION:

The Property is located at 8810 and 8850 SE Otty Road in Happy Valley, Oregon 46360 (the “Property”). The Property is specifically located on the south side of SE Otty Road approximately 180 feet west of US Highway 205. The approximate center of the Property is located 45.45040000 north latitude and -122.57360000 west longitude in the south-central portion of Happy Valley, Oregon.

LEGAL DESCRIPTION:

According to the Clackamas County Department of Assessment and Taxation online database, the Property consists of two contiguous tracts of land in the southwest ¼ of Section 28, Township 1 South, Range 2 East of the Willamette Meridian in Clackamas County, Oregon. Tract 1 was identified as a 3.36 acre (146,361.6 ft2) tract with two physical addresses. The addresses included 8810 and 8830 SE Otty Road. Tract 1 was identified as Parcel ID # 00048647 (Reference Parcel Number 12E28CC00100). Tract 2 was identified as a 1.99 acre (86,684.4 ft2) tract with a physical address of 8850 SE Otty Road. Tract 2 was identified as Parcel ID # 00049101 (Reference Number 12E28CD01100). According to information provided in the Clackamas County Department of Assessment and Taxation online database, the Property is currently owned by Daniel L. Apte as recorded in a Warranty Deed (2012-000924) dated January 10, 2012.

2

PRESENT CONDITION OF SITE:

The Property is irregular in shape and encompasses two tracts of land totaling 5.29 acres. The Property is developed with the operational Spain's Complete Muffler Service facility (8830 SE Otty Road) which occupies the western half of a Quonset type structure located on the northwest portion of the Property and Emerick Construction Company (8850 SE Otty Road) which uses the remaining portions of the Property for equipment storage. The Emerick Construction Company facility consists of a two-story office/storage building, a covered lean-to type structure that includes an enclosed garage, a wood working building attached to the aforementioned Quonset type building, the eastern half of the Quonset building used for storage, a detached storage building, open parking, fenced storage areas and vacant land.

According to the Clackamas County Comprehensive Zoning Plan obtained through the Clackamas County Planning Division's on-line database, the property is zoned SCMU (Station Community Mixed Use).

SITE VICINITY:

The vicinity of the Property can generally be described as mixed-use development. The Property is specifically located in a residentially and commercially developed area that is characterized by commercial retail facilities, manufacturing facilities, service companies, multifamily apartments, and a mobile home park. Adjoining the Property to the north is SE Otty Road with Miles Fiberglass and Composites (8855 SE Otty Road) beyond. Adjoining the Property to the south is a mobile home trailer park. Abutting the Property to the east is TriMet's Max Green Line Commuter train followed by US Interstate Highway 205 with Heritage Heights Townhomes beyond and adjoining the Property to the west is Wal-Mart (10000 SE 82 Avenue).

ASSESSMENT SUMMARY:

As part of this assessment AEI conducted a search of the USFWS database for the presence of endangered or threatened species within a critical habitat as defined in 50 CFR Part 226. According to information reviewed on the USFWS Endangered Species List website, threatened and endangered species for Clackamas County, Oregon, and their listing status are identified in the following table.

Common Name Scientific Name StatusBirds

Northern Spotted Owl Strix occidentalis caurina Threatened

Streaked Horn Lark Eremophila alpestris strigata Threatened

Flowering Plants

Bradshaw's Desert-parsley Lomatium bradshawii Endangered

Kincaid's Lupine Lupinus sulphureus ssp. kincaidii Threatened

Nelson's Checker-mallow Sidalcea nelsoniana Threatened

Water Howellia Howellia aquatillis Threatened

Willamette Daisy Engeron decumbens Endangered

3

Common Name Scientific Name StatusMigratory Birds

Bald Eagle Haliaeetus leucocephalus Bald and Golden Eagle Act

Brewer's Sparrow Spizella breweri Bird of Concern

Calliope Hummingbird Stellala calliope Bird of Concern

Fox Sparrow Passerella iliaca Bird of Concern

Loggerhead Shrike Lanius ludovicianus Bird of Concern

Olive-sided Flycatcher Contopus cooperi Bird of Concern

Peregrine Falcon Falco peregrinus Bird of Concern

Purple Finch Carpodacus purpureus Bird of Concern

Rufous Hummingbird Selasphorus rufus Bird of Concern

Short-eared Owl Asio flammeus Bird of Concern

Vesper Sparrow Pooecetes gramineus ssp. affinis Bird of Concern

Western Grebe Aechmophorus occidentalis Bird of Concern

Willow Flycatcher Empidonax traillii Bird of Concern

AEI also reviewed an EDR NEPACheck report, which states that no natural areas, (i.e. designated wilderness areas; designated wildlife preserves, sanctuaries and refuges; wild and scenic rivers; threatened or endangered wildlife and critical habitat), were identified on the Property or immediate adjoining properties.

Additionally, AEI generated a FWS Trust Resource report for the proposed multifamily apartment complex using the FWS Information Planning and Conservation (IPaC) System online tool. According to the site specific Trust Resources report, there are no critical habitat, not refuges and no wetlands within the project area. In addition to obtaining the iPaC site specific report, AEI submitted a request for an “official species list” for the Rosewood Terrace Apartments project from the USFWS. According to the Official Species List (Consultation Code: 01EOFW00-2016-SLI-0450) for Rosewood Terrace Apartments, there are no critical habitats within the project area.

Based on review of the USFWS threatened and endangered species list, visual observations, the USFWS Trust Resources report, the USFWS Official Species List, the existing development, lack of critical on-site habitat and lack of evidence for the listed species, it is highly unlikely the Property serves as a habitat for endangered species and the proposed development will have no effect.

A site location map, proposed development survey, USGS topographic map, aerial photograph, Official Species List for Rosewood Terrace Apartments, and Trust Resources List have been enclosed for your review.

4

As part of the HUD environmental review, AEI would also appreciate a response as to potential impact to critical habitats on the subject property. AEI requests that a written response be forwarded to Ms. Lui Barkkume at the address shown below.

Arkose Environmental, Inc. P.O. Box 560975 The Colony, Texas 75056

Email: Luib@arkoseinc.com

If you have any questions or require additional information, please contact the undersigned at (214) 682-4582. Your assistance is appreciated.

Sincerely, ARKOSE ENVIRONMENTAL, INC.

Lui Barkkume, P.G., CESCO Senior Project Manager

1

Lui Barkkume

From: Maurice, Kevin <kevin_maurice@fws.gov>Sent: Thursday, September 29, 2016 6:41 PMTo: luib@arkoseinc.comSubject: Rosewood Terrace Apts.- HUD funded/Happy Valley, Oregon. AEI Proj. No.-16-203,

Hi!. I have the impression you may be unfamiliar with the ESA and section 7 consultation process. There is no mechanism to concur with a no effect determination by the Service. As the designated agent for HUD you have made a determination as an environmental professional based on best available information which resulted in a no effect to listed species determination. In your letter (page 3) you point out the IPaC tool indicated there is no designated critical habitat present as well. You have availed yourself of the sec. 7 process. Document your logic train as to how you developed that no effects determination and the supporting documents used and retain that on file to be able to produce it to defend your determination if there is a 3rd party challenge. The site for the proposed action is an already highly disturbed site in a very urban and light industrial area that does not provide habitat for the listed species listed in the generic county species list. Good luck with your project. KJM -- Kevin J. Maurice, Wildlife Biologist U.S. Fish & Wildlife Service Oregon Fish & Wildlife Office 2600 SE 98th Ave., Suite 100 Portland, OR 97266 (503) 231-6179

United States Department of the Interior

FISH AND WILDLIFE SERVICEOregon Fish and Wildlife Office

2600 SOUTHEAST 98TH AVENUE, SUITE 100PORTLAND, OR 97266

PHONE: (503)231-6179 FAX: (503)231-6195URL: www.fws.gov/oregonfwo/Species/Lists/RequestList.asp

Consultation Code: 01EOFW00-2016-SLI-0450 September 24, 2016Event Code: 01EOFW00-2016-E-00530Project Name: Rosewood Terrace Apartments

Subject: List of threatened and endangered species that may occur in your proposed projectlocation, and/or may be affected by your proposed project

To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, aswell as proposed and final designated critical habitat, that may occur within the boundary ofyour proposed project and/or may be affected by your proposed project. The species list fulfillsthe requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of theEndangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 ).et seq.

New information based on updated surveys, changes in the abundance and distribution ofspecies, changed habitat conditions, or other factors could change this list. Please feel free tocontact us if you need more current information or assistance regarding the potential impacts tofederally proposed, listed, and candidate species and federally designated and proposed criticalhabitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 ofthe Act, the accuracy of this species list should be verified after 90 days. This verification canbe completed formally or informally as desired. The Service recommends that verification becompleted by visiting the ECOS-IPaC website at regular intervals during project planning andimplementation for updates to species lists and information. An updated list may be requestedthrough the ECOS-IPaC system by completing the same process used to receive the enclosedlist.

The purpose of the Act is to provide a means whereby threatened and endangered species andthe ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2)of the Act and its implementing regulations (50 CFR 402 ), Federal agencies are requiredet seq.to utilize their authorities to carry out programs for the conservation of threatened andendangered species and to determine whether projects may affect threatened and endangeredspecies and/or designated critical habitat.

A Biological Assessment is required for construction projects (or other undertakings havingsimilar physical impacts) that are major Federal actions significantly affecting the quality of thehuman environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)(c)). For projects other than major construction activities, the Service suggests that a biologicalevaluation similar to a Biological Assessment be prepared to determine whether the project mayaffect listed or proposed species and/or designated or proposed critical habitat. Recommendedcontents of a Biological Assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the Biological Assessment or biological evaluation,that listed species and/or designated critical habitat may be affected by the proposed project, theagency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Servicerecommends that candidate species, proposed species and proposed critical habitat be addressedwithin the consultation. More information on the regulations and procedures for section 7consultation, including the role of permit or license applicants, can be found in the "EndangeredSpecies Consultation Handbook" at:

http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF

Please be aware that bald and golden eagles are protected under the Bald and Golden EagleProtection Act (16 U.S.C. 668 ), and projects affecting these species may requireet seq.development of an eagle conservation plan(http://www.fws.gov/windenergy/eagle_guidance.html). Additionally, wind energy projectsshould follow the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizingimpacts to migratory birds and bats.

Guidance for minimizing impacts to migratory birds for projects including communicationstowers (e.g., cellular, digital television, radio, and emergency broadcast) can be found at:http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/towers.htm;http://www.towerkill.com; andhttp://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/comtow.html.

We appreciate your concern for threatened and endangered species. The Service encouragesFederal agencies to investigate opportunities for incorporating conservation of threatened andendangered species into project planning processes as a means of complying with the Act. Ifyou have questions regarding your responsibilities under the Act, please contact the EndangeredSpecies Division at the Service's Oregon Fish and Wildlife Office at (503) 231-6179. Forinformation regarding listed marine and anadromous species under the jurisdiction of NOAAFisheries Service, please see their website (http://www.nwr.noaa.gov/habitat/habitat_conservation_in_the_nw/habitat_conservation_in_the_nw.html).

Please include the Consultation Tracking Number in the header of this letter with any requestfor consultation or correspondence about your project that you submit to our office.

Attachment

2

http://ecos.fws.gov/ipac, 09/24/2016 09:17 AM 1

Official Species List

Provided by: Oregon Fish and Wildlife Office

2600 SOUTHEAST 98TH AVENUE, SUITE 100

PORTLAND, OR 97266

(503) 231-6179

http://www.fws.gov/oregonfwo/Species/Lists/RequestList.asp Consultation Code: 01EOFW00-2016-SLI-0450Event Code: 01EOFW00-2016-E-00530 Project Type: DEVELOPMENT Project Name: Rosewood Terrace ApartmentsProject Description: Proposed redevelopment of existing commercial site with a single multi-family apartment building including 231 residential units. Please Note: The FWS office may have modified the Project Name and/or Project Description, so itmay be different from what was submitted in your previous request. If the Consultation Codematches, the FWS considers this to be the same project. Contact the office in the 'Provided by'section of your previous Official Species list if you have any questions or concerns.

United States Department of InteriorFish and Wildlife Service

Project name: Rosewood Terrace Apartments

http://ecos.fws.gov/ipac, 09/24/2016 09:17 AM 2

Project Location Map:

Project Coordinates: MULTIPOLYGON (((-122.57256925106049 45.44957170448294, -122.57425367832184 45.449598047831635, -122.57428050041197 45.45135361612286, -122.57396399974823 45.45134608968734, -122.57311105728148 45.45123131142112, -122.57256925106049 45.44957170448294))) Project Counties: Clackamas, OR

United States Department of InteriorFish and Wildlife Service

Project name: Rosewood Terrace Apartments

http://ecos.fws.gov/ipac, 09/24/2016 09:17 AM 3

Endangered Species Act Species List

There are a total of 7 threatened or endangered species on your species list. Species on this list should be considered in

an effects analysis for your project and could include species that exist in another geographic area. For example, certain

fish may appear on the species list because a project could affect downstream species. Critical habitats listed under the

Has Critical Habitat column may or may not lie within your project area. See the Critical habitats within your

project area section further below for critical habitat that lies within your project. Please contact the designated FWS

office if you have questions.

Birds Status Has Critical Habitat Condition(s)

Northern Spotted owl (Strix

occidentalis caurina)

Population: Wherever found

Threatened Final designated

Streaked Horned lark (Eremophila

alpestris strigata)

Population: Wherever found

Threatened Final designated

Flowering Plants

Bradshaw's desert-parsley (Lomatium

bradshawii)

Population: Wherever found

Endangered

Kincaid's Lupine (Lupinus sulphureus

ssp. kincaidii)

Population: Wherever found

Threatened Final designated

Nelson's checker-mallow (Sidalcea

nelsoniana)

Population: Wherever found

Threatened

Water howellia (Howellia aquatilis)

Population: Wherever found

Threatened

United States Department of InteriorFish and Wildlife Service

Project name: Rosewood Terrace Apartments

http://ecos.fws.gov/ipac, 09/24/2016 09:17 AM 4

Willamette daisy (Erigeron

decumbens var.)

Population: Wherever found

Endangered Final designated

United States Department of InteriorFish and Wildlife Service

Project name: Rosewood Terrace Apartments

http://ecos.fws.gov/ipac, 09/24/2016 09:17 AM 5

Critical habitats that lie within your project areaThere are no critical habitats within your project area.

United States Department of InteriorFish and Wildlife Service

Project name: Rosewood Terrace Apartments

IPaC - Information for Planning and Conservation ( ): A project planning tool to helphttps://ecos.fws.gov/ipac/streamline the U.S. Fish & Wildlife Service environmental review process.

U.S. Fish & Wildlife Service

Rosewood TerraceApartmentsIPaC Trust Resources ReportGenerated September 24, 2016 09:19 AM MDT,  IPaC v3.0.9

This report is for informational purposes only and should not be used for planning oranalyzing project level impacts. For project reviews that require U.S. Fish & WildlifeService review or concurrence, please return to the IPaC website and request an officialspecies list from the Regulatory Documents page.

Table of Contents IPaC Trust Resources Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Project Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Endangered Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Migratory Birds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Refuges & Hatcheries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Wetlands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

U.S. Fish & Wildlife Service

IPaC Trust Resources Report

NAME

Rosewood Terrace Apartments

LOCATION

Clackamas County, Oregon

DESCRIPTION

Proposed redevelopment of existingcommercial site with a singlemulti-family apartment buildingincluding 231 residential units.

IPAC LINK

https://ecos.fws.gov/ipac/project/Z735U-S5DRF-FF5EQ-7DVJQ-LJBQQQ

U.S. Fish & Wildlife Service Contact InformationTrust resources in this location are managed by:

Oregon Fish And Wildlife Office2600 Southeast 98th Avenue, Suite 100Portland, OR 97266-1398 (503) 231-6179

Threatened

Threatened

Endangered SpeciesProposed, candidate, threatened, and endangered species are managed by the

of the U.S. Fish & Wildlife Service.Endangered Species Program

This USFWS trust resource report is for informational purposes only and shouldnot be used for planning or analyzing project level impacts.

For project evaluations that require USFWS concurrence/review, please return to theIPaC website and request an official species list from the Regulatory Documentssection.

of the Endangered Species Act Federal agencies to "request of theSection 7 requiresSecretary information whether any species which is listed or proposed to be listed maybe present in the area of such proposed action" for any project that is conducted,permitted, funded, or licensed by any Federal agency.

A letter from the local office and a species list which fulfills this requirement canonly be obtained by requesting an official species list either from the RegulatoryDocuments section in IPaC or from the local field office directly.

The list of species below are those that may occur or could potentially be affected byactivities in this location:

Birds Northern Spotted Owl Strix occidentalis caurina

CRITICAL HABITAT

There is critical habitat designated for this species.final

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B08B

Streaked Horned Lark Eremophila alpestris strigataCRITICAL HABITAT

There is critical habitat designated for this species.final

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0B3

IPaC Trust Resources ReportEndangered Species

9/24/2016 9:19 AM IPaC v3.0.9 Page 2

Endangered

Threatened

Threatened

Threatened

Endangered

Flowering Plants Bradshaw's Desert-parsley Lomatium bradshawii

CRITICAL HABITAT

has been designated for this species.No critical habitat

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=Q1YN

Kincaid's Lupine Lupinus sulphureus ssp. kincaidiiCRITICAL HABITAT

There is critical habitat designated for this species.final

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=Q35E

Nelson's Checker-mallow Sidalcea nelsonianaCRITICAL HABITAT

has been designated for this species.No critical habitat

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=Q21M

Water Howellia Howellia aquatilisCRITICAL HABITAT

has been designated for this species.No critical habitat

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=Q2RM

Willamette Daisy Erigeron decumbensCRITICAL HABITAT

There is critical habitat designated for this species.final

http://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=Q2TF

Critical HabitatsThere are no critical habitats in this location

IPaC Trust Resources ReportEndangered Species

9/24/2016 9:19 AM IPaC v3.0.9 Page 3

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Migratory BirdsBirds are protected by the and the Migratory Bird Treaty Act Bald and Golden Eagle

.Protection Act

Any activity that results in the of migratory birds or eagles is prohibited unlesstake

authorized by the U.S. Fish & Wildlife Service. There are no provisions for allowing[1]

the take of migratory birds that are unintentionally killed or injured.

Any person or organization who plans or conducts activities that may result in the takeof migratory birds is responsible for complying with the appropriate regulations andimplementing appropriate conservation measures.

1. 50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)

Additional information can be found using the following links:Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/birds-of-conservation-concern.phpConservation measures for birds http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/conservation-measures.phpYear-round bird occurrence data http://www.birdscanada.org/birdmon/default/datasummaries.jsp

The following species of migratory birds could potentially be affected by activities in thislocation:

Bald Eagle Haliaeetus leucocephalusSeason: Year-roundhttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B008

Brewer's Sparrow Spizella breweriSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0HA

Calliope Hummingbird Stellula calliopeSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0K3

Fox Sparrow Passerella iliacaSeason: Breeding

IPaC Trust Resources ReportMigratory Birds

9/24/2016 9:19 AM IPaC v3.0.9 Page 4

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern

Bird of conservation concern Loggerhead Shrike Lanius ludovicianusSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0FY

Olive-sided Flycatcher Contopus cooperiSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0AN

Peregrine Falcon Falco peregrinusSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0FU

Purple Finch Carpodacus purpureusSeason: Year-round

Rufous Hummingbird selasphorus rufusSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0E1

Short-eared Owl Asio flammeusSeason: Year-roundhttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0HD

Vesper Sparrow Pooecetes gramineus ssp. affinisSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0F9

Western Grebe aechmophorus occidentalisSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0EA

Willow Flycatcher Empidonax trailliiSeason: Breedinghttp://ecos.fws.gov/tess_public/profile/speciesProfile.action?spcode=B0F6

IPaC Trust Resources ReportMigratory Birds

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Wildlife refuges and fish hatcheriesThere are no refuges or fish hatcheries in this location

IPaC Trust Resources ReportRefuges & Hatcheries

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Wetlands in the National Wetlands InventoryImpacts to and other aquatic habitats may be subject to regulation underNWI wetlandsSection 404 of the Clean Water Act, or other State/Federal statutes.

For more information please contact the Regulatory Program of the local U.S. Army.Corps of Engineers District

DATA LIMITATIONS

The Service's objective of mapping wetlands and deepwater habitats is to produce reconnaissance level informationon the location, type and size of these resources. The maps are prepared from the analysis of high altitude imagery.Wetlands are identified based on vegetation, visible hydrology and geography. A margin of error is inherent in the useof imagery; thus, detailed on-the-ground inspection of any particular site may result in revision of the wetlandboundaries or classification established through image analysis.

The accuracy of image interpretation depends on the quality of the imagery, the experience of the image analysts,the amount and quality of the collateral data and the amount of ground truth verification work conducted. Metadatashould be consulted to determine the date of the source imagery used and any mapping problems.

Wetlands or other mapped features may have changed since the date of the imagery or field work. There may beoccasional differences in polygon boundaries or classifications between the information depicted on the map and theactual conditions on site.

DATA EXCLUSIONS

Certain wetland habitats are excluded from the National mapping program because of the limitations of aerialimagery as the primary data source used to detect wetlands. These habitats include seagrasses or submergedaquatic vegetation that are found in the intertidal and subtidal zones of estuaries and nearshore coastal waters.Some deepwater reef communities (coral or tuberficid worm reefs) have also been excluded from the inventory.These habitats, because of their depth, go undetected by aerial imagery.

DATA PRECAUTIONS

Federal, state, and local regulatory agencies with jurisdiction over wetlands may define and describe wetlands in adifferent manner than that used in this inventory. There is no attempt, in either the design or products of thisinventory, to define the limits of proprietary jurisdiction of any Federal, state, or local government or to establish thegeographical scope of the regulatory programs of government agencies. Persons intending to engage in activitiesinvolving modifications within or adjacent to wetland areas should seek the advice of appropriate federal, state, orlocal agencies concerning specified agency regulatory programs and proprietary jurisdictions that may affect suchactivities.

There are no wetlands in this location

IPaC Trust Resources ReportWetlands

9/24/2016 9:19 AM IPaC v3.0.9 Page 7

SECTION FOUR:

HUD NOISE WORKSHEETS

Worksheet ASite Evaluation

8810 and 8850 SE Otty RoadSite Location

221(d)4Program

Rosewood ApartmentsProject Name

Happy Valley, Clackamas County, OregonLocality

File Number

Pedcor Investments, A Limited Liability Company 317-218-2702Sponsor's Name Phone

770 3rd Avenue SW Carmel, Indiana 46032Street Address City, State

Acceptability Predicted forCategory DNL Operations in Year

1. Roadway Noise Normally Unacceptable 74.6 2026

2. Aircraft Noise Acceptable <65 2026

3. Railway Noise Acceptable 55.6 2026

Value of DNL for all noise sources: 74.6

Final Site Evaluation (circle one)

Acceptable (<65)

Normally Unacceptable (65-75) Property is normally unacceptable; acceptable with proper noise attenuation.

Unacceptable (>75)

Signature Date 10/3/2016

Worksheet BAircraft Noise

List all civil airports within 5 miles and military airports within 15 miles of the site:

1. No civil airports are located within 5 miles and no military airports are located within 15 miles of the site

Necessary Information: Airport 1

1. Are DNL, NEF or CNR contours available? N/A (yes/no)2. Any supersonic aircraft operations? No (yes/no)3. Estimating approximate contours from Figure 3:

a. number of nighttime jet operations

b. number of daytime jet operations

c. effective number of operations (10 times a + b) d. distance A for 65 dB

70 dB

75 dB

e. distance B for 65 dB

70 dB

75 dB

4. Estimating DNL from Table 2:

a. distance from 65 dB contour to flight path, D1 b. distance from NAL to flight path, D2 c. D2 divided by D1

d. DNL <65

5. Operations projected for what year? 2026

6. Total DNL from all airports <65

Signature Date 10/3/2016

Auto Traffic Calculations

Road 1: Road 2: SE Otty RoadProjected Annual IncreaseAuto Traffic* 97.00% Rd. 1 98.00% Rd. 2Medium Traffic* 2.00% 1.00%Heavy Traffic* 1.00% 1.00%

Year I-205 SE Otty2015 144,100 7,2052016 148,423 7,421 Traffic Breakdown - Rd. 12017 152,876 7,644 Auto 193,484 2018 157,462 7,873 Medium 3,989 2019 162,186 8,109 Heavy 1,995 2020 167,051 8,3532021 172,063 8,603 Traffic Breakdown - Rd. 22022 177,225 8,861 Auto 9,774 2023 182,542 9,127 Medium 100 2024 188,018 9,401 Heavy 100 2025 193,658 9,6832026 199,468 9,973

* Breakdown of automobile traffic was estimated, based on site and vicinity observations.

1. 3% annual traffic increase based on standard US DOT annual projection.

2. I-205 traffic counts obtained from the OR DOT and SE Otty Rd traffic counts obtained from Clackamas County Transportation and Engineering Division at: http://cmap.clackamas.us/maps/traffic

3. Distances to noise sources were based on physical measurements and/or scaled measurements from scaled site plans.

4. Nighttime traffic is anticipated to be 15% of daily traffic due to predominant commuter traffic.

5. The Highway numbers recorded in the annual OR DOT traffic volume reports are highway numbers. They are not the same numbers one would see on road side signs when driving on Oregon highways. For those not familiar with Oregon highway numbering system there is a Highway Cross Reference Table with maps available online at: http://www.oregon.gov/ODOT/td/tdata/Pages/tsm/tvt.aspx#Traffic_Volume_Tables

I-205 (OR Hwy 64)

Worksheet C Page 1Roadway Noise

List all major roads within 1,000 feet of the site:

1. I-205

2. SE Otty Road

Necessary Information: Road 1 Road 2 I-205 SE Otty

1. Distance in feet from the NAL to the edge of the road a. nearest lane 101 37

b. farthest lane 319 65

c. average (effective distance) 210 51

2. Distance to stop sign (feet) >600 >600

3. Road gradient in percent 2% 2%

4. Average speed in mph

a. automobiles 55 35

b. heavy trucks - uphill 55 28.35

c. heavy trucks - downhill 55 28.35

5. 24 hour average number of automobiles and medium trucks in both directions (ADT) a. automobiles 193,484 9,774 b. medium trucks 3,989 100 c. effective ADT (a+ (10Xb)) 233,378 10,771

6. 24 hour average of heavy trucks

a. uphill 997 50

b. downhill 997 50

c. total 1995 100

7. Fraction of nighttime traffic (10 p.m. to 7 a.m.) 15% 15%

8. Traffic projected for what year? 2026 2026

Worksheet D Page 1Railway Noise

List All Railways within 3,000 feet of the site:

1. Tri Met Green Line

Necessary Information: Railway No. 1

1. Distance in feet from the NAL to center of the railway track: 76

2. Number of trains in 24 hours:

a. diesel 0

b. electrified 90

3. Fraction of operations occuring at night 15% (10 p.m. - 7 a.m.)

4. Number of diesel locomotives per train: 0

5. Number of rail cars per train

a. diesel trains 0

b. electrified trains 2

6. Average train speed: 30

7. Is track welded or bolted? Welded

8. Are whistles or horns required No for grade crossings?

10/5/2016 DNL Calculator ­ HUD Exchange

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Environmental Review Main (/programs/environmental­review/)

DNL CalculatorThe Day/Night Noise Level Calculator is an electronic assessment tool that calculates the Day/Night Noise Level(DNL) from roadway and railway traffic. For more information on using the DNL calculator, view the Day/NightNoise Level Calculator Electronic Assessment Tool Overview (https://onecpd.info/programs/environmental­review/daynight­noise­level­electronic­assessment­tool/).

GuidelinesTo display the Road and/or Rail DNL calculator(s), click on the "Add Road Source" and/or "Add RailSource" button(s) below.All Road and Rail input values must be positive non­decimal numbers.All Road and/or Rail DNL value(s) must be calculated separately before calculating the Site DNL.All checkboxes that apply must be checked for vehicles and trains in the tables' headers.Note #1: Tooltips, containing field specific information, have been added in this tool and may be accessedby hovering over all the respective data fields (site identification, roadway and railway assessment, DNLcalculation results, roadway and railway input variables) with the mouse.Note #2: DNL Calculator assumes roadway data is always entered. 

DNL Calculator 

Site ID Rosewood Terrace

Record Date 10/03/2016

User's Name Arkose Environmental, Inc.

 

Road # 1 Name: I­205

Road #1

Vehicle Type Cars Medium Trucks Heavy Trucks

Effective Distance 210 210 210

Distance to Stop Sign

Average Speed 55 55 55

Average Daily Trips (ADT) 193484 3989 1995

Night Fraction of ADT 15 15 15

Road Gradient (%) 2

10/5/2016 DNL Calculator ­ HUD Exchange

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Vehicle DNL 71.8 54.9 69.2

Calculate Road #1 DNL 73.7 Reset

Road # 2 Name: SE Otty Road

Road #2

Vehicle Type Cars Medium Trucks Heavy Trucks

Effective Distance 51 51 51

Distance to Stop Sign

Average Speed 35 28 28

Average Daily Trips (ADT) 9774 100 100

Night Fraction of ADT 15 15 15

Road Gradient (%) 2

Vehicle DNL 64.1 42.2 64.6

Calculate Road #2 DNL 67.4 Reset

Railroad #1 Track Identifier: Tri Met Blue Line

Rail # 1

Train Type Electric Diesel

Effective Distance 76

Average Train Speed 30

Engines per Train 1

Railway cars per Train 2

Average Train Operations (ATO) 90

Night Fraction of ATO 15

Railway whistles or horns? Yes: No: Yes:  No: 

Bolted Tracks? Yes: No: Yes:  No: 

10/5/2016 DNL Calculator ­ HUD Exchange

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Train DNL 55.6

Calculate Rail #1 DNL 55.6 Reset

Add Road Source Add Rail Source

Airport Noise Level

Loud Impulse Sounds? Yes  No

 

Combined DNL for allRoad and Rail sources

74.6

Combined DNL including Airport N/A

Site DNL with Loud Impulse Sound

Calculate

 

Mitigation OptionsIf your site DNL is in Excess of 65 decibels, your options are:

No Action Alternative: Cancel the project at this locationOther Reasonable Alternatives: Choose an alternate siteMitigation

Contact your Field or Regional Environmental Officer(https://www.onecpd.info/programs/environmental­review/hud­environmental­staff­contacts/)Increase mitigation in the building walls (only effective if no outdoor, noise sensitive areas)Reconfigure the site plan to increase the distance between the noise source and noise­sensitiveusesIncorporate natural or man­made barriers. See The Noise Guidebook(https://www.onecpd.info/resource/313/hud­noise­guidebook/)Construct noise barrier. See the Barrier Performance Module(https://onecpd.info/programs/environmental­review/bpm­calculator/)

Tools and GuidanceDay/Night Noise Level Assessment Tool User Guide (https://www.onecpd.info/resource/3822/day­night­noise­level­assessment­tool­user­guide/)

Day/Night Noise Level Assessment Tool Flowcharts (https://www.onecpd.info/resource/3823/day­night­noise­level­assessment­tool­flowcharts/)

SECTION FIVE:

FIGURES

SITE LOCATION MAP FIGURE 1

DRAWING NOT TO SCALE N

Site Name: Rosewood Terrace Apartments 8810 - 8850 SE Otty Road Happy Valley, Oregon 97086

Project Number: 16-203

PROPERTY

TOPOGRAPHIC MAP FIGURE 2

Source: USGS 7.5 Minute Topographic Map

Gladstone, OR Quadrangle 2014 N

Site Name: Rosewood Terrace Apartments 8810 - 8850 SE Otty Road Happy Valley, Oregon 97086

Project Number: 16-203

PROPERTY

SITE PLAN FIGURE 3

DRAWING NOT TO SCALE N

Site Name: Rosewood Terrace Apartments 8810 - 8850 SE Otty Road Happy Valley, Oregon 97086

Project Number: 16-203

Mobile Home Park

Tri-Met's Commuter Train and US I-205

Wal-Mart

Miles Fiberglass and Composites

AERIAL PHOTOGRAPH Scale: 1” = 500’ Date: 2012 Figure No. 4

N

Site Name: Rosewood Terrace Apartments 8810 - 8850 SE Otty Road Happy Valley, Oregon 97086

Project Number: 16-203

PROPERTY

 

PROPERTY 

Clackamas County