2019 – 2020 Environmental Review Record Floodplain Investigation

2019 – 2020 ENVIRONMENTAL REVIEW RECORD FLOODPLAIN INVESTIGATION

Prepared by:

Community and Economic Development Department Dearborn Heights, Michigan 2019 – 2020 ENVIRONMENTAL REVIEW RECORD FLOODPLAIN INVESTIGATION Dearborn Heights, Michigan

Prepared by:

Community and Economic Development Department City of Dearborn Heights, Michigan 26155 Richardson Dearborn Heights, MI 48127 (313) 791-3505

With assistance from: Wade-Trim ACKNOWLEDGMENTS

Daniel Paletko, Mayor John J. Riley II, Treasurer

CITY COUNCIL Denise Malinowski-Maxwell, Council Chairperson Bob Constan Bill Bazzi Dave Abdallah Lisa Hicks-Clayton Tom Wencel Ray Muscat

DEPARTMENT ADMINISTRATION Joe Hachem, Director Christopher Klimchalk, Program Coordinator

26155 Richardson Dearborn Heights, MI 48127 (313) 791-3500

ENVIRONMENTAL REVIEW RECORD FLOODPLAIN INVESTIGATION PREPARED WITH ASSISTANCE FROM:

500 Griswold Avenue Suite 2500 Detroit, MI 48226 313.961.3650

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TABLE OF CONTENTS

Acknowledgments ...... 1

Table of Contents ...... 2

Introduction ...... 3

Analysis ...... 4 Part I: Alternatives Alternative Sites Alternative Actions No Action Part II: Adverse Impacts Part III: Public Hearing

Floodplain Values ...... 8

Appendix

Appendix 1 ...... Public Hearing Notice and Minutes Appendix 2 ...... Agency Contact and Comments Appendix 3 ...... Issuance of Findings Statement, Public Hearing Notice Appendix 4 ...... Action Plan Projects Map Appendix 5 ...... Environmental Assessment Matrix

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INTRODUCTION

Pursuant to the procedures for floodplain management and the protection of wetlands specified in Executive Orders 11988 and 11990, the City of Dearborn Heights is considering funding, with 2019/2020 Community Development Block Grant (CDBG) funds, project(s) with potential locations within the 100-year floodplain. The City shall consider alternatives to avoid adverse effects and incompatible development in the floodplains.

Prior to taking action the City shall, (1) design or modify its action in order to minimize potential harm to or within the floodplain, consistent with regulations, and (2) prepare and circulate a notice containing an explanation of why the action is proposed to be located in the floodplain.

As well, the City of Dearborn Heights, Michigan is required by Executive Orders 11988 and 11990, Floodplain Management and Protection of Wetland regulations, to complete an assessment of the effects of proposed CDBG projects on the environment within the 100-year floodplain. The City of Dearborn Heights will receive comments pertaining to concerns or practical alternatives to said proposed projects.

The projects under consideration are:

Housing Rehabilitation The purpose of this City-wide program is to provide no interest loans to income eligible homeowners throughout the City for housing rehabilitation activities where the cost of rehabilitation is less than 50 percent of the current market value of the home. The City will be contributing $205,158 of the FY 2019/2020 CDBG allocation to this program. The location of this project is City-wide.

Code Enforcement This service provides funding to provide code enforcement inspections within areas of low and moderate income. This service will be provided in low and moderate-income areas that may fall within the 100-Year Floodplain. This project is not subject to floodplain review pursuant to 24 CFR 55.12(c)(1) and therefore does not need to follow the decision- making process in 24 CFR 55.20. The City will be contributing $100,000 of the FY 2019/20 CDBG allocation to this program.

Eton Senior Center Facility Improvements The City’s CDBG program is providing funding for improvements to the Eton Senior Center. The Eton Senior Center is located at 4900 Pardee Avenue. The estimated total project cost is $91,000. This includes design, engineering, construction, administration and construction costs. The City will contribute $91,000 of the FY 2019/20 CDBG allocation to this project.

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Demolition Program The purpose of the Demolition Program is to eliminate vacant and blighted structures within the city. The program will take place all over the City. The estimated total for the project is $50,000, and the City of Dearborn Heights will contribute $50,000 of the FY2019/20 CDBG allocation to this project.

ANALYSIS Part I: Alternatives The initial component used in this analysis is the identification and evaluation of practicable alternatives to locating in the floodplain. The alternatives include carrying out the proposed actions at alternative sites, identifying alternative means that could possibly accomplish the same purposes of the proposed actions, and no action.

Alternative Sites The City must evaluate whether or not these activities can occur on “flood-free” sites, or if necessary in a flood prone area, and then select the site having the least risk or environmental impact.

In determining the practicality of an alternative non-floodplain site, the general concepts of “site feasibility” were applied, in accordance with the Floodplain Management Guidelines for implementing Executive Order 11988 issued by the Water Resource Council in 1978. Pursuant to U. S. Department of Housing and Urban Development (HUD) program guidelines, the City’s entitlement allocation can only be spent to: serve low and moderate-income persons; meet other community development needs having a particular urgency (i.e., existing conditions pose a serious threat to health or welfare of the community); and aid in the prevention or elimination of slums and blight (refer to 24 CFR 570.200(a) (2)). HUD has identified low and moderate-income areas in the community where CDBG monies may be expended. These CDBG eligible areas are displayed on the Action Plan Projects Map (Appendix 4).

Housing Rehabilitation The City of Dearborn Heights offers low and moderate-income homeowners the ability to reside in a safe and sanitary home by accessing Housing Rehabilitation dollars. This program is available citywide. As homeowners seek funding from the CEDD, non-floodplain projects will take priority. The City will require that homes located within the floodplain carry the necessary insurance and fully comply with the requirements of 24 CFR 58.5 and 58.6. As well, homeowners within the floodplain will receive limited assistance based on the SEV of the property.

The City could seek to lessen the amount of rehabilitation projects or to avoid assisting homes that are in the floodplain. These options are not acceptable, as it would be detrimental for a large segment of the community that is located within

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the affected areas. The housing rehabilitation program ensures that low and moderate-income homeowners are able to maintain property values due to the availability of financial assistance. Many of these homeowners would not be able to obtain assistance at a reasonable interest rate.

The substantially older age of the City’s housing stock suggests that programs for housing rehabilitation and lead safety are warranted citywide. As a general rule, major housing maintenance and repair is required every 30 years. For example, roofs, windows and even mechanical equipment need to be replaced within 20 to 30 years after a housing structure is originally built.

Approximately, 98% of the housing stock was built prior to 1970. The older housing stock creates a serious maintenance issue for the community. A vast majority of Dearborn Heights’ housing requires maintenance having gone through one or more housing maintenance cycles. Additionally, over 90% of the Dearborn Heights’ housing stock is at risk of having lead-based paint; this poses a potential hazard to children under the age of 6.

In addition, the City’s Housing Rehabilitation Program is an ongoing effort to improve the aging housing supply throughout the City’s low and moderate- income areas. For this reason, the justification of rehabilitating homes within the flood plain is justified. The proposed project does not call for the development of new homes, but instead the rehabilitating of existing homes within the 100-year floodplain.

Eton Senior Center Facility Improvements The City of Dearborn Heights plans to complete facility improvements on the Eton Senior Center located at 4900 Pardee Ave, Dearborn Heights, MI.

The City could refrain from facility improvement projects or to avoid assisting neighborhoods that are in the floodplain. These options are not acceptable, as the facility assists the local and aging community with numerous services. An aging facility becomes more and more of a problem as the population continues to rely on it as it fails to accommodate. This facility needs accessibility and efficiency improvements. This is especially important as the facility primarily serves the elderly population, a group that is more likely to have disabilities. The structure was built in 1959, and would benefit from such improvements.

In addition, the Senior Center Facility improvements is an ongoing effort to improve the aging infrastructure of the City and better protect persons in low and moderate-income areas. For this reason, the justification of the Eton Senior Center facility improvements within the flood plain is justified.

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Demolition Program The City of Dearborn Heights seeks to remove unsafe, condemned, and blighted structures to improve the quality of life and infrastructure within the City. This program is available city-wide.

The City could refrain from demolishing structures that are in the floodplain, or seek to lessen the amount of demolition projects that are in the floodplain. These options are not acceptable, as it would be detrimental for a large segment of the community that is affected by blight within the floodplain areas.

For this reason, the justification of the Demolition Program within the floodplain is justified.

Alternative Actions Alternative actions must also be considered. These are actions which substitute for the proposed actions, in that they comprise new solutions or approaches which serve the same purpose or function as that proposed, but which may have less potential for harm.

The City does not have any practical alternative for rehabilitation of the neighborhoods, improvements to the Eton Senior Center, or the demolition program, which are located in a floodplain. As a result, housing rehabilitation, facility improvements, and blight demolition projects should be available citywide or within CDBG eligible areas. The City will design or modify its action in order to minimize potential harm to or within the floodplain.

No Action No action is the last alternative examined. In every instance, this course of action was viewed as unacceptable.

HOUSING REHABILITATION The Housing Rehabilitation Program is an on-going project throughout the City of Dearborn Heights. The lack of a City-wide rehab program to improve the City’s housing supply could have an adverse affect on neighborhoods. This program improves many aspects of life for Dearborn Heights residents. For example, the updating and rehabilitating of homes prevent blight and slums which improves the overall quality and aesthetic value of homes. Property values are protected by making neighborhoods more attractive to current and potential residents.

Eton Senior Center Facility Improvements The City of Dearborn Heights is updating aging City infrastructure, and this has become a priority for the City.

There are several aspects of this community center that need to be updated, including accessibility. The City will update the facility to meet federal and state law.

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Demolition Program The City of Dearborn Heights seeks to eliminate blight within the City. The City will remove these structures to improve the quality of life, local property values, and safety of its residents.

Part II: Adverse Impacts Since the City has determined that the floodplain sites are the only practicable alternative, the City must next identify what impacts may be expected from the proposed actions.

In assessing the expected impact, four (4) key areas were investigated. They include: 1. Natural Environment (topography, habitat, hazards, etc.); 2. Social Concerns (aesthetics, historical and cultural values, public services, etc.); 3. Economic Aspects (employment, land use pattern, energy resources, among others); 4. Legal Constraints (deeds, leases, etc.).

Tables 1, 2, and 3, the Environmental Assessment Matrix (Appendix 5), assess these features for the proposed Housing Rehabilitation, Eton Senior Center facility improvements, and Demolition Program activities. This table reveals that the impacts of the proposed actions do not warrant the postponement or elimination of the activities included in this analysis.

Part III: Public Hearing and Public Input

Public Hearing Dearborn Heights held public hearings on January 22, 2019 and on March 12, 2019 to seek input on the proposed projects for 2019-2020. At these meetings, the public was notified that they would have the opportunity to offer input on the impact of these projects.

Upon completion of a 15-day public comment period the City will hold a public hearing to present the final results of the Floodplain Investigation Report on April 10, 2019.

Public Input The City is interested in discussing practicable alternatives to these projects, learning public perceptions of possible adverse impacts that could result from undertaking these projects within the floodplain, identifying any possible administrative measures that can be used to reduce or eliminate any adverse effects, and promoting comments in relation to the mentioned projects.

Copies of the proposed FY 2019 floodplain draft will be available for public review at JFK Jr. Library, 24602 Van Born Rd., Dearborn Heights, MI 48125, the

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Caroline Kennedy Library, 24590 George, Dearborn Heights, MI 48127, the Clerk’s Office, 6045 Fenton, Dearborn Heights, MI 48127, and the Dearborn Heights Community and Economic Development Department on March 20, 2019.

Persons with disabilities who require special accommodations should contact 313-791-3500. Advance notice is required. Written comments on all the above plans will be received through April 4, 2019 at 5:00 P.M. at the following address: City of Dearborn Heights, Community and Economic Development Department, 26155 Richardson, Dearborn Heights, Michigan, 48127 ATTN: DIRECTOR

The City is interested in discussing practicable alternatives to these projects, obtaining information on possible adverse impacts that may result and identifying any measures that may be utilized to reduce or eliminate detrimental effects.

In order to seek further input on the 2019-2020 proposed projects, Dearborn Heights is seeking public comments from March 20, 2019 – April 4, 2019.

FLOODPLAIN VALUES

Floodplains preserve water resource values (i.e., groundwater recharge), living resources values (i.e., wildlife and plant resources), cultural resource values (i.e., open space, recreation), and cultivated resource values (i.e., agricultural).

The floodplain exists in a state of dynamic equilibrium. If one part of the floodplain is disturbed, the entire system readjusts toward a new equilibrium and may affect its floodplain values. Actions that are designed for the floodplain must be cognizant of these values and undertake efforts to preserve and protect them. Local governments administer standards and regulations related to engineering, site design, and construction. Aspects of the development, which must be reviewed and approved by the engineer and/or building official, typically include hookups to utilities, wastewater and storm water engineering, and building construction. Sanitary and water service requires county and state permit approval, as well as roadwork may require county or state approval. Permits are withheld unless the construction drawings are in conformity with the approved design.

Listing of Other Agencies Involved and Minimization of Impacts

To mitigate any negative impacts to floodplain values and in order to pursue activities within the floodplain, the City must acquire permits from other governmental agencies. For example, a Floodplain Occupation Permit is required when anything is built above ground in the floodplain from the Michigan Department of Natural Resources. Other agencies to be contacted over the course of the implementation of the actions cited above will include the U.S. Army Corps of Engineers and the Michigan Department of Public Health. In this

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manner, the actions will conform to applicable state and local floodplain protection standards.

Permits applicable to the protection of the floodplain values in the City of Dearborn Heights include the following:

SOIL EROSION AND SEDIMENTATION Resource Affected: All surface CONTROL ACT (Act 347, P.A. of 1972) waters Administrative Mechanism: In most cases, permits are issued by designated county or local agencies. If a permit application involves two or more enforcing jurisdictions, a state permit is issued. Earth changes of one acre or more in size, or earth changes located within 500 feet of a lake or stream are subject to the permit requirements.

GOEMAERE-ANDERSON Resource Affected: Wetlands WETLANDS PROTECTION ACT contiguous to lakes or rivers; lakes or rivers; (Act 203, P.A. of 1979) noncontiguous wetlands greater than five acres in size, plus sites designated by the state.

Administrative Mechanism: State permit issued for activities in wetlands (local governments may also require a wetlands permit).

INLAND LAKES AND STREAMS Resource Affected: Natural and ACT (Act 346, P.A. of 1972) artificial lakes, ponds, rivers, and streams, including major drains.

Administrative Mechanism: State permit required to create, enlarge, or diminish an inland lake or stream, or to build a structure in the lake or waterway.

NATURAL RIVERS ACT Resource Affected: Rivers, (ACT 231, P.A. of 1970) designated by the state for inclusion in the wild, scenic, and recreational river system, plus adjoining or related lands.

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Administrative Mechanism: State may administer zoning regulations in designated areas if the local government zoning does not meet requirements of the law.

DAM CONSTRUCTION ACT Resource Affected: Rivers and (Act 156, P.A. 1851) streams.

Administrative Mechanism: State permit required for the construction of dams which impound more than five acres of land or have a head of five or more feet of water. (This law applies to many retention basins.)

FLOODPLAIN REGULATORY Resource Affected: River channels, AUTHORITY UNDER ACT 245, streambeds, and floodplains with P.A. 1929 (As Amended by Act 167 contributing drainage areas of P.A. of 1968) two square miles or more.

Administrative Mechanism: Permits required to alter or occupy the river channel, stream bed, or floodplain. All developments and structures, including bridges and culverts, are subject to the requirements.

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Appendix 1 Public Notice/ Public Comments

Comments to be inserted.

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PUBLIC NOTICE PROJECTS PARTIALLY OR FULLY LOCATED WITHIN THE 100 YEAR FLOODPLAIN CITY OF DEARBORN HEIGHTS COMMUNITY AND ECONOMIC DEVELOPMENT DEPARTMENT (CEDD) COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PY 2019 PROPOSED PROJECTS FUNDS ESTIMATED ALLOCATION PROPOSED PROJECTS IN THE 100 YEAR FLOODPLAIN Proposed Total RESIDENTIAL REHABILITATION $ 205,158.00 ETON SENIOR CENTER IMPROVEMENTS $ 91,000.00 CODE ENFORCEMENT $ 100,000.00 DEMOLITION PROGRAM $ 50,000.00 TOTAL $ 446,158.00

THE CITY OF DEARBORN HEIGHTS IS NOTIFING THE PUBLIC OF ITS INTENT TO FUND THE ABOVE PROPOSED PROJECT(S) THAT MAY BE LOCATED PARTIALLY OR FULLY WITHIN THE 100 YEAR FLOODPLAIN.

USE OF FEDERAL FUNDS REQUIRE COMPLIANCE WITH FEDERAL EXECTIVE ORDER 11988,

FLOODPLAIN MANAGEMENT AND 11990, PROTECTION OF WETLANDS.

The City is interested in discussing practicable alternatives to these projects, learning public perceptions of possible adverse impacts that could result from undertaking these projects within the floodplain, identifying any possible administrative measures that can be used to reduce or eliminate any adverse effects, and promoting comments in relation to the mentioned projects.

Copies of the proposed DRAFT PY 2019 Floodplain Investigation will be available for public review at JFK Jr. Library, 24602 Van Born Rd., Dearborn Heights, MI 48125, the Caroline Kennedy Library, 24590 George, Dearborn Heights, MI 48127, the Clerks Office, 6045 Fenton, Dearborn Heights, MI 48127, and the Dearborn Heights Community and Economic Development Department on March 20, 2019. Persons with disabilities who require special accommodations should contact 313-791-3500. Advance notice is required. Written comments on all the above plans will be received through April 4, 2019 at 5:00 P.M. at the following address: City of Dearborn Heights, Community and Economic Development Department, 26155 Richardson, Dearborn Heights, Michigan, 48127 ATTN: DIRECTOR

THIS PUBLIC NOTICE REQUIRES 15 DAYS COMMENT PERIOD FROM PUBLISHED DATE

Publish: March 20, 2019 Joe A. Hachem, Director Community and Economic Development Department Appendix 2 Agency Contact and Comments

Comments to be inserted.

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Appendix 3 Issuance of Findings Statement, Public Hearing Notice

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Notice of Public Hearing Floodplain and Wetlands Protection City of Dearborn Heights, Wayne County, Michigan

The City of Dearborn Heights is considering funding, with Community Development Block Grant (CDBG) monies, for projects which may be located partially or fully within the 100-year floodplain. Use of federal funds requires compliance with federal Executive Orders 11988, Floodplain Management, and 11990, Protection of Wetlands. The subject project(s) are as follows:

Housing Rehabilitation

The purpose of this City-wide program is to provide no interest deferred loans to income eligible homeowners throughout the City for housing rehabilitation activities. The location of this project is City-wide. The City will be contributing $205,158.00 of the FY 2019 CDBG allocation to this program.

Demolition Program

The City intends to provide funding for potential clearance and demolition of dilapidated single-family structures throughout the City of Dearborn Heights. The City will contribute $50,000.00 of the FY 2019 CDBG allocation to this project.

Code Enforcement

The City will provide on-going funding assistance for staff, data collection, administration, transportation and other related code enforcement activities in the CDBG low and moderate-income areas of the City. The City will be contributing $100,000.00 of the FY 2019 CDBG allocation to this program.

Eton Senior Center Improvements

Funds will be used to make facility improvements and upgrades to the Eton Senior Center located at 4900 Pardee Avenue, Dearborn Heights, MI 48125. The City will be contributing $91,000.00 of the FY 2019 CDBG allocation to this program.

The City is interested in discussing practicable alternatives to these projects, learning public perceptions of possible adverse impacts that could result from undertaking these projects within the floodplain and identifying any possible administrative measures which can be used to reduce or eliminate any adverse effects. A Public Hearing is scheduled for Wednesday, April 10, 2019 at 7:00 PM, at the City of Dearborn Heights' City Hall Council Chambers, 6045 Fenton Avenue, Dearborn Heights, MI 48127 to secure public input on these issues.

Please attend or send written comments to Mr. Joe Hachem, Community and Economic Development Director, City of Dearborn Heights, 26155 Richardson, Dearborn Heights, Michigan 48127.

Publish: March 27, 2019 Joe Hachem, Director April 3, 2019 Community and Economic Development Department

Appendix 4 Action Plan Projects Map

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\\Dtdata\Projects\DHT6266\04D\GIS-Data\Projects\2019-2020 CDBG Eligible Updated.mxd Appendix 5 Environmental Assessment Matrix

Page 16

TABLE 1 ENVIRONMENTAL ASSESSMENT MATRIX PROJECT DESCRIPTION: Housing Rehabilitation

The purpose of this City wide program is to provide low interest loans to income eligible homeowners throughout the City for housing rehabilitation activities where the cost of rehabilitation is less than 50 percent of the current market value of the home. The City will be contributing $205,158 of the FY 2019 CDBG allocation to this program. Negative Impacts Positive Impacts Assessment Criteria Short Term Long Term Short Term Long Term Direct Indirect Negligible Direct Indirect Negligible Direct Indirect Negligible Direct Indirect Negligible NATURAL ENVIRONMENT Plant and Animal Life Terrain Features Air Water Natural Hazards Resources Temperature SOCIAL ENVIRONMENT Public Services Community Facilities Aesthetics and Urban Design Social - Psychological Historic Properties (n/a) Cultural Values Personal Safety Displacement (n/a) Man-made Hazards Noise ECONOMIC ENVIRONMENT Infrastructure Employment Consumption Opportunities Land Use Tax Base Energy Resources LEGAL ENVIRONMENT Deeds, Leases, Permits Intergovernmental Review Conformance with Local Plans and Codes

*Analysis by Wade-Trim, March 2019 Table 1. TABLE 2 ENVIRONMENTAL ASSESSMENT MATRIX PROJECT DESCRIPTION: Eton Senior Center Improvements Funds will be used to make facility improvements and upgrades to the Eton Senior Center located at 4900 Pardee Avenue, Dearborn Heights, MI 48125. The City will be contributing $91,000.00 of the FY 2019 CDBG allocation to this program. Negative Impacts Positive Impacts Assessment Criteria Short Term Long Term Short Term Long Term Direct Indirect Negligible Direct Indirect Negligible Direct Indirect Negligible Direct Indirect Negligible NATURAL ENVIRONMENT Plant and Animal Life Terrain Features Air Water Natural Hazards Resources Temperature SOCIAL ENVIRONMENT Public Services Community Facilities Aesthetics and Urban Design Social - Psychological Historic Properties (n/a) Cultural Values Personal Safety Displacement (n/a) Man-made Hazards Noise ECONOMIC ENVIRONMENT Infrastructure Employment Consumption Opportunities Land Use Tax Base Energy Resources LEGAL ENVIRONMENT Deeds, Leases, Permits Intergovernmental Review Conformance with Local Plans and Codes

*Analysis by Wade-Trim, March 2019 Table 2. TABLE 3 ENVIRONMENTAL ASSESSMENT MATRIX PROJECT DESCRIPTION: Demolition Program The purpose of this City wide program is to acquire, demolish, and disposition of dilapidated and vacant single family homes within the City of Dearborn Heights. The City will be contributing $50,000 of the FY 2019 CDBG allocation to this program. The location of this project is City-wide. Negative Impacts Positive Impacts Assessment Criteria Short Term Long Term Short Term Long Term Direct Indirect Negligible Direct Indirect Negligible Direct Indirect Negligible Direct Indirect Negligible NATURAL ENVIRONMENT Plant and Animal Life Terrain Features Air Water Natural Hazards Resources Temperature SOCIAL ENVIRONMENT Public Services Community Facilities Aesthetics and Urban Design Social - Psychological Historic Properties (n/a) Cultural Values Personal Safety Displacement (n/a) Man-made Hazards Noise ECONOMIC ENVIRONMENT Infrastructure Employment Consumption Opportunities Land Use Tax Base Energy Resources LEGAL ENVIRONMENT Deeds, Leases, Permits Intergovernmental Review Conformance with Local Plans and Codes

*Analysis by Wade-Trim, March 2019 Table 1.