Frederick P. Whiddon College of Medicine Building, Page 1 of 5

January 30, 2024

MEMORANDUM FOR THE RECORD

From: Mark Liau

NEPA Coordinator

National Institute of Standards and Technology

Subject: Finding of No Significant Impact

Project: Frederick P. Whiddon College of Medicine Building

Location: University of South Alabama

55 University Blvd. Mobile, Alabama

The National Environmental Policy Act (NEPA) and associated implementing regulations (40 

CFR Parts 1500-1508) require that all major federal actions be reviewed with respect to their

environmental consequences. The National Institute of Standards and Technology (NIST) is 

providing a congressionally directed funding grant (FY 2022 Consolidated Appropriations Act, 

P.L. 117-103) for the Frederick P. Whiddon College of Medicine Building. Consequently, 

NEPA and the associated implementing regulations apply to this project. 

An Environmental Assessment (EA) was prepared by the grant recipient for this project and 

provided for public review. The EA is incorporated by reference. This memorandum 

summarizes the impacts identified and the mitigation proposed in the EA, and documents a 

finding of no significant environmental impact (FONSI) for the Frederick P. Whiddon College of 

Medicine Building project.

Description of the Action

This project includes the construction and operation of the Frederick P. Whiddon College of 

Medicine Building on the campus of the University of South Alabama (USA). 
Frederick P. Whiddon College of Medicine Building, Page 2 of 5

The proposed site is 3.7-acres on the USA Campus where the Alpha Hall East and Alpha Hall 

South buildings are located. This site was selected due to its location within the vicinity of the 

existing Medical College buildings. The Alpha Hall East and Alpha Hall South buildings will be 

removed for the new medical school building. Two of the Alpha Hall Complex buildings, Alpha 

Hall North and Alpha Hall West, will remain.

The overall goal of this project is to provide a contemporary academic building to house the 

College of Medicine's research and education programs. Specifically, objectives of the new 

construction are to: 

 Bring research and education together in one building, where collision spaces are 

designed to encourage collaboration between students, faculty, and researchers. 

 Provide state-of-the-art laboratory and laboratory support spaces that provide flexibility 

and efficiency for research today and in the future, expand research capacity and improve 

recruitment and retention for researchers. 

 Expand capacity for students and provide state-of-the-art education spaces for medical 

and doctoral education, improving student recruitment and retention. 

 Provide a multi-purpose contemporary conference space and forum to serve the entire 

USA community as a premier space on campus for large gatherings.

After a review of alternatives that would enable the school to meet growing accreditation 

demands and to accommodate future growth in the educational and research activities of the 

school, USA proposed to construct a new medical education building in the footprint of the aging 

Alpha Hall Complex. A new medical education building would provide MD trainees with a 

contemporary learning environment suited to support not only didactic learning, but small group 

and clinical skills learning as well. The new building will improve the University’s ability to 

recruit and retain basic science faculty who will help grow the College's extramural funding 

portfolio. This project will also allow expansion of the University’s research faculty and will 

support additional research training for doctoral students, medical students, and research fellows.

Summary of Impacts and Mitigation

This FONSI is predicated on the implementation of mitigation measures summarized below:

Aesthetics and Visual Resources

The new building will be constructed in a manner which ties into to the aesthetic of the 

remaining historic Alpha Hall North and Alpha Hall West buildings.
Frederick P. Whiddon College of Medicine Building, Page 3 of 5

Historic/Cultural Resources

The construction the new Frederick P. Whiddon College of Medicine building may have an 

adverse effect on portions of the academic campus which are potentially eligible for listing in the 

National Register of Historic Places. These impacts will be mitigated by the following 

stipulations set forth in an MOA between the Alabama Historic Preservation Officer, NIST, and 

USA, pursuant to 36 CFR Part 800 implementing Section 106 of the NHPA (16 U.S.C. Part 

470t) (attached):

 Prior to the completion of the demolition, USA will make arrangements for archival 

photographic documentation of the Alpha Hall Complex with emphasis upon the visual 

recordation of the Alpha East and Alpha South buildings on the USA campus.

 USA will make arrangements for the research and writing of a historic narrative 

regarding the early period of architectural and campus development on the grounds of the 

USA. 

 USA will create a historic interpretive weather resistant sign panel that is to be located 

within the context of the demolition area and near the remaining Alpha Hall West and 

Alpha Hall North buildings.

 If human remains are discovered at any time during the implementation of this Project, 

the university shall follow the provisions of the Native American Graves Protection and 

Repatriation Act (25 USC Section 3001) and Alabama Burial Laws (Alabama Code 34-

13-111). Construction shall be stopped and the Alabama Historical Commission and 

Consulting Tribes shall be notified.

Air Quality

Air quality impacts will primarily occur during the project construction resulting from heavy 

equipment operation and fugitive dust emissions. Air emissions resulting from construction are 

expected to be minor and will be temporary. Emissions will be minimized through the use of 

best management practices during construction.

Operation of the new building is not expected to be a significant source of criteria air pollutants. 

The new medical building will be heated and cooled via the campus central chilled water and hot 

water systems.

Greenhouse Gas Emissions

Greenhouse Gas Emissions are expected to increase due to the heating and cooling demands of 

the new Frederick P. Whiddon College of Medicine building. These emissions will be offset by 

the removal of the two aged Alpha East and Alpha South buildings. The new 
Frederick P. Whiddon College of Medicine Building, Page 4 of 5

Medical Building will be a state-of-the-art facility designed with current building and 

environmental codes, replacing the existing, aged facilities and mechanical operations from the 

1960s. Energy saving measures will include innovative HVAC systems with energy recovery 

wheels, and air economizers, and electrochromic glazing on the south façade of the building.

Biological 

During the demolition and construction of the new building it is anticipated that 74 trees 

will need to be removed, however 64 trees are planned for the new landscaping design.

Seven endangered or threatened species are found in the area of the project, however, no critical 

habitat for any of these species exists within the project site.

Noise

Noise produced by the proposed project will be solely during the construction period.

Construction is expected to last approximately 20 months. During this time, demolition of two 

buildings will occur, truck traffic will increase, grading and earth moving will be conducted and 

general construction of the new Medical Building will occur. 

Construction noise will be mitigated somewhat by the terrain, trees, and roads and buildings 

surrounding the project site. To further mitigate the construction noise, these operations shall 

only be conducted during daylight hours of 7AM to 5PM, primarily on weekdays and possibly a 

few Saturdays. The University of South Alabama will comply with City of Mobile noise 

ordnances.

Hazardous Materials

Any existing hazardous materials (i.e., asbestos, lead based paint, PCBs) found in the Alpha East 

and Alpha South buildings will be abated and properly disposed in accordance with State and 

Federal regulations prior to demolition.

Hazardous or infectious waste generated by the operation of the new building will be properly 

disposed off-site by licensed haulers/disposal facilities in accordance with State and Federal 

regulations.

Surface Water and Floodplains

No surface water or wetlands exist on the project site, and the site is not located within a 100-

year or 500-year floodplain.

This project will be required to obtain National Pollutant Discharge Elimination System 

(NPDES) permit coverage for a regulated land disturbance and associated discharges of 

stormwater runoff to State waters. The University of South Alabama has been granted a General 
Frederick P. Whiddon College of Medicine Building, Page 5 of 5

NPDES Permit through the Alabama Department of Environmental Management and 

will implement and maintain effective erosion and sediment controls in accordance with a 

Construction Best Management Practices Plan.

Conclusion

NIST hereby adopts the EA prepared by the award recipient for the Frederick P. Whiddon 

College of Medicine Building project. After reviewing the EA and the supporting materials, 

NIST finds that the EA properly documents the project’s environmental impact. NIST has 

determined, with the mitigation measures described above, that the proposed action will have no 

significant impact on the quality of the human environment. With this FONSI, an environmental 

impact statement will not be prepared. 

_________________________________ ______________________

Mark Liau Date

NIST NEPA Coordinator

_________________________________ ______________________

R.C. Vaughn Date

Chief Facilities Management Officer
Attachment A

MEMORANDUMOFAGREEMENT BETWEEN 

THE NATIONAL INSTITUTE OF STANDARDSAND TECHNOLOGY, 

THE ALABAMA STATE HISTORIC PRESERVATION OFFICER, AND 

THE UNIVERSITY OF SOUTH ALABAMA
MEMORANDUM OFAGREEMENT

BETWEEN

THE NATIONALINSTITUTE OF STANDARDS AND TECHNOLOGY, 

THE ALABAMA STATE HISTORIC PRESERVATION OFFICER, AND

THE UNIVERSITY OF SOUTH ALABAMA 

REGARDING THE DEMOLITION OFALPHAHALLS EASTAND SOUTH

551 UNIVERSITY BLVD, MOBILE, ALABAMA

WHEREAS, the University of South Alabama, Mobile, AL(USA), as part of an 

overall initiative to redevelop an existing campus and construct a new medical facility, plans 

to carryout the demolition of Alpha Hall East and Alpha Hall South(undertaking)pursuantto 

36 CFR Part 800 implementing Section 106 of the National Historic Preservation Act (54 

U.S.C. 306108); and

WHEREAS, theundertaking consistsof demolishing two three-story masonry 

combination classrooms and residentialbuildings and related site improvements using 

funds allocatedby theNational Institute of Standards and Technology (NIST) in

preparation for constructing a new academic medical facility; and

WHEREAS,the new construction will be carried out using fundsfrom (NIST); and

WHEREAS,the design ofthe proposed new academic medical facility was undertaken 

with consideration for the surrounding nearby historic portions of the campus. The design is 

intentionally sympathetic to the tone, character, feel, massing, and materials exhibited within the 

surrounding structures. The choice of location away from other buildings, use of brick and 

verticality within the windows, massing, and scale create a design that is noticeably new, while 

also blending into the character of the campus and not detracting or negatively impacting the 

surrounding structures and campus design. Drawings for the proposed new construction are 

included within this submission (Appendix B); and

WHEREAS, NIST hasdefined the undertaking's area ofpotential effect (APE)asthe 

existing Alpha Hall Complex consisting of four similar Buildings referred to as Alpha Halls, 

East, West, South and North andits setting; and

WHEREAS, NIST has determined that the undertaking may have an adverse effect on 

portions of the Alpha Complex (Halls East and South) that has been determined eligible for 

listing in the National Register of Historic Places andh a sconsultedwiththeAlabamaState 

HistoricPreservationOfficer(SHPO) pursuant to36C.F.R. 800,of the regulations implementing 

Section106 of the National Historic Preservation Act(54 U.S.C. 306108); and

NOW, THEREFORE, NIST, USA and the SHPO agree that the undertaking shall be 

implemented in accordance with the following stipulations in order to consider the effect 

of the undertaking on historic properties.
Memorandum of Agreement

Between NIST, AHC and the USA

2

STIPULATIONS

In order to mitigate the adverse effects on historic properties, USA shall ensure that the

following measures are carried out by a professional who meetstheSecretary ofthe Interior's

Professional Qualifications Standards:

I. ARCHIVAL PHOTOGRAPHIC DOCUMENTATION

A. Prior to demolition, USA will complete State-level HABS documentation of the

Alpha Hall Complex with emphasis upon the visual recordation of the Alpha East and

Alpha South on the campus of the University of South Alabama, Mobile, AL.

Photographs shall be made of the representative buildings within the complex

including views of the exterior and interior, the overall complex, itssetting, and the

landscape.

B. The photographer shall comply with the minimum level standards necessary for

document retention at SHPO pursuant to the State agreed format. A draft copy of

the photographic record will be provided to SHPO for review and acceptance.

Upon approval, final copies will be provided to SHPO and the local archives at

the University of South Alabama and will be available for public view.

II. HISTORIC NARRATIVE

USA will make arrangements for the research and writing of a historic narrative regarding

the early period of architectural and campus development on the grounds of the University

of South Alabama.

A. The history shall be written from written documents, primary sources, oral histories,

and archival photographs. The overall purpose of the document is to record the

developmental history of the first period of the construction and expansion of the

University of South Alabama.

B. A draft copy of the developmental history report will be submitted to SHPO for review

and approval. Upon approval of the draft copy by SHPO, a final copy of the report will

be submitted to SHPO in hard copy and digital format. One additional copy will be

submitted to the local archives at the University of South Alabama and will be available

for public view.

III. HISTORIC SIGNAGE

A. USA will create a historic interpretive weather resistant sign panel that is to be located
Memorandum of Agreement

Between NIST, AHC and the USA

3

within the context of the demolition area and near the remaining Alpha Hall West and 

Alpha Hall North.

B. The sign will include historical information about the early period of campus 

construction, architectural explanations of the common style on campus, images of 

Alpha Hall East and Alpha Hall South, as well as the original and changing functions of 

the buildings. The overall purpose of the sign is to educate the public on the early 

planning and architectural development of the campus and to note the previous location 

and information as related to the architecture of Alpha Hall East and Alpha Hall South.

C. A draft copy of the sign layout, text, and images will be submitted to SHPO for review 

and approval. Upon approval of the draft copy by SHPO, a final version will be 

installed within the context of the remaining Alpha Hall buildings and readily in view 

for the public.

IV. ARCHAELOGICAL ASSESSMENT

USA’s Center for Archaeological Studies completed a Phase I Cultural Resources

Survey of the potential area of impact surrounding Alpha Hall East and Alpha Hall

South on April 5, 2023. Their archeological efforts included the excavation of a total

of 11 shovel tests within the project tract in addition to a pedestrian survey. 

A. At the conclusion of the Phase I Cultural Resources Survey, it was determined that 

the efforts did not identify any significant archaeological recoveries or intact 

middens or features from the project tract. Therefore, no further archaeological 

investigation or mitigation is recommended.

B. The Phase I Cultural Resources Survey in its entirety will be filed within the

archives of the University of South Alabama and will be available for public

view.

V. INADVERTENT DISCOVERY

A. Treatment of Human Remains and Funerary Objects - If human remains are 

discovered at any time during the implementation of this Project, the university shall 

follow the provisions of the Native American Graves Protection and Repatriation Act 

(25 USC Section 3001) and Alabama Burial Laws (Alabama Code 34-13-111). If any 

human remains are encountered during the course of the investigation, the 

construction contractor shall cease all construction activities within a 30-foot area 

around the remains and notify the coroner or medical examiner, local law 

enforcement, NIST, USA, and the Alabama Historical Commission. NIST shall also 
Memorandum of Agreement

Between NIST, AHC and the USA

4

notify the Consulting Tribes and the AHC prior to resuming any ground disturbing 

activities in the area. Any exposed remains will be covered with cotton fabric and a 

thin layer of soil until an agreed upon course of action is approved. After 

consultation, the AHC may grant a state permit to relocate the human remains, as 

outlined in state code (Code of Alabama 1975 13-A-7-23.1, as amended). 

B. Post Review Discovery - Pursuant to 36 CFR 800.13(b), NIST, in consultation with 

the Alabama Historical Commission (ALSHPO), shall make a reasonable and good

faith effort to avoid or minimize any adverse effects to NRHP eligible archaeological 

sites that may be discovered after the completion of data recovery excavations. In the 

unlikely event that adverse effects to previously undiscovered NRHP-eligible 

archaeological sites cannot be avoided or minimized, NIST shall consult with 

ALSHPO to resolve these adverse effects through execution of an amendment to this 

agreement document. 

C. In the event that previously unidentified archaeological resources are discovered 

during the project construction, the construction contractor shall cease all 

construction activities immediately within a 30-foot area around the resource. USA 

shall notify NIST and the ALSHPO within 24 hours of the discovery and shall take 

appropriate steps to immediately secure and protect the site. 

VI. DURATION

This MOA will expire if its terms are not carried out within five (5) years from the date 

of its execution. Prior to such time, NIST may consult with the other signatories to 

reconsider the terms of the MOA and amend it in accordance with Stipulation VI below.

VII. MONITORING AND REPORTING 

Six months following the execution of this MOA and every six months thereafter for a 

duration of 36 months, until it expires or is terminated, NIST shall provide all parties to 

this MOA a report summarizing work undertaken pursuant to its terms, based upon field 

and progress reports provided by USA. Such report shall include any scheduling 

changes proposed, any problems encountered, and any disputes and objections received 

in NIST’s efforts on behalf of the USA to carry out the terms of this MOA.

VIII. DISPUTE RESOLUTION

Should any signatory or concurring party to this MOA object at any time to any 

actions proposed or the manner in which the terms of this MOA are implemented, NIST
Memorandum of Agreement

Between NIST, AHC and the USA

5

shall consult with such party to resolve the objection. If NIST determinesthatsuch objection 

cannot be resolved, NIST will:

A. Forward all documentation relevant to the dispute, including the NIST proposed 

resolution, to the Advisory Council on Historic Preservation (ACHP). The ACHP 

shall provide USA with its advice on the resolution of the objection within thirty (30) 

days of receiving adequate documentation. Prior to reaching a final decision on the 

dispute, NIST shall prepare a written response that takes into account any timely 

advice or comments regarding the dispute from the ACHP, signatories and concurring 

parties, and provide them with a copy of this written response. NIST will then 

proceed according to its final decision.

B. If the ACHP does not provide its advice regarding the dispute within the thirty (30) 

daytime period, NIST may make a final decision on the dispute and proceed 

accordingly. Prior to reaching such a final decision, NIST shall prepare a written 

response that takes into account any timely comments regarding the dispute from the 

signatories and concurring parties to the MOA and provide them and the ACHP with 

a copy of such written response.

C. NIST's responsibility to carry out all other actions subject to the terms of this MOA

that are not the subject of the dispute remain unchanged.

IX. ADMENDMENTS

This MOA may be amended by any of its signatories when such an amendment is agreed 

to in writing by all signatories. The amendment will be effective on the date a copy 

signed by all of the signatories is filed with the ALSHPO.

X. TERMINATION

A. If any signatory to this MOA determines that its terms will not or cannot be carried 

out, that party shall immediately consult with the other parties to attempt to develop an

amendment per Stipulation VI, above. If within thirty (30) days(or another time period 

agreed to by all signatories) an amendment cannot be reached, any signatory may 

terminate theMOA upon written notification to the othersignatories.

B. Once theMOAisterminated, and prior to work continuing on the undertaking, NIST

must either (a) execute an MOApursuant to 36CFR § 800.6 or (b) request, consider, 

and respond to the comments of the AL SHPO under 36 CFR § 800.7. NIST shall

notify the signatories asto the course of action it will pursue.

C. Execution of this MOA by NIST, USA, and SHPO and implementation of its 
Memorandum of Agreement

Between NIST, AHC and the USA

6

terms evidence that NIST has considered the effects of this undertaking on

historic properties and afforded the AL SHPO an opportunity to comment.

XI. ELECTRONIC SIGNATURE 

Each party agrees a person may execute this document by electronic symbol or process 

attached to or logically associated with the document, with an intent to sign the 

document and by a method that must include a feature to verify the identity of the signer 

and the authenticity of the document, commonly referred to as verified electronic 

signature. Each party further agrees to accept in-person signature with ink for such party 

who agrees but does not wish to or have access to adequate technology to sign 

electronically.

Final rev: 01_11_2024
MEMORANDUM OFAGREEMENT

BETWEEN THE NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY, 

THE ALABAMA STATE HISTORIC PRESERVATION OFFICER, AND

THE UNIVERSITY OF SOUTH ALABAMA REGARDING

THE DEMOLITION OFALPHAHALLS EASTAND SOUTH

551 UNIVERSITY BLVD N AND 555 UNIVERSITY BLVD N, MOBILE, ALABAMA

Signed:

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY (NIST)

____________________________________________________________________________________________

By: Phillip W. Neuberg, FAIA Date:

NIST Federal Preservation Officer

01/24/2024
8

MEMORANDUM OFAGREEMENT

BETWEEN THE NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY, 

THE ALABAMA STATE HISTORIC PRESERVATION OFFICER, AND

THE UNIVERSITY OF SOUTH ALABAMA REGARDING

THE DEMOLITION OFALPHAHALLS EASTAND SOUTH

551 UNIVERSITY BLVD N AND 555 UNIVERSITY BLVD N, MOBILE, ALABAMA

Signed:

ALABAMA STATE HISTORIC PRESERVATION OFFICER

____________________________________________________________________________________________

By: Lee Anne Hewett, Deputy SHPO Date: 

Alabama Historical Commission

January 12, 2024
MEMORANDUM OF AGREEMENT 

BETWEEN THE NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY, 

THE ALABAMA STATE HISTORIC PRESERVATION OFFICER, AND 

THE UNIVERSITY OF SOUTH ALABAMA REGARDING 

THE DEMOLITION OF ALPHA HALLS EAST AND SOUTH 

551 UNIVERSITY BLVD N AND 555 UNIVERSITY BLVD N, MOBILE, ALABAMA 

Signed: 

UNIVERSITY OF SOUTH ALABAMA 

12/20/2023 

I 

By: Trae Catrett, Contract Officer Date: 

 9
ADDENDUM

January 26, 2024 

MEMORANDUM OFAGREEMENT

BETWEEN THE NATIONAL INSTITUTE OF STANDARDSAND TECHNOLOGY, 

THE ALABAMA STATE HISTORIC PRESERVATION OFFICER, AND

THE UNIVERSITY OF SOUTH ALABAMA REGARDING

THE DEMOLITION OFALPHA HALLS EASTAND SOUTH

551 UNIVERSITY BLVD N AND 555 UNIVERSITY BLVD N, MOBILE, ALABAMA

Subsequent to the MOA public review held at the December 18, 2023 Consulting 

Parties Meeting and then subsequent to execution of MOA, 

The Choctaw Nation on contacted the NIST Federal Preservation Officer on 

January 8, 2024. 

NIST hosted a call with the Choctaw Nation on January 25, 2024 to provide an 

overall orientation to the Consultation conducted to dated. The Choctaw Nation 

THPO indicated that while they did not wish to participate as a signatory to the 

executed MOA, they would like to be directly notified in the event that any 

unidentified remains are found within the APE

Please see copy of email below.