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ENVIRONMENTAL ASSESSMENT - FORMAT II - PUBLIC FACILITIES AND IMPROVEMENTSU.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Community Development Block Grant (CDBG) Program HOME Investment Partnership (HOME) Program ENVIRONMENTAL REVIEWS AT THE COMMUNITY LEVEL ENVIRONMENTAL REVIEW RECORD FORMAT II EVIRONMENTAL ASSESSMENT PROJECT: CITY OF CLEARWATER CO1��IlVILJNITY DEVELOPMENT BLOCK GRANT PROGRAM PUBLIC FACILITIES AND IMPROVEMENTS � PROGRAM: City of Clearwater Community Development Block Grant Program PROJECT ABSTRACT Format II ENVIRONMENTAL ASSESSMENT From: October 1, 2000 Original Revision Name and Title of Certifying Officer: William B. Horne, II, Interim City Mana���•r Name of Grantee City of Clearwater �pplication/Grant Number 13-?000-OS-MC-12-0002 �I���: Septembcr 30. 2005 City of Clearwater, Florida Project Name: City of Clearwater CDBG Proni•rrnr�-I'rrblic Fnciliries ui�d Improvements Location of Physical Developments: Citywide Leading Agency: City of Clearwater, Housin�� I)i� ision P.O. Box 4748 Clearwater, FL 33758 Project Representative: Michael Holmes Address: same Project Information: same � l��l�phone: ���7) �6�-4032 Telephone: samc Address: same Project Summary Description: Fund Other CDBG (Projected) Public Facilities will include acquisition, construction, reconstruction, rehabilitation or installation of public facilities and improvement. Such facilities to include, but not be limited to, shelters for the homeless; convalescent home; hospitals; nursing homes; battered spouse abuse shelters, halfway houses for run-away children, drug offenders or parolees; group homes for mentally impaired persons; child-care facilities and other applicable public facilities that are owned and operated by non-profits. Funding will be provided from the CDBG program grant, program income and matching funds. ENVIROMENTAL ASSESSMENT PROJECT DATA Purpose of the Project: This Environmental Assessment is designed to cover all aspects of public facilities and improvements conducted by the City of Clearwater Housing Division, with the expenditure of CDBG funds and program income. Project will include acquisition, construction, reconstruction, rehabilitation or installation of public facilities and improvement. Such facilities to include, but not be limited to, shelters for the homeless; convalescent home; hospitals; nursing homes; battered spouse abuse shelters, halfway houses for run-away children, drug offenders or parolees; group homes for mentally impaired persons; child-care facilities and other applicable public facilities that are owned and operated by non-profits. STATUS OF THE PROJECT.• This project is ongoing and is currently for unspecified sites. However, all sites, as they are specified, will undergo compliance, as appropriate and proper measures will be taken. PROJECT AND AREA DESCRIPTION.• Project will include acquisition, construction, reconstruction, rehabilitation or installation of public facilities and improvement. Such facilities to include, but not be limited to, shelters for the homeless; convalescent home; hospitals; nursing homes; battered spouse abuse shelters, halfwa�� houses for run-away children, drug offenders or parolees; group homes for mentally impaired persons; child-care facilities and other applicable public facilities that are owned and operated by non-profits. All projects will be Citywide. 4 ENVIRONMENTAL ASSESSMENT PROJECT DATA EXISTING CONDITIONS AND TRENDS: In order to meet goals of making available public facilities to low and moderate income families and individuals, preserving neighborhoods providin`� locations for needed services, the City of Clearwater plans to implement its public facilities and improvements program Citywide. PROJECT AND AREA MAPS AND PLANS: Project will include acquisition, construction, recc�nstruction, rchabilitation or installation of public facilities and improvement. Such facilities t�� include, but not be limited to, shelters for the homeless; convalescent home; hospitals; nursin�� Ilomes; hattered spouse abuse shelters, halfway houses for run-away children, drug offen�l�1-s or parolres: �yroup homes for mentally impaired persons; child-care facilities and other a���licable puhlic facilities that are owned and operated by non-profits. Funding will be pro� i�i�,_I I�rom thc ('DI3G program grant and/or program income. All projects will be Citywide. E Statutory Checklist Summary of Findings Afid Conclusion: Impact/Mitigation will depend upon individual application of site screening. Summary of Environment�cl Conditions: Impact/Mitigation will depend upon individual application of site screening. Project Modifications Aird Alternatives Considered: Impact/Mitigation will depend upon individual application of site screening. Statutory Checklist Additional Stu�lies Performed (Attach Study or Summary) Impact/Mitigation will depend upon individual application of site screening. Mitigation Measures Needed: Impact/Mitigation will depend upon individual application of site screening. 7 Statutory Checklist Checklist of Applicable Statutes and Regulations Citations for the following statutes and Regulations are listed in the appendix: Noise Air Quality Historic Properties Coastal Areas Wetlands and Floodplain Farmlands Water Quality Solid Waste Disposai Man-made Hazards Fish and Wildlife Endangered Species Prepared By: Michael Holmes Reviewed By: Nina Bandoni Date: October 13, 2000 s Title: I�l�i►�a��er Title: Assistant Director Statutory Checklist Noise HUD Regulations (25CFR Part 51, Subpart B) Air Oualitv Clean Air Act of 1970 as Amended (42 U.S.C. 7401-7642) Regulation 40 CFR Part 50, and Partially 40 CFR Part 51.52.61 Historic Properties National Historic Preservation Act of 1966, Section 106 (16 U.S.C. 470-470+1 *) Preservation of Historic and Archeological Data Act of 1974 116 U.S.C. 469-(69c) Executive Order I 1593 — Protection and Enhanceme�t of the Cultural Environment * Except as provided in 24 CFR 58.17 and Section / 7(1) (1), United States Housing Act of 1937, as amended. Coastal Areas Coastal Zone Management Act of 1972 as amended (16 U.S.C.1451-1464) Coastal Barrier Resources Act of 1982 (16 U.S.C. 3501 +) Wild and Scenic River Wild and Scenic Rivers Act of 1968 as Amended (16 U.S.C. 1271 +) Checklist ofApplicable Statutes and Regulations Wetlands and Floodplain Executive Order 11990 Protection of Wetlands Executive Order 11988 Floodplain Management And U. S. Water Resources Council Guidelines Farmlands Farmland Protection Policy Act of 1981 (7 U.S.C. 4201) Water Oualitv Federal; Water Pollution Control Act, as Amended (33 U.S.C. 1251-1376) Safe Drinking Water Act of 1974 (42 U.S.C. 300f 300j-101 as Amended U.S. Environmental Protection Agency (EPA) Implementing Regulations 40 CFR Parts 240-265 Man-made Hazards IiUD Regulations (24 CFR Part 51, Subpart C and Subpart D) Fish and Wildlife Fish and Wildlife Coordination Act (16 U.S.C. 661- 666 C) EndanQered Species Endangered Species Act of 1973 as Amended (16 U.S.C.1531-1543 Environmental Assessment Summar�� of Findings And Conclusions: Impact/1�litigation will depend upon individual application of site screening. Summar�- of Environmental Conditions: Impact/Nlitigation will depend upon individual application of site screening. Project Modifications And Alternative Considered: Impact/Mitigation will depend upon individual application of site screening. 10 Environmental Assessment Additional Studies Performed (Attach Study of Summary) Impact/Mitigation will depend upon individual application of site screening. Mitigation Measures Needed: Impact/Mitigation will depend upon individual �::� �ation ot ���� �cr��ning. m Environmental Assessment Checklist Project Name and identification No.: City of Clearwater, CDBG Program, Citywide, B-00-04- MC-12-0002 1. Is project in compliance with applicable laws and regulation? _X_ YES NO 2. Is an EIS required? YES X NO 3. A Finding of No Significant Impact (FONSI) can be made. Project will not significantly affect the quality of the human environment. _X_ YES NO Prepared by: Michael Holmes Title: Housing Manager Reviewed by: Nina Bandoni Title: Assistant Director Date: October 13, 2000 12 Environmental Assessment Checklist Project Name and identification No.: City of Clearwater, CDBG B-00-04-MC-12-0002 ENVIRONMENTAL REVIEW FINDING On the basis of the environmental assessment of the above project I have made the following finding: _X_ A FINDING OF NO SIGNIFICANT IMPACT I find that this project is not a major federal action which will have a significant effect on the human environment and that a release of project funds will not require an Environment impact Statement. (Date) William B. Horne II, Interim City Manager City of Clearwater 112 South Osceola Avenue Clearwater, Florida, FL 33758 Signature, Title and Address of Certifying Off:cer A FINDING OF SIGNIFICANT IMPACT I find that this project is a major federal action which will have a significant effect on the human environment and that a request to HUD for release of project funds will require an Environmental Impact Statement. (Dale) Signature, Title and Address of CertiJying O�cer 13 CITY OF CLEARWATER HOUSING DIVISION 2000, 2001, 2002, 2003, 2004 ENVIRONMENTAL MONITORING STRATEGY FOR UN5PECIFIED SITES COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM To assure that CDBG Program Projects at sites unspecified prior to the release of funds are in compliance with the environmental laws and authorities, the following strategy will be employed: Projects must comply with environmental statues. rr`�ulation, and executive Orders other than NEPA. Proposed projects to be included in the environm�ntal monitoring strategy under the CDBG program include the following citywide activities: • Acquisition or real property; • Construction; • Reconstruction; • Rehabilitation; • Site improvements; • Installation of public facilities; • Removal of architectural barriers for accessil��;:•� .�nd mohili�� t��r th� elderly or physically impaired persons; • Demolition; HISTORIC PROPERTIES Section 106 of the National Histaric Preservati��n \ct of 1'�����. as amended, mandates the agencies with jurisdiction over Federally assisted <<cti� ities aft�,rci thc National Advisory council on Historic Preservation and the State Historic I'r�servatic�n c)(�(iccr (SHPO) a reasonable opportunity for comment on the project's impact ��n historic prc����rtics. Contact SHPO to obtain review requirements if a structure in over 50 years ��la or is acfj,���nt to ci Historic District of if a project involves soil disturbance (Archaeological � Pursuant to HUD guidance on compliance with thc ��ction 10(, r�� ie�ti �rocess (36 CFR 800), if a structure is over 50 years old, the City of Clear��atcr. Housin`� I)i��ision will need to submit to SHPO for its review, photographs of the existin`� structure an�i �i description of the proposed improvements. The SHPO must approve the proposed impro� c�i�ents as in conformance with 14 the Secretary of Interior Standard for Rehabilitation before the Housing Division can proceed with the assistance. Pending a determination of eligibility for inclusion in the National Register of determination of local historic significance, the proposed rehabilitation of structures over 50 years old must conform to the Secretary of the Interior Standards for Rehabilitation. Housing Division staff must provide a good determination of the age of all structures proposed for rehabilitation. For new developments on previously undisturbed areas, The SHPO (State Historic Preservation Officer) will be consulted on archeological resources. FLOODPLAIN MANAGEMENT Due to the limited availability of undeveloped land in the City of Clearwater, rehabilitation, reconstruction or new construction may take place in the Floodplain. Work may be allowed in a 100 — year floodplain, but all applicable federal, state and local requirements must be complied with. In that case, floodplain impacts must be assessed. An eight-step review process required by Executive Order 11988 will be performed if the project is located in a floodplain area, and is for commercial rehabilitation or residential rehabilitation or residential rehabilitation of 5 or more units in a structure. Executive Order 11988 directs Federally funded agencies to take certain steps to avoid: (a) to the extent possible the long and short term adverse impacts associated with the occupancy and modification of floodplains and (b) the direct development within or modification of floodplains, wherever there is a practical alternative. Because activities maintain the health, welfare and safety of citizens in existing floodplain areas, it has been determined that this activity within a floodplain is unavoidable. However, Housing staff will adhere to the following guidelines: • The extent of rehabilitation should not constitute a significant improvement that will affect the floodplain. • All property owners prior to receiving rehabilitation assistance must purchase floodplain insurance under the National Flood Insurance Program. The City will use the latest version of the Flood Insurance Maps issued by the Federal Emergency Management Agency to access the flood designation for the proposed activity. WETLANDS PROTECTION Executive Order 11990 requires all federal executive agencies to refrain from supporting construction in wetlands wherever there is a practical alternative. Section 10 of Executive Order 11990 authorizes that responsibilities applicable to projects covered by Section 104 (h) of the Housing and Community Development Act of 1974 may be assumed by the applicant if the applicant had also assumed all the responsibilities for environmental review. The executive Order directs the City of Clearwater government to take certain steps: 15 • To avoid to the extent possible the long and short term impacts associated with the destruction or modification of wetlands, and • To avoid direct or indirect support of new construction in wetlands wherever there is a practical alternative. If the City of Clearwater determines that there is no practical alternative to the use of wetlands for a project, the agency must act to reduce the adverse impacts on the wetlands. In this case, an eight (8) step review process required by EYecutive Order 11990 will be performed. The U.S. Water Resources Council Guidelines will be followed in areas where wetlands are suspected. COASTAL AREAS PROTECTION AND MANAGEMENT The Coastal Zone Management Act of 1972, 1976, and 1980 require that all federal grant activities, which "directly affect" the coastal zone be consistent with approved State and Coastal Zone Management Plans. Part of the City of Clearwater is within the coastal zone. Due to the City of Clearwater being highly developed some activities may be funded in the Coastal Zone. Before any action takes the City will review the flood insurance rate maps to determine if the project is located in the affected areas. If the project is located in the flood plain or, the City will comply with all requirements of the Federal Emergency Management Agency and the Eight Step Decision Making Process for activities located in the 100-year flood plain. All applicable regulations will be complied with. WATER QUALITY: SOLE SOURCE AQUIFERS It has been determined that Pinellas County is sited on an aquifer. According to Tom Miller, City of Clearwater Assistant Director of Public Works, if the Community Development Block Grant and HOME Investment Partnership Funds are not used for installing wells or any subsurface activities, the requirements of the Clean Water Act of 1977 do not apply. Source documentation: Telephone interview with Mr. Miller on October 12, 2000 at 727-562- 4749. Activities will not be reviewed for this item because no sole source aquifer has been designated in Clearwater according to Pinellas County Community Development. Pinellas County source documentation was Ron Mikulak, Groundwater Protection Branch of the Environmental Protection Agency in Atlanta on February 14, 1992. Telephone: 404/347-3866. Therefore, the requirements of the Clean Water Act of 1977 do not apply. ENDANGERED SPECIES Under the requirements of the Endangered Species Act of 1973, as amended, the City must determine whether the project/activity is likely to affect endangered or threatened species or Critical Habitats. 16 The City of Clearwater Comprehensive Plan, adopted by the City on May 18, 2000 prohibits destruction and disturbance of all conservation land uses to protect wildlife and plants especially those that are threatened or endangered species. The plan also prohibits development that will needlessly disturb or destroy native vegetation. Therefore the City will not fund any development that will not comply with the City's Comprehensive Plan. WILD AND SCENIC RIVERS There are no wild and scenic rivers in the City of Clearwater. Source data Pinellas County Community Development Department: Wallace Brittan of the National Park Service in Atlanta on February 14, 1992. Telephone: 404-331-�838. Therefore, requirements of the Wild and Scenic Rivers Act of 1969, as amended, do not apply. The City of Clearwater Comprehensive Plan also does �ZOt identify any wild or scenic rivers. AIR QUALITY The City's Comprehensive Plan require all new resi�l�ntial and non-residential development to provide a specified amount of Florida native shad� trces based c�►1 an established desired ration of pervious to impervious surface areas. Shade trres «ill serve tc� provide heat reduction, noise abatement, buffering, replenishment of oxygen, an�i :��sthetic beaut��. The City shall cooperate with the Tampa Bay Rc��i��n.�l Plannin�� C�ouncil and Pinellas County in their efforts to develop plans for improving air q u.l i i��. The City will enforce all local building codes tc, �� mize air i���llutants in the development of housing. In addition, the City will adhere to Pin�l!.: ���uunty [:n� ir�,nmr�ltal Management's Air Quality Division's regulations and other applicai�i� ��ieral ur �t.��� rc`�ulations for removal of asbestos and lead based paint removal. FARMLANDS PROTECTION The City of Clearwater is highly urbanized communit� . No farn�l:u�ci arcas are designated in the Comprehensive Plan, adopted on May 18, 2000. I�h�refore thc �it� :lsscssment Criteria in the regulation (7 CFR Part 658) do not apply. NOISE Activities may be located in areas with a day-ni`�ht average sc�unc! le��el (DNL) exceeding 65 decibels. Therefore, HUD regulations relative tu environmcntal critcria and standards for "Noise Abatement and Control" may apply to the activities. 17 A map of noise sensitive zones with the City of Clearwater should be consulted to determine if the sires are located with these zones. If a project is with a noise sensitive (DNL65 decibels of above), then mitigation of noise impact for housing and other noise sensitive projects are required. HUD Noise Abatement and Control relation 24 CFR 51.10 (a) (5), Subpart B, supports modernization and rehabilitation activities. For projects located in all noise exposed areas, HUD shall encourage noise attenuation featured in alternation. RUNWAY CLEAR ZONES, CLEAR & ACCIDENT POTENTIAL ZONES Clear�uater Airpark is the only airport in the city. It does not provide services for commercial airlines and is only used for recreational airplanes. The City will determine the runway clear zones and accident potential zones. The City will not fund any activities in these areas. THERMAL AND EXPLOSIVE HAZARDS Activities may be located near or in an area exposed to thermal/explosive hazard, where conventional (e.g. petroleum) or hazazdous gases (e.g. propane), or chemical (e.g. benzene of hexane) of flammable nature are stored, if the activity is beyond the Acceptable Separation Distance (ASD) from the hazard under HUD safety standazds of when proper mitigating measures are taken as set forth in 24 CFR 51 Subpart C. The term "hazard" does apply to the following: a) Explosive or fire prone substances stored in container of 100 gallons or less when they contain common industrial fuels, b) hazardous substances stored underground or comply with applicable Federal, State and Local Safety Standards, and c) when hazardous facilities aze shielded for the rehabilitation activity by topography or man-made fire and explosive resistant structures. Housing staff should consult with the City of Clearwater Fire Department of Hazardous Explosive or Flammable sites or HUD if on-site review raises questions concerning the project. If it is determined the site is located within the acceptable separation distance, the owner must take the required measures to mediate the site in conformance with the regulations or re-site the beyond the acceptable separation distance. If not, the City will not recommend funding for the activity. WATER QUALITY The proposed activities will not result in the discharge of effluent into navigable waters, nor result in the dredging, filling, and disposal of dredged materials into any body of water of wetlands, beyond the capacity of the City's wastewater system. T'he City's Comprehensive Plan outline efforts made by the City to ensure dischazges do not adversely impact navigable waters. 18 Therefore, the requirement of the Clean Water Act of 1977 does not apply. SOLID WASTE DISPOSAL The requirements of the Resource Conservation and Recovery Act of 1976 prohibit federally- assisted activities in ecologically sensitive areas which have been affected by hazardous waste disposal sites that do not satisfy the Environmental Protection Agency. It has been determined by the Pinellas County Community Development Department that no hazardous waste disposal sites existing in the City of Clearwater. Source documentation is Martha Gray of Pinellas County Environmental Management Department, August 22, 1991. Telephone: 727-462-4761. Therefore the requirements of the Resource Conservation and Recovery Act of 1976 prohibiting federally assisted projects in ecologically sensitive azeas does not apply. FISH AND WILDLIFE The City of Clearwater Housing Division will determine if activities will be located within or near a fish or wildlife refuge upon this determination the requirements of the Fish and Wildlife Coordination Act will be reviewed for any possible applicability. TOXIC AND HAZARDOUS CHEMICALS The City of Clearwater will give particular attention to any site activity on or within one mile of area that contain or may have contained hazazd waste, such as dumps, landfills and industrial sites. ENVIRONMENTAL JUSTICE Project sites will not adversely affect low and moderate-income citizens; instead the projects will enhance low and moderate-income families. STATE REGULATIONS Consultation with the Department of Community Affairs, Florida State Clearinghouse will be required for all proposed projects including rehabilitation of historic properties. Permits are required for dredging and filling in waters of the State, construction and connection of sewage collection and treatment facilities, drainage appurtenances and dischazge in waters of the State under Federal and State laws. LOCAL REGULATIONS All proposed activities may not commenced until all permits required by the City of Clearwater Planning and Development Services Department have been obtained and approved. 19 IMPLEMENTATION OF COMPLIANCE Housing Division staff, in consultation with appropriate agencies, is responsible for the implementation of environmental requirements and must assure compliance before transferring funds to any projects. DOCUMENTAION OF COMPLIANCE Housing Division staff must maintain documentation of all required consultation and permits with each project file. The Housing Division Housing Manager will complete: a) a checklist showing that each proposed activity will comply with the National Environmental Policy Act and other Federal, State and local environmental laws and autharities, b) citation for all applicable environmental consultation and permits, and c) a finding which sets forth that implementation of any activity will not affect the original finding of categorical exclusion or assessment. PROJECTS IN NON-COMPLIANCE Activities not in compliance with the National En��irc�nmental Policy Act and other Federal, State and local environmental laws and authorities shall not commence until such compliance is achieved 20 ENVIRONMENTAL REVIEW SCREENING CHECKLIST PROPERTY ADDRESS CITY CLIENT NAME(S CDBG PROGRAM STATE ZIP 1. Historic Proaerties a. [s the structure in a Historic District of over 50 years old? b. If yes, indicate consultation and completion of Section 106 process 2. Flood Plain Manasement a. Is structure in 100 year Flood Plain? b. FEMA parcel Number c. Date of Map d. If yes above, has flood insurance been required? e. Is Flood Certification Documentation attached? 3. Wetlands Protection a. Is the structure in a wetland? b. If yes, indicate compliance with EO 11990 (an 8 step process) c. If yes, has the Corps of Engineers been consulted? d. If consulted, has the Corps of Engineers been satisfied? 4. 5. 6. Yes_ no _ Yes_ no _ Yes _ no_ Yes _ no_ Yes _ no_ Yes _ no_ Yes _ no_ Yes _ no_ NOISE a. [s the structure within 3000 feet of a railway, 1000 feet of a major thoroughfare, or within 5 miles of an airport? Yes _ no_ b. If yes, indicate maps consulted (Daytona International Airport) or mitigation measures to reduce noise: RUNWAY CLEAR ZONES CLEAR ZONES. AND ACCIDENT POTENTIALL ZONE (APZI a. Is structure located within runway cleaz zones or clear zones and APZ of Daytona Beach International Airport? Yes _ no_ b. If yes, please describe: THERMAL AND EXPLOSIVE HAZARDS a. Based on maps, studies and on-site visits, are there storage tanks and other facilities (within one mile) that pose danger to the property? Yes _ no b. If yes, explain, including any mitigation measures needed: 7. TOXIC AND HAZARDOUS CHEMICALS a. Is project site on or within one mile of area, which contain or may contain hazard waste? Yes no 8. ENVIRONMENTAL JUSTICE a. Will impact be positive to low/moderate income families? 21 Yes_ no _ � PROGRAM ENVIRONMENTAL REVIEW As many of the specific housing/dwelling units are non-designated at this time the City had to apply a citywide overview in reviewing the statutory checklist to indicate compliance with 24 CFR 58.5. As the specific sites are selected (either individual units or in-groups) further screening will be undertaken to specifically address any applicable checklist items. STRATEGY The City's Strategy to address the site screening process will be as follows: • A notice of Finding of no significant Impact and Notice of Intent was published for the CDBG program on 2000. No furthcr notices will be required unless the scope (location and activities) f the projects chan�e. • HUD has released the funds (given environment�il clearance) for the CDBG Program effective , 2000. No further release ��ill he necessar�� as long as the project scope remains unchanged. • A screening checklist will be prepared for th� cach selected property (or groups of properties) to complete the environmental re��i��� ��rocess. • Any mitigate measures or further complianc� ��ill be tranti»>itted to the property owner. � See Checklist. Any conditions will be carried froth to a devel�����r :�nd/or h��n������n�r. Completion of this checklist indicates compliance with the en� ir��nmental r�� i��� ti�r this above listed dwelling unit(s). Reviewer 23 I)atc ENVIROMENTAL ASSESMENT Checklist ofApplicable Statutes and Regulations Project vame and Identification No: Historic Property Floodplain Management Wetlands Protection Noise Runway Clear Zones ThermaUExplosive Hazards Toxic and Hazardous Chemicals Environmental Justice CDBG Program See Strategy-If structure is in Historic District or over 50 years old the SHPO will be consultede See Strategy-FEMA Map will be checked as residence is selected. See Strategy-Composite wetlands map will be checked. U.S. Fish & Wildlife Map. See Strategy-If near major roadway, railway or airport mitigate as necessary. See Strategy-Clearwater Airpark will be checked as necessary. See Strategy-File review will verify. See Strategy-File review will verify. See Strategy-File review will verify. 22