Our project includes a large location that was disturbed and altered for use as a borrow pit during the construction of a nearby interstate highway. For many years, this location held no vegetation of any kind, which is clearly shown on aerial photos from the 1950s through the 1970s. This area is now also the only location that appears on a FEMA Hazard map as containing 100-year floodplain zones.

The reference guide defines previously developed sites as those which "once had buildings, roadways parking lots or were graded or otherwise altered by direct human activities."

Based on these factors, does it seem reasonable to consider the borrow pit land as previously developed, which would then allow us to follow SLLp5, Option 2?