Reviewer Name: LethaDawson * •• . ,~ ......... Record of Environmental Consideration See44CodeofFederalRegulationPart 10. Project Name/Number: Bunche Middle School / PW 11517 Project Location: 8101 Simon Street, Metairie, Louisiana, Jefferson Parish 70003 (N29 97516 W-90.22475) Project Description: Project activities include installing temporary roofpatches; resetting fallen conduit; performing electrical repair; replacing vent caps, fuses, wires, belts on air handler motor, glass, speakers, asphalt built-up roof, asphalt shingle roof, vents, steel gutters, downspout, tar and gravel, gas line supports, flag pole, carpet, acoustical ceiling tiles, wood baseboard molding, wood doors, fluorescent light bulbs, sheetrock, fur down, ceiling, insulation, VCT flooring and aluminum flashing; cleaning and sealing terrazzo and VCT flooring; repainting CMU walls, ceiling and concrete flooring; and sealing metal roof. Hazard mitigation proposes installing roll roofing on top ofthe canopy inplace ofthetarandgravel. Documentation Requirements • No Documentation Required (Review Concluded) • (Short version) All consultation and agreements implemented to comply with the National Historic Preservation Act, Endangered Species Act, and Executive Orders 11988, 11990 and 12898 are completed and noother laws apply. (Review Concluded) IE1 (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attached to this REC. National Environmental Policy Act (NEPA) Determination • Statutorily excluded from NEPA review. (Review Concluded) ' D Programmatic Categorical Exclusion -Category (Review Concluded) • Categorical Exclusion -Category • No Extraordinary Circumstances exist. Are project conditions required? Q Yes (see section V) D No (Review Concluded) U Extraordinary Circumstances exist (See Section IV). • Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) {J No (Review Concluded) |_J Environmental Assessment D Supplemental Environmental Assessment (Reference EA or PEA in comments) l2Sl Environmental Impact Statement Comments: Although this project would have qualified as aCATEX (xv) and (xvi) under 44 CFR part 10 8(D)(2) this project meets the definition of critical infrastructure (Permanent Schools) under the Alternative Arrangements for NEPA compliance. This project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) Laws which are listed under the NEPA Level of Environmental Review in the Project Worksheet Any changes to this approved scope ofwork will require submission to, and evaluation and approval by, the state and FEMA prior to initiation ofany work, for compliance with the National Environmental Policy Act. The applicant is required to obtain and Record of Environmental Consideration 1 10/13/06 comply with.all local, state and federal permits and requirements. Non-compliance with the requirements noted above may jeopardize the receipt offederal funding.. y Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Letha Dawson, Environmental Specialist S^toe (i^t^xlUft IxVfaPrvN Date 10/13/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Howard R. Bush, ELO Signature—f^—z>-/-* —-*-Date 10/13/2006 l-Compliance Review for Environmental Laws (other than NEPA A. National Historic Preservation Act D Not type ofactivity with potential to affect historic properties. (Review Concluded! IS Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review QQ Activity meets Programmatic Allowance #Appendix A, Section {II-E1, II-B1, II-C2,1-A II-A2 II-A4 II-C1)} Are project conditions required? ^ Yes (see section V) f~l No (Review Concluded! HISTORIC BUILDINGS AND STRUCTURES D No historic properties that are listed or 45/50 years or older in project area. (Review Concluded! U Building or structure listed or 45/50 years or older in project area and activity not exempt from review U Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) • No (Review Concluded! U Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence on file) U Property aNational Historic Landmark and National Park Service was provided early notification during the consultation process. Ifnot, explain incomments • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) DNo (Review Concluded! U Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required D Yes (see section V) \J No (Review Concluded! ARCHEOLOGICAL RESOURCES S Project affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. • Project area has no potential for presence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded! • Project area has potential for presence of archeological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required D Yes (see section V) DNo (Review Concluded! |_J Determination ofhistoric properties affected • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required QYes (see section V) \J No (Review Concluded) U NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on file) Record of Environmental Consideration 2 10/13/06 *1 I Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School system Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program / EJE0234 Bundle Middle School D No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? D Yes (see section V) • No (Review Concluded! • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) • Resolution of Adverse Effect completed. (MOA on file) Are project conditions required? Q Yes (see section V) • No (Review Concluded! Comments: 10/13/2006-FEMA's Programmatic Agreement(PA), dated December 3, 2004, provides for expedited projectreview under Section 106 ofthe National Historic Preservation Act (NHPA). The scope ofwork as submitted in this PW has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section {II-E1, II-B1, II-C2, I-A, II-A2, II-A4, II-C1)}, ofthe document. In accordance with the PA, FEMA is not required to determine the National' Register eligibility ofproperties or to submit projects to the State Historic Preservation Officer (SHPO) for review where the work performed meets these allowances. In keeping with the stipulations ofthe PA, all proposed repair activities should be done in-kind to match existing materials and form. Any change to the approved scope ofwork will require resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt of federal funding. This concludes the Section 106 review for this project. V. Gomez, Historic Preservation Specialist 10/13/2006 -The proposed mitigation measure ofreplacing the canopy roof will have no effect on historic structures as the canopy walkway was constructed post-1960. V. Gomez, Historic Preservation Specialist Correspondence/Consultation/References: B. Endangered Species Act ^ No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action (Review Concluded! U Listedspecies and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. • No effect to species or designated critical habitat (See comments for justification) Are project conditions required? • Yes (see section V) • No (Review Concluded! • May affect, but not likely to adversely affect species or designated critical habitat (FEMA determination/USFWS/NMFS concurrence onfile) (Review Concluded! Are project conditions required? • Yes (see section V) (j No (Review Concluded) D Likely to adversely affect species or designated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) D NO (Review Concluded! Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act pj Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded) D Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on file) D Proposed action an exception under Section 3505.a.6? (Review Concluded! • Proposed action not excepted under Section 3505.a.6. Are project conditions required? • YES (see section V) • NO (Review Concluded! Comments: None Correspondence/Consultation/References: D. Clean Water Act E3 Project would not affect any waters ofthe U.S. (Review Concluded! • Project would affect waters, including wetlands, ofthe U.S. D Project exempted as in kind replacement or other exemption. (Review Concluded! • Project requires Section 404/401/or Section 9/10 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Project isnot inoradjacent toany waterways ofthe US. Record of Environmental Consideration 3 10/13/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School system PiMSter/Emergencv/Program/Projeet Tule: DR1603LA / Hurricane Katrina /Public Assistance Program / EJE0234 Bunche Middle School Correspondence/Consultation/References: E. Coastal Zone Management Act D Project is not located in acoastal zone area and does not affect acoastal zone area (Review concluded! S Project is located in a coastal zone area and/or affects the coastal zone E] State administering agency does not require consistency review. (Review Concluded!. • State administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO (Review Concluded! Comments: This project is located within the Louisiana Coastal Management Zone. LA DNR has determined that receipt of federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the Coastal Zone may still require aCoastal Use Permit or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1-800-267-4019. Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act S Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (ReviewConcluded! • Projectaffects,controlsormodifiesawaterway/bodyofwater. D Coordination with USFWS conducted • No Recommendations offered by USFWS. (Review Concluded! O Recommendations provided by USFWS. Are project conditions required? • YES (see section V) • NO (Review Concluded! Comments: Project is not inoradjacent toany waterways ofthe US. Correspondence/Consultation/References: G. Clean Air Act El Project will not result in permanent air emissions. (Review Concluded! • Project is located in an attainment area. (Review Concluded! LI Projectislocatedinanon-attainmentarea. • Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act P Project does not affect designated prime or unique farmland. (Review Concluded! • Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. • Coordination with Natural Resource Conservation Commission required. • Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? Q YES (see section V) D NO (Review Concluded! Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act • Project not located within aflyway zone. (Review Concluded! El Project located within aflyway zone. EIProject does not have potential to take migratory birds. (Review Concluded! Are project conditions required? • Yes (see section V) ^ No (Review Concluded! • Project has potential to take migratory birds. • Contact made with USFWS Are project conditions required? • YES (see section V) • NO (Review Concluded! Record ofEnvironmental Consideration 4 10/13/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School system Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0234 Bunche Middle School Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has determined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other fish and wildlife reserves. These determinations are based on the understanding that the conditions outlined in the Louisiana Endangered Species Summary are met. Correspondence/Consultation/References: http://pacificflvwav.gov/Documents/Mississippi map.pdfl J. Magnuson-Stevens Fishery Conservation and Management Act El Project not located in ornear Essential Fish Habitat. (Review Concluded! • Project located inornear Essential Fish Habitat. • Project does not adversely affect Essential Fish Habitat. (Review Concluded! Are project conditions required? • Yes (see section V) • No (Review Concluded! • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) • NOAA Fisheries provided no recommendation(s) (Review Concluded!. Are project conditions required? • Yes (see section V) • No (Review Concluded! • NOAA Fisheries provided recommendation(s) O Written reply to NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) • NO (Review Concluded! Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act EIProject is not along and does notaffect Wild or Scenic River (WSR)-(ReviewConcluded! • Project isalong oraffects WSR • Project adversely affects WSR as determined by NPS/USFS. FEMA cannot fund the action. (NPS/USFS/USFWS/BLM consultation on file) (Review Concluded! • Project does not adversely affect WSR. (NPS/USFS/USFWS/BLM consultation on file) Are project conditions required? Q YES (see section V) • NO (Review Concluded! Comments: None Correspondence/Consultation/References: L. Other Relevant Laws and Environmental Regulations II. Compliance Review for Executive Orders A. E.0.11988 -Floodplains • No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded! G3 Located in Floodplain or Effects on Floodplains/Flood levels • No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded!. Are project conditions required? • Yes (see section V) • No (Review Concluded! • Beneficial Effect on Floodplain Occupancy/Values (Review Concluded!. E3 Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment ^ 8Step Process Complete -documentation on file Are project conditions required? El YES (see section V) • NO (Review Concluded! Comments: 07/19/2006 -Jefferson Parish enrolled in the National Flood Insurance Program on 10/01/1971. Per Flood Insurance Rate Map (FIRM) panel 22051C0030E, dated 03/23/1995, project is located in zone AE, area of100-year flooding; base flood elevation determined. Project is for the repair ofabuilding damaged by wind and wind-driven rain and is not likely to affect the floodplain. In compliance with EO 11988, an 8-step process was completed and attached. Per 44 CFR 9.11 (D) (9), the replacement ofbuilding contents, materials, and equipment shall require, as appropriate, disaster proofing and/or elimination ofsuch future losses by relocating those building contents, materials, and equipment outside or above the Advisory Base Flood Elevation. Per 44 CFR 9.12, applicant must publish afinal public notice 15 days prior to the Record ofEnvironmental Consideration 5 10/13/06 Reviewer Name: LethaDawson * •• «. . ^e^e.c^ start ofconstruction activities. Final public notice is to be forwarded to the LA GOHSEP and FEMA for inclusion in the permanent project files. -Kimberiy R. Rogers, Floodplain Management Specialist Correspondence/consultation/references: 8-Step Process B. E.0.11990-Wetlands S No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded! U Located in Wetland oreffects Wetland(s) • Beneficial Effect on Wetland-(Review Concluded) • Possible adverse effect associated with constructing in or near wetland • Review completed as part offloodplain review • 8Step Process Complete -documentation on file Are project conditions required? • YES (see section V) DNO (Review Concluded) Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations £J No Low income or minority population in, near or affected by the project -(Review Concluded! U Low income or minority population in or near project area DNo disproportionately high and adverse impact on low income or minority population-(Review Concluded! LJ Disproportionately high or adverse effects on low income or minority population Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: None Correspondence/Consultation/References: III. Other Environmental Issues Identify other potential environmental concerns in the comment box not clearly falling under alaw or executive order (see environmental concerns scoping checklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based on the review of compliance with other environmental laws and Executive Orders, and in consideration of other environmental factors, review the project for extraordinary circumstances. • A"Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of (ii) which should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can bemitigated, please explain incomments. Ifno, leave blank. Yes D (i) Greater scope or size than normally experienced for aparticular category of action |_| (ii) Actions with ahigh level ofpublic controversy • (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; • (iv) Employment ofunproven technology with potential adverse effects or actions involving unique or unknown environmental risks; • (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, cultural, historical orother protected resources; U (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local regulations orstandards requiring action orattention; Record ofEnvironmental Consideration 6 ' 10/13/06 ReviewerName: Letha Dawson U (v„) Actions wrth the potential to affect special status areas adversely or other critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, S^dTeic rivers pi , .... _ . ,, so,e or Principal drinking water aquifers; ' U (yin) Potential for adverse effects on health or safety-and U Ox) Potential to violate afederal, state, local or tribal law or requirement imposed for the Protection ofthe environment. F e U (x) Potential for significant cumulative impact when the proposed action is combined with other past, present and reasonably foreseeable future actions, even though the impacts of the j .v,.ovv«uii iuiiuc atuons, even mav h* sicnifi^f k„ .u ..... & uapaca or ine proposed proposedproposed action actionaction may not notnot be significant by themselves. Comments: None V. Environmental Review Project Conditinns General comments: None Project Conditions: L?rlTrrZR 9U (D)/9)'^ rePlace^nt of building contents, materials, and equipment shall tZ?Z' ^Ppropnate>dlsaster Pro°fing and/or elimination ofsuch future lossesZTelocatine Son £ZC^T"r'"* CqUipment °UtSide °r ab0Ve ** Advisory BLfpToor blevation. Per 44 CFR 9.12, applicant must publish afinal public notice 15 days prior to the stort of construction activities. Final public notice is to be forwarded to thelJgS^^i FEMA for inclusion in the permanent project files ^ ^ 2' toSI"8 w**"Stipulftionsof*ePA>-«Prosedrepairactivitiesshouldbedonein-kind omatch existing materials and form. Any change to the approved scope of work wilfrequirecomnZr "^T^ SeCti°n l°6 «* «™^with the SHPO Non compliance may jeopardize the receipt offederal funding 3. Unusable equipment, debris and material shall be disposed ofin an approved manner and ££Z1 CfT Si8nifiCant it6mS (0f CVidenCe *6re0f>^ discov^dddu^er^ implementation ofthe project applicant shall handle, manage, and dispose ofneiroleum £23£5£?" l"ft0XlC^ "aCC°rie t0^-"to the satistact on ofthegovernmg local, state and federal agencies Hnl ?ddiSP°f °fdebriS C°ntainin8 household hazardous waste and certain categories of hqud wastes must be performed in accordance with all applicable ftdeTandSLlaws regulations executive orders and guidelines. LAC Title 33 Part VII iSuSto»Sed items mcluding lead acid batteries, used oil filters, used motor oil, scSpITs CFcT 22?^radioactive waste or regulated infectious wastes nu*t be segregated from and ^^^3*-debris collection, staging, processing and d^sal sites F"L Ss*tb^^ 5. In accordance with the Formosan Termite Initiative Act, (LA R.S 3-3391 1thru 3391 1^ th. 7 10/13/06 Reviewer Name: Letha Dawson D^er/EnK^^^ architectural components (e.g. beams, doors and other wood salvaged from astructure) mav not eave the quarantined parishes without written authorization from me Coilis^nefofme LouisianaDepartmentofAgricultureandForestryorhisDesignee(s) LOmmiSS1°ner°f^ 6. Regardless of the asbestos content, the applicant is responsible for ensuring that renovation or demohtion activities are coordinated with the Louisiana Department ofEnvi«XuX (LDEQ) in accordance with the LDEQ "Seventh Amended Declaration ofEm^encv and Administrative Order" dated August 28, 2006 or latest amended declaratioSZatint the provisions of EPA's National Emission Standards for Hazardous AirSSSt *e Louisiana Administrative Code (LAC) 33.111.5151 and Chapter2K^S^f} Containing Materials (ACMS) be present at the project site, thel^applicant is also espTnsible for enuring proper disposal in accordance with the previously referenced adn^^nisfra3der 7. Activities involving abrading (sanding, scraping, etc.), heating, stripping oroSse ~Sl^wt°fPr r^ ^ apP>^^^^^ Parts W«lT ru (? °rker Safety)' ^ 40 CFR 260 ^"gh 268 (EPA -Hazardous Waste). The applicant is responsible for ensuring that renovation or demolition aSes are rfsXteTpltlel^rDepartment/E-—ental QualityforabtS* rT^nldS^ 8. This project potentially involves the disposal ofmetallic mercury containing electronic devices The applicant is responsible for ensuring that these devices m*L^Z££%^ sequestered inaccordancewiththe LouisianaDepartmentofEnvironment? Declara ion ofEmergency; Mercury-Containing Devices and Electronic Equipment^ Universal Waste" letter dated October 3,2005. equipment as Monitoring Requirements: None Record of Environmental Consideration » 8 10/13/06