705 N. Plaza Street, Suite 220 Carson City, NV 89701

Federal Highway Administration – Division

Date: June 4, 2018 Project: Spaghetti Bowl Project (NDOT Project #74020; FHWA Project #NHFP-080- 1(172)) Location: Reno, Washoe County, NV Document: Section 4(f) of Department of Transportation Act, Net Benefit Programmatic for Sage Street Park (under Alternatives 1, 2, and 3): Official with Jurisdiction Concurrence with Findings From: Abdelmoez Abdalla, Ph.D. Environmental Program Manager Federal Highway Administration – Nevada Division To: Andy Bass, MBA, CPRP Director of Parks, Recreation & Community Services City of Reno, Nevada

Project Description

The Nevada Department of Transportation (NDOT), in cooperation with the Federal Highway Administration (FHWA), is proposing to reconstruct , Interstate 580 and US Highway 395 in Reno and Sparks, Nevada. The scope of the proposed action is to rebuild the freeway and bridges, modify access to improve safety and traffic flow, and reconstruct local streets affected by the freeway reconstruction.

The purpose of the project is to address the obsolete design of the study area freeway system and interchanges in order to improve traffic operations and reduce fatal and injury crashes.

Section 4(f) Requirements

Section 4(f) of the USDOT Act of 1966, codified in federal law at 49 U.S.C. 303(c), declares that “it is the policy of the United States Government that special effort should be made to preserve the natural beauty of the countryside and public park and recreation lands, wildlife and waterfowl refuges, and historic sites.” Section 4(f) specifies that “the Secretary [of Transportation] may approve a transportation program or project requiring the use of publicly owned land of a public park, recreation area, or wildlife and waterfowl refuge of national, State, or local significance, or land of an historic site of national, State, or local significance (as determined by the federal, State, or local officials having jurisdiction over the park, area, refuge, or site) only if:

Reno Spaghetti Bowl Project, Project ID #443-16-015

“There is no prudent and feasible alternative to using that land; and ‘The program or project includes all possible planning to minimize harm to the park, recreation area, wildlife and waterfowl refuge, or historic site resulting from the use.” “Use” of a Section 4(f) resource, defined in Section 23 Code of Federal Regulations (CFR) 774.17, occurs in the following circumstances: 1. When land is permanently incorporated into a transportation facility; 2. When there is a temporary occupancy of Section 4(f) property that is adverse in terms of the statute’s preservationist purpose; or 3. When there is a constructive use of land, which occurs when the transportation project does not incorporate land, but its proximity substantially impairs the activities, features, or attributes that qualify a resource for protection under Section 4(f). A determination of constructive use is based on the criteria in 23 CFR 774.15.

Project Impacts and Mitigation

Alternative 1 Under Alternative 1 NDOT would construct at-grade ramp roadways that would directly impact this park, necessitating the acquisition of the entirety of the Sage Street Park parcel that is Section 4(f)-protected (see Figure 1 in Attachment 1). This impact would be a permanent incorporation of parkland under Section 4(f) and therefore a use. Although this impact would result in the permanent incorporation of the entirety of the existing Section 4(f)-protected park parcel, the project would commit to mitigating by constructing recreational improvements on a parcel adjacent to it, thereby resulting in a net benefit for the park. Based on this, the project is proposing to process the Section 4(f) impact to Sage Street Park under Alternative 1 with this Net Benefit Programmatic.

Alternative 2 Under Alternative 2 NDOT would construct at-grade ramp roadways that would directly impact this park, necessitating the acquisition of approximately 0.4-acres of Section 4(f)-protected parkland (see Figure 2 in Attachment 1). This impact would be a permanent incorporation under Section 4(f) and therefore a use. Although this would permanently incorporate approximately 80% of the existing Section 4(f)-protected park, the NDOT would mitigate this impact by constructing recreational improvements on the remainder of the parcel and on an adjacent parcel, thereby resulting in a net benefit for the park; as such the project is proposing to process the Section 4(f) impact to Sage Street Park under Alternative 2 with a Net Benefit Programmatic.

Alternative 3 Under Alternative 3 NDOT would widen existing I-80 along the southern edge of the park. This impact would result in the permanent incorporation of approximately 0.2 acres of parkland at Sage Street Park that is Section 4(f)-protected, thereby resulting in a use (see Figure 3 in Attachment 1). Although this impact would result in the incorporation of approximately 50% of the existing Section 4(f)-protected park parcel, NDOT would mitigate it by constructing

2 Reno Spaghetti Bowl Project, Project ID #443-16-015

recreational improvements on the remainder of the park and on an adjacent parcel, thereby resulting in a net benefit for the park; as such the project is proposing to process the Section 4(f) impact to Sage Street Park under Alternative 3 with a Net Benefit Programmatic.

Findings

FHWA has determined that the project’s use of Sage Street Park under Alternatives 1, 2, and 3 are in accordance with the requirements of the Final Nationwide Programmatic Section 4(f) Evaluation and Determination for Federal-Aid Transportation Projects That Have a Net Benefit to a Section 4(f) Property (FHWA, 2005). Attachments 1 provides the findings which justify this determination.

Concurrence Please indicate your agency’s concurrence with FHWA’s Net Benefit Programmatic findings by signing below by July 31, 2018 and returning this concurrence to the address listed in the letterhead.

Please contact me at 775-687-1231 or [email protected] if you need additional information or if you have any concerns. Thanks for your time.

Sincerely,

Abdelmoez Abdalla, Ph.D. Environmental Program Manager Federal Highway Administration – Nevada Division

The City of Reno, as the official with jurisdiction for Sage Street Park, concurs with the with the assessment of the impacts; the proposed measures to minimize harm; and the mitigation necessary to preserve, rehabilitate and enhance those features and values of the Section 4(f) property; and that such measures will result in a net benefit to Sage Street Park.

Signature: ______Date: ______Hillary Schieve, Mayor City of Reno, Nevada

cc: Steve Cooke, Nevada Department of Transportation Chris Young, Nevada Department of Transportation John Taylor, Jacobs Charlie Webb, Jacobs

3 Attachment 1: Net Benefit Programmatic Findings Memorandum

FHWA NEVADA DIVISION NATIONWIDE PROGRAMMATIC 4(f) EVALUATION FOR TRANSPORTATION PROJECTS THAT HAVE A NET BENEFIT TO A SECTION 4(f) PROPERTY

Project: Reno Spaghetti Bowl Reconstruction 4(f) Resource Name: Sage Street Park Highway: I-80/I-580/US 395 Federal Aid Number: NHFP-080-1(172) Project ID: 74020 County: Washoe

Background Federal Highway Administration Nexus The interchange that connects I‐80 and I‐580/US 395 (known locally as the “Spaghetti Bowl”) is located in the Cities of Reno and Sparks in southern Washoe County, Nevada. The Reno Spaghetti Bowl Reconstruction Project (“project”) study area includes the Spaghetti Bowl and a 5‐mile segment of I‐80 from the Keystone Avenue interchange east to the McCarran Boulevard interchange and a 7.3‐mile segment of I‐580/US 395 from the Meadowood Mall Way interchange north through the Spaghetti Bowl to the Parr Avenue/Dandini Boulevard interchange. In addition to the Spaghetti Bowl, which is a freeway‐to‐freeway interchange, the study area includes 16 service interchanges. The purpose of the project is to address the obsolete design of the study area freeway system and interchanges to improve traffic operations and reduce fatalities and injuries related to crashes. A combination of the following factors demonstrates the need for improvements in and around the Spaghetti Bowl:  Reduce travel delay. High traffic volumes and an outdated freeway design contribute to congestion and travel delays.  Improve safety. The higher crash rates experienced along I‐80 and I‐580/ US 395 in the study area, compared to similar urban freeways in Nevada, make safety improvement a key need.  Bridge condition. Most of the bridges in the study area are at or approaching the end of their planned service life. Furthermore, many are not wide enough to meet NDOT standards for traffic lane and shoulder widths.  Optimize system connectivity. I‐80, I‐580, and US 395 are part of the National Highway System, providing important local and regional connectivity.

The project will use Federal funding provided by the U.S. Department of Transportation Federal Highway Administration to conduct an Environmental Impact Statement (EIS) that evaluates the social, environmental, and economic impacts of the No‐build alternative and a range of Build Alternatives, as well as the extent to which they address the need for the project.

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Description of 4(f) Resource The Section 4(f)‐protected part of Sage Street Park is 0.5 acres in size and is located in Reno at 790 Sage Street, north of and adjacent to I‐80. The City of Reno is the official with jurisdiction for the park. Sage Street Park is classified as a neighborhood park (City of Reno 2007b) and is considered a significant recreational resource by the City of Reno.

The City of Reno leases the eastern half of the land currently known as Sage Street Park from NDOT (the park consists of two parcels – the City of Reno owns the western parcel and leases the eastern parcel). The 99‐year lease period began in February 1971 and ends in January 2070. The lease states that either party may terminate the lease for good cause with 90‐day written notice. FHWA has determined, based on the lease noted above, that Section 4(f) does not apply to the eastern parcel of Sage Street Park per 23 CFR 774.11(h). Section 4(f) does apply to the western parcel of Sage Street Park and it is this park parcel that is assessed in this Net Benefit Programmatic as “Sage Street Park”.

Project Use of 4(f) Resources The project’s EIS studied three Build alternatives – Alternatives 1, 2 and 3. Each Build alternative entails various modifications to the Spaghetti Bowl Interchange and the mainlines and exit/entrance ramps of I‐ 80, I‐580, and I‐395, as well as modifications to local street connections to these highways. All three Build alternatives would result in a use of the Section 4(f)‐protected Sage Street Park, as follows: Alternative 1 Under Alternative 1 NDOT would construct at‐grade ramp roadways that would directly impact this park, necessitating the acquisition of the entirety of the Sage Street Park parcel that is Section 4(f)‐ protected (see Figure 1). This impact would be a permanent incorporation of parkland under Section 4(f) and therefore a use. Although this impact would result in the permanent incorporation of the entirety of the existing Section 4(f)‐protected park parcel, the project would commit to mitigating by constructing recreational improvements on a parcel adjacent to it, thereby resulting in a net benefit for the park. Based on this, the project is proposing to process the Section 4(f) impact to Sage Street Park under Alternative 1 with this Net Benefit Programmatic. Alternative 2 Under Alternative 2 NDOT would construct at‐grade ramp roadways that would directly impact this park, necessitating the acquisition of approximately 0.4‐acres of Section 4(f)‐protected parkland (see Figure 2). This impact would be a permanent incorporation under Section 4(f) and therefore a use. Although this would permanently incorporate approximately 80% of the existing Section 4(f)‐protected park, the NDOT would mitigate this impact by constructing recreational improvements on the remainder of the parcel and on an adjacent parcel, thereby resulting in a net benefit for the park; as such the project is proposing to process the Section 4(f) impact to Sage Street Park under Alternative 2 with a Net Benefit Programmatic. Alternative 3 Under Alternative 3 NDOT would widen existing I‐80 along the southern edge of the park. This impact would result in the permanent incorporation of approximately 0.2 acres of parkland at Sage Street Park that is Section 4(f)‐protected (see Figure 3). Although this impact would result in the incorporation of approximately 50% of the existing Section 4(f)‐protected park parcel, NDOT would mitigate it by constructing recreational improvements on the remainder of the park and on an adjacent parcel, thereby resulting in a net benefit for the park; as such the project is proposing to process the Section 4(f) impact to Sage Street Park under Alternative 3 with a Net Benefit Programmatic.

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Justification for Nationwide Programmatic 4(f) Evaluation for Transportation Projects that Have a Net Benefit to a Section 4(f) Property This section provides the justification for a programmatic Section 4(f) finding that there are no feasible and prudent alternatives to the use of the Section 4(f)‐protected Sage Street Park property. This section has been prepared in accordance with the Final Nationwide Programmatic Section 4(f) Evaluation and Determination for Federal‐Aid Transportation Projects That Have a Net Benefit to a Section 4(f) Property statement (FHWA, 2005); italicized text in the sections below indicates text excerpted directly from the FHWA Net Benefit programmatic statement. Applicability This programmatic evaluation satisfies the requirements of Section 4(f) for projects meeting the applicability criteria listed below. An individual Section 4(f) evaluation will not need to be prepared for such projects: 1. The proposed transportation project uses a Section 4(f) park, recreation area, wildlife or waterfowl refuge, or historic site. 2. The proposed project includes all appropriate measures to minimize harm and subsequent mitigation necessary to preserve and enhance those features and values of the property that originally qualified the property for Section 4(f) protection. 3. For historic properties, the project does not require the major alteration of the characteristics that qualify the property for the National Register of Historic Places (NRHP) such that the property would no longer retain sufficient integrity to be considered eligible for listing. For archeological properties, the project does not require the disturbance or removal of the archaeological resources that have been determined important for preservation in-place rather than for the information that can be obtained through data recovery. The determination of a major alteration or the importance to preserve in-place will be based on consultation consistent with 36 CFR part 800. 4. For historic properties, consistent with 36 CFR part 800, there must be agreement reached amongst the SHPO and/or THPO, as appropriate, the FHWA and the Applicant on measures to minimize harm when there is a use of Section 4(f) property. Such measures must be incorporated into the project. 5. The official(s) with jurisdiction over the Section 4(f) property agree in writing with the assessment of the impacts; the proposed measures to minimize harm; and the mitigation necessary to preserve, rehabilitate and enhance those features and values of the Section 4(f) property; and that such measures will result in a net benefit to the Section 4(f) property. 6. The Administration determines that the project facts match those set forth in the Applicability, Alternatives, Findings, Mitigation and Measures to Minimize Harm, Coordination, and Public Involvement sections of this programmatic evaluation. Response: This programmatic Section 4(f) evaluation is applicable to the Spaghetti Bowl Reconstruction Project for the following reasons: 1. Each alternative entails the use of the Section 4(f)‐protected Sage Street Park property, as described in the Background section of this document. 2. Minimization and mitigation measures are described in both the “Findings” and “Mitigation Measures to Minimize Harm” sections of this document. FHWA has determined that project minimization/mitigation efforts described in this document represent all reasonable measures to minimize harm with respect the impacts of Alternatives 1, 2 and 3 at the Section 4(f)‐ protected Sage Street Park property. 3. Not applicable; this programmatic is for a park resource. 4. Not applicable; this programmatic is for a park resource. 5. The City of Reno, who is the official with jurisdiction for Sage Street Park, has agreed in writing with the assessment of impacts and proposed minimization and mitigation measures presented in this document. The City’s concurrence that each of the Spaghetti Bowl Reconstruction Project

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Build alternatives would result in a net benefit to Sage Street Park is provided in Attachment 1 to this document. 6. FHWA’s signature on this document represents their determination that the project facts match those set forth in the Applicability, Alternatives, Findings, Mitigation and Measures to Minimize Harm, Coordination, and Public Involvement sections of the Net Benefit Programmatic statement. Alternatives To demonstrate that there are no feasible and prudent alternatives to the use of Section 4(f) property, the programmatic evaluation analysis must address alternatives that avoid the Section 4(f) property. The following alternatives avoid the use of the Section 4(f) property: 1. Do nothing. 2. Improve the transportation facility in a manner that addresses the project's purpose and need without a use of the Section 4(f) property. 3. Build the transportation facility at a location that does not require use of the Section 4(f) property. This list is intended to be all-inclusive. The programmatic evaluation does not apply if a feasible and prudent alternative is identified that is not discussed in this document. The project record must clearly demonstrate that each of the above alternatives was fully evaluated before the Administration can conclude that the programmatic evaluation can be applied to the project. Response: As addressed and described in the Findings subsection of this document, none of the three above Avoidance Alternative concepts are feasible and prudent, therefore FHWA has concluded that the Net Benefit Programmatic is applicable to this project. Findings For this programmatic evaluation to be utilized on a project there must be a finding, given the present condition of the Section 4(f) property, that the do-nothing and avoidance alternatives described in the Alternatives section above are not feasible and prudent. The findings (1, 2, and 3. below) must be supported by the circumstances, studies, consultations, and other relevant information and included in the administrative record for the project. This supporting information and determination will be documented in the appropriate NEPA document and/or project record consistent with current Section 4(f) policy and guidance. To support the finding, adverse factors associated with the no-build and avoidance alternatives, such as environmental impacts, safety and geometric problems, decreased transportation service, increased costs, and any other factors may be considered collectively. One or an accumulation of these kinds of factors must be of extraordinary magnitude when compared to the proposed use of the Section 4(f) property to determine that an alternative is not feasible and prudent. The net impact of the do-nothing or build alternatives must also consider the function and value of the Section 4(f) property before and after project implementation as well as the physical and/or functional relationship of the Section 4(f) property to the surrounding area or community. 1. Do-Nothing Alternative. The Do-Nothing Alternative is not feasible and prudent because it would neither address nor correct the transportation need cited as the NEPA purpose and need, which necessitated the proposed project. Response: The No Build Alternative would avoid a use of Sage Street Park, but is deemed not prudent because it neither addresses nor corrects the transportation purpose and need that prompted the proposed project. The No Build Alternative does not address the stated project purpose: “to improve the operations, capacity, and safety of the freeways, system interchange and service interchanges that comprise the transportation system”. The No Build Alternative would not address substandard and deficient features of the existing highway system like lane drops and low‐speed loop ramps with tight curves, nor would it address the need for increased capacity on some of the Spaghetti Bowl system ramps.

2. Improve the transportation facility in a manner that addresses purpose and need without use of the Section 4(f) property. It is not feasible and prudent to avoid Section 4(f) property by using engineering design or transportation system management techniques, such as minor location shifts, changes in engineering design standards,

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use of retaining walls and/or other structures and traffic diversions or other traffic management measures if implementing such measures would result in any of the following: a. Substantial adverse community impacts to adjacent homes, businesses or other improved properties; or b. Substantially increased transportation facility or structure cost; or c. Unique engineering, traffic, maintenance or safety problems; or d. Substantial adverse social, economic or environmental impacts; or e. A substantial missed opportunity to benefit a Section 4(f) property; or f. Identified transportation needs not being met; and g. Impacts, costs or problems would be truly unusual, unique or of extraordinary magnitude when compared with the proposed use of Section 4(f) property after taking into account measures to minimize harm and mitigate for adverse uses, and enhance the functions and value of the Section 4(f) property. Response: This alternative concept would not be prudent per (e) above. As noted, alternatives 1, 2 and 3 would result in a use of the Section 4(f)‐protected Sage Street Park. However, if the project were not constructed, the proposed new park amenities to be built as part of the project (which would result in a substantial enhancement of current park conditions) would not be installed. There are currently no recreational amenities at the Section 4(f)‐protected Sage Street Park property. Existing features at this property are an open grass area, a park bench, and a picnic table. Under alternatives 1, 2 and 3, land adjacent to the existing park property would be purchased and recreational playground and picnic facilities would be constructed. A concept for this new park space park space (which could be utilized for any of the three alternatives) is shown in Attachment 2. The construction of these new Sage Street Park amenities would provide residents of the surrounding Reno Housing Authority public housing complex with recreational features they would not otherwise have close access to. Based on the above, it is concluded here that this avoidance alternative would result in a substantial missed opportunity to benefit the Section 4(f)‐protected Sage Street Park property.

3. Build a new facility at a new location without a use of the Section 4(f) property. It is not feasible and prudent to avoid Section 4(f) property by constructing at a new location if: a. The new location would not address or correct the problems cited as the NEPA purpose and need, which necessitated the proposed project; or b. The new location would result in substantial adverse social, economic or environmental impacts (including such impacts as extensive severing of productive farmlands, displacement of a substantial number of families or businesses, serious disruption of community cohesion, jeopardize the continued existence of any endangered or threatened species or resulting in the destruction or adverse modification of their designated critical habitat, substantial damage to wetlands or other sensitive natural areas, or greater impacts to other Section 4(f) properties); or c. The new location would substantially increase costs or cause substantial engineering difficulties (such as an inability to achieve minimum design standards or to meet the requirements of various permitting agencies such as those involved with navigation, pollution, or the environment); and d. Such problems, impacts, costs, or difficulties would be truly unusual or unique or of extraordinary magnitude when compared with the proposed use of the Section 4(f) property after taking into account proposed measures to minimize harm, mitigation for adverse use, and the enhancement of the Section 4(f) property's functions and value. Response: This alternative concept would not be prudent per (b) above. For any of the Build alternatives, constructing the necessary freeway improvements for that alternative in a different location (while still meeting the project’s purpose and need) would result in a substantial adverse social impact as described below. Under any of the three Build alternatives, avoiding the permanent incorporation (and subsequent use) of parkland at Sage Street Park by building a new freeway at a new location would result in a substantial

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additional number of residential displacements and environmental justice impacts. Because the impacts to Sage Street Park under alternatives 1, 2, and 3 are related to the construction of new ramps connecting I‐580/US‐395 with I‐80, the only way to avoid the park property while still meeting the purpose and need of the project would be to shift the ramps north of the park parcel. A design shift northward away from the existing highway right‐of‐way and into the neighborhood would result in a substantially greater direct impact to the adjacent low‐income community, with associated displacements that would substantially exceed the number of displacements that would occur under alternatives 1, 2, or 3. Due to the scarcity and high cost of low‐income housing in Reno, this higher number of displaced residents would have a difficult time relocating in the immediate vicinity (so as to remain close to their jobs and children’s current school). In addition to the increased displacements, this alternative concept would also result in impacts to an established environmental justice population (at the Mineral Manor housing complex) as well as an adverse effect on community cohesion associated with the introduction of transportation facilities through this older established neighborhood. Mitigation and Measures to Minimize Harm This programmatic evaluation and approval may be used only for projects where the Administration, in accordance with this evaluation, ensures that the proposed action includes all possible planning to minimize harm, includes appropriate mitigation measures, and that the official(s) with jurisdiction agree in writing.

Response: Alternatives 1, 2 and 3 were designed to avoid or minimize impacts to Section 4(f) resources while also meeting project purpose and need, being feasible from an engineering perspective, and not causing substantial adverse effects to other built or natural environmental resources (as discussed in the Findings section of this document). Potential measures to minimize harm were discussed by NDOT and FHWA throughout alternative development – coordination with the City of Reno resulted in a decision that the best way to mitigate for potential project impacts to Sage Street Park would be to construct new park facilities that would result in an enhanced park experience for residents located in the adjacent neighborhood.

A potential minimization effort not discussed in the Findings section of this document is that NDOT examined the possibility, for alternatives 1, 2 and 3, of having all bridges elevated over the park, thereby potentially allowing a recreational use to occur on the land underneath the structure. However, NDOT decided against this because of safety concerns. Unlike other situations where recreational activities under public infrastructure occur in an open setting, in the case of Sage Street Park, the area underneath the roadway structures would, by necessity, be closed at one side (the side abutting I‐80), creating a cave‐like effect that was deemed to be unacceptable from a safety standpoint per concerns about criminal activity in such a setting. At the least, a setting like this would be unappealing for park visitors, especially those with young children. Based on this, NDOT decided, after coordination with the City of Reno, that the best course of action (both for the neighborhood and for the ability of the project to have an efficient design that would meet purpose and need) would be to purchase adjacent property and construct new park amenities that would result in a net recreational benefit to the community. FHWA has determined that project minimization/mitigation efforts described above and in the Findings section of this document represent all reasonable measures to minimize harm with respect the impacts of alternatives 1, 2, and 3. Coordination In early stages of project development, each project will require coordination with the Federal, State, and/or local agency official(s) with jurisdiction over the Section 4(f) property. For non-Federal Section 4(f) properties, i.e., State or local properties, the official(s) with jurisdiction will be asked to identify any Federal encumbrances. When encumbrances exist, coordination will be required with the Federal agency responsible for such encumbrances.

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Copies of the final written report required under this programmatic evaluation shall be offered to the official(s) with jurisdiction over the Section 4(f) property, to other interested parties as part of the normal NEPA project documentation distribution practices and policies or upon request. Response: NDOT, FHWA, and the project consultant team have coordinated with City of Reno Parks, Recreation and Community Services Staff regarding potential impacts to, and mitigation for, Sage Street Park in the period between June 2017 and May 2018. The intent to process project impacts (under alternatives 1, 2, and 3) at Sage Street Park using the Net Benefit Programmatic was conveyed to the City of Reno prior to the publishing of the project’s Draft EIS/Draft Section 4(f) Evaluation. The City was provided a copy of the findings to review and has provided their concurrence per the findings (see Attachment 1). Public Involvement The project shall include public involvement activities that are consistent with the specific requirements of 23 CFR 771.111, Early coordination, public involvement and project development. For a project where one or more public meetings or hearings are held, information on the proposed use of the Section 4(f) property shall be communicated at the public meeting(s) or hearing(s). Response: The public involvement process for the project’s EIS has been conducted in accordance with 23 CFR 771.111. As noted above in the Coordination section of this document, the project conducted early and ongoing coordination with the City of Reno regarding potential impacts from alternatives 1,2, and 3 to Reno parks and recreation resources, including Sage Street Park. The intent to process project impacts (from alternatives 1,2, and 3) at Sage Street Park using the Net Benefit Programmatic was conveyed to the City of Reno prior to the publishing of the project’s Draft EIS/Draft Section 4(f) Evaluation. The City was provided a copy of the findings to review and has provided their concurrence per the findings (see Attachment 1). Findings supporting the applicability of the Net Benefit Programmatic to alternatives 1, 2, and 3 are also being included in the project’s published Draft EIS/Draft Section 4(f) Evaluation to provide opportunity for public comment. Summary The Spaghetti Bowl Reconstruction Project meets all criteria included in the Final Nationwide Programmatic Section 4(f) Evaluation and Determination for Federal‐Aid Transportation Projects that have a Net Benefit to a Section 4(f) Property statement (FHWA, 2005). All required alternatives have been evaluated and the findings made are clearly applicable to this project. The project includes all possible planning to minimize harm and there are assurances that measures to mitigate for the use of the Section 4(f)‐protected Sage Street Park will be completed. Approvals FHWA – NEVADA DIVISION By: ______Susan Klekar, Administrator

Date: ______cc: Abdelmoez Abdalla, FHWA Steve Cooke, NDOT Jacob Waclaw, FHWA Dale Keller, NDOT Juan Balbuena, FHWA John Taylor, Jacobs Greg Novak, NDOT Charlie Webb, Jacobs

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Figure 1: Alternative 1 Impacts at Sage Street Park

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Figure 2: Alternative 2 Impacts at Sage Street Park

Figure 3: Alternative 3 Impacts at Sage Street Park

Attachment 1: City of Reno Net Benefit Concurrence Letter for Sage Street Park

Attachment 2: Sage Street Park Concept Drawing