Appendix A Stakeholder Correspondence Mr. Joshi Page2 Please be sure to include the SHPO ProjectNumber (061-SLC-11) on all future correspondencerelating to this project. If the information is provided via telephone call, please followup in writing forour files. Sincerely, STATE HISTORIC PRESERVATION OFFICE Toni M. Prawl, PhD Director and Deputy State Histo1ic Preservation Officer t- r �v- "',; r.'t.fo"�1-e, " < 0 <· r f-; }l!J ., Das_zo..,,_ TMP:ab c: Mr. Doug Pulak, VA DEPARTMENT OF THE ARMY U.S. ARMY CORPS OF ENGINEERS, ST. LOUIS DISTRICT 1222 SPRUCE STREET ST. LOUIS, MISSOURI 63103-2833 REPLY TO ATTENTION OF: September 4, 2019 Regulatory Branch File Number: MVS-2012-496 Mr. Chanda Joshi VA Project Manager Department of Veterans Affairs Office of Construction & Facilities Management 1425 Tri-State Parkway, Suite 140 Gurnee, Illinois, 60031 Dear Mr. Joshi: We have reviewed your submittal in regard to the proposed expansion and renovation of the existing St. Louis VA Medical Center – John Cochran Division. The VA is considering two alternatives for the new project. The preferred Alternative A includes land acquisition south of the VMAC campus between Enright Avenue and Delmar Boulevard. Alternative B does not include land acquisition. The project is located in an existing commercially developed area, in Section 11, Township 2, Range 10 West of the Fifth Principal Meridian, St. Louis County, Missouri. Based upon our review of the U.S. Geological Survey 7.5-minute topographical map, the National Wetland Inventory maps, USDA’s Web Soil Survey, aerial photos and the submitted project plans; we have determined that the project will not impact streams or wetlands. Since the project will not be completed within waters of the U.S., a Department of the Army permit is not required for the proposed work. If work may infringe on areas believed to be within jurisdictional waters, you are instructed to contact the Corps of Engineers Regulatory Branch for guidance. This determination is applicable only to the permit program administered by the Corps of Engineers Regulatory Branch. It does not eliminate the need to obtain other federal, state or local approvals before beginning work. You are reminded that although your proposal does not need a Section 404 permit, based on your submitted plans, any revisions to your proposal may be subject to Section 404 and require subsequent authorization from this office. If you have any questions, please contact Katie Steinmetz at (314) 331-8593. Please refer to file number MVS-2012-496. The St. Louis District Regulatory Branch is committed to providing quality and timely service to our customers. In an effort to improve customer service, please take a moment to go to our Customer Service Survey found on our web site at http://corpsmapu.usace.army.mil/cm_apex/f?p=regulatory_survey 2 Sincerely, Katie Steinmetz Project Manager Regulatory Branch From: Tilley, Amber <[email protected]> Date: Thursday, Aug 22, 2019, 4:30 PM To: Joshi, Chanda P. (CFM) <[email protected]> Subject: [EXTERNAL] EPA Scoping Comments for Proposed Seismic Upgrade & Expansion for the St. Louis VA Medical Center- John Cochran Division Good afternoon Mr. Joshi, I hope your day is going well. We have received from your office a correspondence regarding a Proposed Seismic Upgrade and Expansion of the St. Louis VA Medical Center-John Cochran Division in St. Louis, Missouri. We appreciate your coordination with our office and the early notification regarding the intent to prepare NEPA compliance documentation for the proposed project. We performed a cursory desktop review of the project area using NEPAssist (https://nepassisttool.epa.gov/nepassist/nepamap.aspx) and have identified the following environmental conditions: • NEPAssist shows that the project location is within an 8-hour non-attainment area for Ozone • Project location is in proximity to one or more Toxic Release Inventory (TRI) site, RCRA facility and air emission facility o The John Cochran VAMC itself is listed as a RCRA & Air Emissions facility • Project location is in proximity to a building listed or eligible for listing on the National Register of Historic Places; we recommend coordinating with the Missouri State Historic Preservation Office • EPA’s EJ Screen tool (https://ejscreen.epa.gov/mapper) shows that the project area may be located within an Environmental Justice area for both low-income and minority populations. The NEPA Committee of the Interagency Working Group (IWG) on Environmental Justice released the Promising Practices for EJ Methodologies in NEPA Reviews report. The report contains a compilation of methodologies used across the federal government for EJ analyses in the NEPA process. While use of the report is not compulsory, we recommend it be considered in conjunction with CEQ and the VA’s guidance on EJ, as appropriate. The report can be accessed here. EPA recommends lead agencies developing NEPA documentation consult the report in development of their EJ strategy and analysis. We also recommend that any specific methodologies referenced in the report should be appropriately cited in the forthcoming NEPA document. • Additionally, based on current EPA policy and guidance, an analysis of impacts to children from construction and operation of the proposed project facilities should be included in a NEPA analysis if there is a possibility of disproportionate impact on children related to the proposed action. EPA views childhood as a sequence of lifestages. Therefore, exposures to children at each life stage, as well as pregnant and nursing women, are relevant and should be considered when addressing health and safety risks for children. Because children can be more susceptible to noise levels, mobile source air pollution, construction dust, and the chemicals associated with building and construction materials, we recommend that the NEPA analysis specifically address the potential direct, indirect, and cumulative impacts of the proposed project on children's health, including consideration of prenatal exposures (exposures that may be experienced by pregnant women). Please contact LaTonya Sanders, EPA Region 7’s Children’s Environmental Health Coordinator, at 913-551-7555 with any questions regarding the consideration of Children’s Health issues. Again, we thank you for the notification and opportunity to provide early feedback on this project. We request that the Region 7 NEPA Program be added to the notification list for any future updates to the project as it progresses, as well as the opportunity to review the draft environmental document. I would be glad to discuss with you any questions or concerns you may have, and if I can be of further assistance as the scoping process commences, please feel free to contact me. Thank you, and have a great afternoon. Amber Tilley NEPA Project Manager-Office of Intergovernmental Affairs-Office of the Regional Administrator P: 913-551-7565 [email protected] - www.epa.gov 11201 Renner Blvd, Lenexa, KS 66219 The environment is where we all meet; where all have a mutual interest; it is the one thing all of us share. – Lady Bird Johnson Appendix B Tribal Consultation DEPARTMENT OF VETERANS AFFAIRS VA St. Louis Health Care System John Cochran Division 915 N. Grand Boulevard St. Louis, MO 63106 September 11, 2019 Quapaw Tribe of Indians Everett Bandy, Tribal Historic Preservation Officer PO Box 765 Quapaw, OK 74363-0765 RE: National Historic Preservation Act Section 106 Consultation: Redevelopment of the John Cochran Division, VA St Louis Health Care System, 915 N Grand Blvd, City of St Louis, Missouri, 63106 Dear Mr. Bandy, The John Cochran Division of the US Department of Veterans Affairs St Louis Heath Care System (JCSLVA) has initiated consultation for redevelopment of its campus at 915 N Blvd in downtown St Louis, pursuant to Section 106 of the National Historic Preservation Act (54 USC 306108). JCSL VA invites the Quapaw Tribe of Indians to participate in this review process. Undertaking JCSL VA has established the undertaking as the proposed reconfiguration of its facility which will relocate in-patient care away from the existing main hospital into a new, up-to-13-story bed tower meeting current seismic-resistance requirements, expand the campus through acquisition of adjacent parcels, demolish multiple buildings, and construct parking garages, utility plant, dedicated clinic buildings, utility substation, water storage system, and associated infrastructure in order to correct current space and functional deficiencies. Enlarging the campus may also require permanent closure of some streets, including the portion of Bell Road between North Grand Boulevard and North Spring Avenue. Coordination with Environmental Review JCSLVA is analyzing environmental impacts for the proposed project in compliance with the National Environmental Policy Act (NEPA) by updating its February 2014 Environmental Assessment (EA), which analyzed three possible parcel acquisition alternatives for the expansion to help identify optimal campus layouts. The EA will address impacts to cultural resources. There will be a 30-day public comment period on the draftEA when it is published. Area of Potential Effect JCSL VA has determined the Area of Potential Effects (APE) as the property surrounding the site of the proposed reconfiguration, taking into account possible direct and indirect alterations in character or use of historic properties (see Attachment 1). DEPARTMENT OF VETERANS AFFAIRS VA St. Louis Health Care System John Cochran Division 915 N. Grand Boulevard St. Louis, MO 63106 September 11, 2019 Apache Tribe of Oklahoma Bobby Komardly, Chairman P.O. Box 1330 Anadarko, OK 73005 RE: National Historic Preservation Act Section 106 Consultation: Redevelopment of the John Cochran Division, VA St Louis Health Care System, 915 N Grand Blvd, City of St Louis, Missouri, 63106 Dear Chairman Komardly, The John Cochran Division of the US Department of Veterans Affairs St Louis Heath Care System (JCSLVA) has initiated consultation for redevelopment of its campus at 915 N Blvd in downtown St Louis, pursuant to Section 106 of the National Historic Preservation Act (54 USC 306108).