HEB Renovation 1 of 3 

November 9, 2023 

MEMORANDUM FOR THE RECORD 

From: Mark Liau 

NEPA Coordinator 

National Institute of Standards and Technology 

Subject: Categorical Exclusion 

Project: Health Education Building Renovation 

Location: University of Toledo 

3000 Arlington Avenue Mail Stop 1020, 

Toledo, OH 43614-2595 

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) has 

selected the project: University of Toledo Health Education Building Renovation for a federal 

funding grant. Consequently, NEPA and the associated implementing regulations apply to this 

project. 

 

This memorandum summarizes NIST’s environmental review of this project and the 

determination that the University of Toledo Health Education Building Renovation is 

categorically excluded from further environmental review under NEPA. 

Description of the Action 

The Health Education Building (HEB) was originally built in 1975 and is a four-story building 

that serves multiple purposes for the University of Toledo and the College of Medical and Life 

Sciences. 

In the HEB basement, biosafety level 3 (BSL3) and animal BSL3 (A-BSL3) laboratories are in 

place to work with highly-infectious and dangerous pathogens. The University of Toledo 

BSL3/A-BSL3 laboratories have been continuously certified by the U.S. Centers for Disease 

Control and Prevention since 1999. 
HEB Renovation 2 of 3 

Two major limitations exist for the BSL3/A-BSL3 laboratories. (1) The current BSL3/A-BSL3 is 

too small (1,099 ft2) to accommodate additional research projects, and (2) the existing spaces 

require renovation to be more efficient, provide additional housing and procedure 

rooms, and create isolated rooms for specialized research needs. 

The renovation of the HEB will include the following: 

Expand and renovate the existing BSL3/A-BSL3 facilities, create 3 new biocontainment suites, 

new shared entry/exit space, and shared equipment spaces. These 3 new suites will be used to 

study diseases like plague, anthrax, and tularemia. 

Remodel 21 existing rooms, unused/redundant hallways, and underutilized spaces (14,350 ft2

gross renovation; 11,308 ft2 room renovations) into new multi-purpose rooms for either animal 

procedures and/or animal housing, including the creation of a new isolation suite that could be 

used for germ-free/microbiome studies. 

All renovation work at the HEB will be to the interior of the building; no work will be conducted 

on the exterior of the building or surrounding grounds of the building. 

Specific Considerations of this Action and any Extraordinary Circumstances 

Air Emissions, Stormwater, Wastewater, Critical Habitats 

Since all renovation are to the interior of the building, no significant impacts to air, water 

resources or critical habitats are expected. 

Building Staffing/Utilities

Staffing at the HEB is not expected to increase significantly. Water consumption and 

electricity use are not expected to change significantly over current building use. 

Greenhouse Gas Emissions 

Building renovations are expected to improve the energy efficiency and reduce greenhouse 

gas emissions resulting from the building. 

Flooding Potential and Resilience 

Since all renovations are to the interior of the building, there will be no impact to the 

flooding potential or flood resilience of this building. 

Hazardous Materials 

Any hazardous materials (i.e., asbestos, lead based paint, polychlorinated biphenyls) that may 

be disturbed in the building renovations will be handled and disposed in accordance with 

State and Federal regulations. 

Environmental Justice 

This renovation project is not anticipated to have any disproportional adverse human health 

or environmental impacts to overburdened and underserved communities, including minority, 

Tribal, or low-income populations. 
HEB Renovation 3 of 3 

Historic/Cultural Significance 

The renovation tasks planned are not considered to have any historic or cultural impacts on 

the project site or vicinity. 

Effects of the Action 

No significant adverse impacts on the environment are expected from this action. 

Categorical Exclusion 

The activities associated with this project fall within the criteria of the following Department of 

Commerce Categorical Exclusion: 

A–1 Minor renovations and additions to buildings, roads, airfields, grounds, equipment, and 

other facilities that do not result in a change in the functional use of the real property (e.g. 

realigning interior spaces of an existing building, adding a small storage shed to an existing 

building, retrofitting for energy conservation, or installing a small antenna on an already 

existing antenna tower that does not cause the total height to exceed 200 feet and where the 

FCC would not require an environmental assessment or environmental impact statement for 

the installation). This CE does not apply in instances where the project must be submitted to 

the National Capital Planning Commission (NCPC) for review and NCPC determines that it 

does not have an applicable Categorical Exclusion. 

Since this grant will only fund the interior renovation of the existing University of Toledo Health 

Education Building, with no change in the functional use of the building, and the project does not 

require review by the NCPC, the project meets the criteria specified in categorical exclusion A-1. 

The proposed project, University of Toledo Health Education Building Renovation is 

categorically excluded from the need for further environmental review under NEPA. Any 

changes to the above project will require additional NEPA review. 

_________________________________ ______________________ 

Mark Liau Date 

NIST NEPA Coordinator 

_________________________________ ______________________ 

R.C. Vaughn Date 

NIST Chief Facilities Management Officer 
Attachment 1 

Letter from the Ohio State Historic Preservation Officer 
In reply, refer to

2023-LUC-59306

November 3, 2023

Phillip W. Neuberg

Architect & Federal Preservation Officer

100 Bureau Drive, MS 190

Gaithersburg, MD 202899

phillip.neuberg@nist.gov

RE: University of Toledo Health Science Campus (HSC), Health Education Building (HEB)

3100 Transverse Drive, Toledo, OH 43614

Dear Mr. Neuberg:

This letter is in response to correspondence received on October 5, 2023. The comments of Ohio’s State Historic 

Preservation Office (SHPO) are made pursuant to Section 106 of the National Historic Preservation Act of 1966, 

as amended, and the associated regulations at 36 CFR Part 800. 

Although the subject building has not yet met the 50 year minimum for inclusion in the National Register of 

Historic Places (NRHP), the University of Toledo HSC Health Education Building (HEB) is considered 

potentially eligible for listing in the NRHP under Criterion C for its architectural style. Proposed work includes 

interior renovations and rehabilitation of the basement level vivaria and animal care laboratories. There is no 

proposed exterior work.

Therefore, it is the opinion of the SHPO that the planned work, if completed as proposed, will have No Adverse 

Effect on historic properties. No further coordination with this office is necessary, unless there is a change in the 

proposed project. 

If you have any questions, please contact Kristen Koehlinger at kkoehlinger@ohiohistory.org or (614) 298-

2000. Thank you for your cooperation.

Sincerely,

Krista Horrocks (for Kristen Koehlinger)

Interim Department Head and Deputy State Historic Preservation Officer

Resource Protection & Review

“Please be advised that this is a Section 106 decision. This review decision may not extend to other SHPO programs.”

RPR Serial No: 1100120