SEWERAGE & WATER BOARD OF NEW ORLEANS RECONSTRUCTION/ELEVATION AND HARDENING OF NINE (9) SEWAGE PUMP STATION, NEW ORLEANS, ORLEANS PARISH, LA Executive Order 11988 – Floodplain Management Eight-Step Decision Making Process Executive Order 11988 (Floodplain Management) requires federal agencies “to avoid, to the extent possible, the long and short term adverse impacts associated with occupancy and modification of the floodplain and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative.” FEMA’s implementing regulations are at 44 CFR Part 9, which includes an eight step decision making process for compliance with this part. This eight step process is applied to the proposed flood protection project, which consists of the reconstruction/elevation and hardening of nine (9) sewage pump stations within Orleans Parish, Louisiana. The proposed project locations and surrounding areas are located within the 100-year or the 500-year floodplain within Orleans Parish. The steps in the decision making process are as follows: Step 1 Determine whether the proposed action is in the Base Floodplain. The Parish of Orleans enrolled in the National Flood Insurance Program (NFIP) on August 3, 1970. The proposed project locations are located within either the base floodplain (the 100-year or 1.0 percent chance of flooding in a given year) or within the 500-year (0.2 percent annual chance of flooding in a given year). The table below summarizes the flood zone for each of the SPS sites. Site # Pumping Station Name Address City Flood Zone Preliminary DFIRM Panel 1A SPS 8 (Existing Location) Corner of North Broad Avenue and Toulouse Street New Orleans AE (EL 0) 22071C 0230F 1B SPS 8 (Proposed New Location) Corner of Lafitte Street and North Dorgenois Street New Orleans AE (EL 0) 22071C 0230F 2 Bullard 5501 Bullard Avenue New Orleans AE (EL -2) 22071C 0140F 3 Dodt 8118 Chef Menteur Highway New Orleans X-500 Year 22071C 0140F 4 SPS 6 242 South Solomon Street New Orleans AE (EL 0) 22071C 0230F 5 Lake Forest 10451 Lake Forest Boulevard New Orleans AE (EL -2) 22071C 0140F 6 Lawrence 7900 Morrison Road New Orleans AE (EL -2) 22071C 0120F 7 Plum Orchard 7300 Chef Menteur Highway New Orleans X-500 Year 22071C 0120F 8 Victoria 3620 Victoria Street New Orleans X-500 Year 22071C 0120F 9 Burke 9001 Morrison Rd New Orleans AE (EL-2) 22071C0140F The proposed project site area is being protected from the 100-year flood hazard by a man-made levee system. Overtopping or failure of any levee system is possible. Step 2 Early public notice. (Preliminary Notice) A cumulative public concerning the Hazard Mitigation Grant Program (HMGP) Assistance in floodplain and wetland areas will be or has been published in the New Orleans Times-Picayune, Baton Rouge Advocate, Lafayette Daily Advertiser, Lake Charles American Press, Hammond Star, Monroe News-Star, Shreveport Times, and the Alexandria Daily Town Talk. Step 3 Identify and evaluate alternatives to locating in the base floodplain. The areas surrounding the proposed project sites are located within the 100-year or 500-year floodplain. ALTERNATIVE 1: NO ACTION (Dismissed): Under this alternative, the Orleans Parish S&WB would not engage in flood protection activities at the eight (8) SPS locations. Consequently, the SPSs, which were built completely below ground, would continue to be susceptible to flooding from heavy rains as well as overtopping of levees. Sewage pump stations unable to supply demand operation would cause a health and safety crisis to the city’s population and environment as raw, untreated sewage backs up throughout the network. Sewage pump stations that are out of service, even for a short period of time, would shut down processing of the entire network. ALTERNATIVE 2: RECONSTRUCTION/ELEVATION AND HARDENING OF NINE (9) SEWAGE PUMP STATIONS (SPSs) (PROPOSED ALTERNATIVE): The scope of work for the proposed action indicates reconstruction and elevation of the existing SPSs to enclose critical equipment within hardened structures. Eight (8) of the SPSs would be reconstructed on the same parcel and one (1) would be reconstructed on a parcel owned by the city of New Orleans located one (1) block southeast of the existing SPS. The level of elevation of critical equipment at each location would meet the minimal ABFE or BFE requirement as provided on preliminary DFIRMS for Orleans Parish, dated November 13, 2008, whichever is higher. Where possible, the critical equipment would be elevated to the 500-year flood level to reduce the infiltration of floodwaters and the possibility of submergence of electrical components, pumps and motors during flood and surge events. In addition, mitigation measures include reinforcing the SPSs by “hardening” the structures around electrical components to protect the contents that could damage vital equipment in such events. ALTERNATIVE 3: ELEVATION OF CRITICAL ELECTRICAL EQUIPMENT ON A METAL PLATFORM WITHOUT A PROTECTIVE ENCLOSURE (Dismissed): The applicant has completed, or is in the process of completing, this action at the majority of SPSs evaluated in this EA as an interim measure to protect the critical electrical equipment at each site. Although this action would elevate the electrical equipment, in some cases the level of elevation achieved would be insufficient to provide protection of the electrical equipment to or above the 500-year flood elevation. In addition, the electrical equipment would be unprotected from the elements and would continue to be vulnerable to failure from water intrusion during rain events. This alternative, while relatively inexpensive, is only considered to be suitable as an interim mitigation measure. This alternative is not considered to be a viable long-term solution to providing adequate flood and severe weather protection to the critical SPSs, and has therefore been dismissed. ALTERNATIVE 4: RECONSTRUCT SPS 8 AT A NEW LOCATION NOT OWNED BY THE CITY OF NEW ORLEANS (Dismissed): Although this proposed site is located closer to the existing structure and would therefore require less disruption of public streets to complete the required underground construction, this parcel is not currently owned by the city of New Orleans, and would therefore need to be purchased by the city. In addition, because of the historic and current use of the parcel as an automobile repair facility, the city of New Orleans would need to perform a Phase I/Phase II Environmental Site Assessment (ESA) to determine whether the soil and/or groundwater on and under the parcel are contaminated with constituents associated with such activities. If, based on the results of the ESA, the parcel is determined to be contaminated; the city of New Orleans would be required to remediate the site prior to developing it with the new SPS 8 structure and associated ground disturbance. FEMA does not provide HMGP funding for sites that contain hazardous materials or contamination over regulatory limits, nor can FEMA funding be used to remediate contaminated sites. In addition, the city of New Orleans would potentially be liable for off-site contamination that has migrated off-site or may migrate off-site at any time in the future. This parcel is also located within the 100-year floodplain; therefore, potential impacts to the floodplain would be similar to Alternative 2. Step 4 Identify impacts of the proposed action associated with occupancy or modification of the floodplain. Impact of the proposed project on the natural function of the floodplain According to FEMA regulations, the lowest floor that would be occupied should be elevated to the higher of the following elevations, which should be used as the design flood elevation (DFE), which is, at a minimum, the BFE, and may include a factor of safety known as freeboard of 1 foot or more, as adopted by the community or Parish for flood load calculations: 1. Two feet above the (BFE), i.e., 2 feet above the flood elevation having a 1.0 percent annual chance of being equaled or exceeded in any given year (100-year event); or 2. The stillwater flood elevation associated with the 0.2 percent annual chance of being equaled or exceed in any given year (500-year event); or 3. The lowest floor elevation required by the community’s floodplain ordinance, if such ordinance exists. According to the applicant, the proposed SPSs would be elevated above the 500-year flood level at each location, where possible. The reconstruction of the new SPSs would result in added fill within the floodplain; however, the amount of fill relative to the area of the floodplain is minimal. Flood flows would be minimally impeded and redirected by construction of the proposed SPSs structure. Implementing the proposed action is not likely encourage further development near or adjacent to the proposed sites because the proposed reconstructed SPSs would be replacing the existing SPSs on the same location, or a nearby location, in case of SPS 8. By implementing the proposed activity, the health and safety of Orleans Parish residents during and after severe weather events would be improved. There are no wetlands in the immediate proposed project areas that would be affected by the proposed action. The reconstruction/elevation and hardening of the new SPSs would be coordinated and comply with the local floodplain administration. All required permits will be obtained and kept for permanent documentation. Impact of the flood water on the proposed facility The proposed project SPSs are part of large sewage processing network. The SPSs, which assist in transporting sewage from the various neighborhoods within the city to the main sewage treatment plant, are required to be located throughout city of New Orleans to perform this function as a network. By performing the proposed actions, the impact of the floodwaters on these SPSs evaluated in this EA would be reduced by elevating critical equipment well above the anticipated floodwater levels during future storm events. Step 5 Design or modify the proposed action to minimize threats to life and property and preserve its natural and beneficial floodplain values. The proposed project is designed to minimize floodplain impacts while providing a protection of critical SPS equipment from floodwaters. Because the proposed new SPS structures would be located on the same parcel or a nearby parcel, with the structure footprint being approximately 400 square feet, and the vast majority of the improvements being installed below the ground surface, the proposed project would have minimal effect on the natural and beneficial values of the floodplain. Step 6 Re-evaluate the proposed action. These SPSs are critical facilities. According to 44 CFR § 9.5(a) FEMA shall use the 500-year floodplain for critical actions when determining whether a proposed action is located within the floodplain. Critical facilities should be located in areas at low risk to flooding and mapped as unshaded zone X on newer DFIRMs and FIRMs or zone C on older FIRMs (outside the 500-year [0.2 percent annual chance] floodplain) wherever possible. Based on review of Preliminary DFIRM panels 22071C 0230F, 22071C 0140F, and 22071C 0120F which include the proposed SPS site locations and the surrounding neighborhoods, there no areas mapped as low risk to flooding or unshaded zone X (refer to Figures 13, 14 and 15 in the EA text). Because the SPSs must be located throughout the East Bank of the city to transport raw sewage from residential, commercial, and industrial structures to the New Orleans East Bank Sewer Treatment Plant (STP), each neighborhood must have one or more SPSs, regardless of whether or not the neighborhood is located within the 100-year or 500-year floodplain. The West Bank of New Orleans is served by separate STP. Because there are no low risk to flooding or unshaded zone X areas in these neighborhoods, there no alternative locations that the city of New Orleans could identify that would be outside of the floodplain. There are no wetlands in the immediate proposed project area that would be affected by the proposed action. Alternatives consisting of locating the proposed project outside the floodplain or taking “no action” are not practicable. Step 7 Findings and Public Explanation (Final Notification). The EA went out for public review from November 5, 2012 to November 25, 2012. After evaluating alternatives, including impacts to the floodplain, Orleans Parish determined that the proposed project is the most practical alternative. It was determined that there is no practicable alternative to constructing and hardening the new community center and interior safe rooms within the 500-year floodplain because: 1. The proposed project areas and entire surrounding neighborhoods lie within the 100-year or 500-year floodplain and there are no practical locations outside of the 100-year or 500-year floodplain that Orleans Parish could utilize for the proposed SPS locations. 2. A “no action” plan would not provide a feasible solution to providing protection to critical SPS equipment from floodwaters which would keep the SPSs operational during and immediately after severe weather events. Step 8 Implement the action. The proposed flood protection project consisting of the construction and hardening of a new community center and safe rooms would be constructed in accordance with all applicable floodplain requirements. 1