Final Notice and Public Explanation of a Proposed Activity in an FFRMS Floodplain To: All interested Agencies including all Federal, State, and Local, Groups and Individuals This is to give notice that HUD, under 24 CFR Part 50 has determined that the following proposed action is in a Federal Flood Risk Management Standard (FFRMS) floodplain. HUD will be identifying and evaluating practicable alternatives to this development located in the FFRMS floodplain and the potential impacts on the floodplain from the proposed action, as required by Executive Order 11988, and in accordance with HUD regulations at 24 CFR 55.20 Subpart C Procedures for Making Determinations on Floodplain Management and Protection of Wetlands. North Pointe Apartments, located at 100 Ripplemeyer Avenue in Columbia, Richland County, South Carolina 29203 (subject property), consists of thirty-three (33) two-story multi-family apartment structures, one (1) single-story leasing office/laundry building, one (1) single-story community building, and one (1) single-story mail kiosk/maintenance building, constructed in 1972. The subject property structures contain a total of one hundred eighty-eight (188) multi-family residential dwelling units residential dwelling units and are situated on 16.17 acres of land. The Sponsor is submitting this project under the HUD Mark Up-To-Market (MUTM) Program and South Carolina State Housing Finance and Development Authority (SCSHFDA), consisting of substantial rehabilitation of the existing apartment complex. With the 500-year floodplain mapped/defined, that is the extent of the Federal Flood Risk Management Standard (FFRMS) floodplain for this project under the 0.2% Annual Chance Flood Approach (0.2PFA). According to the ALTA/NSPS Land Title Survey, Buildings 12, 13, 14, 23, 26, 35, and 36, as well as the clubhouse, are located within the FFRMS floodplain. Since the project involves substantial improvement in the FFRMS floodplain, it is subject to the 8-Step Process outlined in 24 CFR 55.20, including elevation requirements outlined in 24 CFR 55.20(e)(1), which requires residential spaces to be elevated to or above the FFRMS floodplain elevation and non-residential spaces either elevated to or floodproofed to the FFRMS floodplain elevation. In order to determine the FFRMS floodplain elevations, D3G reviewed the FEMA Flood Insurance Study (FIS) #45079C-V003B dated December 21, 2017. According to the Flood Profiles for the relevant sections of Bay Branch, the 500-year floodplain elevation for Buildings 12, 13, and 23 were identified as 258.3 feet, for Buildings 26 and 36 were identified as 259.5 feet, and for Buildings 14 and 35 and the clubhouse were identified as 259.8 feet. Since the project involves substantial improvement in the FFRMS floodplain, it is subject to the 8-Step Process outlined in 24 CFR 55.20, including elevation requirements outlined in 24 CFR 55.20(e)(1), which requires residential spaces to be elevated to or above the FFRMS floodplain elevation and non-residential spaces either elevated to or floodproofed to the FFRMS floodplain elevation. According to the elevation certificates prepared by Site Design Inc., all of the lowest floor elevations are above their respective FFRMS floodplain elevations and all lowest adjacent grades are either above or within 1 foot of their respective FFRMS floodplain elevation. Therefore, the structures are all in compliance with the elevation requirements outlined in 24 CFR 55.20(e)(1). However, with improvements within the regulatory floodway over and above those limitations outlined in 24 CFR 55.8(a)(1), the project must seek the "Alternate processing for existing nonconforming sites" outlined in 24 CFR 55.21 and further defined in HUD's Environmental Review FAQ accessed at https://www.hudexchange.info/faqs/4349/is-new-hud-assistance-or-mortgage-insurance-for-substantial-improvement/. Floodplains provide natural and beneficial values by acting as natural filters, providing water storage, and recharging groundwater aquifers. They can also provide habitat for a variety of biologically unique flora and fauna. HUD has considered the following factors, alternatives, and mitigation measures to be taken to minimize adverse impacts and to restore and preserve beneficial values of the FFRMS floodplain: (i) The existing affordable housing complex is in need of rehabilitation activities to improve the safety, accessibility, and quality of life of the tenants. In addition, the proposed rehabilitation of this existing facility is suitable for carrying out HUD's mission of assisting in providing safe, suitable living environments to residents. The proposed action does not involve any new development or new construction activities within the FFRMS floodplain. There are no proposed significant exterior repairs nor ground disturbances. No alterations to the existing overall drainage patterns will occur. In addition, according to the elevation certificates prepared by Site Design, Inc., all of the lowest floor elevations are above their respective FFRMS floodplain elevations and all lowest adjacent grades are either above or within 1 foot of their respective FFRMS floodplain elevation. Therefore, the structures are all in compliance with the elevation requirements outlined in 24 CFR 55.20(e)(1). It should be noted that the Sponsor will relocate the existing dumpster pad and mail kiosk outside of the regulatory floodway. The Sponsor is also installing The Hurricane PadTM concrete pads (https://www.diversitech.com/product-families/equipment-mounting/pads/hurricane-pads) at all exterior HVAC equipment as additional floodproofing measures. In addition, the Sponsor is purchasing Garrison Flood Control Barriers (https://www.garrisonflood.com/flood-control-walls), specifically the Mayim Barrier spec, to be installed in advance of a severe flooding event by maintenance staff in accordance with the manufacturer's installation instructions accessed at https://static1.squarespace.com/static/60e5f1697187fc1d195aa488/t/633481dee404a55005213172/1664385502358/mayim_install_instructions_FINAL+%285%29.pdf. These flood control barriers will be installed at all front and rear openings for structures located within the FFRMS floodplain (Buildings 12, 13, 14, 23, 26, 35, and 36, and the clubhouse). Therefore, there are no means of further minimizing impacts to a regulated floodplain. (ii) Modifications resulting in avoidance or minimization of activities within the FFRMS floodplain could consist of the relocation of the dumpster pad and mail kiosk within the regulatory floodway, as well as reconfiguration/relocation of the roadways, sidewalks, and dumpster pads within the regulatory floodway. In addition, a reduction of the project's scope of activities below substantial improvement would not subject the project to the full 8-Step Process. However, the project cannot practicably modify the scope of activities below substantial improvement without jeopardizing the feasibility of the entire development. The overall scope of activities of this project are essential for the ongoing wellbeing of the residents and the long-term sustainability of the property as an affordable housing asset in the community. This project was built in 1971 by a partnership of three (3) local African Methodist Episcopal (AME) Churches using HUD financing. When the project opened, it was called Bethel-Bishop-Chappelle Memorial Apartments after those three (3) churches and their efforts to create housing for Columbia's low-income community. Given the community significance, this project has been approved by SHPO for historic designation and once the renovations is complete, will be approved by the NPS for official Federal Historic Registration. Using Section 8(bb) to transfer this HUD assistance would result in the loss of a historic community resource, and it would not be financially feasible to build this type of housing as new construction. The cost of building new construction would require millions of dollars of competitive funding resources from local, state and federal sources, and these sources do not readily exist. The sources the project has received in the form of tax exempt bonds, 4% Federal LIHTC, and Federal Historic Tax Credits, would require either resubmission or not be available. Thus, new construction is not a viable alternative. Furthermore, the impact to the FFRMS floodplain is already extremely minimal. No buildings are within the regulatory floodway, other than the aforementioned mail kiosk and dumpster pad, which will be relocated outside of the floodway. (iii) While the subject property has challenges related to compliance with HUD's floodway limitations outlined in 24 CFR 55.8(a)(1), please note that according to Andrea Bolling, PE, CFM, Deputy Director of Engineering with Columbia Water, the City of Columbia does not have records or complaints of flood events at the subject property. They further advised that the structures are located outside the regulated Special Flood Hazard Area (SFHA), 100-year floodplain, but some structures are within the unregulated SFHA, 500-year floodplain, based on a review of FEMA FIRM #45079C0242L, dated December 21, 2017. It should be noted that according to R.B. Coats, III, President of North Pointe Affordable Housing, LLC and the Current Landowner, since their acquisition of the subject property in 2015, the subject property has experienced zero flooding incidents, despite the occurrence of several notable tropical storms impacting the broader region. Storms impacting the region between 2017 and 2025 consist of the following: a. Hurricane Matthew (October 2016) – Landed near Cape Romain as Category 1 and caused widespread inland flooding. (This storm caused city wide water issues that resulted in the property losing running water for several days. We supplemented the property by distributing bottled waters across the complex and surrounding community.) b. Hurricane Florence (September 2018) – Passed inland as a tropical storm, delivering major flooding in parts of the Carolinas. c. Hurricane Ian (September 2022) – Made landfall near Georgetown as Category 1; brought substantial rain and power outages statewide. d. Hurricane Idalia (August 2023) – Swept through as a tropical storm, producing inland flooding and tornadoes. e. Tropical Storm Debby (August 2024) – Landed near Bulls Bay; caused significant flooding in coastal and low-lying areas. f. Hurricane Helene (September 2024) – Skirted western South Carolina as a tropical storm, causing heavy rainfall and flooding on Saluda and Broad rivers. g. Tropical Storm Chantal (July 2025) – Made landfall near Litchfield Beach; resulted in heavy rain and flooding in parts of South Carolina. According to the National Flood Insurance Program (NFIP) Community Status Book accessed at https://www.fema.gov/flood-insurance/work-with-nfip/community-status-book, the subject property is located in Community ID #450172B, which is a participating community in the NFIP. As no insurable structures are located within the FEMA-designated Special Flood Hazard Area (100-year floodplain), flood insurance is not required to be carried under the provisions of the NFIP. Therefore, the project is in compliance with flood insurance requirements. As the subject property is within the FFRMS floodplain, HUD's FFRMS final rule includes notification requirements for new and renewal leases to ensure that prospective renters are made aware of potential flood risk so that they can make risk-informed decisions. These notification requirements are defined at 24 CFR 55.4, and must include acknowledgements signed by residents indicating that they have been advised that a portion of the property is in a floodplain and flood insurance is available for their personal property. Notification shall also include available emergency notification resources. In addition, in accordance with 24 CFR 55.20(e)(4), evacuation plans have been developed for resident and occupant safety in the event of a flooding event, which includes safe egress route(s) out of the Federal Flood Risk Management Standard (FFRMS) floodplain. The proposed action will not result in adverse impacts to lives, property, or natural flood zone functions and values, and additional mitigation measures are not warranted. HUD has reevaluated the alternatives to approving the project in the floodplain and has determined that it has no practicable alternative. Environmental files that document compliance with Steps 3 through 6 of Executive Orders 11988 are available for public inspection, review and copying upon request at the times and location delineated in the last paragraph of this notice for receipt of comments. There are three primary purposes for this notice: 1. People who may be affected by activities in floodplains and wetlands, and those who have an interest in the protection of the natural environment should be given an opportunity to express their concerns and provide information about these areas. 2. An adequate public notice program can be an important public educational tool. The dissemination of information and request for public comment about floodplains and wetlands can facilitate and enhance Federal efforts to reduce the risks and impacts associated with the occupancy and modification of these special areas. 3. As a matter of fairness, when the Federal government determines it will consider actions taking place in floodplains and wetlands, it must inform those who may be put at greater or continued risk. Written comments must be received by HUD at the following address on or before November 28, 2025 [a minimum 7 calendar day comment period will begin the day after the publication and end on the 8th day after the publication]: HUD, 400 W Bay Street, Suite 1015, Jacksonville, Florida 32202, Attention: Mark Malec, Branch Chief, Technical Team. Mark Malec's direct phone number is (904) 208-6054 and email is Mark.E.Malec@hud.gov. A full description of the project may also be reviewed from 8am to 5pm at the same address as above. Comments may also be submitted via email at FL_Webmanager@hud.gov. Jonathan Mosley, acting in his capacity as Production Division Director of the HUD Multifamily Southeast Regional Center, is the HUD Approving Official. IPL0291863 Nov 20 2025