consumer financial protection bureau · consumer financial protection bureau located at 1700 g...

CONSUMER FINANCIAL PROTECTION BUREAUWASHINGTON, DC

NCPC PROJECT PLANS PRELIMINARY SUBMISSIONPART E: APPENDIX

REVISEDJAN 3, 2014

Consumer FinancialProtection Bureau

ENVIRONMENTAL ASSESSMENT

FOR THE RENOVATION OF THE

CONSUMER FINANCIAL PROTECTION BUREAU HEADQUARTERS' BUILDING LOCATED ON 1700 G STREET, NW, WASHINGTON, DC, 20552

SUBMITTED TO:

THE CONSUMER FINANCIAL PROTECTION BUREAU 1700 G STREET, NW, WASHINGTON, DC

PREPARED BY:

TETRAHEDRON, INC. 1414 KEY HIGHWAY, SUITE B

BALTIMORE, MD 21230

JANUARY 2, 2014

Environmental Assessment for CFPB HQ Building Renovation i January 2014

Contents List of Tables ................................................................................................................................. ivList of Figures ................................................................................................................................ ivACRONYMS AND ABBREVIATIONS ....................................................................................... vEXECUTIVE SUMMARY ............................................................................................................ 11.0 PURPOSE AND NEED OF PROJECT .................................................................................... 3

1.1 Project Description ................................................................................................................ 3Location and Physiography..................................................................................................... 4Building History...................................................................................................................... 4Exterior Wall ........................................................................................................................... 4P-1 and P-2 Levels .................................................................................................................. 4Basement Level ....................................................................................................................... 5Ground Floor Level................................................................................................................. 52nd thru 5th Floor Levels ........................................................................................................ 56th Floor Level ........................................................................................................................ 5Rooftop Level ......................................................................................................................... 5

1.2 Purpose of and Need for Project ........................................................................................... 61.3 Public Involvement and Agency Coordination ..................................................................... 7

National Capital Planning Commission .................................................................................. 7Commission of Fine Arts ........................................................................................................ 7Section 106 Review ................................................................................................................ 7State Historic Preservation Officer for the District of Columbia ........................................... 7

2.0 ALTERNATIVES TO THE PROPOSED ACTION ................................................................ 83.0 AFFECTED AREAS AND POTENTIAL CONSEQUENCES ............................................... 9

3.1 Land Use ............................................................................................................................... 9Affected Areas ........................................................................................................................ 9Potential Consequences .......................................................................................................... 9

3.2 Health and Safety .................................................................................................................. 9Affected Areas ........................................................................................................................ 9Potential Consequences .......................................................................................................... 9

3.3 Local Social and Economic Impact of Proposed Action ....................................................... 9Affected Areas ........................................................................................................................ 9Potential Consequences .......................................................................................................... 9

3.4 Local Social and Economic Impact of Relocated Staff from Proposed Action .................. 10

APPENDIX - 2

PART E: APPENDIXA. ENVIRONMENTAL ASSESSMENT REPORT

Environmental Assessment for CFPB HQ Building Renovation ii January 2014

Affected Areas ...................................................................................................................... 10Potential Consequences ........................................................................................................ 10

3.5 Security Perimeter of Building ............................................................................................ 10Affected Areas ...................................................................................................................... 10Potential Consequences ........................................................................................................ 12

3.6 Local Air Quality ................................................................................................................ 13Affected Areas ...................................................................................................................... 14Potential Consequences ........................................................................................................ 14

3.7 Noise.................................................................................................................................... 14Affected Areas ...................................................................................................................... 14Potential Consequences ........................................................................................................ 14

3.8 Impact on Storm Water ....................................................................................................... 15Affected Areas ...................................................................................................................... 15Potential Consequences ........................................................................................................ 15

3.9 Impact on Waste Water ....................................................................................................... 16Affected Areas ...................................................................................................................... 16Potential Consequences ........................................................................................................ 16

3.10 Impact on Ground Water ................................................................................................... 16Affected Areas ...................................................................................................................... 17Potential Consequences ........................................................................................................ 17

3.11 Wetlands ............................................................................................................................ 18Affected Areas ...................................................................................................................... 18Potential Consequences ........................................................................................................ 18

3.12 Floodplains ........................................................................................................................ 18Affected Areas ...................................................................................................................... 18Potential Consequences ........................................................................................................ 19

3.13 Risk to Threatened and Endangered Species .................................................................... 19Affected Areas ...................................................................................................................... 19Potential Consequences ........................................................................................................ 19

3.14 Historic and Archeological Preservation ........................................................................... 19Affected Areas ...................................................................................................................... 20Potential Consequences ........................................................................................................ 20

3.15 Hazardous Waste Potential ................................................................................................ 20Affected Areas ...................................................................................................................... 20Potential Consequences ........................................................................................................ 21

3.16 Visual Impacts ................................................................................................................... 21

Environmental Assessment for CFPB HQ Building Renovation iii January 2014

Affected Areas ...................................................................................................................... 21Potential Consequences ........................................................................................................ 22

3.17 Energy Consumption ......................................................................................................... 23Affected Areas ...................................................................................................................... 23Potential Consequences ........................................................................................................ 23

3.18 Local Antennas .................................................................................................................. 24Affected Areas ...................................................................................................................... 24Potential Consequences ........................................................................................................ 24

3.19 Cellular Tower Locations .................................................................................................. 24Affected Areas ...................................................................................................................... 25Potential Consequences ........................................................................................................ 26

3.20 Impact to Pedestrians and Bicyclists ................................................................................. 26Affected Areas ...................................................................................................................... 26Potential Consequences ........................................................................................................ 26

3.21 Vehicle Traffic .................................................................................................................. 26Affected Areas ...................................................................................................................... 26Potential Consequences ........................................................................................................ 27

3.22 Relationship of Local Short-term Uses vs. Long-term Productivity ................................. 27Affected Areas ...................................................................................................................... 27Potential Consequences ........................................................................................................ 27

3.23 Irreversible and Irretrievable Commitment of Resources ................................................. 274.0 SUMMARY OF IMPACTS ................................................................................................... 28

4.1 Cumulative Impacts ............................................................................................................. 284.2 Air Quality ........................................................................................................................... 284.3 Noise.................................................................................................................................... 284.3 Water Resources .................................................................................................................. 284.4 Potential for Public Controversy ......................................................................................... 29

5.0 CONCLUSION ....................................................................................................................... 306.0 REFERENCES ....................................................................................................................... 32

APPENDIX - 3


Environmental Assessment for CFPB HQ Building Renovation iv January 2014

List of Tables Table 1-1 Summary of Environmental Impacts 1 Table 3-1 National ambient air quality primary standards and air quality data for Washington, DC, from 2009 through 2012 13 Table 3-2 FCC Registered Cell Phone 26

List of Figures Figure 1-1 Building at 1700 G Street. Southwest View 3 Figure 1-2 Aerial Photograph of Proposed Action Site 3 Figure 1-3 Rendition of the Childcare area of the Rooftop 6 Figure 3-1 Concrete Planters on G Street 10 Figure 3-2 Concrete Planters on F Street 11 Figure 3-3 North Entrance, Corner of G and 17th Street 11 Figure 3-4 Raised Vehicular Plate Barriers at Loading Dock Entrance on F Street 12 Figure 3-5 Proposed Security Features of Ground Floor 12 Figure 3-6 Topographic Map of Proposed Action Site 17 Figure 3-7 Floodplain Map of Proposed Action Site 18 Figure 3-8 Proposed Final Appearance of Building, Southwest View 21 Figure 3-9 Proposed Final Appearance of Building, Plaza View 22 Figure 3-10 Current Building at 1700 G Street and Eisenhower Executive Office Building 22 Figure 3-11 Lightning Rods Along The Rooftop 24 Figure 3-12 Map of Subject Site (black star) and Cell Phone Towers (red balloons) 25

AppendicesHistorical Data A

Environmental Assessment for CFPB HQ Building Renovation v January 2014

ACRONYMS AND ABBREVIATIONS ACHP Advisory Council on Historic Preservation ASHRAE American Society of Heating, Refrigeration, and Air-Conditioning Engineers BMPs Best Management Practices CEQ Council on Environmental Quality CFPB Consumer Financial Protection Bureau CFR Code of Federal Regulations CAA Clean Air Act CWA Clean Water Act D.C. District of Columbia DCMR District of Columbia Municipality Regulations DCRA DC Department of Consumer Regulatory Affairs DDOE DC Department of the Environment DDOT DC Department of Transportation DCSHPO State Historic Preservation Officer for the District of Columbia DEQ Department of Environmental QualityDOE U.S. Department of Energy (also referred to as the Department) EA environmental assessment EIS Environmental Impact Statement E.O. Executive Order EPA U.S. Environmental Protection Agency ESA Endangered Species Act EPEAT Electronic Product Environmental Assessment Tool FCC Federal Communication Commission FHLBB Federal Home Loan Bank Board FEMP U.S. Department of Energy Federal Energy Management Program FIRM Flood Insurance Rate Map FONSI Finding of No Significant Impact HVAC heating, ventilation and air conditioning LEED Leadership in Energy and Environmental Design MHz megahertz MS4 DC Municipal Separate Storm Sewer System NAAQS National Ambient Air Quality Standards NCPC National Capital Planning Commission NEPA National Environmental Policy Act, as amended NFIP National Flood Insurance Program NHPA National Historic Preservation Act NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System OSHA Occupational Safety and Health Administration OTS Office of Thrift Supervision PM particle matter RF radio frequency RCRA Resource Conservation and Recovery Act USACE United States Army Corps of Engineers U.S.C. United States Code FWS U.S. Fish and Wildlife Service USGBC U.S. Green Building Council USGS United States Geological Survey

APPENDIX - 4


Environmental Assessment for CFPB HQ Building Renovation 1 January 2014

EXECUTIVE SUMMARY

This Environmental Assessment is intended to examine the potential effects of the "proposedaction" to renovate the interior and plaza space of the building used as Headquarters for the Consumer Financial Protection Bureau located at 1700 G Street, NW, Washington DC, 20552. The "no action" alternative to the above-proposed action will be that no renovation of the facility would occur. Based on Tetrahedron's evaluation of available records and discussions with various personnel, below is a summary of the foreseeable environmental impacts the proposed action will have at the property and impacts to the local community.

Table 1-1 Summary of Environmental Impacts SUMMARY OF ENVIRONMENTAL IMPACTS

Resource Impact Analysis Overall Consequence

Land Use The land will be used for the same purpose after the proposed action. No new land will be utilized. No impact

Health and Safety

Health and Safety plan to be developed by Rolf Jensen & Associates before proposed action to commence. No impact

Local Social and Economic

Impact at Site

During the proposed action, local businesses near the Subject Site will not have access to as many customers due to

relocated CFPB staff. Construction crews will mitigate some of the losses.

No long term impact, some positive and negative short term

impacts Local Social and

Economic Impact of

Relocated Staff

The current tenants of Constitution Square will be inconvenienced by the increase of office workers during the proposed action. The increase in workers will likely increase

sales to local businesses.

No long term impact, some positive and negative short term

impacts

Security Perimeter of

Building

Current security perimeter features are intended to stay in place (vehicle entrances) or evaluated for possible upgrades

(bollards). New bollards are currently planned for the northern lobby entrance located at 17th and G Street.

Anti-ram device at northern entrance may

negatively impact visual appeal and pedestrian access.

Other security features will have no impact as

they are already in place.

Local Air Quality

Local air quality will be impacted by dust and hazardous pollutants while construction equipment is in use and during demolition phases. Regular building operations do not affect

air quality normally.

Short term disturbance. No long

term impact

Noise Temporary local noise levels will increase during

construction work. Regular building operations do not affect noise levels normally.


term impact

Storm Water BMPs and other measures are to be put in place before the proposed action it to take place. No impact

Waste Water After construction, the improvements are expected to reduce the amount of wastewater entering the DC combined sewage

system from this building. No impact

Ground Water Proposed action is not expected to disturb ground water. No impact Wetlands Nearest wetland is over a mile away. No impact

Floodplains Proposed action site is outside historical DC floodplains No impact


SUMMARY OF ENVIRONMENTAL IMPACTS Resource Impact Analysis Overall Consequence

Threatened and Endangered

Species

The Hay's Spring habitat of Rock Creek is over 1.5 miles from proposed action site. No impact

Historic and Archeological

Building is not listed as a historically significant building and no records of archeological findings are recorded for the

proposed action site. No impact

Hazardous Waste

Normal building operations do not generate hazardous waste. A covered hazardous waste storage area will be present

during the proposed action. A third party will be contracted to remove materials as needed.

No impact

Visual

No additional floors are being planned for the building. A portion of the rooftop will be modified to accommodate a

childcare play area and would only be visible from the interior plaza. Aside from the updated lobby, the current street level view of the building will remain the same.

No impact

Energy Consumption

Building is projected to be rated LEED Gold after the proposed action, leading to less energy consumption. No impact

Antennas

Lightning rods on the rooftop will have to be relocated safely away from the childcare area on the rooftop. No other antennas on the proposed action site or on neighboring

buildings require further action.

No long term impact

Cellular Tower No towers are planned to be erected due to the proposed

action. The three towers in DC high transmission frequency and distance from the site greatly reduce potential impact.

No impact

Pedestrians and Bicyclists

During the proposed action, pedestrian and bicycle traffic will be temporarily impeded to accommodate construction

activities.


term impact

Traffic During the proposed action, vehicle traffic will be temporarily impeded to accommodate construction activities.


term impact Local Short-term Uses vs.

Long-term Productivity

The proposed action will allow more workers to utilize the building space while using fewer resources from the building

upgrades. No impact

Based on the review and analysis of materials, a Finding of No Significant Impact for the proposed action at 1700 G Street, NW, Washington DC, 20552. Due to the temporary nature of the project, any potential environmental and public disturbances will be short-term. Many of the renovations, such as noise damping materials and a green roof, will prove to be beneficial to workers, public, and the local environment over the long term.

APPENDIX - 5



1.0 PURPOSE AND NEED OF PROJECT

1.1 Project Description The project at 1700 G Street, NW is to modernize the interior and plaza space of the building. The building is currently used as the headquarters for the Consumer Financial Protection Bureau (CFPB). Originally built in 1976, the building has three below ground levels that extend beneath a large public plaza (two of which include secured parking) and six floors above ground with a penthouse above the 6th floor for mechanical equipment. Storefront retail is located at the ground level. Structurally, the building is a reinforced concrete frame structure on a 30-foot-by-30-foot column module with waffle slabs.

Figure 1-1 Building at 1700 G Street. Southwest View

The overall project site, outlined in white below, is approximately 51,500 square feet for the building and 16,700 square feet for the plaza, totaling 68,200 square feet. The building footprint is approximately 47,600 square feet, and the interior building area is approximately 502,600 square feet.

Figure 1-2 Aerial Photograph of Proposed Action Site (outlined in white)


Location and Physiography The District of Columbia covers an area of about 65 square miles on the northeast and east side of the Potomac River, adjacent to the mouth of the Anacostia River. The District has two physiographic provinces, the Mid-Atlantic Coastal Plain and the Piedmont Province. The Fall line, which separates the Piedmont Province in the west from Coastal Plain Province in the east, bisects the area diagonally from northeast to southwest. Much of the District is dissected by erosion and is characterized by nearly level to gently rolling uplands, steep valley walls, widely separated inter-stream divides and narrow valley bottoms. In the downtown area, most public buildings and memorials are on nearly level lowlands formed on river terrace deposits, alluvium and artificial fill. Elevation ranges from sea level in the southern part of Washington, where the Anacostia and Potomac Rivers are tidal estuaries, to 20 feet in Tenleytown in the west of the city. Inter-stream ridges are highest in the Piedmont section of the city, and grade gradually to the south and east, where elevations are generally below 230 feet. 1700 G Street, NW is located in a highly developed urban portion of Washington DC. The site shares a plaza with the Winder Building. It is bounded by G Street to the north, 17th Street on the east, the Winder Building and F Street to the south (which share a plaza), and a retail/office building on the west. The Eisenhower Executive building is located across 17th Street, with the White House 0.2 miles further to the east. Many other federal agencies, businesses, and non-governmental organizations occupy neighboring buildings as well.

Building History 1700 G Street was designed and constructed from 1974 to 1977. It originally housed the Federal Home Loan Bank Board (FHLBB) and then its successor agencies, which later shared occupancy of the building with the Office of Thrift Supervision (OTS) until the closure of the OTS on 19 October 2011. The Federal Housing Finance Agency also shared the building from September 2008 until March 2011. The building’s sole occupant is now the Consumer Financial Protection Bureau (CFPB), which began occupying the building in November 2011. An evaluation of the historic significance of 1700 G Street, NW is currently ongoing as of the writing of this report. The current building at 1700 G Street, NW now used by CFPB was constructed in 1975. The FHLBB moved into the building immediately after construction was complete. Since construction, the building has not undergone any renovations except roof maintenance, repair and non-structural adjustments to the building interior. A plaza fountain flows during the summer season, but an area that was previously a skating rink is now a daytime gathering area and a street-to-street short-cut for pedestrians. The overall project will involve significant improvements to the building. Under the proposed action, the planned changes, renovations, expansions and additions include:

Exterior Wall A planned demolition is set for all existing windows, to be replaced with a new window system from the 2nd to 6th floor and the lobby entrance of G and 17th street.

P-1 and P-2 Levels Areas including below grade level house the garage area. Additional shaft openings will be added in the garage levels for mechanical shaft. Security access at elevator vestibules will be provided for the garage elevators at Levels P-1 and P-2. All garage columns require strengthening according to the concept report blast assessment.

APPENDIX - 6



Basement Level Currently contains mixed-use occupancy including childcare, office area, network servers, storage rooms and mechanical areas. Additional openings will be added in the basement levels for mechanical shaft. Renovations for the basement include a new conference center and areas, a communicating stair from the lobby to allow access to the conference center, a fitness center and associated mechanical and electrical upgrades along with security infrastructure. After the renovation, there will be no office spaces or childcare center in the basement.

Ground Floor Level Work includes mechanical and electrical upgrades along with security infrastructure. The existing ground level lobby will be renovated to be commensurate with the new exterior storefront replacement and include security bollards outside the main entrance. The existing retail areas will remain. Existing annunciation panel and fire control room will remain in place. The lobby will incorporate a new communicating stair leading down to the basement conference center. Elevator lobby and elevator cabs will be renovated along with the outdoor plaza and access alleys. A new childcare area is planned to be set up on the ground floor in the area currently used by Met Café.

2nd thru 5th Floor Levels Work includes associated mechanical and electrical upgrades along with security infrastructure. An open communicating stairs is planned for each floor to be in each atria (East and West). Demolition of upturn beam at the atrium opening will be replaced by a glass railing. The current restrooms throughout the floors are planned to be renovated.

6th Floor Level There will be a new extension of the interior exit stair at F St side leading to upper floors. Work includes associated mechanical and electrical upgrades along with security infrastructure and continuation of the open communicating staircase from the lower levels in the East and West atria. Demolition of upturn beam at the atrium opening will be replaced by a glass railing. The current restrooms are planned to be renovated.

Rooftop Level A new cooling tower will be installed, along with air handler units and associated connections and pumps. It will have a new "green" roof and a play area for the childcare with a staircase and dedicated elevator access. A portion of the childcare area will have a shade structure while the rest of the play area will be exposed to the elements. The area will be surrounded by a limestone barrier to protect the children. The perimeter wall will be set back from the edge of the rooftop. No air handlers or HVAC equipment were present on the rooftop portion proposed for the childcare play area. The following image is a depiction of the rooftop level that will be used by the childcare center. No other portions of the roof are expected to be regularly used by personnel.


Figure 1-3 Rendition of the Childcare area of the Rooftop

Currently, portions of the rooftop of 1700 G Street have lighting rods, air handlers and a TV antenna.

1.2 Purpose of and Need for Project In accordance with the National Environmental Policy Act (NEPA) of 1969, the CFPB must evaluate the environmental consequences of proposed actions (renovation of the facility) on the natural and human environment before deciding to fund an action, including evaluating alternative means of addressing the purpose and need for a federal action. The President’s Council on Environmental Quality (CEQ) has developed a series of regulations for implementing NEPA. These regulations are included in 40 CFR, parts 1500-1508. The CFPB is required to prepare a draft environmental assessment (EA) to identify and evaluate potential environmental impacts resulting from the alternative presented in the EA and to determine whether to prepare an Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FONSI). This draft EA will be available for public comments for a month. In addition to complying with NEPA, CEQ regulations (40 CFR Parts 1500-1508), and relevant agency NEPA implementing regulations, this EA also addresses all applicable laws and regulations, including but not limited to the following:

Energy Policy Act of 2005 National Historic Preservation Act (NHPA) Archeological Resources Protection Act The Noise Control Act of 1972, as amended Environmental Justice (Executive Order (EO) 12898) Clean Air Act (CAA and amendments) Clean Water Act (CWA) Coastal Zone Management Act Protection of Wetlands (EO 11990) Floodplain Management (EO 11988) Endangered Species Act Pollution Prevention Act Resource Conservation and Recovery Act

APPENDIX - 7



Comprehensive Environmental Response, Compensation and Liability Act

1.3 Public Involvement and Agency Coordination

National Capital Planning Commission Congress established the National Capital Planning Commission (NCPC) in 1924 to prepare a “comprehensive, consistent and coordinated plan for the National Capital.” NCPC has the primary responsibility for the comprehensive plan since that time. After Congress granted DC home rule, responsibility for many planning functions shifted to the city’s mayor. Today, the DC Office of Planning prepares the District Elements of the comprehensive plan, subject to NCPC review, while NCPC prepares the Federal Elements of the plan. NCPC promotes the efficient operation of the federal government while reinforcing smart growth principles and surrounding local and regional planning objectives. NCPC protects the capital’s historical, cultural and environmental resources, ensuring that they will be here for future generations.

Commission of Fine Arts The Commission of Fine Arts, established in 1910 by Act of Congress, is charged with giving expert advice to the President, Congress and the heads of departments and agencies of the Federal and District of Columbia governments on matters of design and aesthetics, as they affect the Federal interest and preserve the dignity of the nation's capital. The Commission consists of seven "well qualified judges of the fine arts" appointed by the President and serve for a term of four years; they may also be reappointed. Within the District of Columbia, the Commission advises on design matters affecting the Historic District of Georgetown, under the Old Georgetown Act, as well as other private sector areas adjacent to federal interests, under the Shipstead-Luce Act.

Section 106 Review Section 106 of the National Historic Preservation Act of 1966 requires Federal agencies to take into account the effects of their undertakings on historic properties, and afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment. The historic preservation review process mandated by Section 106 is outlined in regulations issued by ACHP. Revised regulations, "Protection of Historic Properties" (36 CFR Part 800), became effective August 5, 2004. Under the regulations, the responsible Federal agency first determines whether it has an undertaking is a type of activity that could affect historic properties. Historic properties are properties that are included in the National Register of Historic Places or that meet the criteria for the National Register. If so, State Historic Preservation Officer for the District of Columbia (DCSHPO) is to be consulted during the process. It should also plan to involve the public, and identify other potential consulting parties. If it determines that it has no undertaking, or that its undertaking is a type of activity that has no potential to affect historic properties, the agency has no further Section 106 obligations.

State Historic Preservation Officer for the District of Columbia The DCSHPO is responsible for protecting the District's unique historical, archaeological, architectural, and cultural resources. This responsibility is shared with each federal agency that administers properties or undertakes construction activities in Washington, DC. Each year the DCSHPO prepares an Annual Work Plan to help the District meet its long-term historic preservation goals. The District of Columbia Historic Preservation Review Board, a group of private citizens appointed by the Mayor to represent professional and community viewpoints in the historic preservation process, advises the DCSHPO on matters relating to Section 106 review. The Historic Preservation Office serves as staff to the DCSHPO and the Historic Preservation Review Board.


2.0 ALTERNATIVES TO THE PROPOSED ACTION If the proposed action at 1700 G Street, NW cannot proceed, the alternative "no action" will be no renovations or improvements to the entire building or plaza. In the event that "no action" for the building and plaza renovation were to take place, some smaller forms of interior renovations will likely still occur. These actions would likely include items such as renovations to the buildings electrical, heating ventilation and air conditioning (HVAC) systems, and mechanical systems. Other building features, such as windows and carpets, would likely be repaired or replaced.

APPENDIX - 8



3.0 AFFECTED AREAS AND POTENTIAL CONSEQUENCES

3.1 Land Use The site of the proposed action currently occupies a heavily urbanized area of Washington DC. The building currently on-site was built in 1976. It currently shares a plaza with the Winder Building to the south, and another office building to the west.

Affected Areas The proposed renovations and construction will take place on the footprint of the current building and plaza. No new land is expected to be developed for the project.

Potential Consequences No impact is given that no new land will be developed for the Proposed Action site.

3.2 Health and Safety Normal building operations do not pose a risk to workers or the public currently and will not after the project is complete. To comply with Occupational Safety and Health Administration (OSHA) standards, a health and safety plan will need to be developed for the project.

Affected Areas For the proposed project, Rolf Jensen & Associates Inc. will generate a health and safety plan for the people and workers involved in the project.

Potential Consequences Once the proposed action is approved, a worker Health and Safety plan will be developed by the General Contractor.

3.3 Local Social and Economic Impact of Proposed Action During the proposed renovation and construction activities at the site, all personnel working for the CFPB will be relocated to Constitution Square at 1275 First Street, NE, Washington, DC, 20417, about 2 miles from the site of the proposed action. The building is also used by the U.S. General Services Administration.

Affected Areas During the renovation and construction activities at the site, all personnel working for the CFPB will be relocated from the facility. Other local shops and restaurants will be temporarily affected by the relocation of CFPB workers. Construction perimeters and other barriers set up around the Subject Site may also impede customers from access to local retailers during the duration of the proposed action.

Potential Consequences Retailers dependent on sales from staffers at the CFPB will likely register a lower rate of sales since the staff will not be present during the renovation. During the renovation, access to retailers could also be hindered on a temporary basis. Construction crews could patronize local restaurants and eateries, temporarily replacing CFPB workers. Any negative impacts on local businesses will dissipate after the proposed action is complete.


3.4 Local Social and Economic Impact of Relocated Staff from Proposed Action During the proposed action, employees of the CFPB will be relocated to work at Constitution Square at 1275 First Street, NE, Washington, DC, 20417, about 2 miles from the site of the proposed action. The building is also used by the U.S. General Services Administration.

Affected Areas The current occupants of Constitution Square and nearby businesses will be affected during the proposed action. The additional workers will also influence local streets, parking lots and transit systems.

Potential Consequences The current occupants of Constitution Square may be inconvenienced the personnel being temporarily relocated to their building. The retail space at Constitution Square and nearby will likely see an increase in sales and revenue from the increased number of workers. Parking facilities at Constitution Square will gain an increase of users, possibly leading to some facilities being at capacity. These consequences will only last during the duration of the proposed action.

3.5 Security Perimeter of Building A risk assessment performed by Strauchs LLC states that after the proposed action, the facility will be refurbished to meet Facility Security Level III, which applies to buildings with 80,000 to 150,000 square feet, and/or with moderate to high public access.

Affected Areas The plaza entrances are blocked with concrete planters (Figure 3-1 and 3-2). The planters are planned to be evaluated during the proposed action and compared with other anti-ram solutions. Currently at the main entrance of the lobby, there are no planters or bollards providing protection (Figure 3-3).

Figure 3-1 Concrete Planters on G Street

APPENDIX - 9



Figure 3-2 Concrete Planters on F Street

Figure 3-3 North Entrance, Corner of G and 17th Street

The loading dock, located on the southwest corner of the ground floor, is secured by personnel and vehicular plate barriers as shown in Figure 3-4. All other vehicle entrances and exits to the building have similar movable barriers. All mail and packages are screened at the loading dock before being moved throughout the building.


Figure 3-4 Raised Vehicular Plate Barriers at Loading Dock Entrance on F Street

Potential Consequences A site plan of the building highlighting planned perimeter security features is shown below.

Figure 3-5 Proposed Security Features of Ground Floor

APPENDIX - 10



Current features, such as vehicular plate barriers, will remain in place. Bollards are planned for the lobby entrance at the corner of G and 17th Street. The concrete planters currently in place at the plaza entry points will be replaced with bollards. Bollards will be present at the entrances to the plaza from F, G and 17th Streets. Bollards will also be installed at the main entrance at the corner of 17th and G Street. The visual impact and impact on pedestrian traffic will be minimal after the proposed action given that current features either will remain in place or obtain upgrades. It is the understanding of Tetrahedron that as the proposed action progresses, further evaluation will continue on existing structural systems to determine how material will handle various sized blasts. Changes to materials or the layout of planned security features may change in order to satisfy safety requirements.

3.6 Local Air Quality The ambient air quality in an area can be characterized in terms of whether it complies with the primary and secondary National Ambient Air Quality Standards. The Clean Air Act (42 U.S.C. 7401 et seq.) requires the U.S. Environmental Protection Agency (EPA) to set national standards for pollutants considered harmful to public health and the environment. National Ambient Air Quality Standards have been established for six criteria pollutants: carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter (PM) (with a size 10 microns and 2.5 microns), and sulfur dioxide. Primary standards define levels of air quality the EPA has determined as necessary to provide an adequate margin of safety to protect public health, including the health of sensitive populations such as children and the elderly. Secondary standards define levels of air quality deemed necessary to protect the public welfare, including protection against decreased visibility and damage to animals, crops, vegetation and buildings. The Table 3-1 lists the primary National Ambient Air Quality Standards (NAAQS) for each of the criteria pollutants and provides air quality data from air monitors near the subject site in Washington DC for the last four years of records available from the DC Department of the Environment (DDOE). Since 2009, average air quality data in the monitored areas of Washington DC have not exceeded national standards, when data is available.

Table 3-1 National ambient air quality primary standards and air quality data for Washington, DC, from 2009 through 2012

Pollutant Sampling Period

Maximum Allowable Units Average Quality by Year

2009 2010 2011 2012 Carbon

Monoxide 8 hours 9 ppm 1.02 1.01 0.85 0.81

Lead Quarterly 1.5 μg/m3 * * * 0.003 Nitrogen Dioxide 24 hours 0.053 ppm 0.03 0.03 0.03 0.03

Ozone 8 hours 0.075 ppm 0.04 0.04 0.04 0.04 PM10 24 hours 150 μg/m3 17.97 21.29 16.95 17.00 PM2.5 24 hours 35 μg/m3 9.63 10.46 10.67 10.36 Sulfur

Dioxide 24 hours 0.14 ppm 0.009 0.006 0.004 0.003 * Data unavailable for these years ppm = parts per million μg/m3 = micrograms per cubic meter


Normal building operations currently at the Subject Site do not generate air emissions and would not affect the amount of pollutants in the air.

Affected Areas During the renovation, the local air quality in and around the site of the proposed action will be adversely impacted by the operation of construction equipment. No other areas are expected to be impacted.

Potential Consequences Construction equipment used for the renovation will discharge pollutants into the local air, especially during demolition phases. However, due to the limited amount of time the equipment will be present on the Subject Site, and that normal building operations do not generate air pollution, the impact to the local air quality will be temporary and last only during the renovation period. The proposed green space in the plaza and the green roof to be in place after the proposed action will help to improve the local air quality.

3.7 Noise It is the declared public policy of the District to reduce the ambient noise level in the District to promote public health, safety, welfare, and the peace and quiet of the inhabitants of the District, and to facilitate the enjoyment of the natural attraction of the District. (DCMR 20, Sec. 2700.1). Title 20 District of Columbia Municipality Regulations, Chapter 27, Noise Control and Chapter 28, Maximum Noise Levels, and Chapter 29, Noise Measuring Test Procedures. The DC Department of Consumer and Regulatory Affairs (DCRA) states that construction is allowed Monday through Saturday from 7 am to 7 pm without any special permits. If it is necessary to work outside those hours or on Sunday, an after-hours permit to work will need to be obtained from DCRA. Currently, normal building operations do not generate noise outside of the building, nor expected to after the renovation.

Affected Areas The proposed project is located in a populated commercial area of the city with minimal green space or other methods to absorb noise. Most of the buildings surrounding the site are commercial properties and are used during normal hours of operation during the day. Occupants of the Winder Building, The Eisenhower Executive Building and other buildings will likely be most impacted by noises associated with demolition and construction.

Potential Consequences During the construction and reconstruction, noise levels in the area are expected to be elevated. Loud work operations are usually brief to prevent injury to construction workers. Additionally, noise control plans are to be put in place for the demolition operations of the project, further limiting noise. Work during the proposed action is not expected to occur outside normally approved construction hours set by DCRA. Based on the proposed renovations, a number of noise cancelling components will be included in the final building. This will decrease interior noise on and in between floors.

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3.8 Impact on Storm Water Under federal law, the District is required to control its storm water that enters the local watersheds (Potomac, Anacostia) and reduce the amounts of pollutants that the stormwater contains. Local city agencies such as District of Columbia Department of the Environment (DDOE) and District of Columbia Department of Transportation (DDOT) have implemented and are developing additional practices that reduce pollutants at the source, before they enter critical water bodies.

Affected Areas Two existing 10” storm water mains exit the G Street side of the building at the basement floor. One 8” and one 10” storm water main exit the 17th Street side of the building on the basement floor. One 10” and one 12” storm water main exit the F Street side of the building at the basement floor. The proposed action will abandon the existing storm sewer connections to the public main and reroute the storm laterals to an on-site treatment system. On-site treatment of the sanitary sewerage will be provided by a "Living Machine", a system consisting of two sanitary storm water holding tanks located within public space. Placement of these tanks in the public space will be subject to the approval and permitting of DDOT, DDOE, and DC Water and will require a perpetual maintenance contract relieving the District of Columbia of maintenance of the storage tanks. Each "Living Machine" storm water holding tank will be provided with an overflow connection to new manholes constructed above the DC Water public combined sewer. All materials will be in accordance with DC Water standards and specifications. Existing sidewalks will be retained throughout construction with the exception of portions that will be sawcut and removed as needed for the installation of storm water management structures. Additional renovations to the outside of the building and the plaza will include modifications to reduce the amount of storm water runoff. Planned improvements include:

Permeable pavement Vegetated wells

Green roof (subject to DDOE approval) Layering of vegetation visible to the public

Storm water runoff is likely to increase during the renovation of the plaza, as soil is added and replaced. Sediment runoff can also increase due to construction equipment moving on and off site.

Potential Consequences As per the work plans for the proposed action, "All sediment and erosion control methods shall be installed before the start of any excavation and/or demolition as per District of Columbia Erosion and Sediment Control Handbook. If any onsite inspection reveals further erosion control measures are necessary, the same shall be provided." Best Management Practices (BMPs) and other methods to control and limit the amount of storm water runoff from the site of the proposed action will be addressed before the start of the project. Any storm water runoff generated by the presence of construction equipment or renovation to the plaza will not further occur after the project is complete. With the number of planned


improvements to the Subject Site such as the green roof and the living machine, the amount of storm water runoff is expected to decrease once the project is complete.

3.9 Impact on Waste Water The 1972 amendments to the Federal Water Pollution Control Act provide the statutory basis for the National Pollutant Discharge Elimination System (NPDES) permit program and the basic structure for regulating the discharge of pollutants from point sources to waters of the United States. Section 402 of the CWA specifically required EPA to develop and implement the NPDES program.

Affected Areas The proposed project is located in a populated commercial area with little green space. The sanitary sewer flow from the building is currently conveyed via three lateral connections to combined sewers located in public space along G Street NW and 17th Street NW. The sanitary sewer laterals eventually connect with the DC combined sewer system outside the building. Wastewater is then treated by the DC Department of Public Works before discharging into local waterways.

Potential Consequences During the reconstruction, the intent is to abandon two existing sanitary sewer connections to the public main, and reroute using new PVC sanitary sewer laterals and cleanouts to holding tanks for the on-site engineered wetland treatment system built into the plaza. All sanitary sewage leaves the building by gravity and enters one of two sewage holding tanks, just outside the building footprint, but within the plaza area at the southeast of the building, where it is stored until the next stage. The wastewater holding tanks will be provided with PVC overflow connection to the D.C. combined sewer system. From the holding tank, the sewage is sent through a solids screen, while solids are removed by a dry cake, then completely sealed and removed with the trash. Remaining liquid waste will be sent to the equalization tank and then through the stage 1 and 2 tidal flow wetland and then treated with UV light and chlorine before reuse for irrigation and to supplement toilet flush valves and cooling tower make-up. After construction, the improvements are expected to reduce the amount of wastewater entering the DC combined sewage system from this building.

3.10 Impact on Ground Water Based on the following topographic map, groundwater is expected to flow southeast of the Subject Site (outlined in white). If not picked up by storm water drain, water would likely continue to flow towards the Tidal Basin.

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Figure 3-6 Topographic Map of Proposed Action Site

Center: 38.8972°N 77.0438°W Elevation at center: 85 feet (26 meters)

Quad: USGS Washington West Drg Name: o38077h1 Drg Source Scale: 1:24,000 In the Coastal Plain portion of the District of Columbia, the topography and drainage pattern have been significantly affected by urbanization. At the time of the earliest settlement, the topography of the downtown Washington area was marked by the drainage systems of Tiber Creek, which discharged into the Potomac River, and St. James Creek, which discharged into the Anacostia. These streams circled the southwestern portion of Washington on the lines of the Mall, Canal Street and Delaware Avenue. Small tributaries to this system cut across near Judiciary Square and along the line of 10th Street, and a larger tributary slowed southwest from Union Station. Another creek called Slash Run flowed south from the vicinity of Wyoming Avenue and 18th Street NW it turned west, crossing Connecticut Avenue and then turned north again to discharge into Rock Creek.

Affected Areas Scientists at the USGS have measured stream flow and ground water levels in wells to assess water resources for over 125 years. In addition to providing the most extensive set of historical stream flow and ground water data available to the public, precipitation and reservoir data are also presented to give a complete picture of the region’s water resource. In March, 2013, 65% of the ground water levels in the DC area were in the normal range and 85% of the stream flow levels were in the normal range in the proposed site. The normal range is considered between the 25th to 75th percentiles.

Potential Consequences The proposed action should not affect the ground water in District of Columbia area.


3.11 Wetlands

Affected Areas The nearest wetlands to the subject site are on Theodore Roosevelt Island, over a mile to the west of the subject site. Groundwater flow from the subject site does not flow towards these wetlands or any other existing wetlands in DC.

Potential Consequences No impact is expected to the wetlands on Theodore Roosevelt Island due to their distance from the site and flow of ground water.

3.12 Floodplains Flooding is a frequent and costly hazard in the District of Columbia. Flood risks vary from property to property, even in the same neighborhood. Additionally, flood risks can change over time due to erosion, land use and other factors. In the face of mounting flood losses and escalating costs of disaster relief to the general taxpayers, the U.S. Congress established the National Flood Insurance Program (NFIP) on August 1, 1968. The District of Columbia has enacted and implemented the floodplain regulations required for participation in NFIP. NFIP is based on a mutual agreement between the Federal Government and District of Columbia. The D.C. Construction Codes 2008 (DCMR 12) adopted all flood resistant provisions in the International Codes. The revised Flood Hazard Rules (DCMR 20 Chapter 31), dated 2010, provided details and technical provisions for floodplain development requirements and permitting process.

Affected Areas According to the District of Columbia's Flood Insurance Rate Map (FIRM), the proposed action site (the red X on the map below) is not located on known historical floodplains.

Figure 3-7 Floodplain Map of Proposed Action Site

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Potential Consequences The Subject Site is not located near any local flood plains and the construction project will not expand the site to include land that is on a flood plain. Risk of flooding is likely minimal.

3.13 Risk to Threatened and Endangered Species The Endangered Species Act (ESA) provides a program for the conservation of threatened and endangered plants and animals and the habitats in which they are found. The lead federal agencies for implementing ESA are the U.S. Fish and Wildlife Service and the U.S. National Oceanic and Atmospheric Administration (NOAA) Fisheries Service. The U.S. Fish and Wildlife Service maintains a worldwide list of endangered species. Species include birds, insects, fish, reptiles, mammals, crustaceans, flowers, grasses and trees. The law requires federal agencies, in consultation with the U.S. Fish and Wildlife Service and/or the NOAA Fisheries Service, to ensure that actions they authorize, fund, or carry out are not likely to jeopardize the continued existence of any listed species or result in the destruction or adverse modification of designated critical habitat of such species. The law also prohibits any action that causes a "taking" of any listed species of endangered fish or wildlife. Likewise, import, export, interstate, and foreign commerce of listed species are all generally prohibited.

Affected Areas No known endangered plant species exist in Washington DC. One endangered animal species lives in the Washington DC area: Hay's Spring (Stygobromus hayi). This shrimp-like creature is endemic to Washington DC, where it occurs only in Rock Creek, a tributary of the Potomac River. This species is listed as "Critically Imperiled" and is threatened by the degradation of its habitat. However, the subject site is over 1.5 miles from Rock Creek and the proposed renovation will not influence the stream. In addition, surface water at the site flows to the southeast, away from Rock Creek.

Potential Consequences No impact to Rock Creek, and thus the habitat of the Hay's Spring, is anticipated to occur from proposed renovation activities.

3.14 Historic and Archeological Preservation Before the current building at 1700 G Street, NW was constructed, that city block contained four distinct buildings: Nichols Café built in 1830, the Winder Building built in 1854, Winder Annex built in 1882, and a building constructed by the Washington Loan and Trust Company built in 1924 which later became Riggs National Bank in 1954 (later vacated and used as a warehouse in 1965). In 1949, the U.S. General Services Administration (GSA) took control of the Winder Building and has maintained it ever since. This management control by GSA included the adjacent buildings occupying the site near the Winder Building. GSA proposed to demolish the four buildings at 1700 G Street, NW in 1974 to construct a new office building. By that time, the Winder Building was listed on the National Register of Historic Places. The Government Accountability Office (GAO) reviewed and reported (see appendix A2) these actions to determine if the buildings and demolition were a voluntary example of the preservation and mixed use promoted by the act, or alternatively was the failure to reuse existing historic structures. GAO found that GSA interpreted the act as a way to acquire and preserve


historic structures, whereas GAO believes the intent of the act is to acquire land and buildings for additional federal office space. The building currently used by the Consumer Financial Protection Bureau (CFPB) at 1700 G Street, NW resembles neighboring buildings with elements of brutalism in the architecture. The building did apply to be listed as a historically significant property through a DOE, and was recommended for historical preservation in accordance with Determination of Eligibility signed by SHPO on 24 July 2013. The Section 106 process has resulted in a Memorandum of Agreement between the CFPB and SHPO.

Affected Areas The Historic Preservation Office of Washington DC does not list the building used by the CFPB as a historically significant building or having archeological findings (Appendix A). Some buildings nearby, such as the Winder and Executive Office buildings, are registered by the Historic Preservation Office.

Potential Consequences No impact is expected. With proper care, the proposed action would not affect nearby buildings which are registered by the Historic Preservation Office as being historically significant. An application for historical significance is currently under review as of this writing.

3.15 Hazardous Waste Potential The Resource Conservation and Recovery Act (RCRA) was enacted by Congress in 1976. RCRA's primary goals are to protect human health and the environment from the potential hazards of waste disposal, to conserve energy and natural resources, to reduce the amount of waste generated, and to ensure that wastes are managed in an environmentally sound manner. RCRA is the public law that creates the framework for the proper management of hazardous and nonhazardous solid waste.

Affected Areas Very little hazardous waste is currently generated by the CFPB, as it is mostly an administrative facility. Current hazardous wastes on-site include: fluorescent light bulbs and tubes, and oil/grease from equipment operations. The current materials on-site are not present in large amounts, nor do the materials pose any current concerns. Renovation can potentially generate (i.e., produce or have present on site) wastes that are:

Ignitable wastes: paint thinners, paints, paint and varnish strippers, epoxy resins, adhesives, degreasers, and spent cleaning solvents Corrosive wastes: rust removers, cleaning fluids, and battery acids Reactive wastes: plating waste, bleaches, and waste oxidizers Toxic wastes: materials containing metals (mercury, cadmium, or lead) or solvents Resins, roofing cement, adhesives, machinery lubricants, and caulk Cleanup materials (such as rags) contaminated with the items listed above Drums and containers that once contained the items listed above Computer monitors and televisions with cathode ray tubes Gypsum drywall (due to dust and sulfate)

APPENDIX - 14



During the renovations, there will be a designated, covered hazardous waste storage area.

Potential Consequences There would be temporary impact and risk due to the temporary storage of hazardous waste generated at the site during renovation. A hazardous waste plan will be in place during the renovations, instructing workers on the location of the temporary hazardous waste storage area. A contracted third party will be responsible for disposal of the materials. The hazardous waste plan should also include BMPs to reduce the risk of release during the renovation. After the renovation, the hazardous materials present on-site are expected to be the same as those currently on-site, in similar negligible quantities.

3.16 Visual Impacts The maximum height of a building in the DC area is generally based on the relationship of the building to the width of the adjacent streets. For the proposed action site, the maximum allowable height of the building is within accordance with the Building Height Act of 1910.

Affected Areas The primary visual differences planned for the renovation will be the new glass walls around the main lobby. The windows from the 2nd to the 6th floor will also be updated.

Figure 3-8 Proposed Final Appearance of Building, Southwest View

With the construction of the childcare play area on the rooftop, the associated limestone enclosure wall and stairwell, the rooftop of the building will appear slightly different when viewed from the interior plaza. The change is minor in appearance, appearing as a small addition to the rooftop which will not be easily visible outside of the plaza. The proposed new addition to the building is outlined in black on the next image.

Updated lobby Updated

windows


Figure 3-9 Proposed Final Appearance of Building, Plaza View

Across 17th Street from the site of the proposed action is the Eisenhower Executive Office Building.

Figure 3-10 Current Building at 1700 G Street (right) and Eisenhower Executive Office Building (left)

Potential Consequences Aside from a childcare play area on the roof and a penthouse for mechanical equipment, the proposed action for the building does not include additional floors, allowing the building to remain in accordance with the Building Height Act. These structures will only be visible from

APPENDIX - 15



the interior plaza. The new glass walls and lobby will not negatively affect the surrounding area or nearby buildings when viewed from the street. Additional consultation, in accordance with Section 106, will continue throughout the proposed action.

3.17 Energy Consumption In October 2009, Executive Order 13514 on Federal Leadership in Environmental, Energy and Economic Performance was issued, directing all federal agencies to strengthen their sustainable practices. The E.O. expanded on the Energy Independence and Security Act, the Energy Policy Act of 2005, and Executive Order 13423 by requiring federal agencies to implement strategies to measure, manage, and reduce greenhouse gas emissions, water consumption, and diversion of materials. The order mandates federal agencies to meet various energy and environmental targets and defines requirements for sustainability in buildings and leases, sustainable acquisition, and electronic stewardship. E.O. 13514 includes product efficiency and stewardship. Federal agencies must:

Ensure 95% of new contract actions, task orders, and delivery orders for products and services (excluding weapon systems) are energy efficient (ENERGY STAR® or Federal Energy Management Program (FEMP)-designated) water efficient, bio-based, environmentally preferable (Electronic Product Environmental Assessment Tool (EPEAT) certified), non-ozone depleting, contain recycled content, or are non-toxic or less-toxic alternatives where such products and services meet agency performance requirements. Implement best management practices for the energy-efficient management of servers and Federal data centers.

The Energy Policy Act of 2005 requires a 30% annual energy cost reduction against American Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE) 90.1-2004. The CFPB’s current headquarters is a minimally compliant building, discounting the plug loads. LEED 2009 requires that renovations to the existing building be designed to achieve at least 5% energy cost reduction as compared to an ASHRAE 90.1-2007 model.

Affected Areas The proposed action will affect the entire building and plaza area at 1700 G Street, NW, Washington DC.

Potential Consequences HVAC and other mechanical systems are on site and slated for renovation, and would improve existing mechanical systems to varying degrees depending on which concept is selected. Low-energy, long-life bulbs are to be used in overhead lighting fixtures. The proposed lighting design is expected to give a 20% reduction in lighting power density as compared to the baseline.


3.18 Local Antennas

Affected Areas The proposed action on the rooftop will affect some of the lightning rods, mainly those currently present in the area planned for the childcare play area. Most of the rods, as shown below, are located at the perimeter of the rooftop. The only other antenna on the rooftop of the building is an old TV antenna, which is probably no longer in use.

Figure 3-11 Lightning Rods Along The Rooftop

Potential Consequences The lightning rods present in the area for the proposed childcare play area should not be accessible to the children or staff due to the proposed 8 foot tall limestone wall. Any remaining lightning rods outside the childcare area can remain in place if in good condition.

3.19 Cellular Tower Locations Cellular Towers generate a radiofrequency (RF), which is non-ionizing, meaning it is not strong enough to normally affect a person's physical health. RF can be dangerous at very high levels because it creates heat, and has the ability to heat tissue rapidly; similar to how a microwave oven cooks food. Cell phones and wireless networks produce RF, but not at levels that can cause significant heating. For cell towers, RF energy decreases rapidly with distance and ground-level exposures are typically well below exposure limits set by the Federal Communications Commission (FCC). The quantity used to measure the rate at which RF energy is actually absorbed in a body is called the "Specific Absorption Rate" or "SAR." A standing ungrounded human adult absorbs RF energy at a maximum rate when the frequency of the RF radiation is in the range of about 70 megahertz (MHz). RF safety standards are generally most restrictive in the frequency range of about 30 to 300 MHz. Cellular towers typically transmit using frequencies between 824 and 894 MHz. At relatively low levels of exposure to RF radiation, i.e., levels lower than those that would produce significant heating; the evidence for production of harmful biological effects is ambiguous and unproven. Such effects, if they exist, have been referred to as "non-thermal"

APPENDIX - 16



effects. The health effect of electromagnetic radiation can be divide into thermal (heating) and non-thermal. Non thermal affects on the cells, genes and DNA are more harmful than the thermal effect. Children are more vulnerable due to a developing immune system and thinner skulls which allows radiation to penetrate deeper. A number of reports have appeared in the scientific literature describing the observation of a range of biological effects resulting from exposure to low-levels of RF energy. However, in most cases, further experimental research has been unable to reproduce these effects. When cellular antennas are mounted at rooftop locations it is possible to encounter RF levels greater than encountered on the ground. However, exposures approaching or exceeding the safety guidelines are only likely to be encountered very close to and directly in front of the antennas. Measurements made near tower-mounted antennas have shown that ground-level power densities are thousands of times less than the FCC's limits for safe exposure. This makes it extremely unlikely for exposure to RF levels to be in excess of FCC guidelines due solely to antenna location.

Affected Areas There are three registered cell phone towers located in Washington DC. As shown on the following figure, the closest tower is over 1.5 miles with the other towers being farther away.

Figure 3-12 Map of Subject Site (black star) and Cell Phone Towers (red balloons)


Table 3-2 - FCC Registered Cell Phone Tower Location 900 V Street NE,

Washington DC, 20018 2001 East Capitol Street SE, Washington, DC, 20003

1372 E St NE Washington, DC 20002

Owner Verizon Wireless Verizon Wireless Verizon Wireless Height 32.9 meters 32.6 meters 19.5 meters Frequencies 880.020 MHz, 880.020

MHz, 880.020 MHz, 835.020 MHz, 835.020 MHz, 835.020 MHz, 891.510 MHz, 891.510 MHz, 891.510 MHz, 846.510 MHz, 846.510 MHz, 846.510 MHz

880.020 MHz, 880.020 MHz, 880.020 MHz, 835.020 MHz, 835.020 MHz, 835.020 MHz, 891.510 MHz, 891.510 MHz, 891.510 MHz, 846.510 MHz, 846.510 MHz, 846.510 MHz

880.020 MHz, 880.020 MHz, 880.020 MHz, 835.020 MHz, 835.020 MHz, 835.020 MHz, 891.510 MHz, 891.510 MHz, 891.510 MHz, 846.510 MHz, 846.510 MHz, 846.510 MHz

License Start and End Date

11/15/2004 - 10/01/2014 11/15/2004 - 10/01/2014 11/15/2004 - 10/01/2014

Potential Consequences With cellular towers over a mile and a half from the subject site, RF signals are expected to lose most of their intensity and minimize the risk of being absorbed into the body. Additionally, the frequency used by the cellular towers broadcast is at a higher frequency (846.51-880.02 MHz) than what calls for normal safety standards (30-300 MHz).

3.20 Impact to Pedestrians and Bicyclists

Affected Areas Pedestrian pathways include sidewalks, breezeways and a plaza. On the building’s street facing sides are wide sidewalks and street trees. Breezeways through the ground level of the building connect the plaza with the sidewalks. There is a shared plaza with the neighboring Winder Building. The plaza is included in the renovation plans. Although there are planned bicycle lanes for the adjacent streets, these have not yet been implemented.

Potential Consequences Construction perimeters and other barriers set up around the site of the proposed action may partially or wholly block and impede surrounding sidewalks from pedestrian traffic, making redirection necessary. After construction, pathways will be unobstructed.

3.21 Vehicle Traffic

Affected Areas 1700 G Street, NW is located in a highly developed urban portion of Washington DC. The site shares a plaza with the Winder Building. It is bounded by G Street to the north, 17th Street on the east, the Winder Building to the south (which shares a plaza), and a retail/office building on the west. 17th Street, a two-way street with three northbound and two southbound lanes, is moderately busy, averaging around 20,500 vehicles a day in the area adjacent to the building. G Street NW is one-way westbound with two traffic lanes and metered premium demand parking lanes on each

APPENDIX - 17



side, averaging around 4,100 vehicles daily. The side including the parking garage entrance and a café faces onto F Street NW, which is one-way eastbound with two traffic lanes and metered premium demand parking lanes on each side, averaging around 3,400 vehicles daily.

Potential Consequences Construction may cause increased traffic congestion especially during busy periods. For safety reasons, barriers should be constructed around work areas. There is a possibility that such safety barriers may extend into a parking or traffic lane of the road. In addition, vehicles related to the work may cause congestion or periodically impede the flow of vehicular and pedestrian traffic. Traffic should only be adversely affected temporarily during the course of construction.

3.22 Relationship of Local Short-term Uses vs. Long-term Productivity Council on Environmental Quality regulations that implement the procedural requirements of NEPA requires consideration of the relationship between short-term uses of man's environment and the maintenance and enhancement of long-term productivity (40 CFR 1502.16).

Affected Areas The proposed action will affect the subject site and plaza. The proposed renovation would include improvements to employee spaces, sustainable construction, and an increase in green space. During the proposed action, workers for the CFPB will continue their work at another facility.

Potential Consequences Due to workers relocating to a nearby building, work conducted by the CFPB is unlikely to be stalled during the course of the proposed action. After the proposed action is complete, the larger building and increased square footage can allow the CFPB to accommodate more employees than it does currently. The building is also expected to be LEED Certified Gold, utilizing fewer resources to operate over the long-term use of the building.

3.23 Irreversible and Irretrievable Commitment of Resources There would be an irretrievable commitment of materials for equipment at the proposed project site. CFPB asserts that the irreversible and irretrievable commitment of resources does not exceed any extraordinary amount as could be associated with any other type of major building improvement project.


4.0 SUMMARY OF IMPACTS

4.1 Cumulative Impacts Council on Environmental Quality regulations stipulate that the cumulative impacts analysis in an EA consider the potential environmental impacts resulting from the incremental impacts of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such actions (40 CFR 1508.7). Because the impacts of the proposed project generally would be minor and localized (see Section 3), the CFPB focused this evaluation of cumulative impacts on activities immediately surrounding the proposed project site and other past, present, and reasonably foreseeable future actions on and around the CFPB building. In this analysis of cumulative impacts, the CFPB determined that only impacts to air quality, noise and water resources from past, present, and reasonably foreseeable actions near the project site would be cumulative with the renovation of the building. Impacts of the proposed project to other resources would be negligible or would not occur. Therefore, based upon the context and intensity of the impacts, the building renovation project does not establish any future actions with significant effects.

4.2 Air Quality The proposed action of redevelopment would cause emissions of particulate matter and other pollutants in the project area. However, emissions from the construction project would be temporary. The energy efficiency improvements for the building, installation of the green roof and upgrades to the plaza would contribute to independence from fossil fuel for energy, which would contribute to the beneficial cumulative impact on air quality by reducing air emissions from traditional power generating sources.

4.3 Noise The proposed action would add to the cumulative noise generated in the area. The contribution of the proposed action to the noise in the area is expected to be temporary and only occur during daytime hours. Noise from these various sources may not occur at the same time, but they could all contribute to the amount of time that people in the area would be exposed to the sounds of construction.

4.3 Water Resources The site of the proposed action is located in a highly urbanized area of Washington DC. Most storm water is from onsite is directed to the municipal storm water system before entering local waterways. The site is not located near wetlands or floodplains. BMPs and other efforts to reduce storm water runoff and erosion on the site are to be in place before construction is to begin. The proposed action will include installation of a green roof and a renovated plaza which will increase the amount of green space at the building site. These improvements will reduce runoff and increase water filtration, contributing to the beneficial cumulative impact on water resources.

APPENDIX - 18



4.4 Potential for Public Controversy During the course of the proposed action, there is the potential for local public controversy from temporary impediment of local traffic and lack of access to retailers on the ground floor of the site of the proposed action. This will be done for the safety of workers and the public, and will be temporary in nature. For the proposed action site, the front of the building along 17th Street will be at the maximum allowable height of 90 feet. It is anticipated the final building's appearance will not negatively influence the surrounding area and nearby buildings. No new antennas, aside from possibly new lightning rods, are planned to be installed on the building. The cellular towers are not expected to affect the site due to the frequency of their broadcast and distance. The improvements to perimeter security should not have a large impact due to most features consisting of keeping in place or upgrading current systems. The planned bollards for the northern entrance will not negatively affect visual appeal and pedestrian access. After the proposed action is complete, the public should be able to resume normal activities at the site.


5.0 CONCLUSION The proposed action is to renovate the interior and plaza space and to provide more space to the building located at 1700 G Street, NW, Washington DC, 20552, currently used by the CFPB as its headquarters. Tetrahedron, Inc. concludes the following about the potential environmental impacts of its proposed action:

Implementation of the proposed action would overall involve no potential for significant environmental impacts. Impacts to the environment will occur during the proposed action and steps will be taken to limit their influence. After the proposed action is complete, the improvements to the structure are anticipated to have an overall positive environmental impact. Normal building operations do not normally generate air emissions. There will be an increase in air pollutants during the proposed action as construction equipment is used and demolition occurs. After the proposed action is complete, the increase in green space on the site will improve local air quality. Current security features will either remain in place (vehicular plate barriers), or receive possible upgrades. An anti-ram device is planned for the main entrance to the building, but it has yet to be designed. After the proposed action is complete, the building will be rated LEED Gold, in part from the numerous energy efficiency improvements to be installed. Therefore, the proposed action would slightly reduce regional greenhouse gas emissions. Construction activities during the proposed action would cause a negligible increase in noise volumes. After the proposed action is complete, noise levels are expected to return to normal. The aesthetics of the area would look the same to the casual observer. The building will remain at its current height and appear the same from the street, aside from new glass walls, windows and lobby. From the interior plaza, a portion of the barrier wall for the childcare play area on the rooftop will be visible. The necessary controls on runoff to ensure there would be no erosion or sedimentation issues are to be in place before the proposed action is to take place. The project location does not involve wetlands or floodplains. Positive impacts to the local watershed are expected due to decreased storm water and higher quality storm water due to filtration of the proposed green roof and other improvements. The proposed project would have no effect on species protected under the Federal Endangered Species Act, and there is no reason to suspect the project site has unique habitat for any protected or rare species. No impacts to wetlands are expected to occur since the closest wetlands are a mile away and do not extend to the project site. No work will be conducted on neighboring historic buildings. No new antennas, aside from lightning rods, are planned for construction at the site. Any impacts from cellular towers to the inhabitants of the building will be non-existent. Relative to the cumulative changes in the environment that would be caused by the proposed project in combination with other planned activities nearby, the implementation of the proposed action would cause minor, adverse incremental changes to air quality and noise during construction. The proposed project would result in small, beneficial,

APPENDIX - 19



incremental impacts to aesthetics, the region’s water quality by reducing storm water runoff and air quality during operation by reducing greenhouse gas emissions. Under the No-Action Alternative, there would be no site improvements to the building or plaza at the site. For comparison purposes, it is assumed no impacts to the existing environment would occur, and any beneficial impacts of the proposed project would not be realized.

Based on the review and analysis of materials, a Finding of No Significant Impact for the proposed action at 1700 G Street, NW, Washington DC, 20552 is recommended. Due to the temporary nature of the project, environmental or public disturbances will be short-term. Many of the renovations, such as noise damping materials and a green roof, will prove to be beneficial to the tenants, workers and the public over the long term.


6.0 REFERENCES

1. District of Columbia Historic Preservation Office, 1100 4th Street SW, Suite E650 Washington, DC 20024

2. Environmental FirstSearch, 1709 New York Avenue, NW, Washington, DC 20006,

November 16, 2010.

3. National Wetland Inventory Maps, U.S. Fish and Wildlife Service http://wetlandsfws.er.usgs.gov/wtlnds/launch.html

4. Property Quest, Real Property Data, Aerial Photographs, District of Columbia,

www.dc.gov

5. USGS 7.5-minute Series Topographic Map, Washington West, DC Quadrangle, Scale, 1:24,000, Contour Interval 10', 1965 Photo revised 1983.

6. U.S. Census Bureau, 2000 Demographic Information http://www.census.gov/

7. U.S. Environmental Protection Agency, Nonattainment Ozone Areas, www.epa.gov

8. Wild and Scenic Rivers Website http://www.rivers.gov/

9. U.S. Department of Transportation, Federal Highway Administration, Policy and

Procedure Memorandum 90-2, Noise Standards and Procedures (February 8,1973)

10. Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, October 2009. http://www.whitehouse.gov/assets/documents/2009fedleader_eo_rel.pdf

11. Executive Order 13423, Strengthening Federal Environmental, Energy, and

Transportation Management, Signed January 24, 2007. http://www.gpo.gov/fdsys/pkg/FR-2007-01-26/pdf/07-374.pdf

12. Energy Independence and Security Act of 2007. H.R. 6 (110th).

http://www.gpo.gov/fdsys/pkg/PLAW-110publ140/pdf/PLAW-110publ140.pdf

13. Energy Policy Act of 2005 (Pub.L. 109–58), July 29, 2005. http://www.gpo.gov/fdsys/pkg/PLAW-109publ58/pdf/PLAW-109publ58.pdf

14. NEPA Regulations, 40 CFR Parts 1500-1508, Section 1502.16 (e). 43 FR 56003, Nov.

29, 1978 and 44 FR 874, Jan. 3, 1979. http://ceq.hss.doe.gov/ceq_regulations/Council_on_Environmental_Quality_Regulations.pdf

APPENDIX - 20



15. ASHRAE 90.1-2007. Energy Standard for Buildings Except Low-Rise Residential Buildings, 2007.

16. ASHRAE 90.1-2010. Energy Standard for Buildings Except Low-Rise Residential

Buildings, 2010. https://www.ashrae.org/resources--publications/bookstore/standard-90-1#2010

17. Resource Conservation and Recovery Act (RCRA), 1976. http://www.epa.gov/epawaste/inforesources/data/index.htm

18. Clean Water Act of 1976. http://cfpub.epa.gov/npdes/cwa.cfm?program_id=45

19. District of Columbia Municipality Regulations (DCMR); Chapter 5 (Water Quality and

Pollution) of Title 21 (Water and Sanitation) http://ddoe.dc.gov/sites/default/files/dc/sites/ddoe/publication/attachments/Water%20Quality-title21-chapter5.pdf

20. Regulations Handbook:, Department of Consumer and Regulatory Affairs, 1100 4th

Street SW Washington, DC 20024.http://dc.gov/DC/DCRA/Inspections/Trash+Truck+Noise+Complaints/Noise+Regulations+Handbook.

21. Occupational Safety and Health Administration (OSHA) regulations 29 CFR Part 1920

addresses workplace noise, additional information can be found at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9735.

22. DDOT. January 3, 2012. “DC Meter Rates and Hours Operations Map”

http://ddot.dc.gov/DC/DDOT/Publication%20Files/On%20Your%20Street/Traffic%20Management/Parking/Parking%20Meters/DC_MeterRates-and-HoursOperations_Map.pdf

23. DDOT. March 2012. “2010 Traffic Volumes” http://ddot.dc.gov/DC/DDOT/About+DDOT/Maps/Traffic+Volume+Map+2010

24. DDOT. 2005. “District of Columbia Bicycle Master Plan” http://ddot.dc.gov/DC/DDOT/On+Your+Street/Bicycles+and+Pedestrians/Bicycles/Bicycle+Master+Plan/DC+Bicycle+Master+Plan+-+April+2005

25. Review of the Public Buildings Cooperative Use Act of 1976 and Its Implementations, LCD-79-302, Jan 25, 1979

26. Paul H. (1977). New GSA Building Has Ice Rink, Café. Washington Post

27. ANSI-C95.1, 1982, American National Standards Institute. American national standard safety levels with respect to human exposure to radiofrequency electromagnetic fields, 300 kHz to 100 Ghz. New York: IEEE.


28. Baan R, Grosse Y, Lauby-Secretan B, El Ghissassi F, Bouvard V, Benbrahim-Tallaa L,

Guha N, Islami F, Galichet L, Straif K; WHO International Agency for Research on Cancer Monograph Working Group. Carcinogenicity of radiofrequency electromagnetic fields. Lancet Oncol. 2011 Jul;12(7):624-626.

APPENDIX - 21


Appendix A

Historical Documents

Appendix A-1

State Historic Preservation Officer for the District of Columbia Listings (Current as of March 2011)

APPENDIX - 22


APPENDIX - 23


(and interior)

APPENDIX - 24


(and interior)

APPENDIX - 25


APPENDIX - 26


APPENDIX - 27


APPENDIX - 28


(and interior)

(& interior)

(and interior)

APPENDIX - 29


APPENDIX - 30


APPENDIX - 31


APPENDIX - 32


APPENDIX - 33


(and interior)

interior pending

(and interior)

(and interior of arcade)

APPENDIX - 34


Philadelphia

APPENDIX - 35


APPENDIX - 36


APPENDIX - 37


(and interior)

(and interior)

APPENDIX - 38


(and interior)

(and interior)

APPENDIX - 39


(and interior)

(and interior)

APPENDIX - 40


APPENDIX - 41


APPENDIX - 42


(and interior)

APPENDIX - 43


(and interior)

APPENDIX - 44


Appendix A-2

Newspaper Articles Documenting Building

APPENDIX - 45


APPENDIX - 46


APPENDIX - 47


APPENDIX - 48


APPENDIX - 49


APPENDIX - 50


APPENDIX - 51


1

DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM

PROPERTY INFORMATION

Property Name(s): 1700 G Street, NW; Federal Home Loan Bank Board (FHLBB) Building; Consumer Financial Protection Bureau (CFPB) Building

Street Address: 1700 G Street, NW, Washington, DC 20552 Square(s) and Lot(s): 0169 0832 Property Owner(s): Office of the Comptroller of the Currency (OCC)

North Elevation of 1700 G Street, NW (The Federal Home Loan Bank Board Building).

The property is being evaluated for potential historical significance as:

An individual building or structure: A contributing element of a historic district (specify): A possible expansion of a historic district (specify): A previously unevaluated historic district to be known as (specify): An archaeological resource with site number(s) (specify): An object (e.g. statue, stone marker etc.) (specify): A new multiple property/thematic study regarding (specify): Association with a multiple property/thematic study (specify): Other (specify):

DC STATE HISTORIC PRESERVATION OFFICE DETERMINATION OF ELIGIBILITY FORM FHLBB BUILDING, 1700 G STREET, NW

2

Location of 1700 G Street, NW on the Washington, D.C. Real Property Map (Office of the Chief

Technology Officer 2013).

Location of 1700 G Street on the 2013 Bing Aerial (Bing 2013).

Description, rationale for determination, photos & other pertinent information (enter below):

Introduction

The office building at 1700 G Street, NW, currently occupied by the Consumer Financial Protection Bureau (CFPB), was originally designed by Max Urbahn Associates (now Urbahn Architects) and constructed between 1974–1977. The building is immediately west and north of the Winder Building, which is listed in the National Register of Historic Places (NRHP).

1700 G Street, NW

N

1700 G Street, NW

N

APPENDIX - 52

PART E: APPENDIXB. HISTORIC PRESERVATION DOCUMENTATION

DETERMINATION OF ELIGIBILITY (DOE)


3

Methodology for Evaluation as an Individual Landmark

To address the potential individual eligibility of this property, CFPB and Dovetail Cultural Resource Group (Dovetail) consulted key resources as part of a background review to put this building within a historic, social, architectural, and landscape context. This included the General Services Administration (GSA) study Growth, Efficiency, and Modernism: GSA Buildings of the 50s, 60s, and 70s (Robinson & Associates 2005), which provides an in-depth historical context on federal buildings of the Modern era, several newspaper and journal articles on file with the CFPB, books on the development and architecture of Washington, D.C., interviews, and historic maps. To assess the building’s potential eligibility, resources such as the previously mentioned GSA study, the American Institute of Architects Guide to Architecture of Washington, D.C., and the Society of Architectural Historian’s Buildings of the District of Columbia were consulted for a context of other buildings in the area.

Fieldwork was conducted on June 25 and July 11, 2013. The building was evaluated for architectural significance as well as historic and physical integrity. This resource was documented through written notes and digital photography. The information obtained during the survey was then used to create the DOE form and make recommendations on the property’s NRHP potential.

Building Description

The office building at 1700 G Street, NW (known as the Federal Home Loan Bank Board [FHLBB] building) is situated on a parcel of land bounded by G Street, F Street, and 17th Street in the Northwest quadrant of Washington, D.C. It is set back from G and 17th Streets by approximately 30 feet. The Winder Building is situated immediately southeast of the building on the same block and stretches along F Street, and a commercial building at 1776 G Street, NW is at the western boundary. Across 17th Street, the Eisenhower Executive Office Building occupies the entire block.

1700 G Street, NW is a six-story federal office building with a gross area of 345,000 square feet. It consists of two perpendicular wings forming an L shape that also includes a full basement, two parking sub-floors, and a mechanical level on the roof. The structure consists of reinforced concrete clad with shot-sawn, limestone-box panels on all flat surfaces of exterior walls. The design, although angular, is slightly asymmetrical, which allows each elevation to reflect and mimic the neighboring buildings through windows and geometric shapes (Figure 1 and Figure 2, p. 5). The primary entrance to 1700 G Street, NW is located on the northeast corner of the building near the corner of G and 17th Streets. Another entrance is on the opposite side of the lobby with a secondary entrance in the connecting corridor between G Street and the courtyard.

The first story is lined with commercial spaces that are intended for stores and restaurants (Figure 3 and Figure 4, p. 6). The façades of these retail spaces are lined with plate glass windows and accessed by double-leaf, glass doors. The fenestrations are set within narrow, metal frames. Many of the commercial spaces are accentuated by arched, red awnings with the name of the business in white letters. An analysis of old photographs of this building suggests that these awnings are later additions (Figure 5, p. 6). There are three curved windows on the


4

ground level: one located on the southeast corner of the 17th Street elevation, one located on the southeast corner of the F Street elevation, and one on the southeast corner where the two wings of the buildings come together at the northwestern edge of the plaza. The upper levels of the building feature story-height windows around the entire perimeter of the building, inset from the exterior structural face 3 to 5 feet. The 90-foot building bays are joined by vertical light wells from the second to sixth floors to skylights in the roof. The building architect, Martin Stein, recently stated that the story-high recessed windows around the building were intended to “fill the office space with a maximum of natural light” (Stein 2013). Outdoor terraces or verandas are located at the ends of each building wing on the sixth floor. An additional sky-lit room is located in the east wing on the sixth floor.

The exterior building design has not been altered over time, but the office interiors are no longer an open workplace as originally designed. Portable and temporary partitions have divided the space into small office cubicles. Overall, the exterior of 1700 G Street, NW is in good condition with little wear to concrete and limestone surfaces.

Figure 1: North Elevation of the FHLBB Building.

APPENDIX - 53




5

Figure 2: Columns on the Corner of the FHLBB Building. These mirror the size and

shape of those on the Eisenhower Executive Office Building.

Figure 3: Ground Level Plan of the FHLBB Building (Comptroller General

of the United States [CGUS] 1978:10)


6

Figure 4: Ground Level of the FHLBB Building (left) and Sixth Floor Veranda (Right).

Figure 5: View of the FHLBB Building, Winder Building, and Liberty Plaza Looking

West from 17th Street, NW. The picture on the left was taken during the early 1990s and the one on the right was taken during the June 2013 fieldwork. These pictures suggest that the red

awnings are a later addition (Scott and Lee 1993:206).

The ground floor houses the main entrance lobby of the CFPB and a variety of shops facing G Street, F Street, and the courtyard. The lobby is accessed by doors on the north (G Street) and south (Liberty Plaza) sides and lined with floor-to-ceiling, plate-glass windows and coffered wood that covers the ceiling. The brickwork visible on the exterior is continued on the interior which creates a blurring of the exterior and interior spaces. Surrounding the bricks are pebbles and potted plants and the ceiling is covered by a dropped, wooden, geometric ceiling that reflects the coffering found on the exterior and interior of the building (Figure 6, p. 7). A circular-shaped staircase that connects the lobby to the second floor is located west of the lobby behind the security station. This feature is made of light-brown, blonde-colored wood that ties into the other wooden elements of the building (Figure 7, p. 7). Beyond the staircase is an elevator shaft

Red Awnings No Awnings

APPENDIX - 54




7

that features the original light switch, call box, and textured metal pattern on the interior (Figure 8, p. 8).

It is suggested that much of the lobby décor—the brickwork, potted plants, coffered wood work on the ceiling, and the staircase—was added after the 1976 construction date. At the time of this project, that fact can neither be confirmed nor denied; however, it is important to note that these elements were designed and installed in a way that reflected some of the architectural ideals and trends present when the FHLBB building was built such as curvilinear features, light-colored wood, the blending of the plaza and the lobby spaces, and an overall aesthetic feel that was common during the late 1970s.

Figure 6: Lobby of the FHLBB Building, Looking South.

Figure 7: Security Station and Staircase (Left) and Staircase and Elevators (Right).


8

Figure 8: Detail of the Original Elevator Elements and Limestone Blocks.

The second through sixth floors are, for the most part, designed to be identical. Each features two atria, which extend from a skylight at the sixth floor ceiling to the second floor and are lined with fixed, light-colored wood planters (Figure 9, p. 9). The second level has an auditorium at the east elevation which is believed to be significantly altered from its original design. The linear room has built-in, curvilinear elements, terraced, carpeted levels for seating, and an arched, wooden stage.

Each floor between the second and the sixth is filled with cubical offices and meeting spaces that have carpet on the floor and slatted-wood ceilings (Figure 10, p. 10; Figure 11, p. 10). The office spaces were developed as open workplaces with maximum flexibility to accommodate a changing and growing workforce. As originally designed, the interior levels are covered by a 4-inch high, raised floors which accommodate and provide access to the distribution of electrical and communications systems wiring. Each floor also features men’s and women’s bathrooms that are covered in square tiles (Figure 12, p. 11).

APPENDIX - 55




9

Figure 9: View of Atrium from the Sixth Floor Looking Down to the Second Floor.


10

Figure 10: Auditorium on the Second Floor, Looking North.

Figure 11: Overview of Materials Used on Second through Sixth Levels of the FHLBB Building.

APPENDIX - 56




11

Figure 12: View of the Use of Tiles In and Around the Bathrooms.

The basement, which once functioned, in part, as a cafeteria, is now used as a mail room, library, offices, fitness center, and child-care area. The walls of this part of the building are covered in a brick, stretcher-bond veneer and the ceilings are lined with the same slatted material seen on other floors (Figure 13). Light wells or skylights penetrate the ceilings along the building perimeter. Levels P1 and P2 allow parking for 220 cars and provide space for mechanical and electrical building components and storage areas. The parking garage is accessed through an F Street down ramp entrance and the garage exit ramps up to G Street. The interior remains in relatively good condition, although it does show signs of aging and wear over time.

Figure 13: Overview of the Basement.


12

Liberty Plaza and the landscape around the FHLBB and adjacent Winder Building were designed by Sasaki Associates. The plaza is located southeast of the FHLBB building and functions as a courtyard for employees, the shops along the ground level, and has several access points to 17th Street, F Street, and G Street. Two of these pedestrian access locations are covered by solid, unpunctured concrete sections of the building; the ceilings of these covered areas are formed of coffered concrete. The brick-lined plaza once boasted an ice rink/reflecting pool, tables with umbrellas, plentiful vegetation, and a “plant festooned indoor portion” of the café called the Galleria. Today, the area that functioned as an ice rink in the winter and a reflecting pool in the summer has no water in it but the outline and shape are still visible, and a small waterfall feature is located on the western side. The built-in planters and vegetation are still intact; trees in triangular planters line the northwest side of the plaza and three sets of paired circular planters are situated at the east side. The Galleria, a partially covered structure, continues to line the north elevation of the Winder Building; however, it is no longer filled with plants. None of the tables, chairs, or umbrellas remain in the plaza (Figure 14–Figure 16, pp. 12–13). There are two lower (disconnected) levels to the plaza. The level near the 17th Street entrance features vegetation, brick planters, and four bronze medallions on its southern wall which were removed from the demolished Riggs Bank Building that once stood on the site of the FHLBB Building (Figure 17, p. 13). The lower level on the western side of the plaza behind the former ice-skating rink once functioned as an access to a cafeteria located in the basement. A set of stairs extends from the ground to lower level and a fountain with bronze cannon-like features is situated in the center of this basement level (Figure 17, p. 13).

Figure 14: Site Plan of the Liberty Plaza. The red, dashed line marks

the location of the plaza (Uncited journal article nd).

APPENDIX - 57




13

Figure 15: Looking Southwest at Liberty Plaza. Note the triangular and circular planters.

Figure 16: View of the Galleria, Looking Northeast.

Figure 17: Two of the Four Bronze Medallions on the Eastern Plaza Wall (Left) and the Water

Feature on the West Side of Plaza (Right).


14

Site and Building Chronology

The office building at 1700 G Street, NW was built in the mid-1970s, near the end of an architectural movement referred to as mid-century Modern. Beginning in World War II architecture in Washington, D.C., especially Federal building architecture, drastically changed. By the mid-twentieth century “what may be considered the first wave of Modern-era buildings was largely coming to a close—the “Moderne” styles of Art Deco, Streamlined Moderne, and Stripped Classical generally dated from the 1920s to the 1940s…The stage was set for fresh architectural innovation ” (Robinson & Associates 2005:12).

Around this same time, the United States Government was spread throughout the country and it was decided that a single support agency was needed. Established as part of the Federal Property and Administrative Service Act of 1949, the GSA was “formed to achieve the following goals: standardization, direct purchase, mass production, and fiscal savings,” and they would be in charge of creating and providing “the resources needed by United States agencies to accomplish their missions” (Gutheim and Lee 2006:245–249; Robinson & Associates, Inc. 2005:29). Included in their umbrella of services was the task of solving the need for more government office space in some of the major cities across the country, especially Washington, D.C. (Robinson & Associates, Inc. 2005:6, 38).

In the early 1950s, the Federal government started “encouraging Modern design” and introduced the second wave of that architectural movement (Robinson & Associates, Inc. 2005:6, 25). Many times, low construction, maintenance, and decorative costs were a high priority, often resulting in stark, angular, functional buildings.

Unlike predecessor buildings of the nineteenth and early-twentieth centuries, this new wave of Modern architecture and design exhibited “transparent building materials served to visually unite exterior and interior spaces,” smaller offices, which gave way to larger common spaces, the use of “electrical and mechanical innovations and methods and materials—such as steel, glass, plastic, and reinforced concrete—that were previously unavailable” (Robinson & Associates, Inc. 2005:30). Early national examples of this radical shift in design and execution of new buildings include the Lever House, a 1952 office building in New York City; the Seagram Building, constructed by Mies van der Rohe and Philip Johnson in 1958, also in New York City; Yale Art Gallery, a 1953 example of Louis Kahn’s work; and the Washington Dulles Airport, designed by Eero Saarinen (Great Buildings 2013; Metropolitan Washington Airports Authority 2013; Mies van der Rohe Society 2013; Robinson & Associates, Inc. 2005:32; Yale University 2013).

President John F. Kennedy played an important role during this period of American architecture. Reportedly, during his 1961 inaugural parade he noted that many older federal buildings along the north side of Pennsylvania Avenue were vacant, boarded up, or in extremely poor condition; this was in strong contrast to the monumental Federal Triangle on the south side. In June of the following year the Ad Hoc Committee on Federal Office Space reported that “office space in and around Washington was disorderly, inefficient, and wasteful” and “of the 291 buildings occupied by the Government agencies in the area, 66 are obsolete Government-owned buildings, 47 are Government-owned temporary buildings, and 129 are leased buildings” (Robinson & Associates,

APPENDIX - 58




15

Inc. 2005:42). Further, the Ad Hoc Committee suggested “a decade-long program that would eliminate temporary and obsolete buildings while constructing a minimum of 12 new Federal buildings” (Robinson & Associates, Inc. 2005:42). This resulted in the demolition of entire blocks, giving the government the freedom and space to develop new office buildings.

In response, in part, to the major changes being made to the historic urban landscapes, Congress passed the National Historic Preservation Act (NHPA) in 1966 (Robinson & Associates, Inc. 2005:50; Stipe 2003). Two sections became extremely important in the Federal government’s development of inner-city office buildings: Section 106 and Section 110. Section 106 requires that the effects of a Federal undertaking on any district, site, building, structure, or object that is included in or eligible for inclusion in the NRHP be taken into account. Furthermore, it states that the agency must provide the Advisory Council on Historic Preservation (Advisory Council) a reasonable opportunity to comment regarding the undertaking (Advisory Council 1966). Section 110 “governs Federal agency programs by providing for consideration of historic preservation in the management of properties under Federal ownership or control” (Advisory Council 2000).

Ten years later, President Richard Nixon’s Task Force on Federal Architecture created the Public Buildings Cooperative Use Act, which helped tie together the previous goals of the GSA as well as historic preservationists. It states that the GSA shall “acquire and utilize space in suitable buildings of historic, architectural, or cultural significance, unless use of such space would not prove feasible and prudent compared with available alternatives” (NPS 1976). In addition to the concept of using historic and extant buildings, this act specifically promoted the idea of allowing multiple uses in many of the Federal buildings. The purpose of this was to “energize streets, offer amenities to Federal employees during work hours, and provide revenue for underused spaces” (Robinson & Associates, Inc. 2006:59). By emphasizing mixed-use in these office buildings on the street level, the government was able to produce a space that was used by its employees as well as members of the surrounding communities. Often, this results in a revitalization of a neighborhood and community and can result in a successful reuse of an extant building.

Amidst all of this was the development of the FHLBB Building on the 1700 block of G Street, NW. During the early 1970s the eastern half of this block comprised four buildings: the Winder Building, an 1847 brick building that once housed the Treasury Department and War Department and is listed in the NRHP; the late-nineteenth century Winder Building Annex; the 1920s Riggs Bank Building; and an early-nineteenth century, Federal-styled townhouse that functioned as the Nicolas Café (Savings and Loan News nd; Taylor 1969). As part of the previously discussed movement to create inner-city office space for federal government employees, GSA was responsible for developing office space for the FHLBB, and in the late 1960s, GSA received approval to acquire land and construct buildings for this agency. In 1968, “GSA purchased land for the building site on each side of Third Street between D and E Streets, NW…The Board indented to use part of the land for its building and part for parking facilities” (Shafer 1974:2). FHLBB desired a location that was closer to Washington’s financial district and requested that GSA look into additional, larger sites; this resulted in the acquisition of the eastern half of the 1700 block of G Street, NW in 1972 (Shafer 1974:2). In late 1973, GSA “issues a preinvitation to bid for the demolition at the 17th Street site to the Commerce Business Daily of the


16

Department of Commerce…GSA received 12 bids ranging from $118,640 to $278,888. The contract for $118,640 was awarded to the lowest bidder, the Julian C. Cohen Salvage Corporation” (Shafer 1974:3).

Once the site was acquired, early building design and construction plans were needed. It seems apparent that FHLBB, as an agency, was interested in a different type of building design—one with a unique interior and exterior concept as well as constructed landscape. They:

asked for and [were] granted permission by GSA's project manager to hire a space planning consulting firm for the interior of the building. FHLBB awarded a contract to Hunter/Miller Associates, Incorporated, in March 1975 to design the building's interior. That contract was subsequently terminated by FHLBB and another contract was awarded to Max O. Urbahn Associates, Incorporated. FHLBB contracted with Tate Architectural Products, Incorporated, to finish the interior, and with numerous other firms for furnishings, equipment, and other services for the building. GSA hired Max Urbahn Associates to design the building and Sasaki Associates to determine the layout and landscape of the surrounding site (CGUS 1978:3).

Max Urbahn Associates, a New York City-based firm, was founded by Max O. Urbahn in 1946. Prior to opening his own firm, he worked for Eggers and Higgins, the successor architecture firm to John Russell Pop, and was an important member of the firm and was involved in the firm’s design for the Jefferson Memorial in D.C. Later he went on to become the President of the American Institute of Architects (AIA) (The New York Times 1995). Max Urbahn Associates designed 909 Third Avenue in New York City, Fermi National Accelerator Laboratory Complex in Champaign, Illinois, Lincoln Hospital in Bronx, New York, NASA’s Vehicle Assembly Building in Cape Canaveral, Florida, and Junior High School 144 in the Bronx, New York (Figure 18) (The New York Times 1995: Urbahn Architects 2013).

Figure 18: Max Urbahn Associates-Designed Buildings 909 Third Street in New York City

(Left) and the NASA Vehicle Assembly Building (Right) (NASA 1999; Vornado Realty Trust 2013).

APPENDIX - 59




17

Following the National Capital Planning Commission’s (NCPC) recommendations in June of 1973, their plans called for height restrictions and façade treatment that would be compatible and sympathetic to the neighboring historic buildings, specifically the Winder Building and the Eisenhower Executive Office Building, located just east of the FHLBB building on the opposite side of 17th Street, NW. Early plans also called for mixed-use of the building’s street level and an outdoor plaza (called Liberty Plaza), both of which had the intent of bringing the general public and the Federal employees together in the same space:

GSA and FHLBB have selected an alternative concept for development of the site which…incorporates two levels of commercial development at grade, opening both on the streets and into the court or plaza formed by the Winder Building and the FHLBB building. This design reflects the determination to provide a public amenity in the form of a spacious, vibrant plaza alive during the day and evenings hours, which will revitalize this area in the city (NCPC 1973).

As regulated by the NHPA, in 1973 GSA informed the Advisory Council of their plans, which involved demolition of all buildings except the Winder Building; on January 31, 1974 they entered into a contract for demolition. Almost immediately, the Advisory Council expressed its concern about the future of the historic buildings on this site, both those that would be directly impacted by demolition and the Winder Building, whose feeling, association, and setting would be affected. Furthermore, it felt that the Riggs Bank Building, early-nineteenth century townhouse, and Winder Annex had the potential to be eligible for the NRHP. The Secretary of Interior reviewed the buildings, concurred with the Advisory Council, and determined that the buildings possessed enough historic and architectural significance to be eligible for the NRHP, which made this project subject to Executive Order No. 11593. This order required the Federal government to:

(1) administer the cultural properties under their control in a spirit of stewardship and trusteeship for future generations, (2) initiate measures necessary to direct their policies, plans and programs in such a way that federally owned sites, structures, and objects of historical, architectural or archaeological significance are preserved, restored, and maintained for the inspiration and benefit of the people, and (3), in consultation with the Advisory Council on Historic Preservation (16 U.S.C. 470i), institute procedures to assure that Federal plans and programs contribute to the preservation and enhancement of non-federally owned sites, structures and objects of historical, architectural or archaeological significance (National Archives 2013).

In late-February of 1974, GSA met with the Advisory Council and it agreed to discuss possible ways to minimize the adverse effect on the listed and eligible properties before continuing with its demolition plans. However, on Sunday, March 3, 1974, wreckers were sent to the site. They demolished the townhouse, destroyed all but the façade of the Riggs Bank Building, and pierced the roof of the Winder Building Annex before the Advisory Council could obtain a restraining order. Immediately, a citizen’s group called Don’t Tear it Down, Inc. sued the GSA; however, the court ultimately ruled the following (Advisory Council 1975):

The court dismisses the injunctive action brought to the General Services Administration from completing destruction of certain historically significant


18

buildings in Washington, D.C. without first consulting the Advisory Council on Historic Preservation, as required by the National Historic Preservation Act of 1966. The court spreads upon the record the equivocal maneuvers which enabled the GSA to cause substantial damage to the buildings before plaintiffs could secure a temporary restraining order banning further demolition. Subsequently, however, the GSA formally complied with the consultation requirement of the National Historic Preservation Act. Therefore, although defendants’ acts so damaged the buildings that they were beyond salvage, the court concludes that the action is moot.

Following this decision, GSA continued with the construction of the FHLBB building. They took their existing plans and, in light of the major controversy, put even more emphasis on incorporating citizen’s thoughts and concerns into the building’s development. GSA, Max Urbahn Associates, and Sasaki Associates designed a building that was at the forefront of this movement—sometimes referred to as Contextualism— among Federal buildings in Washington, D.C. The development of this site came on the heels of the Modern-era Brutalist style, which populated the city’s landscape with stark, hard buildings that were often designed without regard to their pre-existing surroundings, such as Third Church of Christ, Scientist, Robert C. Weaver Building, and the Forrestal Building near L’Enfant Plaza (Gutheim and Lee 2006:271–275; Robinson & Associates 2003).

Architecturally, the FHLBB building was designed to be sympathetic to the surrounding landscape and streetscape. The color matches that of the neighboring Winder Building; furthermore, the height and bulk of the building were monitored and designed to complement the Winder Building, not to overwhelm the surrounding extant historic buildings. In addition, the overall scale of the building was diminished by “making the wall around its top veranda level with the Winder’s cornice” (Savings and Loan News nd). The horizontal concrete features on the façade line up almost perfectly with the windows of the Winder Building, giving this part of F Street a cohesive appearance and feel despite the nearly 120-year age difference between the two buildings (Figure 19). The design was also meant to be sympathetic to the Eisenhower Executive Office Building. Martin Stein, current Managing Partner for Max Urbahn Architects (formerly Associates), stated that “the building design was essentially a modern-style copy of the building materials and character of the Eisenhower Executive Office Building, which is located across 17th Street from 1700 G Street, NW” (Stein 2013). The east elevation of the FHLBB building was designed to mirror, in an abstract way, the historic building across the street. The central, projecting pavilion on the Eisenhower Executive Office Building was replicated using window design on the FHLBB building. The color of the building and the concrete columns pay homage to and play off of the neighboring historic office building (Figure 20, p. 19) (Moller, Jr. 2012:150; Uncited journal article nd).

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19

Figure 19: Looking East Along F Street, NW Toward 17th Street. Note how the horizontal

elements of the FHLBB building are similar to those of the Winder Building.

Figure 20: View of 17th Street, NW Looking South. The Eisenhower Executive Office Building

is on the left and the FHLBB Building is on the right. The yellow arrows note the way both buildings emphasize the central projecting primary elevation. The red arrows point out the use

of single-story columns on both buildings.

The building design and the site’s landscape were developed to encourage a sense of community. Although the Liberty Plaza itself demonstrates an attempt to reach out to the public, this was a design concept that had already been done in other earlier Modern buildings around Washington, D.C. What set this project apart from previous undertakings are the additional details and elements. As previously mentioned, the street level was filled with shops and restaurants; some sources state that this was the first completed Federal building to do this (Figure 21, p. 20) (Moller, Jr. 2012; Savings and Loan News nd). In addition, the plaza featured an ice rink, which functioned as a reflecting pool in the summer, to be surrounded by tables and chairs covered by brightly colored umbrellas (Figure 22, p. 20) (Hodge 1977:1–2). Sasaki Associates created a “greenhouse-like structure called a galleria [that] runs almost the full length of the [Winder]

FHLBB Building

Winder Building


20

building. The galleria reaches to the Winder’s second story and will serve as the plant festooned indoor portion of the courtyard’s café” (Figure 23, p. 21) (Savings and Loan News nd).

Figure 21: View of the FHLBB Building, Winder Building, and Liberty Plaza Looking

West from 17th Street, NW in the early 1990s (Scott and Lee 1993:206).

Figure 22: Former Ice Skating Rink at Liberty Plaza with the

FHLBB Building in the Background, Circa 1978 (Uncited journal article nd).

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21

Figure 23: Circa-1976 Drawing of the Proposed Liberty Plaza and Galleria

(Savings and Loan News nd).

Also, Max Urbahn Associates, along with the engineering firm, Syska and Hennessey, designed the building to be environmentally sensitive. Instead of large, overhead lights, each work space was lit using desk or office lamps, three air systems were used instead of two, variable ventilation and unheated air was used for the parking garages, large and angled windows to capture even the low, winter sunlight, lukewarm water was provided in bathrooms instead of both hot and cold, the masonry walls were insulated, and the windows were either double glazed or had insulated panels on the back (Architectural Record nd).

As part of the mitigation efforts for the demolition of the historic building on the block, GSA and Max Urbahn Associates also worked together to restore, rehabilitate, and sensitively update the Winder Building. They completed restoration in 1976. The building:

included air conditioning, heat, and general ventilation. To satisfy the fire safety codes, the stairwells were enclosed in glass and sprinklers were installed throughout the building. An elevator room was added to the building (the older elevators had been in a different location). Doors were restored to replicate the originals. The intricate wrought iron balcony was restored. The original balcony, which ran along the second floor, had been sold as scrap metal in 1922 (Figure 24) (United States Trade Representative 2013).

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MEMORANDUM OF AGREEMENT AMONG

CONSUMER FINANCIAL PROTECTION BUREAU THE DISTRICT OF COLUMBIA STATE HISTORIC

PRESERVATION OFFICER AND THE ADVISORY COUNCIL ON HISTORIC PRESERVATION

REGARDING THE FEDERAL HOME LOAN BANK BOARD BUILDING

AT 1700 G STREET, NW IN WASHINGTON, D.C.

WHEREAS, the Consumer Financial Protection Bureau (“CFPB”) proposes to renovate the Federal Home Loan Bank Board (“FHLBB”) Building at 1700 G Street, NW in Washington, D.C. including large-scale modifications to the interior of the building and exterior courtyard, and some minor changes to the exterior of the building (the “Undertaking”) (Figures 1 and 2); and WHEREAS, the proposed Undertaking consists of a building that is currently owned and occupied by the Federal Government (the “Property”); and WHEREAS, CFPB has consulted with the District of Columbia State Historic Preservation Officer (“SHPO”) in accordance with Section 106 of the National Historic Preservation Act (“NHPA”) to take into account the effects of the Undertaking on historic properties included in, or eligible for inclusion in, the National Register of Historic Places (“NRHP”); and WHEREAS, pursuant to 36 CFR 800.4(a)(1), CFPB and SHPO have determined that the Area of Potential Effect for the Undertaking is the building footprint, adjacent courtyard, and areas where alterations to the property’s setting and feeling may be visually impacted by the Undertaking (surrounding viewshed as determined by topography, vegetation, and distance); and WHEREAS, the FHLBB is located within the Area of Potential Effect; and WHEREAS, the circa-1974 FHLBB was the subject of an intensive architectural evaluation by Dovetail Cultural Resource Group (“Dovetail”) in June and July 2013 and recorded through a Determination of Eligibility form, which was reviewed by the SHPO in July 2013; and WHEREAS, the CFPB and the SHPO has determined that the FHLBB is eligible for listing on the NRHP; and WHEREAS, the CFPB and the SHPO has determined that the Undertaking will have an adverse effect on the FHLBB; and

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WHEREAS, the CFPB and the SHPO has notified the Advisory Council on Historic Preservation (“ACHP”) of the adverse effect in accordance with 36 CFR 800.6(a)(1) and the ACHP has chosen not to participate in the consultation; and WHEREAS, the CFPB, their consultants, and the SHPO have met to discuss the proposed project plans on March 14, 2013, April, 15, 2013, October 2, 2013, November 12, 2013, and December 4, 2013, to minimize the project’s impact on character-defining features of the property; and, WHEREAS, pursuant to 36 CFR 800.6(c)(1)(i), the CFPB and the SHPO are the signatories to this Memorandum of Agreement (MOA). NOW THEREFORE, CFPB and the SHPO agree that the Undertaking shall be implemented in accordance with the following stipulations in order to take into account the adverse effects of the Undertaking on historic properties.

STIPULATIONS

CFPB shall ensure that the following measures are carried out:

I. PROFESSIONAL QUALIFICATIONS

a. All cultural resource work carried out pursuant to this agreement shall be conducted by or under the direct supervision of an individual or individuals who meet, at a minimum, the Secretary of the Interior’s Professional Qualifications Standards (48 FR 44738–9, September 29, 1983) (SOI Standards).

b. All cultural resource studies resulting from this MOA shall take into account guidelines set forth by the National Park Service and the SHPO, as appropriate.

II. TREATMENT OF FHLBB

a. Because character-defining features of the NRHP-eligible FHLBB will be diminished, at such time as it begins the Undertaking, CFPB or its representatives shall create or cause to be created a NRHP nomination and a DC Inventory of Historic Sites nomination form for this property. This includes any additional research required to author the nominations, completion of the nomination forms, and creation of all accompanying nomination documentation. Further, the draft nominations and all supporting documents shall be submitted to the SHPO and NPS for review and requested modifications shall be made to the document for presentation at both local- and federal-level review meeting.

b. The SHPO shall continue to be consulted during project design process. This includes involvement in dialogues on material selection, design details, building

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MEMORANDUM OF UNDERSTANDING (MOU)

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layout, courtyard design, etc. This consultation shall include, as appropriate, attendance at meetings, inclusion in email discussions, and receipt of preliminary plans for review.

c. The four bronze medallions once located on the Riggs Bank Building formerly located on this parcel shall be placed in a spot of prominence within the new building or courtyard design. The CFPB and SHPO shall come to an agreement on an appropriate installation location.

d. In association with the reuse of the historic elements listed in II.c above, the CFPB shall create or cause to be created interpretive signage to be installed near the historic elements. The signage shall contain images and verbiage appropriate for the public interpretation of the historic elements. The quantity of signs, location of sign installation, and sign design (including both visuals and text) shall be approved by both the CFPB and the SHPO before construction and installation.

III. PREPARATION AND REVIEW OF DOCUMENTS

a. A draft of the NRHP nomination shall be submitted to the SHPO for review and comment. CFPB shall ensure that all comments received within thirty (30) days of text/report receipt shall be addressed in the final documents. Two copies of all final documents shall be provided to the SHPO.

b. Unless otherwise stated in this MOA, any technical reports prepared pursuant to this agreement shall be consistent with the federal standards entitled Archeology and Historic Preservation: Secretary of the Interior’s Standards and Guidelines (48 FR 44716–42, September 29, 1983) and the Guidelines for Preparing Identification and Evaluation Reports for Submission Pursuant to Sections 106 and 110, National Historic Preservation Act.

IV. DISPUTE RESOLUTION

Should any signatory to this MOA object in writing to any action carried out in accordance with the MOA, the signatories shall consult to resolve the objection. Should the signatories be unable to resolve the disagreement, CFPB shall forward all documentation relevant to the dispute to the ACHP. Within 45 days after receipt of all pertinent documentation, the ACHP will either:

a. Provide CFPB with recommendations, which CFPB will take into account in

reaching a final decision regarding the dispute; or

b. Notify CFPB that it will comment pursuant to 36 CFR 800.7(c), and proceed to comment. Any ACHP comment provided in response to such a request shall be taken into account by CFPB in accordance with 36 CFR 800.7(c)(4) with reference to the subject of the dispute. Any ACHP recommendation or comment will be understood to pertain only to the subject of the dispute;

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CFPB’s responsibility to carry out all actions under this MOA that are not subjects of the dispute will remain unchanged.

V. AMENDMENTS AND TERMINATION

a. Any signatory to this MOA may propose that the MOA be amended, whereupon the signatories shall consult to consider such an amendment. All signatories to the MOA must agree to the proposed amendment in accordance with 800.6(c)(7).

b. This MOA may be terminated by any signatory in accordance with the procedures described in 36 CFR 800.6(c)(8). Termination shall include the submission of a technical letter report by CFPB on any work done up to and including the date of termination. If the signatories are unable to execute another memorandum of agreement following termination, CFPB shall comply with 36 CFR Part 800 for any other project proposed for the Property.

VI. DURATION OF AGREEMENT

Subject to the terms of Article V above pertaining to the termination hereof, this MOA shall continue in full force and effect until five (5) years after the date of the last signature. At any time in the six-month period prior to such date, any signatory may request the other signatories to consider an extension or modification of this MOA. No extension or modification shall be effective unless all parties have executed and delivered a written amendment to this MOA.

Execution of this MOA and implementation of its terms evidences that CFPB has taken into account the effects of the Undertaking on historic properties and afforded the ACHP a reasonable opportunity to comment.

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SIGNATORIES CONSUMER FINANCIAL PROTECTION BUREAU By:_________________________________ Date:________________ NAME TITLE

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DISTRICT OF COLUMBIA STATE HISTORIC PRESERVATION OFFICER By:__________________________________ Date:________________ David Maloney District of Columbia State Historic Preservation Officer

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North Elevation of 1700 G Street, NW

(The Federal Home Loan Bank Board Building).

Location of 1700 G Street, NW on the Washington, D.C. Real Property Map (Office of

the Chief Technology Officer 2013).

1700 G Street, NW

N

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