Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services Record of Environmental Consideration See44Code ofFederal Regulation Part10. Project Name/Number: EJE 0238 West Bank Student Services / PW 11631 Proiect Location: 2300Barataria Boulevard, Marrero, Louisiana, Jefferson Parish70072 (N29.86191,W-90.09847) Proiect Description: Project activities include removing and replacing 4,000 SF ofroll roofing, 4,000 SFofroofdeckinsulation(2.0"),64SFofsuspendedceilingtile(4.0'X2.0')and64 SFoffiberglass insulation (3.5" thick). Hazard Mitigation will be achieved through compliance with current codes and standards and good construction practices. • (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 no other laws apply. (Review Concluded) ^ (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 0 Statutorily excluded from NEPA review. (Review Concluded) • Programmatic Categorical Exclusion -Category (Review Concluded) l~l Categorical Exclusion -Category l~l No Extraordinary Circumstances exist. Are project conditions required? • Yes (see section V) • No (Review Concluded) CU Extraordinary Circumstances exist (See Section rV). • Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) 1 I Environmental Assessment • Supplemental Environmental Assessment (Reference EA or PEA in comments) ^ Environmental Impact Statement Comments: This project meets the criteria for an Alternative Arrangement for (Permanent Schools) type ofproject. Record ofEnvironmental Consideration 1 07/26/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: June RnGriffin, Environmental Specialist Signature (YjUJU. (K.\LjA/uf/' ^ Date 7/26/06 , FEMA Regional Environmental ^fmcer or delegated approving official. Name: Ddjiald Fairley, ELO Signature' 7-—^— /—a ^=^ Date 7/26/06 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act 0>3 Not type ofactivity with potential to affect historic properties. (Review Concluded) • Applicable executed Programmatic Agreement . Otherwise, conduct standard Section 106 review. Q Activity meets Programmatic Allowances . Are project conditions required? • Yes (see section V) • No(Review Concluded) HISTORIC BUILDINGS AND STRUCTURES 0*3 No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) • Building or structure listed or 45/50 years or older in project area and activity not exempt from review. • Determination ofNo Historic Properties Affected (FEMA fmding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) QNo (ReviewConcluded) • Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence on file) • Property aNational Historic Landmark and National Park Service was provided early notification duringthe consultationprocess.If not, explainin comments • No Adverse Effect Determination (FEMA fmding/SHPO/THPO concurrence on file). Are project conditions required? • Yes (see section V) • No(Review Concluded) • Adverse Effect Determination (FEMA fmding/SHPO/THPO concurrence on file) • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required Q Yes (see section V) • No(Review Concluded) ARCHEOLOGICAL RESOURCES K Project affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. d 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) l~~l Project area has potential for presence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) • No (Review Concluded) C] Determination ofhistoric properties affected • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required QYes (see section V) • No(Review Concluded) • NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) • No(Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Record of Environmental Consideration 2 07/26/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required? • Yes (see section V) • No (Review Concluded) Comments: Buildings constructed in 1964 & 1977. 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. Seview Concluded) Listed species and/or designated critical habitat present inthe areas affected directly orindirectly bythe 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 concurrenceonfile)(ReviewConcluded) Are project conditions required? • Yes (see section V) • No(Review Concluded) • Likely to adversely affect species ordesignated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: None C. Coastal Barrier Resources Act G3 ProjectisnotonorconnectedtoCBRA UnitorOtherwise Protected Area(Review Concluded). • Project is on orconnected to CBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on file) • 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 [3 Project would not affect any waters ofthe U.S. (Review Concluded) • Project would affect waters, including wetlands, ofthe U.S. • 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 isnotinoradjacenttoanywaterways ofthe U.S. Correspondence/Consultation/References: E. Coastal Zone Management Act • Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) E3Projectislocatedina coastal zone area and/or affects thecoastal zone ^ State administering agency does not require consistency review. (Review Concluded). d State administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO(Review Concluded) Comments: FEMA has determined that this project isconsistent with the Coastal Zone Management Act and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: Record of Environmental Consideration 07/26/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services F. Fish and Wildlife Coordination Act E]Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (ReviewConcluded) O Project affects, controls ormodifies awaterway/body ofwater. • Coordination with USFWS conducted • No Recommendations offered by USFWS. (Review Concluded) • Recommendations provided by USFWS. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the U.S. Correspondence/Consultation/References: G. Clean Air Act 03 Project will not result in permanent airemissions. (Review Concluded) C]Projectislocatedinanattainmentarea. (ReviewConcluded) O Projectislocatedina non-attainmentarea. n Coordination required with applicable state administering agency.. Are project conditions required? Q YES (see section V) QNO (Review Concluded) Comments: Projectwillnotresult inpermanentair emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act El Project does not affect designated prime orunique farmland. (Review Concluded) • Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. O Coordination with Natural Resource Conservation Commission required. • Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act [UProjectnotlocatedwithinaflywayzone. (ReviewConcluded) ^ Project located within a flyway zone. ^ Project does not have potential totake migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) ^ No(Review Concluded) Q Project has potential to take migratory birds. • Contact made withUSFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) 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 nothave adverse impacts onmigratory birds orother fishandwildlifereserves. Thesedeterminationsarebasedontheunderstandingthatthe conditionsoutlinedinthe Louisiana Endangered SpeciesSummaryare met. Correspondence/Consultation/References: http://pacificflvwav.gov/Documents/Mississippi_map.pdf, Record of Environmental Consideration 4 07/26/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services J. Magnuson-Stevens Fishery Conservation and Management Act El Project not located inornear 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) C]NOAA Fisheries provided recommendation(s) d 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 ^ Project is not along and does not affect Wild orScenic River (WSR) -(Review Concluded) • 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)(ReviewConcluded) • Project does not adversely affect WSR. (NPS/USFS/USFWS/BLM consultation on file) Are project conditions required? • 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) (3 Located in Floodplain orEffects 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). • Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment • 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: 07/26/2006-Jefferson Parishenrolled inthe National Flood Insurance Program(NFIP) on10/01/1971. Per FloodInsuranceRateMap(FIRM)Panel#22051C0135E,dated03/23/1995,siteislocatedwithinan"X"Zone,project is repairpre-disasterfootprint, andisgenerallynotregulatedbylocalfloodplainordinance.- Rezwan Karim, CFM Correspondence/Consultation/References: B. E.0.11990-Wetlands ^ No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) • Beneficial Effecton Wetland -(Review Concluded) O Possible adverse effect associated with constructing in or near wetland n Review completed as part offloodplain review • 8StepProcessComplete-documentationonfile Record ofEnvironmental Consideration 5 07/26/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Tide: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations £3 No Low income or minority population in, near or affected by the project -(Review Concluded) • Low income or minority population in or near project area • No disproportionately high and adverse impact on low income or minority population-(Review Concluded) • Disproportionately high or adverse effects on low income or minority population Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: III. Other Environmental Issues Identifyotherpotentialenvironmental concernsinthecommentboxnotclearly falling underalawor 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 considerationofotherenvironmental factors, reviewtheprojectforextraordinarycircumstances. *A"Yes" under any circumstance may require anEnvironmental Assessment (EA) with the exception of(ii) which should beapplied inconjunction with controversy onan environmental issue. Ifthe circumstance can be mitigated, please explain in comments. Ifno, leave blank. Yes • (i) Greater scope or size than normally experienced for aparticular category ofaction C] (ii) Actions with ahigh level ofpublic controversy • (iii) Potential for degradation, even though slight, ofalready 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 or other protected resources; • (vi) Presence ofhazardous or toxic substances atlevels which exceed Federal, state or local regulationsor standardsrequiringaction or attention; • (vii) Actions with the potential to affect special status areas adversely or other critical resources suchas wetlands, coastalzones, wildlife refuge andwilderness areas, wildand scenic rivers, sole or principaldrinkingwater aquifers; • (viii) Potential for adverse effects on health orsafety; and • (ix) Potential to violate afederal, state, local or tribal law or requirement imposed for the protection ofthe environment. • (x) Potential for significant cumulative impact when the proposed action is combined with other past, present and reasonably foreseeable future actions, even though theimpacts ofthe proposedactionmaynotbe significantbythemselves. Comments: None Record of Environmental Consideration 6 07726/06 f t Reviewer Name: June R. Griffin Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EJE 0238 West Bank Student Services V. Environmental Review Proiect Conditions Project Conditions: None Monitoring Requirements: None Record ofEnvironmental Consideration 7 07/26/06