Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EIE0276 Douglas Elementary School Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number; Douglas Elementary School / PW 12354 ProjectLocation; 1400 Huey Long Avenue, Gretna, Louisiana, Jefferson Parish 70053 (N29.54259, W-90.03322) Project Description: Projectactivities include repairing theintercom andfire alarm systems; removing andreplacing flattile roof, roofsheathing, terracottaridgeline, roofventcaps, woodsoffit, window glass, fluorescent light fixtures, metal gutter, fascia board, acoustical ceiling tiles, carpet, VCT floors, gypsum board walls, wall mounted gas heaters, shingles and felt, gutters, rafter ceiling, plywood ceiling, downspout and plywood siding; repainting CMU walls; andcleaning andsealing terrazzo floorsandVCT floors. Somehazardmitigationwillbe achievedbycompliancewithcurrent codesand standards and by good construction practices. Documentation Requirements f~l No Documentation Required (Review Concluded) l~~l (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) 1X1 (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 l~~l Statutorily excluded from NEPA review. (Review Concluded) 0 Programmatic Categorical Exclusion -Category (Review Concluded) 1 I Categorical Exclusion -Category I I No Extraordinary Circumstances exist. Are project conditions required? O Yes (see section V) Q No (Review Concluded) I I Extraordinary Circumstances exist (See Section IV). I I Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? O Yes (see section V) • No (Review Concluded) I I Environmental Assessment |~1 Supplemental Environmental Assessment (Reference EA or PEA incomments) 1X1 Environmental Impact Statement Comments: ThisprojectmeetsthecriteriaforanAlternative Arrangement(PermanentSchools)typeofproject. This projecthasconditions andrequiresmitigationundertheotherEnvironmental andHistoricPreservation(EHP) Laws. Record of Environmental Consideration 1 08/05/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0276 Douglas Elementary School Reviewer and Approvals d Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Letha Specialist ;tha Dawson, Dawson,Dawson, Environmental EnvironmentalEnvironmental S SignaturelY AmWKVMklJ'GJV &Date 08/05/2006 FEMARegional Environmental Officerordelegated approving official. Name: Howard R. Bush, ELO Signature r^^-/*^ ^ . Date 08/05/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act • Not type ofactivity with potential toaffect historic properties. (Review Concluded) [3 Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. ^ Activity meets Programmatic Allowance # Appendix A, Section {II-B1, II-B2, II-E1, II-C2, II-A2, II-A4, IID2} Are project conditions required? ^ Yes (see section V) • No(Review Concluded) HISTORIC BUILDINGS AND STRUCTURES d No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) C] Building or structure listed or45/50 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) C]PropertyaNational Historic LandmarkandNational Park Service was provided early notification during the consultation process. If not, explain in comments • 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) Q Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required • Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES Kl Project affects only previously disturbed ground. (Review Concluded) f~l Project affects undisturbed ground. d Project area has no potential for presence ofarcheological resources • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation onfile). (Review Concluded) l~l Project area has potential for presence of archeological resources • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) • No (Review Concluded) f~l Determination ofhistoric properties affected • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required DYes (see section V) • No (Review Concluded) O 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 08/05/06 I f j || jJ j { S I j f { | | f Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0276 Douglas Elementary School • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required? • Yes (see section V) • No (Review Concluded) Comments: 08/04/2006 -FEMA's Programmatic Agreement (PA), dated December 3,2004, provides for expedited project review under Section 106 ofthe National Historic Preservation Act (NHPA). The scope ofwork assubmitted in this PW has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section {II-B1, II-B2, II-E1, II-C2, II-A2, II-A4, II-D2}, ofthe document. In accordance with the PA, FEMA isnot required todetermine the National Register eligibility ofproperties orto 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 offederal funding. This concludes the Section 106 review for this project. V. Gomez, Historic Preservation Specialist Correspondence/Consultation/References: B. Endangered Species Act E3 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) • Listed species 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? Q 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 on file) (Review Concluded) 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) • NO(Review Concluded) Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act ^ ProjectisnotonorconnectedtoCBRAUnitorOtherwiseProtectedArea(ReviewConcluded). • Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on file) • Proposed action anexception 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 G3 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 orother 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: Projectisnotinoradjacenttoany waterways oftheUS. Correspondence/Consultation/References: E. Coastal Zone Management Act O Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) ^ Projectislocatedina coastalzoneareaand/oraffectsthecoastalzone Record of Environmental Consideration 08/05/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergeiicy/Prograin/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program / EJE0276 Douglas Elementary School EI State administering agency does not require consistency review. (Review Concluded). Lj State administering agency requires consistency review. Are project conditions required? • YES (see section V) f~l NO (Review Concluded) Comments: FEMA has determined that this project is consistent with the Coastal Zone Management Act (CZMA) and theLouisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act S Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (Review Concluded) D Projectaffects,controlsormodifiesawaterway/bodyofwater. • 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 isnot inoradjacent toany waterways ofthe US. Correspondence/Consultation/References: G. Clean Air Act ^ Project will not result in permanent air emissions. (Review Concluded) • Projectislocated inanattainmentarea. (Review Concluded) C] Project islocated ina non-attainment area. • Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act ^ Project does not affect designated prime or unique farmland. (Review Concluded) • Project causes unnecessary or irreversible conversion of designated 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) ^ Project located within aflyway zone. E3 Project 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. • ContactmadewithUSFWS 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 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://pacificflvway.gov/Documents/Mississippi mapjxlf. Record of Environmental Consideration 08/05/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0276 Douglas Elementary School J. Magnuson-Stevens Fishery Conservation and Management Act ED Project not located inornear Essential Fish Habitat. (Review Concluded) • Projectlocatedinor nearEssentialFishHabitat. • 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) [H NOAA Fisheries provided recommendation(s) • Written reply to NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act M Project is not along and does not affect Wild or Scenic 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 consultationonfile)(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) [X] 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). O Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain environment O 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: 07/31/06 -The Parish ofJefferson enrolled intheNational Flood Insurance Program (NFIP) 10/01/71. Per Flood Insurance Rate Map2205IC0135 E,dated 03/23/95, projectislocated inzone Xshaded; areaprotected from the 100-yr flood by levee, dike orother structures subject topossible failure orovertopping during larger floods. Project is repairofbuilding, which was damaged bywind andwind-driven rain, topre-disaster footprint andshouldhave noeffecton the floodplain. Casey Barefield, FPM. Correspondence/consultation/references: B. E.0.11990-Wetlands £3 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) O Beneficial Effecton Wetland -(ReviewConcluded) CH Possible adverse effect associated with constructing in ornear wetland O Review completed aspart offloodplain review Record of Environmental Consideration 08/05/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0276 Douglas Elementary School • 8 Step Process Complete -documentation on file 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^ No Low income or minority population in, near or affected by the project -(Review Concluded) LZ1 Low income orminority population in ornear 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 Identifyotherpotentialenvironmentalconcernsinthecommentboxnotclearly fallingunderalawor executiveorder (see environmentalconcernsscopingchecklistforguidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Basedonthereviewofcompliancewith otherenvironmentallawsandExecutiveOrders,andin consideration of otherenvironmental factors, review the project for extraordinary circumstances. • A"Yes" under any circumstance may require anEnvironmental Assessment (EA) with the exception of(ii) which should be applied in conjunction withcontroversy on an environmental issue. If the circumstance can be mitigated, please explain in comments. If no, leave blank. Yes • (i) Greater scope or size than normally experienced for aparticular category ofaction CI (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 ortoxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; • (vii) Actions with the potential to affect special status areas adversely or other critical resources suchas wetlands, coastal zones, wildlife refuge andwilderness areas, wildandscenic rivers, sole or principaldrinkingwateraquifers; • (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 of the 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 proposed action may not be significantby themselves. RecordofEnvironmentalConsideration 6 08/05/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System j Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0276 Douglas Elementary School 1 Comments: None V. Environmental Review Project Conditions ! i General comments: None { | Project Conditions: j | 1. In keeping with the stipulations of the PA, all proposed repair activities should be done in-j kindtomatchexistingmaterialsandform. Anychangetotheapprovedscopeofworkwill { require resubmission for re-evaluation under Section 106 and consultation with the SHPO. j Non-compliance mayjeopardize the receipt of Federal funding. I f l Monitoring Requirements: None I Record ofEnvironmental Consideration 7 08/05/06