CONSUMER FINANCIAL PROTECTION BUREAU WASHINGTON, DC

NCPC PROJECT PLANS PRELIMINARY SUBMISSION PART E: APPENDIX REVISED JAN 3, 2014

Consumer Financial Protection Bureau PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

ENVIRONMENTAL ASSESSMENT Contents FOR THE RENOVATION OF THE List of Tables ...... iv CONSUMER FINANCIAL PROTECTION BUREAU HEADQUARTERS' BUILDING List of Figures ...... iv LOCATED ON 1700 G STREET, NW, WASHINGTON, DC, 20552 ACRONYMS AND ABBREVIATIONS ...... v EXECUTIVE SUMMARY ...... 1 1.0 PURPOSE AND NEED OF PROJECT ...... 3 1.1 Project Description ...... 3 Location and Physiography...... 4 Building History...... 4 Exterior Wall ...... 4 P-1 and P-2 Levels ...... 4 Basement Level ...... 5 Ground Floor Level...... 5 2nd thru 5th Floor Levels ...... 5 6th Floor Level ...... 5 Rooftop Level ...... 5 1.2 Purpose of and Need for Project ...... 6 1.3 Public Involvement and Agency Coordination ...... 7 National Capital Planning Commission ...... 7 Commission of Fine Arts ...... 7 Section 106 Review ...... 7  State Historic Preservation Officer for the District of Columbia ...... 7 SUBMITTED TO: 2.0 ALTERNATIVES TO THE PROPOSED ACTION ...... 8

THE CONSUMER FINANCIAL PROTECTION BUREAU 3.0 AFFECTED AREAS AND POTENTIAL CONSEQUENCES ...... 9 1700 G STREET, NW, WASHINGTON, DC 3.1 Land Use ...... 9

PREPARED BY: Affected Areas ...... 9 Potential Consequences ...... 9 3.2 Health and Safety ...... 9 Affected Areas ...... 9

TETRAHEDRON, INC. Potential Consequences ...... 9 1414 KEY HIGHWAY, SUITE B 3.3 Local Social and Economic Impact of Proposed Action ...... 9 BALTIMORE, MD 21230 Affected Areas ...... 9

JANUARY 2, 2014 Potential Consequences ...... 9 3.4 Local Social and Economic Impact of Relocated Staff from Proposed Action ...... 10

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APPENDIX - 2 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

Affected Areas ...... 10 Affected Areas ...... 21 Potential Consequences ...... 10 Potential Consequences ...... 22 3.5 Security Perimeter of Building ...... 10 3.17 Energy Consumption ...... 23 Affected Areas ...... 10 Affected Areas ...... 23 Potential Consequences ...... 12 Potential Consequences ...... 23 3.6 Local Air Quality ...... 13 3.18 Local Antennas ...... 24 Affected Areas ...... 14 Affected Areas ...... 24 Potential Consequences ...... 14 Potential Consequences ...... 24 3.7 Noise...... 14 3.19 Cellular Tower Locations ...... 24 Affected Areas ...... 14 Affected Areas ...... 25 Potential Consequences ...... 14 Potential Consequences ...... 26 3.8 Impact on Storm Water ...... 15 3.20 Impact to Pedestrians and Bicyclists ...... 26 Affected Areas ...... 15 Affected Areas ...... 26 Potential Consequences ...... 15 Potential Consequences ...... 26 3.9 Impact on Waste Water ...... 16 3.21 Vehicle Traffic ...... 26 Affected Areas ...... 16 Affected Areas ...... 26 Potential Consequences ...... 16 Potential Consequences ...... 27 3.10 Impact on Ground Water ...... 16 3.22 Relationship of Local Short-term Uses vs. Long-term Productivity ...... 27 Affected Areas ...... 17 Affected Areas ...... 27 Potential Consequences ...... 17 Potential Consequences ...... 27 3.11 Wetlands ...... 18 3.23 Irreversible and Irretrievable Commitment of Resources ...... 27 Affected Areas ...... 18 4.0 SUMMARY OF IMPACTS ...... 28 Potential Consequences ...... 18 4.1 Cumulative Impacts ...... 28 3.12 Floodplains ...... 18 4.2 Air Quality ...... 28 Affected Areas ...... 18 4.3 Noise...... 28 Potential Consequences ...... 19 4.3 Water Resources ...... 28 3.13 Risk to Threatened and Endangered Species ...... 19 4.4 Potential for Public Controversy ...... 29 Affected Areas ...... 19 5.0 CONCLUSION ...... 30 Potential Consequences ...... 19 6.0 REFERENCES ...... 32 3.14 Historic and Archeological Preservation ...... 19 Affected Areas ...... 20 Potential Consequences ...... 20 3.15 Hazardous Waste Potential ...... 20 Affected Areas ...... 20 Potential Consequences ...... 21 3.16 Visual Impacts ...... 21

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APPENDIX - 3 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

List of Tables ACRONYMS AND ABBREVIATIONS Table 1-1 Summary of Environmental Impacts 1 ACHP Advisory Council on Historic Preservation Table 3-1 National ambient air quality primary standards and air quality data for Washington, ASHRAE American Society of Heating, Refrigeration, and Air-Conditioning Engineers DC, from 2009 through 2012 13 BMPs Best Management Practices Table 3-2 FCC Registered Cell Phone 26 CEQ Council on Environmental Quality CFPB Consumer Financial Protection Bureau CFR Code of Federal Regulations List of Figures CAA Clean Air Act Figure 1-1 Building at 1700 G Street. Southwest View 3 CWA Clean Water Act Figure 1-2 Aerial Photograph of Proposed Action Site 3 D.C. District of Columbia Figure 1-3 Rendition of the Childcare area of the Rooftop 6 DCMR District of Columbia Municipality Regulations Figure 3-1 Concrete Planters on G Street 10 DCRA DC Department of Consumer Regulatory Affairs Figure 3-2 Concrete Planters on F Street 11 DDOE DC Department of the Environment Figure 3-3 North Entrance, Corner of G and 17th Street 11 DDOT DC Department of Transportation Figure 3-4 Raised Vehicular Plate Barriers at Loading Dock Entrance on F Street 12 DCSHPO State Historic Preservation Officer for the District of Columbia Figure 3-5 Proposed Security Features of Ground Floor 12 DEQ Department of Environmental Quality Figure 3-6 Topographic Map of Proposed Action Site 17 DOE U.S. Department of Energy (also referred to as the Department) Figure 3-7 Floodplain Map of Proposed Action Site 18 EA environmental assessment Figure 3-8 Proposed Final Appearance of Building, Southwest View 21 EIS Environmental Impact Statement Figure 3-9 Proposed Final Appearance of Building, Plaza View 22 E.O. Executive Order Figure 3-10 Current Building at 1700 G Street and Eisenhower Executive Office Building 22 EPA U.S. Environmental Protection Agency Figure 3-11 Lightning Rods Along The Rooftop 24 ESA Endangered Species Act Figure 3-12 Map of Subject Site (black star) and Cell Phone Towers (red balloons) 25 EPEAT Electronic Product Environmental Assessment Tool FCC Federal Communication Commission Appendices FHLBB Federal Home Loan Bank Board Historical Data A FEMP U.S. Department of Energy Federal Energy Management Program FIRM Flood Insurance Rate Map FONSI Finding of No Significant Impact HVAC heating, ventilation and air conditioning LEED Leadership in Energy and Environmental Design MHz megahertz MS4 DC Municipal Separate Storm Sewer System NAAQS National Ambient Air Quality Standards NCPC National Capital Planning Commission NEPA National Environmental Policy Act, as amended NFIP National Flood Insurance Program NHPA National Historic Preservation Act NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System OSHA Occupational Safety and Health Administration OTS Office of Thrift Supervision PM particle matter RF radio frequency RCRA Resource Conservation and Recovery Act USACE United States Army Corps of Engineers U.S.C. United States Code FWS U.S. Fish and Wildlife Service USGBC U.S. Green Building Council USGS United States Geological Survey

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APPENDIX - 4 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

SUMMARY OF ENVIRONMENTAL IMPACTS Resource Impact Analysis Overall Consequence EXECUTIVE SUMMARY Threatened and The Hay's Spring habitat of Rock Creek is over 1.5 miles Endangered No impact from proposed action site. This Environmental Assessment is intended to examine the potential effects of the "proposed Species Building is not listed as a historically significant building and action" to renovate the interior and plaza space of the building used as Headquarters for the Historic and no records of archeological findings are recorded for the No impact Consumer Financial Protection Bureau located at 1700 G Street, NW, Washington DC, 20552. Archeological The "no action" alternative to the above-proposed action will be that no renovation of the proposed action site. Normal building operations do not generate hazardous waste. facility would occur. Hazardous A covered hazardous waste storage area will be present No impact Waste during the proposed action. A third party will be contracted Based on Tetrahedron's evaluation of available records and discussions with various personnel, to remove materials as needed. below is a summary of the foreseeable environmental impacts the proposed action will have at No additional floors are being planned for the building. A the property and impacts to the local community. portion of the rooftop will be modified to accommodate a Visual childcare play area and would only be visible from the No impact Table 1-1 Summary of Environmental Impacts interior plaza. Aside from the updated lobby, the current SUMMARY OF ENVIRONMENTAL IMPACTS street level view of the building will remain the same. Energy Building is projected to be rated LEED Gold after the Resource Impact Analysis Overall Consequence No impact The land will be used for the same purpose after the Consumption proposed action, leading to less energy consumption. Land Use No impact proposed action. No new land will be utilized. Lightning rods on the rooftop will have to be relocated safely Health and Health and Safety plan to be developed by Rolf Jensen & away from the childcare area on the rooftop. No other No impact Antennas No long term impact Safety Associates before proposed action to commence. antennas on the proposed action site or on neighboring During the proposed action, local businesses near the Subject No long term impact, buildings require further action. Local Social and Site will not have access to as many customers due to some positive and No towers are planned to be erected due to the proposed Economic relocated CFPB staff. Construction crews will mitigate some negative short term Cellular Tower action. The three towers in DC high transmission frequency No impact Impact at Site of the losses. impacts and distance from the site greatly reduce potential impact. During the proposed action, pedestrian and bicycle traffic Short term Local Social and The current tenants of Constitution Square will be No long term impact, Pedestrians and will be temporarily impeded to accommodate construction disturbance. No long Economic inconvenienced by the increase of office workers during the some positive and Bicyclists Impact of proposed action. The increase in workers will likely increase negative short term activities. term impact Relocated Staff sales to local businesses. impacts Short term During the proposed action, vehicle traffic will be Traffic disturbance. No long Anti-ram device at temporarily impeded to accommodate construction activities. northern entrance may term impact negatively impact Local Short- Current security perimeter features are intended to stay in The proposed action will allow more workers to utilize the Security visual appeal and term Uses vs. place (vehicle entrances) or evaluated for possible upgrades building space while using fewer resources from the building No impact Perimeter of pedestrian access. Long-term (bollards). New bollards are currently planned for the upgrades. Building Other security features Productivity northern lobby entrance located at 17th and G Street. will have no impact as they are already in Based on the review and analysis of materials, a Finding of No Significant Impact for the place. proposed action at 1700 G Street, NW, Washington DC, 20552. Local air quality will be impacted by dust and hazardous Short term Local Air pollutants while construction equipment is in use and during disturbance. No long Due to the temporary nature of the project, any potential environmental and public disturbances Quality demolition phases. Regular building operations do not affect term impact will be short-term. Many of the renovations, such as noise damping materials and a green roof, air quality normally. will prove to be beneficial to workers, public, and the local environment over the long term. Temporary local noise levels will increase during Short term Noise construction work. Regular building operations do not affect disturbance. No long noise levels normally. term impact BMPs and other measures are to be put in place before the Storm Water No impact proposed action it to take place. After construction, the improvements are expected to reduce Waste Water the amount of wastewater entering the DC combined sewage No impact system from this building. Ground Water Proposed action is not expected to disturb ground water. No impact Wetlands Nearest wetland is over a mile away. No impact Floodplains Proposed action site is outside historical DC floodplains No impact

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APPENDIX - 5 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

1.0 PURPOSE AND NEED OF PROJECT Location and Physiography The District of Columbia covers an area of about 65 square miles on the northeast and east side of the Potomac River, adjacent to the mouth of the Anacostia River. The District has two 1.1 Project Description physiographic provinces, the Mid-Atlantic Coastal Plain and the Piedmont Province. The Fall The project at 1700 G Street, NW is to modernize the interior and plaza space of the building. line, which separates the Piedmont Province in the west from Coastal Plain Province in the east, The building is currently used as the headquarters for the Consumer Financial Protection Bureau bisects the area diagonally from northeast to southwest. Much of the District is dissected by (CFPB). Originally built in 1976, the building has three below ground levels that extend beneath erosion and is characterized by nearly level to gently rolling uplands, steep valley walls, widely a large public plaza (two of which include secured parking) and six floors above ground with a separated inter-stream divides and narrow valley bottoms. penthouse above the 6th floor for mechanical equipment. Storefront retail is located at the ground level. Structurally, the building is a reinforced concrete frame structure on a 30-foot-by- In the downtown area, most public buildings and memorials are on nearly level lowlands formed 30-foot column module with waffle slabs. on river terrace deposits, alluvium and artificial fill. Elevation ranges from sea level in the southern part of Washington, where the Anacostia and Potomac Rivers are tidal estuaries, to 20 Figure 1-1 Building at 1700 G Street. Southwest View feet in Tenleytown in the west of the city. Inter-stream ridges are highest in the Piedmont section of the city, and grade gradually to the south and east, where elevations are generally below 230 feet.

1700 G Street, NW is located in a highly developed urban portion of Washington DC. The site shares a plaza with the Winder Building. It is bounded by G Street to the north, 17th Street on the east, the Winder Building and F Street to the south (which share a plaza), and a retail/office building on the west. The Eisenhower Executive building is located across 17th Street, with the White House 0.2 miles further to the east. Many other federal agencies, businesses, and non- governmental organizations occupy neighboring buildings as well. Building History 1700 G Street was designed and constructed from 1974 to 1977. It originally housed the Federal Home Loan Bank Board (FHLBB) and then its successor agencies, which later shared occupancy of the building with the Office of Thrift Supervision (OTS) until the closure of the OTS on 19

October 2011. The Federal Housing Finance Agency also shared the building from September The overall project site, outlined in white below, is approximately 51,500 square feet for the 2008 until March 2011. The building’s sole occupant is now the Consumer Financial Protection building and 16,700 square feet for the plaza, totaling 68,200 square feet. The building footprint Bureau (CFPB), which began occupying the building in November 2011. An evaluation of the is approximately 47,600 square feet, and the interior building area is approximately 502,600 historic significance of 1700 G Street, NW is currently ongoing as of the writing of this report. square feet. The current building at 1700 G Street, NW now used by CFPB was constructed in 1975. The Figure 1-2 Aerial Photograph of Proposed Action Site (outlined in white) FHLBB moved into the building immediately after construction was complete. Since construction, the building has not undergone any renovations except roof maintenance, repair and non-structural adjustments to the building interior. A plaza fountain flows during the summer season, but an area that was previously a skating rink is now a daytime gathering area and a street-to-street short-cut for pedestrians.

The overall project will involve significant improvements to the building. Under the proposed action, the planned changes, renovations, expansions and additions include: Exterior Wall A planned demolition is set for all existing windows, to be replaced with a new window system from the 2nd to 6th floor and the lobby entrance of G and 17th street. P-1 and P-2 Levels Areas including below grade level house the garage area. Additional shaft openings will be added in the garage levels for mechanical shaft. Security access at elevator vestibules will be provided for the garage elevators at Levels P-1 and P-2. All garage columns require

strengthening according to the concept report blast assessment.

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APPENDIX - 6 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

Basement Level Figure 1-3 Rendition of the Childcare area of the Rooftop Currently contains mixed-use occupancy including childcare, office area, network servers, storage rooms and mechanical areas. Additional openings will be added in the basement levels for mechanical shaft. Renovations for the basement include a new conference center and areas, a communicating stair from the lobby to allow access to the conference center, a fitness center and associated mechanical and electrical upgrades along with security infrastructure. After the renovation, there will be no office spaces or childcare center in the basement. Ground Floor Level Work includes mechanical and electrical upgrades along with security infrastructure. The existing ground level lobby will be renovated to be commensurate with the new exterior storefront replacement and include security bollards outside the main entrance. The existing retail areas will remain. Existing annunciation panel and fire control room will remain in place. The lobby will incorporate a new communicating stair leading down to the basement conference center. Elevator lobby and elevator cabs will be renovated along with the outdoor plaza and access alleys. A new childcare area is planned to be set up on the ground floor in the area currently used by Met Café.

2nd thru 5th Floor Levels Currently, portions of the rooftop of 1700 G Street have lighting rods, air handlers and a TV Work includes associated mechanical and electrical upgrades along with security infrastructure. antenna. An open communicating stairs is planned for each floor to be in each atria (East and West). 1.2 Purpose of and Need for Project Demolition of upturn beam at the atrium opening will be replaced by a glass railing. The current In accordance with the National Environmental Policy Act (NEPA) of 1969, the CFPB must restrooms throughout the floors are planned to be renovated. evaluate the environmental consequences of proposed actions (renovation of the facility) on the 6th Floor Level natural and human environment before deciding to fund an action, including evaluating There will be a new extension of the interior exit stair at F St side leading to upper floors. Work alternative means of addressing the purpose and need for a federal action. The President’s includes associated mechanical and electrical upgrades along with security infrastructure and Council on Environmental Quality (CEQ) has developed a series of regulations for implementing continuation of the open communicating staircase from the lower levels in the East and West NEPA. These regulations are included in 40 CFR, parts 1500-1508. atria. Demolition of upturn beam at the atrium opening will be replaced by a glass railing. The current restrooms are planned to be renovated. The CFPB is required to prepare a draft environmental assessment (EA) to identify and evaluate potential environmental impacts resulting from the alternative presented in the EA and to Rooftop Level determine whether to prepare an Environmental Impact Statement (EIS) or a Finding of No A new cooling tower will be installed, along with air handler units and associated connections Significant Impact (FONSI). This draft EA will be available for public comments for a month. and pumps. It will have a new "green" roof and a play area for the childcare with a staircase and dedicated elevator access. A portion of the childcare area will have a shade structure while the In addition to complying with NEPA, CEQ regulations (40 CFR Parts 1500-1508), and relevant rest of the play area will be exposed to the elements. The area will be surrounded by a limestone agency NEPA implementing regulations, this EA also addresses all applicable laws and barrier to protect the children. The perimeter wall will be set back from the edge of the rooftop. regulations, including but not limited to the following: No air handlers or HVAC equipment were present on the rooftop portion proposed for the x Energy Policy Act of 2005 childcare play area. The following image is a depiction of the rooftop level that will be used by x National Historic Preservation Act (NHPA) the childcare center. No other portions of the roof are expected to be regularly used by personnel. x Archeological Resources Protection Act x The Noise Control Act of 1972, as amended x Environmental Justice (Executive Order (EO) 12898) x Clean Air Act (CAA and amendments) x Clean Water Act (CWA) x Coastal Zone Management Act x Protection of Wetlands (EO 11990) x Floodplain Management (EO 11988) x Endangered Species Act x Pollution Prevention Act x Resource Conservation and Recovery Act

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APPENDIX - 7 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

x Comprehensive Environmental Response, Compensation and Liability Act 1.3 Public Involvement and Agency Coordination National Capital Planning Commission 2.0 ALTERNATIVES TO THE PROPOSED ACTION Congress established the National Capital Planning Commission (NCPC) in 1924 to prepare a “comprehensive, consistent and coordinated plan for the National Capital.” NCPC has the If the proposed action at 1700 G Street, NW cannot proceed, the alternative "no action" will be primary responsibility for the comprehensive plan since that time. After Congress granted DC no renovations or improvements to the entire building or plaza. home rule, responsibility for many planning functions shifted to the city’s mayor. Today, the DC Office of Planning prepares the District Elements of the comprehensive plan, subject to NCPC In the event that "no action" for the building and plaza renovation were to take place, some review, while NCPC prepares the Federal Elements of the plan. NCPC promotes the efficient smaller forms of interior renovations will likely still occur. These actions would likely include operation of the federal government while reinforcing smart growth principles and surrounding items such as renovations to the buildings electrical, heating ventilation and air conditioning local and regional planning objectives. NCPC protects the capital’s historical, cultural and (HVAC) systems, and mechanical systems. Other building features, such as windows and environmental resources, ensuring that they will be here for future generations. carpets, would likely be repaired or replaced. Commission of Fine Arts The Commission of Fine Arts, established in 1910 by Act of Congress, is charged with giving expert advice to the President, Congress and the heads of departments and agencies of the Federal and District of Columbia governments on matters of design and aesthetics, as they affect the Federal interest and preserve the dignity of the nation's capital. The Commission consists of seven "well qualified judges of the fine arts" appointed by the President and serve for a term of four years; they may also be reappointed. Within the District of Columbia, the Commission advises on design matters affecting the Historic District of Georgetown, under the Old Georgetown Act, as well as other private sector areas adjacent to federal interests, under the Shipstead-Luce Act. Section 106 Review Section 106 of the National Historic Preservation Act of 1966 requires Federal agencies to take into account the effects of their undertakings on historic properties, and afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment. The historic preservation review process mandated by Section 106 is outlined in regulations issued by ACHP. Revised regulations, "Protection of Historic Properties" (36 CFR Part 800), became effective August 5, 2004. Under the regulations, the responsible Federal agency first determines whether it has an undertaking is a type of activity that could affect historic properties. Historic properties are properties that are included in the National Register of Historic Places or that meet the criteria for the National Register. If so, State Historic Preservation Officer for the District of Columbia (DCSHPO) is to be consulted during the process. It should also plan to involve the public, and identify other potential consulting parties. If it determines that it has no undertaking, or that its undertaking is a type of activity that has no potential to affect historic properties, the agency has no further Section 106 obligations. State Historic Preservation Officer for the District of Columbia The DCSHPO is responsible for protecting the District's unique historical, archaeological, architectural, and cultural resources. This responsibility is shared with each federal agency that administers properties or undertakes construction activities in Washington, DC. Each year the DCSHPO prepares an Annual Work Plan to help the District meet its long-term historic preservation goals. The District of Columbia Historic Preservation Review Board, a group of private citizens appointed by the Mayor to represent professional and community viewpoints in the historic preservation process, advises the DCSHPO on matters relating to Section 106 review. The Historic Preservation Office serves as staff to the DCSHPO and the Historic Preservation Review Board.

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APPENDIX - 8 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

3.0 AFFECTED AREAS AND POTENTIAL CONSEQUENCES 3.4 Local Social and Economic Impact of Relocated Staff from Proposed Action During the proposed action, employees of the CFPB will be relocated to work at Constitution 3.1 Land Use Square at 1275 First Street, NE, Washington, DC, 20417, about 2 miles from the site of the The site of the proposed action currently occupies a heavily urbanized area of Washington DC. proposed action. The building is also used by the U.S. General Services Administration. The building currently on-site was built in 1976. It currently shares a plaza with the Winder Building to the south, and another office building to the west. Affected Areas The current occupants of Constitution Square and nearby businesses will be affected during the Affected Areas proposed action. The additional workers will also influence local streets, parking lots and transit The proposed renovations and construction will take place on the footprint of the current systems. building and plaza. No new land is expected to be developed for the project. Potential Consequences Potential Consequences The current occupants of Constitution Square may be inconvenienced the personnel being No impact is given that no new land will be developed for the Proposed Action site. temporarily relocated to their building. The retail space at Constitution Square and nearby will likely see an increase in sales and revenue from the increased number of workers. 3.2 Health and Safety Normal building operations do not pose a risk to workers or the public currently and will not Parking facilities at Constitution Square will gain an increase of users, possibly leading to some after the project is complete. To comply with Occupational Safety and Health Administration facilities being at capacity. These consequences will only last during the duration of the proposed (OSHA) standards, a health and safety plan will need to be developed for the project. action. Affected Areas 3.5 Security Perimeter of Building For the proposed project, Rolf Jensen & Associates Inc. will generate a health and safety plan for A risk assessment performed by Strauchs LLC states that after the proposed action, the facility the people and workers involved in the project. will be refurbished to meet Facility Security Level III, which applies to buildings with 80,000 to Potential Consequences 150,000 square feet, and/or with moderate to high public access. Once the proposed action is approved, a worker Health and Safety plan will be developed by the Affected Areas General Contractor. The plaza entrances are blocked with concrete planters (Figure 3-1 and 3-2). The planters are 3.3 Local Social and Economic Impact of Proposed Action planned to be evaluated during the proposed action and compared with other anti-ram solutions. During the proposed renovation and construction activities at the site, all personnel working for Currently at the main entrance of the lobby, there are no planters or bollards providing protection the CFPB will be relocated to Constitution Square at 1275 First Street, NE, Washington, DC, (Figure 3-3). 20417, about 2 miles from the site of the proposed action. The building is also used by the U.S. General Services Administration. Figure 3-1 Concrete Planters on G Street Affected Areas During the renovation and construction activities at the site, all personnel working for the CFPB will be relocated from the facility. Other local shops and restaurants will be temporarily affected by the relocation of CFPB workers.

Construction perimeters and other barriers set up around the Subject Site may also impede customers from access to local retailers during the duration of the proposed action. Potential Consequences Retailers dependent on sales from staffers at the CFPB will likely register a lower rate of sales since the staff will not be present during the renovation. During the renovation, access to retailers could also be hindered on a temporary basis. Construction crews could patronize local restaurants and eateries, temporarily replacing CFPB workers.

Any negative impacts on local businesses will dissipate after the proposed action is complete.

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APPENDIX - 9 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

Figure 3-2 Concrete Planters on F Street Figure 3-4 Raised Vehicular Plate Barriers at Loading Dock Entrance on F Street

Figure 3-3 North Entrance, Corner of G and 17th Street

Potential Consequences A site plan of the building highlighting planned perimeter security features is shown below.

Figure 3-5 Proposed Security Features of Ground Floor

The loading dock, located on the southwest corner of the ground floor, is secured by personnel and vehicular plate barriers as shown in Figure 3-4. All other vehicle entrances and exits to the building have similar movable barriers. All mail and packages are screened at the loading dock before being moved throughout the building.

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APPENDIX - 10 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

Current features, such as vehicular plate barriers, will remain in place. Bollards are planned for Normal building operations currently at the Subject Site do not generate air emissions and would the lobby entrance at the corner of G and 17th Street. not affect the amount of pollutants in the air.

The concrete planters currently in place at the plaza entry points will be replaced with bollards. Affected Areas Bollards will be present at the entrances to the plaza from F, G and 17th Streets. Bollards will During the renovation, the local air quality in and around the site of the proposed action will be also be installed at the main entrance at the corner of 17th and G Street. The visual impact and adversely impacted by the operation of construction equipment. No other areas are expected to impact on pedestrian traffic will be minimal after the proposed action given that current features be impacted. either will remain in place or obtain upgrades. Potential Consequences

Construction equipment used for the renovation will discharge pollutants into the local air, It is the understanding of Tetrahedron that as the proposed action progresses, further evaluation especially during demolition phases. However, due to the limited amount of time the equipment will continue on existing structural systems to determine how material will handle various sized will be present on the Subject Site, and that normal building operations do not generate air blasts. Changes to materials or the layout of planned security features may change in order to pollution, the impact to the local air quality will be temporary and last only during the renovation satisfy safety requirements. period. 3.6 Local Air Quality The ambient air quality in an area can be characterized in terms of whether it complies with the The proposed green space in the plaza and the green roof to be in place after the proposed action primary and secondary National Ambient Air Quality Standards. The Clean Air Act (42 U.S.C. will help to improve the local air quality. 7401 et seq.) requires the U.S. Environmental Protection Agency (EPA) to set national standards 3.7 Noise for pollutants considered harmful to public health and the environment. National Ambient Air It is the declared public policy of the District to reduce the ambient noise level in the District to Quality Standards have been established for six criteria pollutants: carbon monoxide, lead, promote public health, safety, welfare, and the peace and quiet of the inhabitants of the District, nitrogen dioxide, ozone, particulate matter (PM) (with a size 10 microns and 2.5 microns), and ” ” and to facilitate the enjoyment of the natural attraction of the District. (DCMR 20, Sec. 2700.1). sulfur dioxide. Primary standards define levels of air quality the EPA has determined as Title 20 District of Columbia Municipality Regulations, Chapter 27, Noise Control and Chapter necessary to provide an adequate margin of safety to protect public health, including the health 28, Maximum Noise Levels, and Chapter 29, Noise Measuring Test Procedures. of sensitive populations such as children and the elderly. Secondary standards define levels of air quality deemed necessary to protect the public welfare, including protection against decreased The DC Department of Consumer and Regulatory Affairs (DCRA) states that construction is visibility and damage to animals, crops, vegetation and buildings. allowed Monday through Saturday from 7 am to 7 pm without any special permits. If it is

necessary to work outside those hours or on Sunday, an after-hours permit to work will need to The Table 3-1 lists the primary National Ambient Air Quality Standards (NAAQS) for each of be obtained from DCRA. the criteria pollutants and provides air quality data from air monitors near the subject site in

Washington DC for the last four years of records available from the DC Department of the Currently, normal building operations do not generate noise outside of the building, nor expected Environment (DDOE). Since 2009, average air quality data in the monitored areas of to after the renovation. Washington DC have not exceeded national standards, when data is available. Affected Areas Table 3-1 National ambient air quality primary standards and air quality data for The proposed project is located in a populated commercial area of the city with minimal green Washington, DC, from 2009 through 2012 space or other methods to absorb noise. Most of the buildings surrounding the site are Sampling Maximum Average Quality by Year Pollutant Units commercial properties and are used during normal hours of operation during the day. Occupants Period Allowable 2009 2010 2011 2012 of the Winder Building, The Eisenhower Executive Building and other buildings will likely be Carbon 8 hours 9 ppm 1.02 1.01 0.85 0.81 Monoxide most impacted by noises associated with demolition and construction. 3 Lead Quarterly 1.5 μg/m * * * 0.003 Potential Consequences Nitrogen 24 hours 0.053 ppm 0.03 0.03 0.03 0.03 During the construction and reconstruction, noise levels in the area are expected to be elevated. Dioxide Loud work operations are usually brief to prevent injury to construction workers. Additionally, Ozone 8 hours 0.075 ppm 0.04 0.04 0.04 0.04 noise control plans are to be put in place for the demolition operations of the project, further PM10 24 hours 150 μg/m3 17.97 21.29 16.95 17.00 3 limiting noise. Work during the proposed action is not expected to occur outside normally PM2.5 24 hours 35 μg/m 9.63 10.46 10.67 10.36 approved construction hours set by DCRA. Sulfur 24 hours 0.14 ppm 0.009 0.006 0.004 0.003 Dioxide * Data unavailable for these years ppm = parts per million μg/m3 = micrograms per cubic meter Based on the proposed renovations, a number of noise cancelling components will be included in the final building. This will decrease interior noise on and in between floors.

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3.8 Impact on Storm Water improvements to the Subject Site such as the green roof and the living machine, the amount of Under federal law, the District is required to control its storm water that enters the local storm water runoff is expected to decrease once the project is complete. watersheds (Potomac, Anacostia) and reduce the amounts of pollutants that the stormwater contains. Local city agencies such as District of Columbia Department of the Environment 3.9 Impact on Waste Water (DDOE) and District of Columbia Department of Transportation (DDOT) have implemented and The 1972 amendments to the Federal Water Pollution Control Act provide the statutory basis for are developing additional practices that reduce pollutants at the source, before they enter critical the National Pollutant Discharge Elimination System (NPDES) permit program and the basic water bodies. structure for regulating the discharge of pollutants from point sources to waters of the United States. Section 402 of the CWA specifically required EPA to develop and implement the NPDES Affected Areas program. Two existing 10” storm water mains exit the G Street side of the building at the basement floor. One 8” and one 10” storm water main exit the 17th Street side of the building on the basement Affected Areas floor. One 10” and one 12” storm water main exit the F Street side of the building at the The proposed project is located in a populated commercial area with little green space. The basement floor. sanitary sewer flow from the building is currently conveyed via three lateral connections to combined sewers located in public space along G Street NW and 17th Street NW. The sanitary The proposed action will abandon the existing storm sewer connections to the public main and sewer laterals eventually connect with the DC combined sewer system outside the building. reroute the storm laterals to an on-site treatment system. Wastewater is then treated by the DC Department of Public Works before discharging into local waterways. On-site treatment of the sanitary sewerage will be provided by a "Living Machine", a system Potential Consequences consisting of two sanitary storm water holding tanks located within public space. Placement of During the reconstruction, the intent is to abandon two existing sanitary sewer connections to the these tanks in the public space will be subject to the approval and permitting of DDOT, DDOE, public main, and reroute using new PVC sanitary sewer laterals and cleanouts to holding tanks and DC Water and will require a perpetual maintenance contract relieving the District of for the on-site engineered wetland treatment system built into the plaza. All sanitary sewage Columbia of maintenance of the storage tanks. Each "Living Machine" storm water holding tank leaves the building by gravity and enters one of two sewage holding tanks, just outside the will be provided with an overflow connection to new manholes constructed above the DC Water building footprint, but within the plaza area at the southeast of the building, where it is stored public combined sewer. All materials will be in accordance with DC Water standards and until the next stage. The wastewater holding tanks will be provided with PVC overflow specifications. connection to the D.C. combined sewer system. From the holding tank, the sewage is sent

through a solids screen, while solids are removed by a dry cake, then completely sealed and Existing sidewalks will be retained throughout construction with the exception of portions that removed with the trash. Remaining liquid waste will be sent to the equalization tank and then will be sawcut and removed as needed for the installation of storm water management structures. through the stage 1 and 2 tidal flow wetland and then treated with UV light and chlorine before

reuse for irrigation and to supplement toilet flush valves and cooling tower make-up. Additional renovations to the outside of the building and the plaza will include modifications to reduce the amount of storm water runoff. Planned improvements include: After construction, the improvements are expected to reduce the amount of wastewater entering Permeable pavement Green roof (subject to DDOE approval) x x the DC combined sewage system from this building. x Vegetated wells x Layering of vegetation visible to the public 3.10 Impact on Ground Water Storm water runoff is likely to increase during the renovation of the plaza, as soil is added and Based on the following topographic map, groundwater is expected to flow southeast of the replaced. Sediment runoff can also increase due to construction equipment moving on and off Subject Site (outlined in white). If not picked up by storm water drain, water would likely site. continue to flow towards the Tidal Basin. Potential Consequences As per the work plans for the proposed action, "All sediment and erosion control methods shall be installed before the start of any excavation and/or demolition as per District of Columbia Erosion and Sediment Control Handbook. If any onsite inspection reveals further erosion control measures are necessary, the same shall be provided." Best Management Practices (BMPs) and other methods to control and limit the amount of storm water runoff from the site of the proposed action will be addressed before the start of the project.

Any storm water runoff generated by the presence of construction equipment or renovation to the plaza will not further occur after the project is complete. With the number of planned

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Figure 3-6 Topographic Map of Proposed Action Site 3.11 Wetlands Affected Areas The nearest wetlands to the subject site are on Theodore Roosevelt Island, over a mile to the west of the subject site. Groundwater flow from the subject site does not flow towards these wetlands or any other existing wetlands in DC. Potential Consequences No impact is expected to the wetlands on Theodore Roosevelt Island due to their distance from the site and flow of ground water. 3.12 Floodplains Flooding is a frequent and costly hazard in the District of Columbia. Flood risks vary from property to property, even in the same neighborhood. Additionally, flood risks can change over time due to erosion, land use and other factors. In the face of mounting flood losses and escalating costs of disaster relief to the general taxpayers, the U.S. Congress established the National Flood Insurance Program (NFIP) on August 1, 1968.

The District of Columbia has enacted and implemented the floodplain regulations required for

Center: 38.8972°N 77.0438°W Elevation at center: 85 feet (26 meters) participation in NFIP. NFIP is based on a mutual agreement between the Federal Government Quad: USGS Washington West Drg Name: o38077h1 Drg Source Scale: 1:24,000 and District of Columbia. The D.C. Construction Codes 2008 (DCMR 12) adopted all flood resistant provisions in the International Codes. The revised Flood Hazard Rules (DCMR 20 In the Coastal Plain portion of the District of Columbia, the topography and drainage pattern Chapter 31), dated 2010, provided details and technical provisions for floodplain development have been significantly affected by urbanization. At the time of the earliest settlement, the requirements and permitting process. topography of the downtown Washington area was marked by the drainage systems of Tiber Creek, which discharged into the Potomac River, and St. James Creek, which discharged into the Affected Areas Anacostia. According to the District of Columbia's Flood Insurance Rate Map (FIRM), the proposed action site (the red X on the map below) is not located on known historical floodplains. These streams circled the southwestern portion of Washington on the lines of the Mall, Canal Street and Delaware Avenue. Small tributaries to this system cut across near Judiciary Square Figure 3-7 Floodplain Map of Proposed Action Site and along the line of 10th Street, and a larger tributary slowed southwest from Union Station. Another creek called Slash Run flowed south from the vicinity of Wyoming Avenue and 18th Street NW it turned west, crossing Connecticut Avenue and then turned north again to discharge into Rock Creek. Affected Areas Scientists at the USGS have measured stream flow and ground water levels in wells to assess water resources for over 125 years. In addition to providing the most extensive set of historical stream flow and ground water data available to the public, precipitation and reservoir data are also presented to give a complete picture of the region’s water resource. In March, 2013, 65% of the ground water levels in the DC area were in the normal range and 85% of the stream flow levels were in the normal range in the proposed site. The normal range is considered between the 25th to 75th percentiles. Potential Consequences The proposed action should not affect the ground water in District of Columbia area.

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Potential Consequences historic structures, whereas GAO believes the intent of the act is to acquire land and buildings The Subject Site is not located near any local flood plains and the construction project will not for additional federal office space. expand the site to include land that is on a flood plain. Risk of flooding is likely minimal. The building currently used by the Consumer Financial Protection Bureau (CFPB) at 1700 G 3.13 Risk to Threatened and Endangered Species Street, NW resembles neighboring buildings with elements of brutalism in the architecture. The The Endangered Species Act (ESA) provides a program for the conservation of threatened and building did apply to be listed as a historically significant property through a DOE, and was endangered plants and animals and the habitats in which they are found. The lead federal recommended for historical preservation in accordance with Determination of Eligibility signed agencies for implementing ESA are the U.S. Fish and Wildlife Service and the U.S. National by SHPO on 24 July 2013. The Section 106 process has resulted in a Memorandum of Oceanic and Atmospheric Administration (NOAA) Fisheries Service. The U.S. Fish and Wildlife Agreement between the CFPB and SHPO. Service maintains a worldwide list of endangered species. Species include birds, insects, fish, reptiles, mammals, crustaceans, flowers, grasses and trees. Affected Areas The Historic Preservation Office of Washington DC does not list the building used by the CFPB The law requires federal agencies, in consultation with the U.S. Fish and Wildlife Service and/or as a historically significant building or having archeological findings (Appendix A). Some the NOAA Fisheries Service, to ensure that actions they authorize, fund, or carry out are not buildings nearby, such as the Winder and Executive Office buildings, are registered by the likely to jeopardize the continued existence of any listed species or result in the destruction or Historic Preservation Office. adverse modification of designated critical habitat of such species. The law also prohibits any action that causes a "taking" of any listed species of endangered fish or wildlife. Likewise, Potential Consequences import, export, interstate, and foreign commerce of listed species are all generally prohibited. No impact is expected. With proper care, the proposed action would not affect nearby buildings which are registered by the Historic Preservation Office as being historically significant. Affected Areas No known endangered plant species exist in Washington DC. One endangered animal species An application for historical significance is currently under review as of this writing. lives in the Washington DC area: Hay's Spring (Stygobromus hayi). This shrimp-like creature is endemic to Washington DC, where it occurs only in Rock Creek, a tributary of the Potomac 3.15 Hazardous Waste Potential River. This species is listed as "Critically Imperiled" and is threatened by the degradation of its The Resource Conservation and Recovery Act (RCRA) was enacted by Congress in 1976. habitat. However, the subject site is over 1.5 miles from Rock Creek and the proposed renovation RCRA's primary goals are to protect human health and the environment from the potential will not influence the stream. In addition, surface water at the site flows to the southeast, away hazards of waste disposal, to conserve energy and natural resources, to reduce the amount of from Rock Creek. waste generated, and to ensure that wastes are managed in an environmentally sound manner. RCRA is the public law that creates the framework for the proper management of hazardous and Potential Consequences nonhazardous solid waste. No impact to Rock Creek, and thus the habitat of the Hay's Spring, is anticipated to occur from proposed renovation activities. Affected Areas Very little hazardous waste is currently generated by the CFPB, as it is mostly an administrative 3.14 Historic and Archeological Preservation facility. Current hazardous wastes on-site include: fluorescent light bulbs and tubes, and Before the current building at 1700 G Street, NW was constructed, that city block contained four oil/grease from equipment operations. The current materials on-site are not present in large distinct buildings: Nichols Café built in 1830, the Winder Building built in 1854, Winder Annex amounts, nor do the materials pose any current concerns. built in 1882, and a building constructed by the Washington Loan and Trust Company built in 1924 which later became Riggs National Bank in 1954 (later vacated and used as a warehouse in Renovation can potentially generate (i.e., produce or have present on site) wastes that are: 1965). In 1949, the U.S. General Services Administration (GSA) took control of the Winder x Ignitable wastes: paint thinners, paints, paint and varnish strippers, epoxy resins, Building and has maintained it ever since. This management control by GSA included the adhesives, degreasers, and spent cleaning solvents adjacent buildings occupying the site near the Winder Building. x Corrosive wastes: rust removers, cleaning fluids, and battery acids x Reactive wastes: plating waste, bleaches, and waste oxidizers GSA proposed to demolish the four buildings at 1700 G Street, NW in 1974 to construct a new x Toxic wastes: materials containing metals (mercury, cadmium, or lead) or solvents office building. By that time, the Winder Building was listed on the National Register of Historic x Resins, roofing cement, adhesives, machinery lubricants, and caulk Places. The Government Accountability Office (GAO) reviewed and reported (see appendix A2) x Cleanup materials (such as rags) contaminated with the items listed above these actions to determine if the buildings and demolition were a voluntary example of the x Drums and containers that once contained the items listed above preservation and mixed use promoted by the act, or alternatively was the failure to reuse existing x Computer monitors and televisions with cathode ray tubes historic structures. GAO found that GSA interpreted the act as a way to acquire and preserve x Gypsum drywall (due to dust and sulfate)

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During the renovations, there will be a designated, covered hazardous waste storage area. Figure 3-9 Proposed Final Appearance of Building, Plaza View Potential Consequences There would be temporary impact and risk due to the temporary storage of hazardous waste generated at the site during renovation. A hazardous waste plan will be in place during the renovations, instructing workers on the location of the temporary hazardous waste storage area. A contracted third party will be responsible for disposal of the materials. The hazardous waste plan should also include BMPs to reduce the risk of release during the renovation.

After the renovation, the hazardous materials present on-site are expected to be the same as those currently on-site, in similar negligible quantities. 3.16 Visual Impacts The maximum height of a building in the DC area is generally based on the relationship of the building to the width of the adjacent streets. For the proposed action site, the maximum allowable height of the building is within accordance with the Building Height Act of 1910. Affected Areas The primary visual differences planned for the renovation will be the new glass walls around the main lobby. The windows from the 2nd to the 6th floor will also be updated. Across 17th Street from the site of the proposed action is the Eisenhower Executive Office Building. Figure 3-8 Proposed Final Appearance of Building, Southwest View Figure 3-10 Current Building at 1700 G Street (right) and Eisenhower Executive Office Building (left)

Updated lobby Updated windows

With the construction of the childcare play area on the rooftop, the associated limestone enclosure wall and stairwell, the rooftop of the building will appear slightly different when Potential Consequences viewed from the interior plaza. The change is minor in appearance, appearing as a small addition Aside from a childcare play area on the roof and a penthouse for mechanical equipment, the to the rooftop which will not be easily visible outside of the plaza. The proposed new addition to proposed action for the building does not include additional floors, allowing the building to the building is outlined in black on the next image. remain in accordance with the Building Height Act. These structures will only be visible from

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the interior plaza. The new glass walls and lobby will not negatively affect the surrounding area 3.18 Local Antennas or nearby buildings when viewed from the street. Affected Areas Additional consultation, in accordance with Section 106, will continue throughout the proposed The proposed action on the rooftop will affect some of the lightning rods, mainly those currently action. present in the area planned for the childcare play area. Most of the rods, as shown below, are located at the perimeter of the rooftop. The only other antenna on the rooftop of the building is 3.17 Energy Consumption an old TV antenna, which is probably no longer in use. In October 2009, Executive Order 13514 on Federal Leadership in Environmental, Energy and Economic Performance was issued, directing all federal agencies to strengthen their sustainable Figure 3-11 Lightning Rods Along The Rooftop practices. The E.O. expanded on the Energy Independence and Security Act, the Energy Policy Act of 2005, and Executive Order 13423 by requiring federal agencies to implement strategies to measure, manage, and reduce greenhouse gas emissions, water consumption, and diversion of materials. The order mandates federal agencies to meet various energy and environmental targets and defines requirements for sustainability in buildings and leases, sustainable acquisition, and electronic stewardship.

E.O. 13514 includes product efficiency and stewardship. Federal agencies must: x Ensure 95% of new contract actions, task orders, and delivery orders for products and services (excluding weapon systems) are energy efficient (ENERGY STAR® or Federal Energy Management Program (FEMP)-designated) water efficient, bio-based, environmentally preferable (Electronic Product Environmental Assessment Tool (EPEAT) certified), non-ozone depleting, contain recycled content, or are non-toxic or less-toxic alternatives where such products and services meet agency performance requirements. x Implement best management practices for the energy-efficient management of servers Potential Consequences and Federal data centers. The lightning rods present in the area for the proposed childcare play area should not be accessible to the children or staff due to the proposed 8 foot tall limestone wall. Any remaining The Energy Policy Act of 2005 requires a 30% annual energy cost reduction against American lightning rods outside the childcare area can remain in place if in good condition. Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE) 90.1-2004. The CFPB’s current headquarters is a minimally compliant building, discounting the plug loads. 3.19 Cellular Tower Locations LEED 2009 requires that renovations to the existing building be designed to achieve at least 5% Cellular Towers generate a radiofrequency (RF), which is non-ionizing, meaning it is not strong energy cost reduction as compared to an ASHRAE 90.1-2007 model. enough to normally affect a person's physical health. RF can be dangerous at very high levels because it creates heat, and has the ability to heat tissue rapidly; similar to how a microwave Affected Areas oven cooks food. Cell phones and wireless networks produce RF, but not at levels that can cause The proposed action will affect the entire building and plaza area at 1700 G Street, NW, significant heating. For cell towers, RF energy decreases rapidly with distance and ground-level Washington DC. exposures are typically well below exposure limits set by the Federal Communications Commission (FCC). Potential Consequences HVAC and other mechanical systems are on site and slated for renovation, and would improve The quantity used to measure the rate at which RF energy is actually absorbed in a body is called existing mechanical systems to varying degrees depending on which concept is selected. the "Specific Absorption Rate" or "SAR." A standing ungrounded human adult absorbs RF energy at a maximum rate when the frequency of the RF radiation is in the range of about 70 Low-energy, long-life bulbs are to be used in overhead lighting fixtures. The proposed lighting megahertz (MHz). RF safety standards are generally most restrictive in the frequency range of design is expected to give a 20% reduction in lighting power density as compared to the baseline. about 30 to 300 MHz. Cellular towers typically transmit using frequencies between 824 and 894 MHz.

At relatively low levels of exposure to RF radiation, i.e., levels lower than those that would produce significant heating; the evidence for production of harmful biological effects is ambiguous and unproven. Such effects, if they exist, have been referred to as "non-thermal"

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effects. The health effect of electromagnetic radiation can be divide into thermal (heating) and non-thermal. Non thermal affects on the cells, genes and DNA are more harmful than the thermal Table 3-2 - FCC Registered Cell Phone effect. Children are more vulnerable due to a developing immune system and thinner skulls Tower Location 900 V Street NE, 2001 East Capitol Street SE, 1372 E St NE which allows radiation to penetrate deeper. A number of reports have appeared in the scientific Washington DC, 20018 Washington, DC, 20003 Washington, DC 20002 literature describing the observation of a range of biological effects resulting from exposure to Owner Verizon Wireless Verizon Wireless Verizon Wireless low-levels of RF energy. However, in most cases, further experimental research has been unable Height 32.9 meters 32.6 meters 19.5 meters to reproduce these effects. Frequencies 880.020 MHz, 880.020 880.020 MHz, 880.020 880.020 MHz, 880.020 MHz, 880.020 MHz, MHz, 880.020 MHz, MHz, 880.020 MHz, When cellular antennas are mounted at rooftop locations it is possible to encounter RF levels 835.020 MHz, 835.020 835.020 MHz, 835.020 835.020 MHz, 835.020 MHz, 835.020 MHz, MHz, 835.020 MHz, MHz, 835.020 MHz, greater than encountered on the ground. However, exposures approaching or exceeding the 891.510 MHz, 891.510 891.510 MHz, 891.510 891.510 MHz, 891.510 safety guidelines are only likely to be encountered very close to and directly in front of the MHz, 891.510 MHz, MHz, 891.510 MHz, MHz, 891.510 MHz, antennas. Measurements made near tower-mounted antennas have shown that ground-level 846.510 MHz, 846.510 846.510 MHz, 846.510 846.510 MHz, 846.510 power densities are thousands of times less than the FCC's limits for safe exposure. This makes it MHz, 846.510 MHz MHz, 846.510 MHz MHz, 846.510 MHz extremely unlikely for exposure to RF levels to be in excess of FCC guidelines due solely to License Start and 11/15/2004 - 10/01/2014 11/15/2004 - 10/01/2014 11/15/2004 - 10/01/2014 antenna location. End Date

Affected Areas Potential Consequences There are three registered cell phone towers located in Washington DC. As shown on the With cellular towers over a mile and a half from the subject site, RF signals are expected to lose following figure, the closest tower is over 1.5 miles with the other towers being farther away. most of their intensity and minimize the risk of being absorbed into the body. Additionally, the frequency used by the cellular towers broadcast is at a higher frequency (846.51-880.02 MHz) Figure 3-12 Map of Subject Site (black star) and Cell Phone Towers (red balloons) than what calls for normal safety standards (30-300 MHz). 3.20 Impact to Pedestrians and Bicyclists Affected Areas Pedestrian pathways include sidewalks, breezeways and a plaza. On the building’s street facing sides are wide sidewalks and street trees. Breezeways through the ground level of the building connect the plaza with the sidewalks. There is a shared plaza with the neighboring Winder Building. The plaza is included in the renovation plans.

Although there are planned bicycle lanes for the adjacent streets, these have not yet been implemented. Potential Consequences Construction perimeters and other barriers set up around the site of the proposed action may partially or wholly block and impede surrounding sidewalks from pedestrian traffic, making redirection necessary. After construction, pathways will be unobstructed. 3.21 Vehicle Traffic Affected Areas 1700 G Street, NW is located in a highly developed urban portion of Washington DC. The site shares a plaza with the Winder Building. It is bounded by G Street to the north, 17th Street on the east, the Winder Building to the south (which shares a plaza), and a retail/office building on the west.

17th Street, a two-way street with three northbound and two southbound lanes, is moderately busy, averaging around 20,500 vehicles a day in the area adjacent to the building. G Street NW is one-way westbound with two traffic lanes and metered premium demand parking lanes on each

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side, averaging around 4,100 vehicles daily. The side including the parking garage entrance and a café faces onto F Street NW, which is one-way eastbound with two traffic lanes and metered premium demand parking lanes on each side, averaging around 3,400 vehicles daily. 4.0 SUMMARY OF IMPACTS Potential Consequences 4.1 Cumulative Impacts Construction may cause increased traffic congestion especially during busy periods. For safety Council on Environmental Quality regulations stipulate that the cumulative impacts analysis in reasons, barriers should be constructed around work areas. There is a possibility that such safety an EA consider the potential environmental impacts resulting from the incremental impacts of barriers may extend into a parking or traffic lane of the road. In addition, vehicles related to the the action when added to other past, present, and reasonably foreseeable future actions regardless work may cause congestion or periodically impede the flow of vehicular and pedestrian traffic. of what agency or person undertakes such actions (40 CFR 1508.7). Because the impacts of the Traffic should only be adversely affected temporarily during the course of construction. proposed project generally would be minor and localized (see Section 3), the CFPB focused this evaluation of cumulative impacts on activities immediately surrounding the proposed project site 3.22 Relationship of Local Short-term Uses vs. Long-term Productivity and other past, present, and reasonably foreseeable future actions on and around the CFPB Council on Environmental Quality regulations that implement the procedural requirements of building. NEPA requires consideration of the relationship between short-term uses of man's environment and the maintenance and enhancement of long-term productivity (40 CFR 1502.16). In this analysis of cumulative impacts, the CFPB determined that only impacts to air quality, noise and water resources from past, present, and reasonably foreseeable actions near the project Affected Areas site would be cumulative with the renovation of the building. Impacts of the proposed project to The proposed action will affect the subject site and plaza. The proposed renovation would other resources would be negligible or would not occur. Therefore, based upon the context and include improvements to employee spaces, sustainable construction, and an increase in green intensity of the impacts, the building renovation project does not establish any future actions space. During the proposed action, workers for the CFPB will continue their work at another with significant effects. facility. 4.2 Air Quality Potential Consequences The proposed action of redevelopment would cause emissions of particulate matter and other Due to workers relocating to a nearby building, work conducted by the CFPB is unlikely to be pollutants in the project area. However, emissions from the construction project would be stalled during the course of the proposed action. temporary.

After the proposed action is complete, the larger building and increased square footage can allow The energy efficiency improvements for the building, installation of the green roof and upgrades the CFPB to accommodate more employees than it does currently. The building is also expected to the plaza would contribute to independence from fossil fuel for energy, which would to be LEED Certified Gold, utilizing fewer resources to operate over the long-term use of the contribute to the beneficial cumulative impact on air quality by reducing air emissions from building. traditional power generating sources. 3.23 Irreversible and Irretrievable Commitment of Resources 4.3 Noise There would be an irretrievable commitment of materials for equipment at the proposed project The proposed action would add to the cumulative noise generated in the area. The contribution of site. CFPB asserts that the irreversible and irretrievable commitment of resources does not the proposed action to the noise in the area is expected to be temporary and only occur during exceed any extraordinary amount as could be associated with any other type of major building daytime hours. Noise from these various sources may not occur at the same time, but they could improvement project. all contribute to the amount of time that people in the area would be exposed to the sounds of construction. 4.3 Water Resources The site of the proposed action is located in a highly urbanized area of Washington DC. Most storm water is from onsite is directed to the municipal storm water system before entering local waterways. The site is not located near wetlands or floodplains. BMPs and other efforts to reduce storm water runoff and erosion on the site are to be in place before construction is to begin.

The proposed action will include installation of a green roof and a renovated plaza which will increase the amount of green space at the building site. These improvements will reduce runoff and increase water filtration, contributing to the beneficial cumulative impact on water resources.

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4.4 Potential for Public Controversy 5.0 CONCLUSION During the course of the proposed action, there is the potential for local public controversy from temporary impediment of local traffic and lack of access to retailers on the ground floor of the The proposed action is to renovate the interior and plaza space and to provide more space to the site of the proposed action. This will be done for the safety of workers and the public, and will be building located at 1700 G Street, NW, Washington DC, 20552, currently used by the CFPB as temporary in nature. its headquarters.

For the proposed action site, the front of the building along 17th Street will be at the maximum Tetrahedron, Inc. concludes the following about the potential environmental impacts of its allowable height of 90 feet. It is anticipated the final building's appearance will not negatively proposed action: influence the surrounding area and nearby buildings. x Implementation of the proposed action would overall involve no potential for significant No new antennas, aside from possibly new lightning rods, are planned to be installed on the environmental impacts. Impacts to the environment will occur during the proposed action building. The cellular towers are not expected to affect the site due to the frequency of their and steps will be taken to limit their influence. After the proposed action is complete, the broadcast and distance. improvements to the structure are anticipated to have an overall positive environmental impact. The improvements to perimeter security should not have a large impact due to most features x Normal building operations do not normally generate air emissions. There will be an consisting of keeping in place or upgrading current systems. The planned bollards for the increase in air pollutants during the proposed action as construction equipment is used northern entrance will not negatively affect visual appeal and pedestrian access. and demolition occurs. After the proposed action is complete, the increase in green space on the site will improve local air quality. After the proposed action is complete, the public should be able to resume normal activities at x Current security features will either remain in place (vehicular plate barriers), or receive the site. possible upgrades. An anti-ram device is planned for the main entrance to the building, but it has yet to be designed. x After the proposed action is complete, the building will be rated LEED Gold, in part from the numerous energy efficiency improvements to be installed. Therefore, the proposed action would slightly reduce regional greenhouse gas emissions. x Construction activities during the proposed action would cause a negligible increase in noise volumes. After the proposed action is complete, noise levels are expected to return to normal. x The aesthetics of the area would look the same to the casual observer. The building will remain at its current height and appear the same from the street, aside from new glass walls, windows and lobby. From the interior plaza, a portion of the barrier wall for the childcare play area on the rooftop will be visible. x The necessary controls on runoff to ensure there would be no erosion or sedimentation issues are to be in place before the proposed action is to take place. The project location does not involve wetlands or floodplains. Positive impacts to the local watershed are expected due to decreased storm water and higher quality storm water due to filtration of the proposed green roof and other improvements. x The proposed project would have no effect on species protected under the Federal Endangered Species Act, and there is no reason to suspect the project site has unique habitat for any protected or rare species. No impacts to wetlands are expected to occur since the closest wetlands are a mile away and do not extend to the project site. x No work will be conducted on neighboring historic buildings. x No new antennas, aside from lightning rods, are planned for construction at the site. Any impacts from cellular towers to the inhabitants of the building will be non-existent. x Relative to the cumulative changes in the environment that would be caused by the proposed project in combination with other planned activities nearby, the implementation of the proposed action would cause minor, adverse incremental changes to air quality and noise during construction. The proposed project would result in small, beneficial,

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APPENDIX - 19 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

incremental impacts to aesthetics, the region’s water quality by reducing storm water runoff and air quality during operation by reducing greenhouse gas emissions. x Under the No-Action Alternative, there would be no site improvements to the building or 6.0 REFERENCES plaza at the site. For comparison purposes, it is assumed no impacts to the existing environment would occur, and any beneficial impacts of the proposed project would not 1. District of Columbia Historic Preservation Office, 1100 4th Street SW, Suite E650 be realized. Washington, DC 20024

Based on the review and analysis of materials, a Finding of No Significant Impact for the 2. Environmental FirstSearch, 1709 New York Avenue, NW, Washington, DC 20006, proposed action at 1700 G Street, NW, Washington DC, 20552 is recommended. Due to the November 16, 2010. temporary nature of the project, environmental or public disturbances will be short-term. Many of the renovations, such as noise damping materials and a green roof, will prove to be beneficial 3. National Wetland Inventory Maps, U.S. Fish and Wildlife Service to the tenants, workers and the public over the long term. http://wetlandsfws.er.usgs.gov/wtlnds/launch.html

4. Property Quest, Real Property Data, Aerial Photographs, District of Columbia, www.dc.gov

5. USGS 7.5-minute Series Topographic Map, Washington West, DC Quadrangle, Scale, 1:24,000, Contour Interval 10', 1965 Photo revised 1983.

6. U.S. Census Bureau, 2000 Demographic Information http://www.census.gov/

7. U.S. Environmental Protection Agency, Nonattainment Ozone Areas, www.epa.gov

8. Wild and Scenic Rivers Website http://www.rivers.gov/

9. U.S. Department of Transportation, Federal Highway Administration, Policy and Procedure Memorandum 90-2, Noise Standards and Procedures (February 8,1973)

10. Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, October 2009. http://www.whitehouse.gov/assets/documents/2009fedleader_eo_rel.pdf

11. Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management, Signed January 24, 2007. http://www.gpo.gov/fdsys/pkg/FR-2007-01-26/pdf/07-374.pdf

12. Energy Independence and Security Act of 2007. H.R. 6 (110th). http://www.gpo.gov/fdsys/pkg/PLAW-110publ140/pdf/PLAW-110publ140.pdf

13. Energy Policy Act of 2005 (Pub.L. 109–58), July 29, 2005. http://www.gpo.gov/fdsys/pkg/PLAW-109publ58/pdf/PLAW-109publ58.pdf

14. NEPA Regulations, 40 CFR Parts 1500-1508, Section 1502.16 (e). 43 FR 56003, Nov. 29, 1978 and 44 FR 874, Jan. 3, 1979. http://ceq.hss.doe.gov/ceq_regulations/Council_on_Environmental_Quality_Regulations. pdf

Environmental Assessment for CFPB HQ Building Renovation 31 January 2014 Environmental Assessment for CFPB HQ Building Renovation 32 January 2014

APPENDIX - 20 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

15. ASHRAE 90.1-2007. Energy Standard for Buildings Except Low-Rise Residential Buildings, 2007. 28. Baan R, Grosse Y, Lauby-Secretan B, El Ghissassi F, Bouvard V, Benbrahim-Tallaa L, Guha N, Islami F, Galichet L, Straif K; WHO International Agency for Research on 16. ASHRAE 90.1-2010. Energy Standard for Buildings Except Low-Rise Residential Cancer Monograph Working Group. Carcinogenicity of radiofrequency electromagnetic Buildings, 2010. https://www.ashrae.org/resources--publications/bookstore/standard-90- fields. Lancet Oncol. 2011 Jul;12(7):624-626. 1#2010

17. Resource Conservation and Recovery Act (RCRA), 1976. http://www.epa.gov/epawaste/inforesources/data/index.htm

18. Clean Water Act of 1976. http://cfpub.epa.gov/npdes/cwa.cfm?program_id=45

19. District of Columbia Municipality Regulations (DCMR); Chapter 5 (Water Quality and Pollution) of Title 21 (Water and Sanitation) http://ddoe.dc.gov/sites/default/files/dc/sites/ddoe/publication/attachments/Water%20Qua lity-title21-chapter5.pdf

20. Regulations Handbook:, Department of Consumer and Regulatory Affairs, 1100 4th Street SW Washington, DC 20024. http://dc.gov/DC/DCRA/Inspections/Trash+Truck+Noise+Complaints/Noise+Regulation s+Handbook.

21. Occupational Safety and Health Administration (OSHA) regulations 29 CFR Part 1920 addresses workplace noise, additional information can be found at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=97 35.

22. DDOT. January 3, 2012. “DC Meter Rates and Hours Operations Map” http://ddot.dc.gov/DC/DDOT/Publication%20Files/On%20Your%20Street/Traffic%20M anagement/Parking/Parking%20Meters/DC_MeterRates-and-HoursOperations_Map.pdf

23. DDOT. March 2012. “2010 Traffic Volumes” http://ddot.dc.gov/DC/DDOT/About+DDOT/Maps/Traffic+Volume+Map+2010

24. DDOT. 2005. “District of Columbia Bicycle Master Plan” http://ddot.dc.gov/DC/DDOT/On+Your+Street/Bicycles+and+Pedestrians/Bicycles/Bicy cle+Master+Plan/DC+Bicycle+Master+Plan+-+April+2005

25. Review of the Public Buildings Cooperative Use Act of 1976 and Its Implementations, LCD-79-302, Jan 25, 1979

26. Paul H. (1977). New GSA Building Has Ice Rink, Café. Washington Post

27. ANSI-C95.1, 1982, American National Standards Institute. American national standard safety levels with respect to human exposure to radiofrequency electromagnetic fields, 300 kHz to 100 Ghz. New York: IEEE.

Environmental Assessment for CFPB HQ Building Renovation 33 January 2014 Environmental Assessment for CFPB HQ Building Renovation 34 January 2014

APPENDIX - 21 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

Appendix A Appendix A-1

Historical Documents State Historic Preservation Officer for the District of Columbia Listings (Current as of March 2011)

APPENDIX - 22 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 24 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 28 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 29 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 30 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 31 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 32 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 33 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 34 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 35 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 37 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 38 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 39 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 40 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 41 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 43 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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APPENDIX - 44 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

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Appendix A-2

Newspaper Articles Documenting Building



APPENDIX - 45 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

APPENDIX - 46 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

APPENDIX - 47 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

APPENDIX - 48 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

APPENDIX - 49 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

APPENDIX - 50 PART E: APPENDIX A. ENVIRONMENTAL ASSESSMENT REPORT

APPENDIX - 51 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW

PROPERTY INFORMATION 1700 G Street, NW Property Name(s): 1700 G Street, NW; Federal Home Loan Bank Board (FHLBB) Building; Consumer Financial Protection Bureau (CFPB) Building Street Address: 1700 G Street, NW, Washington, DC 20552 Square(s) and Lot(s): 0169 0832 Property Owner(s): Office of the Comptroller of the Currency (OCC)

N

Location of 1700 G Street, NW on the Washington, D.C. Real Property Map (Office of the Chief Technology Officer 2013).

1700 G Street, NW

North Elevation of 1700 G Street, NW (The Federal Home Loan Bank Board Building).

The property is being evaluated for potential historical significance as: N An individual building or structure: A contributing element of a historic district (specify): A possible expansion of a historic district (specify): Location of 1700 G Street on the 2013 Bing Aerial (Bing 2013). A previously unevaluated historic district to be known as (specify): An archaeological resource with site number(s) (specify): Description, rationale for determination, photos & other pertinent information (enter below): An object (e.g. statue, stone marker etc.) (specify): Introduction A new multiple property/thematic study regarding (specify): Association with a multiple property/thematic study (specify): The office building at 1700 G Street, NW, currently occupied by the Consumer Financial Other (specify): Protection Bureau (CFPB), was originally designed by Max Urbahn Associates (now Urbahn Architects) and constructed between 1974–1977. The building is immediately west and north of the Winder Building, which is listed in the National Register of Historic Places (NRHP).

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APPENDIX - 52 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Methodology for Evaluation as an Individual Landmark ground level: one located on the southeast corner of the 17th Street elevation, one located on the southeast corner of the F Street elevation, and one on the southeast corner where the two wings To address the potential individual eligibility of this property, CFPB and Dovetail Cultural of the buildings come together at the northwestern edge of the plaza. The upper levels of the Resource Group (Dovetail) consulted key resources as part of a background review to put this building feature story-height windows around the entire perimeter of the building, inset from the building within a historic, social, architectural, and landscape context. This included the General exterior structural face 3 to 5 feet. The 90-foot building bays are joined by vertical light wells Services Administration (GSA) study Growth, Efficiency, and Modernism: GSA Buildings of the from the second to sixth floors to skylights in the roof. The building architect, Martin Stein, 50s, 60s, and 70s (Robinson & Associates 2005), which provides an in-depth historical context recently stated that the story-high recessed windows around the building were intended to “fill on federal buildings of the Modern era, several newspaper and journal articles on file with the the office space with a maximum of natural light” (Stein 2013). Outdoor terraces or verandas are CFPB, books on the development and architecture of Washington, D.C., interviews, and historic located at the ends of each building wing on the sixth floor. An additional sky-lit room is located maps. To assess the building’s potential eligibility, resources such as the previously mentioned in the east wing on the sixth floor. GSA study, the American Institute of Architects Guide to Architecture of Washington, D.C., and the Society of Architectural Historian’s Buildings of the District of Columbia were consulted for The exterior building design has not been altered over time, but the office interiors are no longer a context of other buildings in the area. an open workplace as originally designed. Portable and temporary partitions have divided the space into small office cubicles. Overall, the exterior of 1700 G Street, NW is in good condition Fieldwork was conducted on June 25 and July 11, 2013. The building was evaluated for with little wear to concrete and limestone surfaces. architectural significance as well as historic and physical integrity. This resource was documented through written notes and digital photography. The information obtained during the survey was then used to create the DOE form and make recommendations on the property’s NRHP potential.

Building Description

The office building at 1700 G Street, NW (known as the Federal Home Loan Bank Board [FHLBB] building) is situated on a parcel of land bounded by G Street, F Street, and 17th Street in the Northwest quadrant of Washington, D.C. It is set back from G and 17th Streets by approximately 30 feet. The Winder Building is situated immediately southeast of the building on the same block and stretches along F Street, and a commercial building at 1776 G Street, NW is at the western boundary. Across 17th Street, the Eisenhower Executive Office Building occupies the entire block.

1700 G Street, NW is a six-story federal office building with a gross area of 345,000 square feet. It consists of two perpendicular wings forming an L shape that also includes a full basement, two parking sub-floors, and a mechanical level on the roof. The structure consists of reinforced concrete clad with shot-sawn, limestone-box panels on all flat surfaces of exterior walls. The design, although angular, is slightly asymmetrical, which allows each elevation to reflect and mimic the neighboring buildings through windows and geometric shapes (Figure 1 and Figure 2, p. 5). The primary entrance to 1700 G Street, NW is located on the northeast corner of the building near the corner of G and 17th Streets. Another entrance is on the opposite side of the lobby with a secondary entrance in the connecting corridor between G Street and the courtyard. Figure 1: North Elevation of the FHLBB Building. The first story is lined with commercial spaces that are intended for stores and restaurants (Figure 3 and Figure 4, p. 6). The façades of these retail spaces are lined with plate glass windows and accessed by double-leaf, glass doors. The fenestrations are set within narrow, metal frames. Many of the commercial spaces are accentuated by arched, red awnings with the name of the business in white letters. An analysis of old photographs of this building suggests that these awnings are later additions (Figure 5, p. 6). There are three curved windows on the

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APPENDIX - 53 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Figure 2: Columns on the Corner of the FHLBB Building. These mirror the size and Figure 4: Ground Level of the FHLBB Building (left) and Sixth Floor Veranda (Right). shape of those on the Eisenhower Executive Office Building. No Awnings Red Awnings

Figure 5: View of the FHLBB Building, Winder Building, and Liberty Plaza Looking West from 17th Street, NW. The picture on the left was taken during the early 1990s and the one on the right was taken during the June 2013 fieldwork. These pictures suggest that the red awnings are a later addition (Scott and Lee 1993:206).

The ground floor houses the main entrance lobby of the CFPB and a variety of shops facing G Street, F Street, and the courtyard. The lobby is accessed by doors on the north (G Street) and south (Liberty Plaza) sides and lined with floor-to-ceiling, plate-glass windows and coffered wood that covers the ceiling. The brickwork visible on the exterior is continued on the interior which creates a blurring of the exterior and interior spaces. Surrounding the bricks are pebbles and potted plants and the ceiling is covered by a dropped, wooden, geometric ceiling that reflects the coffering found on the exterior and interior of the building (Figure 6, p. 7). A circular-shaped staircase that connects the lobby to the second floor is located west of the lobby behind the Figure 3: Ground Level Plan of the FHLBB Building (Comptroller General security station. This feature is made of light-brown, blonde-colored wood that ties into the of the United States [CGUS] 1978:10) other wooden elements of the building (Figure 7, p. 7). Beyond the staircase is an elevator shaft

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APPENDIX - 54 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

that features the original light switch, call box, and textured metal pattern on the interior (Figure 8, p. 8).

It is suggested that much of the lobby décor—the brickwork, potted plants, coffered wood work on the ceiling, and the staircase—was added after the 1976 construction date. At the time of this project, that fact can neither be confirmed nor denied; however, it is important to note that these elements were designed and installed in a way that reflected some of the architectural ideals and trends present when the FHLBB building was built such as curvilinear features, light-colored wood, the blending of the plaza and the lobby spaces, and an overall aesthetic feel that was common during the late 1970s.

Figure 8: Detail of the Original Elevator Elements and Limestone Blocks.

The second through sixth floors are, for the most part, designed to be identical. Each features two atria, which extend from a skylight at the sixth floor ceiling to the second floor and are lined with fixed, light-colored wood planters (Figure 9, p. 9). The second level has an auditorium at Figure 6: Lobby of the FHLBB Building, Looking South. the east elevation which is believed to be significantly altered from its original design. The linear room has built-in, curvilinear elements, terraced, carpeted levels for seating, and an arched, wooden stage.

Each floor between the second and the sixth is filled with cubical offices and meeting spaces that have carpet on the floor and slatted-wood ceilings (Figure 10, p. 10; Figure 11, p. 10). The office spaces were developed as open workplaces with maximum flexibility to accommodate a changing and growing workforce. As originally designed, the interior levels are covered by a 4- inch high, raised floors which accommodate and provide access to the distribution of electrical and communications systems wiring. Each floor also features men’s and women’s bathrooms that are covered in square tiles (Figure 12, p. 11).

Figure 7: Security Station and Staircase (Left) and Staircase and Elevators (Right).

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APPENDIX - 55 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Figure 10: Auditorium on the Second Floor, Looking North.

Figure 9: View of Atrium from the Sixth Floor Looking Down to the Second Floor.

Figure 11: Overview of Materials Used on Second through Sixth Levels of the FHLBB Building.

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APPENDIX - 56 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Liberty Plaza and the landscape around the FHLBB and adjacent Winder Building were designed by Sasaki Associates. The plaza is located southeast of the FHLBB building and functions as a courtyard for employees, the shops along the ground level, and has several access points to 17th Street, F Street, and G Street. Two of these pedestrian access locations are covered by solid, unpunctured concrete sections of the building; the ceilings of these covered areas are formed of coffered concrete. The brick-lined plaza once boasted an ice rink/reflecting pool, tables with umbrellas, plentiful vegetation, and a “plant festooned indoor portion” of the café called the Galleria. Today, the area that functioned as an ice rink in the winter and a reflecting pool in the summer has no water in it but the outline and shape are still visible, and a small waterfall feature is located on the western side. The built-in planters and vegetation are still intact; trees in triangular planters line the northwest side of the plaza and three sets of paired circular planters are situated at the east side. The Galleria, a partially covered structure, continues to line the north elevation of the Winder Building; however, it is no longer filled with plants. None of the tables, chairs, or umbrellas remain in the plaza (Figure 14–Figure 16, pp. 12–13). There are two lower (disconnected) levels to the plaza. The level near the 17th Street entrance features vegetation, brick planters, and four bronze medallions on its southern wall which were removed

from the demolished Riggs Bank Building that once stood on the site of the FHLBB Building Figure 12: View of the Use of Tiles In and Around the Bathrooms. (Figure 17, p. 13). The lower level on the western side of the plaza behind the former ice-skating rink once functioned as an access to a cafeteria located in the basement. A set of stairs extends The basement, which once functioned, in part, as a cafeteria, is now used as a mail room, library, from the ground to lower level and a fountain with bronze cannon-like features is situated in the offices, fitness center, and child-care area. The walls of this part of the building are covered in a center of this basement level (Figure 17, p. 13). brick, stretcher-bond veneer and the ceilings are lined with the same slatted material seen on other floors (Figure 13). Light wells or skylights penetrate the ceilings along the building perimeter. Levels P1 and P2 allow parking for 220 cars and provide space for mechanical and electrical building components and storage areas. The parking garage is accessed through an F Street down ramp entrance and the garage exit ramps up to G Street. The interior remains in relatively good condition, although it does show signs of aging and wear over time.

Figure 14: Site Plan of the Liberty Plaza. The red, dashed line marks the location of the plaza (Uncited journal article nd). Figure 13: Overview of the Basement.

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APPENDIX - 57 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Site and Building Chronology

The office building at 1700 G Street, NW was built in the mid-1970s, near the end of an architectural movement referred to as mid-century Modern. Beginning in World War II architecture in Washington, D.C., especially Federal building architecture, drastically changed. By the mid-twentieth century “what may be considered the first wave of Modern-era buildings was largely coming to a close—the “Moderne” styles of Art Deco, Streamlined Moderne, and Stripped Classical generally dated from the 1920s to the 1940s…The stage was set for fresh architectural innovation ” (Robinson & Associates 2005:12).

Around this same time, the United States Government was spread throughout the country and it was decided that a single support agency was needed. Established as part of the Federal Property and Administrative Service Act of 1949, the GSA was “formed to achieve the following goals: standardization, direct purchase, mass production, and fiscal savings,” and they would be in

charge of creating and providing “the resources needed by United States agencies to accomplish Figure 15: Looking Southwest at Liberty Plaza. Note the triangular and circular planters. their missions” (Gutheim and Lee 2006:245–249; Robinson & Associates, Inc. 2005:29). Included in their umbrella of services was the task of solving the need for more government office space in some of the major cities across the country, especially Washington, D.C. (Robinson & Associates, Inc. 2005:6, 38).

In the early 1950s, the Federal government started “encouraging Modern design” and introduced the second wave of that architectural movement (Robinson & Associates, Inc. 2005:6, 25). Many times, low construction, maintenance, and decorative costs were a high priority, often resulting in stark, angular, functional buildings.

Unlike predecessor buildings of the nineteenth and early-twentieth centuries, this new wave of Modern architecture and design exhibited “transparent building materials served to visually unite exterior and interior spaces,” smaller offices, which gave way to larger common spaces, the use of “electrical and mechanical innovations and methods and materials—such as steel, glass,

plastic, and reinforced concrete—that were previously unavailable” (Robinson & Associates, Figure 16: View of the Galleria, Looking Northeast. Inc. 2005:30). Early national examples of this radical shift in design and execution of new buildings include the Lever House, a 1952 office building in New York City; the Seagram Building, constructed by Mies van der Rohe and Philip Johnson in 1958, also in New York City; Yale Art Gallery, a 1953 example of Louis Kahn’s work; and the Washington Dulles Airport, designed by Eero Saarinen (Great Buildings 2013; Metropolitan Washington Airports Authority 2013; Mies van der Rohe Society 2013; Robinson & Associates, Inc. 2005:32; Yale University 2013).

President John F. Kennedy played an important role during this period of American architecture. Reportedly, during his 1961 inaugural parade he noted that many older federal buildings along the north side of Pennsylvania Avenue were vacant, boarded up, or in extremely poor condition; this was in strong contrast to the monumental Federal Triangle on the south side. In June of the following year the Ad Hoc Committee on Federal Office Space reported that “office space in and around Washington was disorderly, inefficient, and wasteful” and “of the 291 buildings occupied

by the Government agencies in the area, 66 are obsolete Government-owned buildings, 47 are Figure 17: Two of the Four Bronze Medallions on the Eastern Plaza Wall (Left) and the Water Government-owned temporary buildings, and 129 are leased buildings” (Robinson & Associates, Feature on the West Side of Plaza (Right). 13 14

APPENDIX - 58 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Inc. 2005:42). Further, the Ad Hoc Committee suggested “a decade-long program that would Department of Commerce…GSA received 12 bids ranging from $118,640 to $278,888. The eliminate temporary and obsolete buildings while constructing a minimum of 12 new Federal contract for $118,640 was awarded to the lowest bidder, the Julian C. Cohen Salvage buildings” (Robinson & Associates, Inc. 2005:42). This resulted in the demolition of entire Corporation” (Shafer 1974:3). blocks, giving the government the freedom and space to develop new office buildings. Once the site was acquired, early building design and construction plans were needed. It seems In response, in part, to the major changes being made to the historic urban landscapes, Congress apparent that FHLBB, as an agency, was interested in a different type of building design—one passed the National Historic Preservation Act (NHPA) in 1966 (Robinson & Associates, Inc. with a unique interior and exterior concept as well as constructed landscape. They: 2005:50; Stipe 2003). Two sections became extremely important in the Federal government’s development of inner-city office buildings: Section 106 and Section 110. Section 106 requires asked for and [were] granted permission by GSA's project manager to hire a space that the effects of a Federal undertaking on any district, site, building, structure, or object that is planning consulting firm for the interior of the building. FHLBB awarded a included in or eligible for inclusion in the NRHP be taken into account. Furthermore, it states contract to Hunter/Miller Associates, Incorporated, in March 1975 to design the that the agency must provide the Advisory Council on Historic Preservation (Advisory Council) building's interior. That contract was subsequently terminated by FHLBB and a reasonable opportunity to comment regarding the undertaking (Advisory Council 1966). another contract was awarded to Max O. Urbahn Associates, Incorporated. Section 110 “governs Federal agency programs by providing for consideration of historic FHLBB contracted with Tate Architectural Products, Incorporated, to finish the preservation in the management of properties under Federal ownership or control” (Advisory interior, and with numerous other firms for furnishings, equipment, and other Council 2000). services for the building. GSA hired Max Urbahn Associates to design the building and Sasaki Associates to determine the layout and landscape of the Ten years later, President Richard Nixon’s Task Force on Federal Architecture created the Public surrounding site (CGUS 1978:3). Buildings Cooperative Use Act, which helped tie together the previous goals of the GSA as well as historic preservationists. It states that the GSA shall “acquire and utilize space in suitable Max Urbahn Associates, a New York City-based firm, was founded by Max O. Urbahn in 1946. buildings of historic, architectural, or cultural significance, unless use of such space would not Prior to opening his own firm, he worked for Eggers and Higgins, the successor architecture firm prove feasible and prudent compared with available alternatives” (NPS 1976). In addition to the to John Russell Pop, and was an important member of the firm and was involved in the firm’s concept of using historic and extant buildings, this act specifically promoted the idea of allowing design for the Jefferson Memorial in D.C. Later he went on to become the President of the multiple uses in many of the Federal buildings. The purpose of this was to “energize streets, American Institute of Architects (AIA) (The New York Times 1995). Max Urbahn Associates offer amenities to Federal employees during work hours, and provide revenue for underused designed 909 Third Avenue in New York City, Fermi National Accelerator Laboratory Complex spaces” (Robinson & Associates, Inc. 2006:59). By emphasizing mixed-use in these office in Champaign, Illinois, Lincoln Hospital in Bronx, New York, NASA’s Vehicle Assembly buildings on the street level, the government was able to produce a space that was used by its Building in Cape Canaveral, Florida, and Junior High School 144 in the Bronx, New York employees as well as members of the surrounding communities. Often, this results in a (Figure 18) (The New York Times 1995: Urbahn Architects 2013). revitalization of a neighborhood and community and can result in a successful reuse of an extant building.

Amidst all of this was the development of the FHLBB Building on the 1700 block of G Street, NW. During the early 1970s the eastern half of this block comprised four buildings: the Winder Building, an 1847 brick building that once housed the Treasury Department and War Department and is listed in the NRHP; the late-nineteenth century Winder Building Annex; the 1920s Riggs Bank Building; and an early-nineteenth century, Federal-styled townhouse that functioned as the Nicolas Café (Savings and Loan News nd; Taylor 1969). As part of the previously discussed movement to create inner-city office space for federal government employees, GSA was responsible for developing office space for the FHLBB, and in the late 1960s, GSA received approval to acquire land and construct buildings for this agency. In 1968, “GSA purchased land for the building site on each side of Third Street between D and E Streets, NW…The Board indented to use part of the land for its building and part for parking facilities” (Shafer 1974:2). FHLBB desired a location that was closer to Washington’s financial district and requested that GSA look into additional, larger sites; this resulted in the acquisition of the eastern half of the Figure 18: Max Urbahn Associates-Designed Buildings 909 Third Street in New York City 1700 block of G Street, NW in 1972 (Shafer 1974:2). In late 1973, GSA “issues a preinvitation (Left) and the NASA Vehicle Assembly Building (Right) (NASA 1999; Vornado Realty Trust to bid for the demolition at the 17th Street site to the Commerce Business Daily of the 2013). 15 16

APPENDIX - 59 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

Following the National Capital Planning Commission’s (NCPC) recommendations in June of buildings in Washington, D.C. without first consulting the Advisory Council on 1973, their plans called for height restrictions and façade treatment that would be compatible and Historic Preservation, as required by the National Historic Preservation Act of sympathetic to the neighboring historic buildings, specifically the Winder Building and the 1966. The court spreads upon the record the equivocal maneuvers which enabled Eisenhower Executive Office Building, located just east of the FHLBB building on the opposite the GSA to cause substantial damage to the buildings before plaintiffs could side of 17th Street, NW. Early plans also called for mixed-use of the building’s street level and secure a temporary restraining order banning further demolition. Subsequently, an outdoor plaza (called Liberty Plaza), both of which had the intent of bringing the general however, the GSA formally complied with the consultation requirement of the public and the Federal employees together in the same space: National Historic Preservation Act. Therefore, although defendants’ acts so damaged the buildings that they were beyond salvage, the court concludes that the GSA and FHLBB have selected an alternative concept for development of the site action is moot. which…incorporates two levels of commercial development at grade, opening both on the streets and into the court or plaza formed by the Winder Building and Following this decision, GSA continued with the construction of the FHLBB building. They the FHLBB building. This design reflects the determination to provide a public took their existing plans and, in light of the major controversy, put even more emphasis on amenity in the form of a spacious, vibrant plaza alive during the day and evenings incorporating citizen’s thoughts and concerns into the building’s development. GSA, Max hours, which will revitalize this area in the city (NCPC 1973). Urbahn Associates, and Sasaki Associates designed a building that was at the forefront of this movement—sometimes referred to as Contextualism— among Federal buildings in Washington, As regulated by the NHPA, in 1973 GSA informed the Advisory Council of their plans, which D.C. The development of this site came on the heels of the Modern-era Brutalist style, which involved demolition of all buildings except the Winder Building; on January 31, 1974 they populated the city’s landscape with stark, hard buildings that were often designed without regard entered into a contract for demolition. Almost immediately, the Advisory Council expressed its to their pre-existing surroundings, such as Third Church of Christ, Scientist, Robert C. Weaver concern about the future of the historic buildings on this site, both those that would be directly Building, and the Forrestal Building near L’Enfant Plaza (Gutheim and Lee 2006:271–275; impacted by demolition and the Winder Building, whose feeling, association, and setting would Robinson & Associates 2003). be affected. Furthermore, it felt that the Riggs Bank Building, early-nineteenth century townhouse, and Winder Annex had the potential to be eligible for the NRHP. The Secretary of Architecturally, the FHLBB building was designed to be sympathetic to the surrounding Interior reviewed the buildings, concurred with the Advisory Council, and determined that the landscape and streetscape. The color matches that of the neighboring Winder Building; buildings possessed enough historic and architectural significance to be eligible for the NRHP, furthermore, the height and bulk of the building were monitored and designed to complement the which made this project subject to Executive Order No. 11593. This order required the Federal Winder Building, not to overwhelm the surrounding extant historic buildings. In addition, the government to: overall scale of the building was diminished by “making the wall around its top veranda level with the Winder’s cornice” (Savings and Loan News nd). The horizontal concrete features on the (1) administer the cultural properties under their control in a spirit of stewardship façade line up almost perfectly with the windows of the Winder Building, giving this part of F and trusteeship for future generations, (2) initiate measures necessary to direct Street a cohesive appearance and feel despite the nearly 120-year age difference between the two their policies, plans and programs in such a way that federally owned sites, buildings (Figure 19). The design was also meant to be sympathetic to the Eisenhower structures, and objects of historical, architectural or archaeological significance Executive Office Building. Martin Stein, current Managing Partner for Max Urbahn Architects are preserved, restored, and maintained for the inspiration and benefit of the (formerly Associates), stated that “the building design was essentially a modern-style copy of the people, and (3), in consultation with the Advisory Council on Historic building materials and character of the Eisenhower Executive Office Building, which is located Preservation (16 U.S.C. 470i), institute procedures to assure that Federal plans across 17th and programs contribute to the preservation and enhancement of non-federally Street from 1700 G Street, NW” (Stein 2013). The east elevation of the FHLBB owned sites, structures and objects of historical, architectural or archaeological building was designed to mirror, in an abstract way, the historic building across the street. The significance (National Archives 2013). central, projecting pavilion on the Eisenhower Executive Office Building was replicated using window design on the FHLBB building. The color of the building and the concrete columns pay In late-February of 1974, GSA met with the Advisory Council and it agreed to discuss possible homage to and play off of the neighboring historic office building (Figure 20, p. 19) (Moller, Jr. ways to minimize the adverse effect on the listed and eligible properties before continuing with 2012:150; Uncited journal article nd). its demolition plans. However, on Sunday, March 3, 1974, wreckers were sent to the site. They demolished the townhouse, destroyed all but the façade of the Riggs Bank Building, and pierced the roof of the Winder Building Annex before the Advisory Council could obtain a restraining order. Immediately, a citizen’s group called Don’t Tear it Down, Inc. sued the GSA; however, the court ultimately ruled the following (Advisory Council 1975): The court dismisses the injunctive action brought to the General Services Administration from completing destruction of certain historically significant 17 18

APPENDIX - 60 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW FHLBB BUILDING, 1700 G STREET, NW

building. The galleria reaches to the Winder’s second story and will serve as the plant festooned FHLBB Building indoor portion of the courtyard’s café” (Figure 23, p. 21) (Savings and Loan News nd).

Winder Building

Figure 19: Looking East Along F Street, NW Toward 17th Street. Note how the horizontal elements of the FHLBB building are similar to those of the Winder Building.

Figure 21: View of the FHLBB Building, Winder Building, and Liberty Plaza Looking West from 17th Street, NW in the early 1990s (Scott and Lee 1993:206).

Figure 20: View of 17th Street, NW Looking South. The Eisenhower Executive Office Building is on the left and the FHLBB Building is on the right. The yellow arrows note the way both buildings emphasize the central projecting primary elevation. The red arrows point out the use of single-story columns on both buildings.

The building design and the site’s landscape were developed to encourage a sense of community. Although the Liberty Plaza itself demonstrates an attempt to reach out to the public, this was a design concept that had already been done in other earlier Modern buildings around Washington, D.C. What set this project apart from previous undertakings are the additional details and elements. As previously mentioned, the street level was filled with shops and restaurants; some sources state that this was the first completed Federal building to do this (Figure 21, p. 20) (Moller, Jr. 2012; Savings and Loan News nd). In addition, the plaza featured an ice rink, which functioned as a reflecting pool in the summer, to be surrounded by tables and chairs covered by brightly colored umbrellas (Figure 22, p. 20) (Hodge 1977:1–2). Sasaki Associates created a Figure 22: Former Ice Skating Rink at Liberty Plaza with the “greenhouse-like structure called a galleria [that] runs almost the full length of the [Winder] FHLBB Building in the Background, Circa 1978 (Uncited journal article nd).

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APPENDIX - 61 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION DETERMINATION OF ELIGIBILITY (DOE)

DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW

Figure 23: Circa-1976 Drawing of the Proposed Liberty Plaza and Galleria (Savings and Loan News nd).

Also, Max Urbahn Associates, along with the engineering firm, Syska and Hennessey, designed the building to be environmentally sensitive. Instead of large, overhead lights, each work space was lit using desk or office lamps, three air systems were used instead of two, variable ventilation and unheated air was used for the parking garages, large and angled windows to capture even the low, winter sunlight, lukewarm water was provided in bathrooms instead of both hot and cold, the masonry walls were insulated, and the windows were either double glazed or had insulated panels on the back (Architectural Record nd).

As part of the mitigation efforts for the demolition of the historic building on the block, GSA and Max Urbahn Associates also worked together to restore, rehabilitate, and sensitively update the Winder Building. They completed restoration in 1976. The building: included air conditioning, heat, and general ventilation. To satisfy the fire safety codes, the stairwells were enclosed in glass and sprinklers were installed throughout the building. An elevator room was added to the building (the older elevators had been in a different location). Doors were restored to replicate the originals. The intricate wrought iron balcony was restored. The original balcony, which ran along the second floor, had been sold as scrap metal in 1922 (Figure 24) (United States Trade Representative 2013).

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APPENDIX - 62 PART E: APPENDIX B. HISTORIC PRESERVATION DOCUMENTATION MEMORANDUM OF UNDERSTANDING (MOU)

MEMORANDUM OF AGREEMENT WHEREAS, the CFPB and the SHPO has notified the Advisory Council on Historic AMONG Preservation (“ACHP”) of the adverse effect in accordance with 36 CFR 800.6(a)(1) CONSUMER FINANCIAL PROTECTION BUREAU and the ACHP has chosen not to participate in the consultation; and

THE DISTRICT OF COLUMBIA STATE HISTORIC WHEREAS, the CFPB, their consultants, and the SHPO have met to discuss the PRESERVATION OFFICER AND proposed project plans on March 14, 2013, April, 15, 2013, October 2, 2013, November THE ADVISORY COUNCIL ON HISTORIC PRESERVATION 12, 2013, and December 4, 2013, to minimize the project’s impact on character-defining REGARDING features of the property; and, THE FEDERAL HOME LOAN BANK BOARD BUILDING AT 1700 G STREET, NW IN WASHINGTON, D.C. WHEREAS, pursuant to 36 CFR 800.6(c)(1)(i), the CFPB and the SHPO are the signatories to this Memorandum of Agreement (MOA).

NOW THEREFORE, CFPB and the SHPO agree that the Undertaking shall be WHEREAS, the Consumer Financial Protection Bureau (“CFPB”) proposes to renovate implemented in accordance with the following stipulations in order to take into account the Federal Home Loan Bank Board (“FHLBB”) Building at 1700 G Street, NW in the adverse effects of the Undertaking on historic properties. Washington, D.C. including large-scale modifications to the interior of the building and exterior courtyard, and some minor changes to the exterior of the building (the “Undertaking”) (Figures 1 and 2); and STIPULATIONS

WHEREAS, the proposed Undertaking consists of a building that is currently owned CFPB shall ensure that the following measures are carried out: and occupied by the Federal Government (the “Property”); and

WHEREAS, CFPB has consulted with the District of Columbia State Historic I. PROFESSIONAL QUALIFICATIONS Preservation Officer (“SHPO”) in accordance with Section 106 of the National Historic a. All cultural resource work carried out pursuant to this agreement shall be Preservation Act (“NHPA”) to take into account the effects of the Undertaking on conducted by or under the direct supervision of an individual or individuals historic properties included in, or eligible for inclusion in, the National Register of who meet, at a minimum, the Secretary of the Interior’s Professional Historic Places (“NRHP”); and Qualifications Standards (48 FR 44738–9, September 29, 1983) (SOI

Standards). WHEREAS, pursuant to 36 CFR 800.4(a)(1), CFPB and SHPO have determined that the Area of Potential Effect for the Undertaking is the building footprint, adjacent b. All cultural resource studies resulting from this MOA shall take into account courtyard, and areas where alterations to the property’s setting and feeling may be guidelines set forth by the National Park Service and the SHPO, as appropriate. visually impacted by the Undertaking (surrounding viewshed as determined by topography, vegetation, and distance); and II. TREATMENT OF FHLBB WHEREAS, the FHLBB is located within the Area of Potential Effect; and a. Because character-defining features of the NRHP-eligible FHLBB will be WHEREAS, the circa-1974 FHLBB was the subject of an intensive architectural diminished, at such time as it begins the Undertaking, CFPB or its evaluation by Dovetail Cultural Resource Group (“Dovetail”) in June and July 2013 representatives shall create or cause to be created a NRHP nomination and a and recorded through a Determination of Eligibility form, which was reviewed by the DC Inventory of Historic Sites nomination form for this property. This includes SHPO in July 2013; and any additional research required to author the nominations, completion of the nomination forms, and creation of all accompanying nomination WHEREAS, the CFPB and the SHPO has determined that the FHLBB is eligible for documentation. Further, the draft nominations and all supporting documents listing on the NRHP; and shall be submitted to the SHPO and NPS for review and requested modifications shall be made to the document for presentation at both local- and WHEREAS, the CFPB and the SHPO has determined that the Undertaking will have an federal-level review meeting. adverse effect on the FHLBB; and b. The SHPO shall continue to be consulted during project design process. This includes involvement in dialogues on material selection, design details, building

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layout, courtyard design, etc. This consultation shall include, as appropriate, CFPB’s responsibility to carry out all actions under this MOA that are not attendance at meetings, inclusion in email discussions, and receipt of subjects of the dispute will remain unchanged. preliminary plans for review.

c. The four bronze medallions once located on the Riggs Bank Building formerly V. AMENDMENTS AND TERMINATION located on this parcel shall be placed in a spot of prominence within the new a. Any signatory to this MOA may propose that the MOA be amended, building or courtyard design. The CFPB and SHPO shall come to an agreement whereupon the signatories shall consult to consider such an amendment. All on an appropriate installation location. signatories to the MOA must agree to the proposed amendment in accordance with 800.6(c)(7). d. In association with the reuse of the historic elements listed in II.c above, the CFPB shall create or cause to be created interpretive signage to be installed b. This MOA may be terminated by any signatory in accordance with the near the historic elements. The signage shall contain images and verbiage procedures described in 36 CFR 800.6(c)(8). Termination shall include the appropriate for the public interpretation of the historic elements. The quantity submission of a technical letter report by CFPB on any work done up to and of signs, location of sign installation, and sign design (including both visuals including the date of termination. If the signatories are unable to execute and text) shall be approved by both the CFPB and the SHPO before another memorandum of agreement following termination, CFPB shall comply construction and installation. with 36 CFR Part 800 for any other project proposed for the Property.

III. PREPARATION AND REVIEW OF DOCUMENTS VI. DURATION OF AGREEMENT

a. A draft of the NRHP nomination shall be submitted to the SHPO for review and Subject to the terms of Article V above pertaining to the termination hereof, this comment. CFPB shall ensure that all comments received within thirty (30) days MOA shall continue in full force and effect until five (5) years after the date of the of text/report receipt shall be addressed in the final documents. Two copies of last signature. At any time in the six-month period prior to such date, any signatory all final documents shall be provided to the SHPO. may request the other signatories to consider an extension or modification of this MOA. No extension or modification shall be effective unless all parties have b. Unless otherwise stated in this MOA, any technical reports prepared pursuant to executed and delivered a written amendment to this MOA. this agreement shall be consistent with the federal standards entitled

Archeology and Historic Preservation: Secretary of the Interior’s Standards Execution of this MOA and implementation of its terms evidences that CFPB has and Guidelines (48 FR 44716–42, September 29, 1983) and the Guidelines for taken into account the effects of the Undertaking on historic properties and afforded Preparing Identification and Evaluation Reports for Submission Pursuant to the ACHP a reasonable opportunity to comment. Sections 106 and 110, National Historic Preservation Act.

IV. DISPUTE RESOLUTION

Should any signatory to this MOA object in writing to any action carried out in accordance with the MOA, the signatories shall consult to resolve the objection. Should the signatories be unable to resolve the disagreement, CFPB shall forward all documentation relevant to the dispute to the ACHP. Within 45 days after receipt of all pertinent documentation, the ACHP will either:

a. Provide CFPB with recommendations, which CFPB will take into account in reaching a final decision regarding the dispute; or

b. Notify CFPB that it will comment pursuant to 36 CFR 800.7(c), and proceed to comment. Any ACHP comment provided in response to such a request shall be taken into account by CFPB in accordance with 36 CFR 800.7(c)(4) with reference to the subject of the dispute. Any ACHP recommendation or comment will be understood to pertain only to the subject of the dispute;

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SIGNATORIES DISTRICT OF COLUMBIA STATE HISTORIC PRESERVATION OFFICER

CONSUMER FINANCIAL PROTECTION BUREAU By:______Date:______David Maloney By:______Date:______District of Columbia State Historic Preservation Officer NAME TITLE

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North Elevation of 1700 G Street, NW (The Federal Home Loan Bank Board Building).

1700 G Street, NW

N

Location of 1700 G Street, NW on the Washington, D.C. Real Property Map (Office of the Chief Technology Officer 2013).

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