Environmental Narrative Requirements

The National Environmental Policy Act (NEPA) requires Federal agencies to assess the potential 

environmental impacts associated with proposed federal actions, including financial assistance. 

Applicants are encouraged to contact their designated Economic Development Representative or the 

applicable EDA Regional Environmental Officer with questions (please see the EDA website or the 

applicable Federal Funding Opportunity for contact information) regarding this template and/or the 

appropriate level of documentation. Resources of available information are listed in many of the 

sections. If you are using a locally saved copy of this template, please check EDA’s website to confirm 

this is the current version.

For further information regarding EDA’s obligations under NEPA, please refer to the regulations for 

implementing NEPA at 40 C.F.R. 1500-1508. The Council on Environmental Quality’s 2007 guidance 

document “A Citizen’s Guide to the NEPA is another resource available online. 

Several issues discussed in the environmental narrative below may require consultation with other State 

or Federal agencies at a later date (for example, the State Historic Preservation Office or the U.S. Fish 

and Wildlife Service). While EDA does not require that applicants complete such consultations before 

submitting an initial application, applicants should be aware that in the event their project is selected for 

further evaluation for funding, EDA may delegate these consultations to the applicant and expect them 

to be completed in an expeditious manner and prior to approval of an award. 

Applicants must provide information on the following items in the environmental narrative. For 

any area in which the applicant asserts that an item is not applicable to a project, provide an 

explanation.

A. PROJECT DESCRIPTION

1. Beneficiaries

Identify any existing businesses or major developments that will benefit from the proposed 

project, and those that will expand or locate in the area because of the project.

Beneficiaries will include 3 businesses that have already shown interest in locating into 

the incubator: Slippery Soap, Mazios Fine Vinegars, and Golden Nugget Honey. It is 

anticipated that during the first five years of operation that the incubator will assist 10 

businesses and create 75 jobs. Except for four fire impacted businesses that are 

temporarily housed in the space, it is anticipated that all businesses in the incubator will 

be scalable startups. 

2. Proposed Construction

As an exhibit to this Narrative, provide a topographical map of the project area and a site map 

(with legend and north arrow) displaying the project location and boundaries, existing and 

proposed project components and location of all sites and/or companies benefitting from the 

proposed project. The documents should be of sufficient clarity for adequate interpretation of 

the Applicant’s intentions.

Describe the project construction components in detailed, quantifiable terms. Describe the 

project location, proposed construction methods, and schedule. It is sufficient to simply 

reference the Preliminary Engineering Report (PER) here if a PER containing this 
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information has been submitted or will be submitted concurrently. See the mock example

below for the level of specificity expected by EDA:

The Town of Anytown is proposing to renovate an existing 45,000 sq ft building into a 

business incubator. The project is located within Township 39N, Range 10E, Section 24 

in the Town of Anytown, Gold County, California. Construction on the project will occur

over an 18-month period from Mid 2021 – to late 2022 or early 2023. Construction of this 

project would entail removing the existing roof and replacing it, upgrading all plumbing, 

electrical, and mechanical systems, adding ADA upgrades, adding internal walls and 

fixtures, resurfacing the parking lot, and installing landscaping. Total land disturbance 

will be less than1 acre.

The construction staging area would be located entirely within the parking lot. More 

details can be found in the Preliminary Engineering Report.

3. Need and Purpose

Provide a brief summary of the underlying need and purpose of the proposal for EDA funding.

This project was originally conceived as a catalyst to bring businesses back into the 

downtown area which has been in a decline for some time and as a source for new 

manufacturing businesses and job creation. This has become more important in the 

aftermath of the Zaphan Fire in 2019 which destroyed 250 commercial/industrial 

buildings and the Pandemic in 2020, which repeatedly shuttered businesses in attempts 

to control the COVID-19 virus. The need for more new businesses is now greater than 

before. 

4. Alternatives to the Proposed Project

Based in the Need and Purpose summary above, provide a detailed description of alternative 

actions that were considered during the project planning but were not selected (e.g., alternative 

locations, designs, other projects having similar benefits, and a “no project” alternative). Explain 

why this project/site was selected as the preferred alternative with respect to other choices. 

Provide detail on why other alternatives were rejected (e.g. did not meet the purpose and need of 

the project, implicated more environmental impacts than the proposed action). If the selected 

project would impact wetlands or floodplains, please provide a detailed description of alternatives 

to those proposed impacts. 

Alternatives to this project include renovating other buildings, building a new building, 

and doing nothing. There are other buildings in downtown Anytown, but none the size 

of the building chosen for this project. Multiple buildings would have to be renovated to 

achieve the same square footage, those buildings would probably not be co-located, in 

addition, the project would cost more because the buildings would have to be purchased. 

A new building could be built for this project, unfortunately the only land the Town owns 

is located near the landfill, a location not suited for this business incubator, and would do 

nothing to revitalize downtown. The no-action alternative would leave the building as is 

potentially adding to downtown blight. Some benefit would derive from having 

businesses in their temporarily, but until it is brought up to code – no businesses can be 

there long term. The Town would loose out on the job creation and start-up potential 
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this project has to offer. The Town feels this project is the best use of this building the 

best option for job creation and small business start-up support. 

B. HISTORIC/ARCHEOLOGICAL RESOURCES

Identify any known historic/archeological resources within the project site(s) or area of potential 

effect that are either listed on the National Register of Historic Places or considered to be of local 

or State significance and perhaps eligible for listing on the National Register. In many states, the 

State Historic Preservation Office (SHPO) maintains GIS databases of historic properties and 

cultural resources. Delineate an Area of Potential Effect (APE) for the project. The APE is the 

geographic area or areas within which a proposal may cause changes in the character or use of 

historic properties, which would include (but is not limited to) any new development or 

renovation by the beneficiary facilitated by the proposed EDA project. Discuss the potential 

impacts of the project on culturally significant resources and provide a determination as to 

whether there will be: no historical properties/cultural resources present; no historical 

properties/cultural resources adversely affected; or historical properties/cultural resources 

adversely impacted.

Note that the applicant is not required to contact the SHPO until directed to do so by 

EDA. If comments from the SHPO have already been received, they should be attached along 

with copies of the information provided to the SHPO. If you wish to initiate early consultation, 

please consult the website of the appropriate SHPO for instructions on required information. 

The project is in historic downtown Anytown at the corner of Main Street and Nugget 

Alley (38.728229-120.802563). The building to be renovated, although more than fifty 

years old, is not characterized as historic and is not listed on any historic register, state or 

federal, nor has there ever been any mention of listing this building. The Town means to 

maintain the building’s current façade to keep it consistent with other buildings on the 

street. 

The site itself has been disturbed for more than 150 years, with no known reference to 

historical or prehistorical significance. No EIR has ever been prepared for this site, 

however there was an EIR done when the sewer and water lines were upgraded 20 years 

ago (see attached). The Town anticipates conducting an historic records search as part 

of the SHPO process. 

There are three federally recognized tribes who are reported to have lived in the vicinity: 

the Maidu, the Konkow, and the Nisenan. The Town has a good working relationship 

with each, and recognizes that EDA will consult directly with them before and during 

this project. 

C. AFFECTED ENVIRONMENT

For the resource areas identified below, indicate potential direct and indirect impacts from 

proposed project activities and specify proposed measures to mitigate probable impacts. Direct 

impacts are caused by the action and occur at the same time and place. Indirect impacts are those 

that are caused by a proposed action, but that may occur later in time or farther removed in 

distance, relative to the primary impacts of the proposed action (40 C.F.R. Section 1508.8)

Development induced by the proposed project would be an example of an indirect impact. 
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1. Affected Area

Describe the general project area, including topography, historic land usages, unique geological 

features, and economic history. Provide site photographs if available. Identify native vegetation 

and wildlife found in the project area or its immediate vicinity. Describe the amount and type of 

vegetation in the project area and indicate the impact to vegetation if removed (e.g., 1.2 acres of 

early successional native hardwood forest). Identify any designated State and National Parks, 

National Wildlife Refuges, or National Game Preserves located on or in the vicinity of the 

proposed project activities. Identify any Wilderness Areas, as designated or proposed under the 

Wilderness Act, or wild or scenic rivers, as designated or proposed under the Wild and Scenic 

Rivers Act, that are located on or in the vicinity of the proposed project activities.

1. Direct effects 

2. Indirect effects

The project site is in the area known as downtown in the incorporate Town of Anytown, 

in Gold County, California. Anytown is located 70 miles northeast of Sacramento, in the 

foothills of the Sierra Nevada Mountains at an elevation of 2500 ft. The downtown is a 

totally built environment on the southern bank of the Nugget River. 

The population of Anytown was 53,462 as of the 2010 census. The Town’s population had 

decreased by .3% according to the American Community Survey 5-year estimate in 2018

and has probably decreased even further due to relocations from survivors of the Zathan 

Fire. The unemployment rate is estimated to be 4.5% and the poverty rate 24%.

Surrounding land uses include retail and commercial development, some of them within 

historic buildings. It is not anticipated that the work associated with the proposed 

project will adversely impact neighboring businesses or structures.

The project is to renovate an existing building in the relatively flat downtown area. No 

known unique geological features are in the vicinity of the site. No State or National 

Parks, Wildlife Refuges, or National Game Preserves Wilderness Areas, or designated 

wild or scenic rivers are located on or in the vicinity of the project site. The Nugget River 

is classified as a scenic river from 15 miles east of the site to its origins near Mt. Zulu. 

It is anticipated that there will be few direct impacts on the environment during 

construction (see discussion on Endangered Species and Hazardous and Toxic 

Substances below) or during the operation of the incubator. 

Indirect impacts, during construction and once the incubator is operational, will include 

increased foot and vehicular traffic. The later may contribute to poorer air quality in the 

area. It is hoped that this project will catalyze the revitalization of the downtown which 

will lead to more commercial activity, more businesses located in the area and the 

rehabilitation of the nearby homes. In the long run, it is anticipated that concentrating 

these activities in or near the downtown corridor will lead to improved air quality and a 

better quality of life for residents. 
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2. Coastal Zones

Indicate whether the project is located within a designated coastal zone subject to the Coastal

Zone Management Act. Information on coastal zone boundaries is available on the National 

Oceanic and Atmospheric Administration’s (NOAA) website. Identify any shorelines, beaches, 

dunes, or estuaries within or adjacent to the project site(s). Also indicate if there are any 

proposed overwater structures that could impact navigable waters.

The Project is not within a designated coastal zone. 

3. Wetlands

Identify any wetlands within or adjacent to the project site(s). If available, provide an on-site 

wetland/waters delineation performed in accordance with the 1987 (or current version) U.S.

Army Corps of Engineers Wetland Delineation Manual, as amended. Provide any 

correspondence from the U.S. Army Corps of Engineers (USACE), including any jurisdictional

determination or permit documents.

1. Provide a determination of direct and indirect effects including the amount of jurisdictional 

waters affected by type (e.g. 1.1 acres of palustrine emergent wetlands would be impacted by 

the proposed project). 

2. If any wetlands would be impacted by the project, provide an analysis of alternatives to 

wetland impact in this section or in the Alternatives to the Project section above. 

3. Describe any mitigation plans here or in Section D below. 

If wetlands, streams, or navigable waters may be impacted, it is recommended that Applicants

contact USACE concerning any jurisdictional waters resources. 

The project is in a developed area of Anytown and not within or adjacent to any wetlands. 

Refer to the National Wetlands Inventory map with the proposed project clearly marked

(Attachment A).

4. Floodplains

Please state whether the project is located within a mapped 100- or 500-year floodplain. Provide a 

FEMA floodplain map (with the map number and effective date) displaying the project location 

and boundaries, existing and proposed project components, and location of all sites and/or 

companies benefiting from the proposed project. The document should be of sufficient clarity 

for adequate interpretation of the applicant’s intentions. 

Floodplain maps can be viewed and printed from FEMA’s website. If FEMA floodplain maps 

do not exist in the project area, provide a letter from a Professional Engineer regarding the 

presence or absence of a 100-year floodplain.

i) Describe direct and indirect effects to 100-year floodplains, if any.

ii) If any 100-year floodplains would be impacted by the project, provide an analysis of 

alternatives to floodplain impact in this section or in the Alternatives to the Project section 

above.

iii) Indicate whether the Applicant’s community participates in the National Flood Insurance 

Program.

iv) Indicate if a critical action (e.g., emergency response facility, hospital, wastewater treatment 

plant) is being located within the 500-year floodplain.
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Project Site is on the boundary of the 100-year flood plain of Nugget River (Zone AE). 

Nugget River will over flow its banks during heavy rains or during spring runoff season, 

however, the waters have never reached this location. The Army Corps has erected flood 

control structure along the back of the River to contain high water levels. During 

flooding episodes roads next to the River are closed and traffic is routed down Main 

Street. This project should not impact the floodplain. 

The Town does participate in the National Flood Insurance Program. The project is not 

a critical action. Please refer to the FEMA floodplain map with the proposed project site 

clearly marked (Attachment B).

5. Climate Change

Identify any current or potential risks to the project due to climate change (e.g., flooding, 

wildfires, sea level rise, severe weather), utilizing federal resources, including the National Climate 

Assessment. Describe any steps taken in the planning and design of the project to mitigate those 

risks, including utilizing federal resources such as the U.S. Climate Resilience Toolkit. Identify any 

ways in which the project may contribute to future climate risks, such as by increasing flood risks, 

and any potential measures for mitigating those contributions. Describe any steps taken to reduce 

the project’s immediate and future carbon footprint (e.g., use of renewable building materials, 

incorporation of energy-efficient design features).

Climate change will impact Anytown primarily through changes in weather patterns. The 

changing climate is having a significant impact on Anystate, with the state growing 

progressively warmer, experiencing more severe wildfires, and undergoing a shift of 

seasons resulting in less snowpack and lower summer stream flows.

To mitigate this risk, the preferred action is a renovation of an existing building instead 

of new construction, reducing the carbon footprint of the project. According to the 

American Institute of Architects (AIA), renovating buildings dramatically reduces 

embodied carbon, which is the carbon emitted during new construction by the 

manufacture, transport, and assembly of materials. As a result, renovating an existing 

building reduces operational carbon to zero, lessening the contribution to climate change 

(Renovating Buildings to Protect the Climate and Rejuvenate Communities, AIA 

Blueprint for Better, website).

The proposed rehabilitation of the existing building would not contribute to greenhouse 

gas (GHG) emissions any more than other remodeling projects of similar size. Materials 

and methods would be selected to minimize greenhouse gas emissions and further lower 

the facility’s carbon footprint. 

6. Endangered Species

Provide a list of all threatened, endangered, and candidate species located in or near the project 

area, including any proposed development by the beneficiary, and the immediate vicinity. 

Identify these species’ potential or existing habitat, and critical habitat designations in the project 

area. Identify the potential for direct or indirect impacts on these species. Critical habitat 

designations list of protected species by county, and information on effect determinations are 

available on the U.S. Fish and Wildlife Service’s (FWS) website. The FWS’ web-based 

Information, Planning, and Conservation System (IPaC) may also be useful for the early planning 
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stage of a project. If an Effect Determination or Biological Assessment has been completed for 

any of the species listed, please provide. Attach any correspondence with FWS that exists related 

to their proposal. For projects with possible impacts to fisheries and marine/coastal species, 

provide any correspondence with the National Marine Fisheries Service (NMFS).

The IPaC report is attached (Attachment C) for downtown Anytown. As the area is a 

built environment there is no critical habitat for terrestrial endangered species known to 

be in the area. However, there is a pair of Great Gray Owls that have been known to nest 

in the south eave of the building. These owls and their off-spring are very special to the 

Town and it has been made clear by the citizenry that every effort will be made to 

preserve this nesting site. The Town Council has mandated that no roof construction or 

work will be done around this eave while the pair is in residence from mid-March 

through late summer. Representatives from the local chapter of the Audubon Society will 

maintain a vigilant watch on the nesting pair during this period. It is not anticipated that 

work inside the building will bother the birds, but if it does it will be postponed until the 

fall when the male and owlets move out. Consultations with US Fish and Wildlife and CA 

Fish and Wildlife will be conducted to assure compliance with all suggested mitigation 

measures. 

7. Land Use and Zoning

Describe the present formal zoning designation and current land use of the specific project site 

and adjacent land parcels. The areas include: the site of construction activities, adjacent areas, 

and areas affected by the primary beneficiaries. Land uses to be considered include, but are not

limited to, industrial, commercial, residential, agriculture, recreational, woodlands, mines/quarries, 

and open spaces. Please indicate whether the project is located entirely within a city limit.

Identify agriculture land parcels designated as “prime/unique agriculture lands” by the U.S. 

Department of Agriculture (USDA) under the Federal Farmlands Protection Act or a local 

equivalent. Additional information may be found at the USDA’s Natural Resources 

Conservation Service website.

The future use of this building is consistent with the existing zoning for this area: light 

industrial/commercial. No changes to zoning will need to be made. The site is wholly 

inside the Town’s city limits. The proposed project does not adversely impact 

prime/unique farmlands. A zoning map has been provided with the proposed project 

site clearly marked (Attachment D).

8. Solid Waste Management

Indicate the types and quantities of solid wastes to be produced by the project facilities and 

primary beneficiary. Describe local solid waste collection and disposal methods and the expected

useful life of the disposal facility. Indicate if recycling or resource recovery programs are currently 

being used or will be used in the future.

The Town’s landfill, Anytown Municipal Landfill, is a municipal solid waste landfill 

permitted to receive household waste, commercial solid waste, nonhazardous sludge, 

conditionally exempt small quantity generator waste, and industrial nonhazardous solid 

waste. The landfill is operated by contractor Recology and is estimated to have a useful 

life of 15 years. The landfill was enlarged in 2016 to provide a 20-year life expectancy, but 

debris from the Fire in 2019 consumed 3 years of that capacity. The State of California 
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has enacted a zero-waste policy and is mandating that all communities find ecologically 

friendly and positive uses for sold waste. The Town is currently exploring waste-toenergy options as well as ag-waste uses. 

It is estimated that the building renovation will generate 5 30-yard dumpsters of waste 

during construction. This waste stream will be comprised of construction and demolition 

waste. The Anytown Municipal Landfill can accept up to a 1,000 yards per day, so 

construction waste is not expected to have an adverse impact on the landfill.

Use of the building for its intended purpose is expected to generate enough waste to fill a 

20-yard dumpster on a weekly basis. On-site recycling and reuse programs will target a 

15% reduction in waste generation.

9. Hazardous or Toxic Substances

Describe any toxic, hazardous, or radioactive substances that will be utilized or produced by the 

proposed project facilities and primary beneficiaries. Describe the manner in which these 

substances will be stored, used, or disposed. Complete and sign one “Applicant Certification 

Clause” for each co-applicant (see Appendix A). Indicate if hazardous or toxic substances have 

been or must be remediated prior to construction, demolition, or renovation. If a recent Phase I 

or Phase II Environmental Site Assessment has been performed, please provide a copy of the 

executive summary (a full copy may be requested at a later date).

The existing roof of the facility leaks and is known to contain asbestos (see the provided 

Asbestos Survey, Attachment E) and during this project will need to be removed by a 

licensed contractor and replaced with new materials. This will be done following all 

applicable federal and state guidelines, with all required permits in place and under the 

guidance of the State Department of Toxic Substances, EDA and all other applicable 

regulatory boards. It is important to the Town’s leadership and residents that this 

substance is removed in the safest and least disruptive manner possible. Asbestoscontaining materials removed during renovation will be disposed in a properly permitted 

facility. The Town will keep all records pertaining to the identification, removal, and 

disposal of asbestos-containing materials.

The proposed project building has also been surveyed for lead-based paint (see report 

provided as Attachment F). No lead-based paint was found in the building.

It is not anticipated that any product developed in the incubator will utilize or be a toxic, 

hazardous or radioactive substance. 

10. Water Resources

Describe surface and underground water resources at or near the project site(s) and any impacts 

of the project to these. If groundwater will be used, is the aquifer in overdraft and /or 

adjudicated? If there will be discharges to surface water, is the receiving surface water body listed 

on the U.S. Environmental Protection Agency’s (EPA) Section 303(d) list of impaired waters? Is 

a National Pollution Discharge Elimination System (NPDES) permit required for any discharges 

to surface waters? Indicate if the proposed project is located within an area mapped by the EPA 

as sole source aquifer recharge area (maps and further information are available on EPA’s 
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website). Describe any induced changes in local surface water runoff patterns, and the status of 

storm water discharge permit processes (if applicable). 

The project site is located within 1800 feet of the Nugget River within the Nugget River 

watershed. The Clean Water Act’s Section 303(d) list identifies the Nugget River as 

impaired for nutrients, pathogens, and sediment as “medium priority” pollutants, and 

diazinon and nickel as “low priority” pollutants (see surface water quality reports, 

Attachment G). The project would not alter the Nugget River and does not discharge 

directly into it. The Town’s existing stormwater collection and conveyance facilities 

would address runoff generated within the project site. The project site is not underlain 

by a groundwater basin. No groundwater is anticipated to be used for the project. The 

project site is not located within an area mapped by the EPA as a sole source aquifer 

recharge area.

11. Water Supply and Distribution System

Indicate the source, quality, and supply capacity of local domestic and industrial/commercial 

water resources, and the amount of water that project facilities and primary beneficiaries are 

expected to utilize. Note whether the water that is being supplied is in compliance with the Safe 

Drinking Water Act, and if not, what steps are being taken to ensure compliance.

The Town of Anytown purchases surface water from the Nugget Irrigation District. The 

specific amount of water demand for the incubator has not yet been estimated as some 

value-added processing uses more water than others. However, based on similar 

facilities, it is assumed the building will use 18 gallons per square foot per day. The

project will likely result in an increase in demand for water in the downtown area, but not 

for the Town as a whole. Prior to the Zathan Fire the Town of Anytown’s Water 

Management Plan indicated that the Town’s water supply would exceed demand through 

the year 2035 under the multiple-dry year condition. Due to the loss of water customers 

the Town may to revisit its purchase agreement with NID until use can return to pre-fire 

levels, however the increased requirements from more businesses located in downtown 

will be considered. It is anticipated that the Town will have enough water supply 

capacity to meet current and future demands, including the demands of the project.

In order to ensure that tap water is safe to drink, the U.S. Environmental Protection 

Agency (U.S. EPA) and the State Water Resources Control Board (State Board) prescribe 

regulations that limit the number of certain contaminants in water provided by public 

water systems. Based on the Anytown Public Works and Utilities Annual Water Quality 

Report for Reporting Year 2019 (Attachment H), the Town’s water supply is in 

compliance with the Safe Drinking Water Act and other regulations applicable to public 

water systems.

12. Wastewater Collection and Treatment Facilities

Describe the wastewater treatment facilities available for processing the additional effluent 

including usage by the beneficiary(s). Indicate design capacities and current loading (both daily 

average and peak), and adequacy in terms of degree and type of treatment required. Describe all 

domestic class or process wastewater or other discharges associated with the project facilities and 

its primary beneficiaries, and the expected composition and quantities to be discharged either to a 

municipal system or to the local environment. Indicate all discharges that will require on-site pre-
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treatment. Note whether the wastewater treatment plant is in violation of the Clean Water Act, 

and if so, what steps are being taken to ensure compliance. If local treatment and sewer systems 

are or will be inadequate or overloaded, describe the steps being taken for necessary 

improvements and their completion dates.

The Foothills Sewage Treatment District collects and processes all wastewater from 

Anytown. The District upgraded and expanded its capacity in 2012 to accommodate 

growth until 2032. Due to the loss of customers because of the Fire, the District projects 

that it will be unable to service its debt and has petitioned the State Revolving Loan Fund 

for a reprieve from payments for 5 -10 years, to allow for time for rebuilding the District’s 

customer base, including the incubator. 

The Sewer Treatment Plant is permitted for 1 million gallons per day. It is currently at 

275,000 gallons, well below its limit. The facility is permitted and is meeting all 

regulatory obligations.

13. Environmental Justice (Executive Order 12898)

Describe whether the proposed project will result in disproportionate adverse human health or 

environmental impacts relative to minority and low-income populations. Sufficient detail should 

be provided to enable EDA to determine whether the project will comply with Executive Order 

12898.

It is not anticipated that this project will have any adverse human health or 

environmental impacts relative to minority and low-income populations. On the 

contrary, it is anticipated that this project will help revitalize the Town’s downtown by 

transforming an existing underutilized building into a small business hub, attract more 

businesses downtown, and help bring the neighborhoods in the vicinity back to life. Part 

of the Anytown’s Downtown Revitalization Plan calls for small grants to downtown 

residents to help spruce up their homes along with a five-year property tax reduction if 

current residents stay in their homes to counteract any potential displacement risks. 

14. Transportation (Streets, Traffic and Parking)

Briefly describe the local street/road system serving the project site(s) and describe any new 

traffic patterns that may arise because of the project. Indicate if land use in the vicinity, such as 

residential, hospital, school, or recreational, will be affected by these new traffic patterns.

Indicate if any existing capacities of these transportation facilities will be exceeded as a direct or 

indirect result of this project implementation, particularly in terms of car and truck traffic, and 

what the new Level of Service designation will be.

The project is located on Main Street in Anytown, the primary north/south street through 

the center of town. We anticipate increased traffic during construction and once in 

operation. This is however desirable for other businesses in our downtown core. We do 

not anticipate any new traffic patterns. The building has its own parking lot at the rear of 

the building, so we do not see that parking in the area will be negatively impacted as a 

direct result. We do not anticipate that the Level of Service designation will change. 
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Certain construction activities may require temporary lane closures. To reduce traffic 

impacts, these activities will be scheduled during lighter traffic hours or traffic will be 

rerouted through temporary detours. 

15. Air Quality

Indicate types and quantities of air emissions (including odors) to be produced by the project 

facilities and its primary beneficiaries, and any measures proposed to mitigate adverse impacts. 

Indicate the impact that the project would have on greenhouse gas emissions. Is the proposed

project site classified as a “non-attainment” area for any criteria pollutants? If so, what are those 

pollutants? Indicate any local topographical or meteorological conditions that hinder the 

dispersal of air emissions.

The Town anticipates that there will be, from time to time, pleasant and enticing odors 

emanating from the incubator as small businesses housed within are testing new 

products or making batches of existing products. It is not anticipated that the facility 

will increase greenhouse gas emissions significantly. The Town is generally an 

attainment area under the National Ambient Air Quality Standards (NAAQS), however, 

when a wildfire is burning upwind of the Town, smoke has been known to settle creating 

Unhealthy to Hazardous conditions due to particulate matter.

Temporary emissions will be generated during construction activities. These emissions 

will mainly be particulates due to use of heavy equipment and dust. It is not anticipated 

that these emissions would have a lingering adverse impact to air quality in the area. 

Best Management Practices (BMPs) will be implemented to reduce emissions and dust 

generation. 

The licensed asbestos removal contractor will provide a plan to ensure that asbestos 

fibers are not released into the air during roof removal.

16. Noise 

Will operation of project facilities or primary beneficiaries’ facilities increase local ambient noise 

levels? If yes, indicate the estimated levels of increase, and the areas and sensitive receptors (e.g., 

residences) to be affected. 

No. There should be no increase in ambient noise levels when the incubator is up and 

running. There might be increased noise levels during construction, which will be 

limited to 7am to 7 pm M-F. 

17. Permits

Identify any Federal, State, or local permits of an environmental nature needed for the project 

(e.g., USACE, US Environmental Protection Agency (EPA), Coastal Zone 

Management/Shoreline Management, Air Quality, State Environmental Policy Act, NPDES, etc.) 

and the status of any such permits. Attach copies of any such permits and all associated 

correspondence, including the permit applications.

As this is a building renovation it is not anticipated that any federal or state permits will 

be required. All local and county building permits will be applied for at appropriate time 

in the construction/inspection process. 
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The proposed project qualifies for an exemption under the California Environmental 

Quality Act (CEQA) process.

18. Public Notification/Controversy

Provide evidence of the community’s awareness of the project, such as newspaper articles or 

public notification and/or public meetings, as applicable. If a formal public hearing has been 

held, attach a copy of the minutes. Fully describe any public controversy or objections which 

have been made concerning this proposed project and discuss steps taken to resolve such 

objections.

This project has been vetted and approved by the Town Council. Two Public Hearings 

were conducted, one as an amendment to the General Plan and one just for this project in 

regard to the owls. Attached (Attachment H) are copies of all those minutes as well as 

the Council resolution in support of the incubator and the negotiated measures to protect 

the owls. 

19. Direct, Indirect, and Cumulative Effects

Please list projects (public and private, whether or not directly related to the proposed project 

described above) that have occurred or will occur in the past, present, and future in and around 

the project area that could result in significant cumulative impacts when considered in aggregate 

with the proposed EDA project. Cumulative impacts result from the incremental impacts of a 

proposed action when added to other past, present and reasonably foreseeable future actions (40 

C.F.R. Section 1508.7). In other words, cumulative impacts can result from individually minor but 

collectively significant impacts. Based on the direct and indirect impacts identified in Sections 

C1-18, identify which resources, ecosystems, and human communities are affected; and which 

effects on these resources are important from a cumulative effects’ perspective.

This project is part of an overall downtown revitalization project that will find new uses 

for empty and abandon buildings, and in doing so increase the number of people 

traveling to the downtown corridor that runs parallel to the Nugget River from the 

highway off ramp on 5th Street to the north, south to Prospect Lane. It is anticipated that 

as abandoned buildings find new uses, even more businesses will want to locate in this 

corridor and that homes in the vicinity will be rehabbed for sale or new tenants. The 

cumulative impacts from all of this activity will include: less over all air pollution as 

people will be making shorter trips in their cars overall and with fewer trips to the 

outskirts of town; buildings will be reused instead of allowed to deteriorate to the point 

they have to be torn down and the debris sent to the landfill; the population of vermin and 

other disease laden pests will be diminished; the Town will become more economically

resilient with new businesses and more jobs. More importantly, this project will help 

Anytown start building its employment base back. This project will begin to replace jobs 

and livelihoods lost in the Fire. 

D. MITIGATION

Describe methods to be employed to reduce impacts to any and all adverse impacts identified in 

Section C. List all mitigation measures that would be implemented to minimize impacts to 

environmental resources from project implementation.
 EDA Environmental Narrative Requirements

13

Mitigation measures to be deployed will include:

• the work arounds that will be implemented for the Great Grey Owl in residence at 

the site described above,

• the containment measures to be implemented during the removal of the asbestos 

on the roof, 

• Best Management Practices to manage noise and traffic during construction 

activities

E. LIST OF ATTACHMENTS

The following checklist is a list of required and optional attachments to the Environmental

Narrative as described in the sections above. The items listed in the optional section may be 

required by EDA at a later date to complete the project review and selection process, so it is 

recommended that you provide them now if they are currently available. While the documents 

listed below are the most frequently required for scoping determinations, EDA reserves the right 

to request additional items that are not listed below when necessary.

Applicants are not required to contact other governmental agencies for environmental or 

historical resources consultation until directed by EDA, though any interagency coordination

letters that may be currently available should be provided. EDA expects that all Applicants 

whose projects are selected for further evaluation will proceed with consultations in an 

expeditious manner. As such, Applicants should have the required information prepared 

for submission immediately upon notification of selection by EDA. If you determine prior 

to application that your project may affect environmental or historical resources, you may contact 

the appropriate Regional Environmental Officer to determine if early interagency consultation is 

appropriate.

Please refer to the applicable Federal Funding Opportunity for unique requirements for each 

individual grant competition and a list of documents required for submittal with the application.

Checklist of Optional Environmental Documents that should be submitted with Application if 

available (will expedite review and selection process):

oSHPO/THPO and Tribal leader comments and copy of submittals (see Section B)

oSite photographs (see Section C1)

oCoastal Zone consistency determination (see C2)

o Wetland delineation and/or Jurisdictional Determination (see C3)

oPreliminary wetland info (see C3)

o U.S. Army Corps of Engineers comments, Section 404 Permit, Section 10 Permit, and/or 

Water Quality Certification (401 approval) (see C3)

oBiological Assessment and/or survey for federally protected species (see C5)

oCorrespondence with US Fish and Wildlife Service and/or National Marine Fisheries 

Service (see C5)

oNatural Resources Conservation Service determination of Prime Farmland, Form AD-1006, 

if applicable (see C6)

oPhase I and II Environmental Site Assessment (seeC8)

oSole Source Aquifer review by US Environmental Protection Agency, if applicable (see C9)

oOther federal, state and local environmental permits (see C16)
 EDA Environmental Narrative Requirements

14

o Copies of public notices, public hearing minutes, etc. (see C17)
EDA Environmental Narrative Requirements

Appendix A: Applicant Certification Clause

15

The applicant represents and certifies that it has used due diligence to determine that the description of 

the project site described herein is accurate with respect to the presence or absence of contamination 

from toxic and hazardous substances. The term “site” includes the entire scope of the project, including 

future phases of the project and all areas where construction will occur.

1. Is the site currently, or has it in the past 50 years, been used for any of the following operations 

or activities:

a. Generation of hazardous substances or waste?

______ Yes ___X___ No 

b. Treatment, storage (temporary or permanent), or disposal of solid or hazardous substances or 

waste?

______ Yes __X____ No 

c. Storage of petroleum products?

______ Yes ___X___ No 

d. Used/waste oil storage or reclamation units?

______ Yes ___X___ No 

e. Research or testing laboratory?

______ Yes ____X__ No 

f. Ordinance research, testing, production, use, or storage?

______ Yes ___X___ No 

g. Chemical manufacturing or storage?

______ Yes ___X___ No 

h. Weapons or ammunition training, use, or testing?

______ Yes ___X___ No 

i. Iron works/foundry?

______ Yes ___X___ No 

j. Railroad yard?

______ Yes ___X___ No 

k. Industrial or manufacturing operation?

______ Yes ___X___ No

If any of the above operations ever occurred at the site, and if appropriate cleanup or other mitigation 

actions were performed in accordance with the local, State, and federal laws, please attach 

documentation of these actions.

2. Do wells draw from an underlying aquifer to provide the local domestic water supply?
EDA Environmental Narrative Requirements

Appendix A: Applicant Certification Clause

16

______ Yes ____X__ No

3. Has a federal, State, or local regulatory authority ever conducted an environmental assessment, 

environmental impact statement, or a preliminary assessment/site inspection, or similar 

environmental surveyor inspection report at the site? If yes, please list here and attach copies of 

these reports or results.

___X___ Yes ______ No

1) Building inspection report from 2012 

__________________________________________________________________________

2) EIR for the sewer upgrades done in 1999 

__________________________________________________________________

3) 

_______________________________________________________________________________

4) 

_______________________________________________________________________________

5) 

_______________________________________________________________________________

4. Have any environmental or OSHA citations or notices of violation been issued to a facility at the 

site? If yes, please attach copies.

______ Yes ___X___ No

5. Have any unauthorized releases of hazardous substances occurred at any facility at the site which 

resulted in notification of the EPA’s National Response Center?

______ Yes ___X___ No

6. Is any material containing asbestos or lead paint located at the site? If yes, please attach 

information concerning State and federal regulatory compliance.

___X___ Yes ______ No

7. Is there any equipment (electrical transformers, etc.) containing polychlorinated biphenyls (PCB) 

on the site? If yes, please attach a description of the equipment.

______ Yes __X____ No

8. Are there underground or above ground storage tanks on the site? If yes, please attach a detailed 

description, including the number of underground storage tanks on the site, whether the tanks 

have been inspected (or removed) and the results of such inspections.

______ Yes ___X___ No

9. Has the site been tested for radon? If yes, please attach results.

___X___ Yes ______ No

10. Have there been, or are there now any environmental investigations by federal, State or local 

government agencies that could affect the site in question? If yes, please attach available 

information. 

______ Yes ___X___ No
EDA Environmental Narrative Requirements

Appendix A: Applicant Certification Clause

17

The applicant acknowledges that this certification regarding hazardous substances and/or waste is a 

material representation of fact upon which EDA relies when making and executing an award. EDA 

reserves the right to terminate any award made in conjunction with the representations contained 

herein if, at any time during the useful life of the project, EDA becomes aware of the presence of 

hazardous materials or waste at the site, or that hazardous materials or waste have been 

inappropriately handled thereon.

Further, if it is determined at any time that the presence of hazardous materials or waste, or handling 

thereof, has been misrepresented, EDA may pursue other available legal remedies against the 

applicant.

_____Town of Anytown______________________________________________________________

Applicant’s Name

_____John R. Smith, Town Manager ____________________________________________________

Name and Title of Applicant’s Authorized Representative

__________________________________________________________________________________

Signature of Applicant’s Authorized Representative Date