Draft Tiered Site-Specific Environmental Assessment Port Fourchon, Multi-Agency Emergency Response Operations Center Lafourche Parish, Louisiana Port Security Grant Program American Recovery and Reinvestment Act Project # 2009-PU-T9-K023 (01) May 2012 Federal Emergency Management Agency Department of Homeland Security 500 C Street, SW Washington, DC 20472 I. Background In accordance with 44 Code of Federal Regulations (CFR) for the Federal Emergency Management Agency (FEMA), Subpart B, Agency Implementing Procedures, Part 10.9, a Programmatic Environmental Assessment (PEA) for Grant Programs Directorate Programs was prepared and a Finding of No Significant Impacts (FONSI) was issued in July 2010 (Appendix B), pursuant to Section 102 of the National Environmental Policy Act (NEPA) of 1969, as implemented by the regulations promulgated by the President’s Council on Environmental Quality (CEQ; 40 CFR Parts 1500-1508). This Tiered Site-Specific Environmental Assessment (SEA) is being prepared in accordance the July 2010 PEA. The focus of this Tiered SEA is on those areas of concern requiring additional discussion or analysis that are beyond the scope of the PEA. The proposed site is located next to 108 A. O. Rappelet Road in Port Fouchon, Louisiana (Latitude: 29.15307, Longitude -90.18045). Currently, it is an undeveloped gravel lot with a 400-foot self-support telecommunications tower and ancillary equipment to the west. There are several nearby buildings to the north and the Greater Lafourche Port Commission Operations Center and a warehouse south of the site (Appendix A). II. Purpose and Need The Greater Lafourche Port Commission has applied for Port Security Grant Program, American Recovery and Reinvestment Act program funding under application number 2009-PU-T9-K023 (01). The purpose of this program is to provide for activities which help to enhance the security and safety of ports in the United States. Currently fire and emergency medical services are provided by the Lafourche Parish Fire Department and the Lafourche Parish emergency medical services with the nearest responding units having travel time in excess of 20 minutes. Based on national response guidelines for survivability of a critically injured person, this response time is unacceptable. Additionally, response times would dictate firefighting effectiveness to combat a vessel or structure fire. Based on interviews with tenants, most would engage in their own fire suppression efforts and not depend on the fire department because of this concern regarding response time. The Greater LaFourche Port Commission has indicated that it needs to provide command and control situational awareness monitoring capability, house fire and Emergency Medical Service personnel, and shelter the emergency response vehicles necessary to provide adequate response times to the port community. III. Alternatives Two project alternatives are proposed in this SEA: 1) No Action and 2) Proposed Action Alternative- Installation of a Multi-Agency Emergency Response Operations Center at Port Fourchon. Under the No Action Alternative, no changes would be made to the existing site. As a result of this alternative, the region would continue to lack adequate response times from the fire and emergency medical services. The Greater LaFourche Port Commission proposes to enhance command and control situational awareness monitoring capability, provide housing for fire and Emergency Medical Service personnel, and shelter the emergency response vehicles necessary to provide adequate response times to the port community. The Proposed Action Alternative is the construction of an Emergency Operations Center that would be available during times when an incident command structure is required for long term Emergency Management operations. This Emergency Operations Center would provide command and control situational awareness monitoring capability, house fire and Emergency Medical Service (EMS) personnel, and shelter the emergency response vehicles necessary to provide adequate response times to the port community. During non-emergency operational periods, the portion of the structure designated as the Emergency Operations Center area can serve as a class room training area for security, fire and emergency medical responders. It is planned that the structure will be two stories with the first floor designed to house the two emergency response vehicles (fire truck & Emergency Medical Service transport) and the second floor having an Emergency Operations Center with a command and control consol, and living quarters for the response personnel staffing the vehicles based at the port. To minimize damage from flooding, the entire structure, other than the vertical conveyance systems (stairs and elevator) has been engineered to be elevated on piles above the 100-year Base Flood Elevation. Likewise, the emergency generator and its associated equipment, as well as the HVAC (air conditioning) systems are also located on the elevated equipment platform directly adjacent and connected to the main structure (Appendix C). The proposed Emergency Operations Center is located at 108 A. O. Rappelet Road, Port Fourchon, Lafourche Parish, LA 70357 (Latitude: 29.15307, Longitude -90.18045). (Appendix A). IV. Environmental Impacts Discussion of the environmental impacts associated with the No Action Alternative is included in the July 2010 PEA. This document incorporates the PEA by reference. The PEA can be found in FEMA’s electronic library at http://www.fema.gov/library/viewRecord.do?id=4143. Environmental impacts are not anticipated to occur as a result of the No Action Alternative. Therefore, only the environmental impacts associated with the Proposed Action Alternative were evaluated in this Environmental Assessment. FEMA’s environmental planning and historic preservation review reveals that all environmental areas of concern are appropriately accounted for in the PEA with the exception of floodplain impacts. Table 1-1 provides a summary of the findings for the environmental areas of concern that FEMA typically reviews. Table 1-1. Summary of Other Environmental Areas of Concern Area of Concern : Historic properties No Action Alternative: No effects Proposed Action Alternative: FEMA made the determination of No Historic Properties Affected by the construction of the Emergency Operations Center because the Area of Potential Effect (APE) for this project is limited to the proposed project parcel, and no buildings within the proposed project's view shed that are older than 45 years of age, and the ground was previously graded during the construction of the surrounding existing structures. In response to a letter submitted by FEMA dated June 27, 2011, the State Historic Preservation Office (Department of Culture, Recreation & Tourism) indicated on August 24, 2011 that No Historic Properties Affected (Appendix C). Area of Concern : Endangered and threatened species and critical habitat No Action Alternative: No effects. Proposed Action Alternative: No effects. The proposed site is a maintained lawn. The Louisiana Department of Wildlife and Fisheries indicated in a letter dated December 8, 2011 that no impacts to rare, threatened, or endangered species or critical habitats are anticipated (Appendix C). Area of Concern: Migratory birds No Action Alternative: No effects. Proposed Action Alternative: No effects. The proposed site is a maintained lawn. Area of Concern: Water quality No Action Alternative: No effects. Proposed Action Alternative: No effects. Area of Concern: Coastal resources No Action Alternative: No effects. Proposed Action Alternative: The project is within a CZMA. The Louisiana Department of Natural Resources, Office of Coastal Management indicated in a letter dated February 24, 2012 that the proposed project is exempt and a Coastal Use Permit is not required (Appendix C). Area of Concern: Wetlands No Action Alternative: No effects. Proposed Action Alternative: The U.S. Army Corps of Engineers (USACE), New Orleans District indicated in a letter dated January 5, 2012 that the project is not in a wetland subject to the USACE jurisdiction (Appendix C). Area of Concern: Low-income and minority populations No Action Alternative: The port community would continue to rely on delayed response time from fire and emergency medical services. This would leave emergency response unchanged and results in a lower level of overall public safety Proposed Action Alternative: The Proposed Action Alternative would benefit all populations in the project service area by providing better response times for emergency responder personnel. In compliance with FEMA regulations implementing Executive Order 11988, Floodplain Management, FEMA is required to carry out the Eight-step decision-making process for actions that are proposed in the floodplain per 44 CFR §9.6. Executive Order 11988 requires federal agencies “to avoid to the extent possible the long and short term adverse impacts associated with the occupancy and modification of the floodplain and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative.” This Eight-step process is applied to the proposed Port Fourchon, Multi-Agency Emergency Response Operations Center. Almost the entire Lafourche Parish is located in the 100-year floodplain of the Gulf of Mexico. The steps in the decision making process are as follows: Step 1 Determine if the Proposed Action Alternative is located in the Base Floodplain The Proposed Action Alternative involves the construction of a proposed Emergency Response Operations Center. FEMA has determined that the Proposed Action Alternative is located in a 100-year floodplain, Zone A13 (Areas of 100-year flood; base flood elevations and flood hazard factors determined), as depicted on FIRM Community Panel 2252020825D, with the effective date May 4, 1992 (Appendix A). Step 2 Early public notice (Preliminary Notice) A public notice for the proposed Emergency Response Operations Center will be published in the regional newspapers, Daily Comet, Lafourche Gazette, and Houma Courier, as part of the notice of availability for this SEA. Step 3 Identify and evaluate alternatives to locating in the base floodplain The proposed Emergency Response Operations Center must take place in the floodplain because almost the entire Lafourche Parish is located in the floodplain. Therefore no practicable alternative outside of the floodplain exists that would provide the port community adequate response times from fire and emergency medical personnel. Step 4 Identify impacts of Proposed Action Alternative associated with occupancy or modification of the floodplain Impact on natural function of the floodplain The proposed Emergency Response Operations Center would not affect the functions and values of the 100-year floodplain nor would it impede or redirect flood flows. The Emergency Response Operations Center would be located in a partially developed area with existing infrastructure. When compared to the extensive floodplain area, the proposed Emergency Response Operations Center will little potential to impact the floodplain. Therefore, the Preferred Action should not result in an increased base discharge or increase the flood hazard potential to other structures. Impact of the floodwater on the proposed facilities The proposed Emergency Response Operations Center has been designed to minimize impacts from flooding. The entire structure, other than the vertical conveyance systems (stairs and elevator) has been engineered to be elevated on piles above the 100-year Base Flood Elevation. Likewise, the emergency generator and its associated equipment, as well as the HVAC (air conditioning) systems are also located on the elevated equipment platform directly adjacent and connected to the main structure (Appendix C). However, there is a potential that the proposed Emergency Response Operations Center could be damaged if a catastrophic flooding event were to occur. Step 5 Design or modify the Proposed Action Alternative to minimize threats to life and property and preserve its natural and beneficial floodplain values In order to reduce the impact identified in Step 4 of flood hazards on the proposed new facilities, the proposed Emergency Response Operations Center will be designed to be compliant with FEMA recommendations for construction in flood hazard areas. The Applicant must follow all applicable local, State, and Federal laws, regulations and requirements and obtain and comply with all required permits and approvals, prior to initiating work on this project. No staging of equipment or project activities shall begin until all permits are obtained. Step 6 Re-evaluate the Proposed Action Alternative Per the discussions above, the proposed site will be appropriately designed for the 100-year floodplain. Almost the entire Lafourche Parish is located in the floodplain. The proposed Emergency Response Operations Center is intended to provide the port with an emergency operations center during times when an incident command structure is required for long-term Emergency Management operations, provide command and control situational awareness monitoring capability, house fire and EMS personnel, and shelter the emergency response vehicles necessary to provide adequate response times to the port community. The Proposed Action Alternative will not aggravate the current flood hazard because the project would not impede or redirect flood flows. The project will not disrupt floodplain values because it will not change water levels in the floodplain. Therefore, it is still practicable to construct the proposed project within the floodplain. Alternatives consisting of locating the project outside the floodplain or taking “no action” are not practicable. Step 7 Findings and Public Explanation (Final Notification) In accordance with 44 CFR §9.12, the Greater Lafourche Port Commission must prepare and provide a final public notice 15 days prior to the start of construction activities. Documentation of the public notices are to be forwarded to FEMA for inclusion in the permanent project files. Step 8 Implement the action The Greater Lafourche Port Commission will incorporate into the design necessary mitigation efforts for building within a 100-year floodplain. As a result of this Eight-step process, FEMA has determined that the Port Fourchon, Multi-Agency Emergency Response Operations Center is in compliance with 44 CFR §9.6 because there are no practicable alternatives outside the 100-year floodplain. V. Mitigation 1. Significant change, addition, and/or supplement to the approved scope of work which alters the existing use and function of the structure, including additional work not funded by FEMA but performed substantially at the same time, will require re-submission of the application prior to construction to FEMA for re-evaluation under the National Environmental Policy Act. 2. The Greater Lafourche Port Commission must comply with all permit conditions and conditions required by the local floodplain management ordinance for this project. A copy of the permit and documentation of compliance with permit conditions will be forwarded to FEMA for inclusion in the permanent project file. 3. In accordance with 44 CFR §9.12, The Greater Lafourche Port Commission must publish a public notice 15 days prior to the start of construction activities. Documentation of the public notice is to be forwarded to FEMA for inclusion in the permanent project files. In addition, The Greater Lafourche Port Commission will be required to comply with the conditions that are stated in the PEA FONSI, dated July 7, 2010, for the Proposed Action Alternative (see Appendix B). VI. Correspondence and Agencies Consulted (see Appendix C) * Louisiana Department of Culture, Recreation & Tourism * Louisiana Department of Natural Resources, Office of Coastal Management * Louisiana Department of Wildlife and Fisheries * U.S. Army Corps of Engineers, New Orleans District VII. Public Comment The public was notified of the availability of the Draft SEA through the publication of a public notice on May 9, 2012 in Daily Comet, Lafourche Gazette, and Houma Courier. The Draft SEA document was also made available for public review between May 9, 2012 and May 24, 2012 on the Greater Lafourche Port Commission website at www.portfourchon.com and FEMA’s website at http://www.fema.gov/plan/ehp/envdocuments/ea-region6.shtm and at the Greater Lafourche Administrative Office located at 16829 East Main Street, Galliano, LA during the hours of 8:00 AM to 4:30 PM, and the Greater Lafourche Port Operations Center located at 108 A. O. Rappelet Road, Port Fourchon, LA, immediately adjacent to the project site during the hours of 8:00 AM to 4:30 PM. A 15-day public comment period will commence on the initial date of the public notice. FEMA will consider and respond to all public comments in the Final SEA. VIII. List of Preparers Kevin Jaynes, CHMM, Regional Environmental Officer, FEMA Region VI Alan Hermely, EHP Specialist, FEMA Region VI Appendix A Figures and Photographs Appendix B Finding of No Significant Impact (FONSI) For Final Programmatic Environmental Assessment Grant Programs Directorate Programs Appendix C Correspondence