Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EJE0312GretnaParkElementarySchool Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number: Gretna Park Elementary School / PW 13088 Project Location: 1130 Gretna Blvd., Gretna, Louisiana, Orleans Parish 70053 (N30.01536, W-90.00852) Project Description: Project activities include removing and replacing roof vents, suspended ceiling tile, fiberglass insulation, wood paneling, carpet, modified bitumen roofing, roof deck insulation, flashing, metal gutter, plywood soffit, fluorescent light fixtures, gypsum drywall, vinyl asbestos tile and replace with VCT flooring, communications and fire alarm systems, and asphalt shingles; repainting CMU walls; refinishing VCT flooring, wood flooring, and terrazzo flooring; and cleaning and sterilizing metal ductwork. Some mitigation will be achieved by compliance with current codes and standards and by good construction practices. Documentation Requirements I I No Documentation Required (Review Concluded) I I (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) CK] (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 I I Statutorily excluded from NEPA review. (Review Concluded) I I Programmatic Categorical Exclusion -Category (Review Concluded) I I Categorical Exclusion -Category I I NoExtraordinary Circumstances exist. Are project conditions required? Q Yes (see section V) Q No (Review Concluded) I I Extraordinary Circumstances exist (See Section IV). I I Extraordinary Circumstances mitigated. (See Section IVcomments) Are project conditions required? O Yes (see section V) Q No (Review Concluded) I I Environmental Assessment I I SupplementalEnvironmentalAssessment(ReferenceEAorPEAincomments) 1X1 Environmental Impact Statement Comments: 8/10/2006 This project meets the criteria for an Alternative Arrangement (Permanent Schools) type of project. This project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) Laws. Record of Environmental Consideration 1 08/10/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System I Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program / EJE 0312 Gretna Park Elementary School 1 Reviewerand Approvals j CH Project is Non-Compliant (See attached documentation justifying selection). t i FEMA Environmental Reviewer. I Name: Letha Dawson, Environmental Specialist } Signature rt&kaAQn./X^WfiAV^i i t/2xg~^ . Date 08/10/2006 FEMARegional Environmental Officeror delegated approving official. Name: Howard R. Bush, ELO Signaturen&j^—f*f^ , Date 08/10/2006 A—~2^-r I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act I • Not type ofactivity with potential toaffect historic properties. (Review Concluded) I S Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. | ^ Activity meets Programmatic Allowance # Appendix A, Sections II.A. 1; II.A.2; II.A.4; II.A.6; II.B. 1; II.D. 1; I II.D.2;II.E.landII.F.l S Are project conditions required? ^ Yes (see section V) • No (Review Concluded) f fflSTORIC BUILDINGS AND STRUCTURES % \ • No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) f O Building orstructure listed or45/50 years orolder in project area and activity not exempt from review. ! • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) I Are project conditions required? • Yes (see section V) • No (Review Concluded) \ • Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence on file) \ • Property aNational Historic Landmark and National Park Service was provided early notification f duringtheconsultation process. Ifnot, explainincomments \ • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? • Yes (see section V) • No (Review Concluded) f • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) [, • Resolution ofAdverse Effect completed. (MOA on file) \ Are project conditions required • Yes (see section V) • No (Review Concluded) % \ ARCHEOLOGICAL RESOURCES | E3 Project affects only previously disturbed ground. (Review Concluded) f Q Project affects undisturbed ground. I l~1 Project area has no potential for presence ofarcheological resources 1 • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence or j consultation on file). (ReviewConcluded) { f~l Project area has potential for presence ofarcheological resources f • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) j Are project conditions required • Yes (see section V) • No (Review Concluded) j O Determination ofhistoric properties affected f • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). | Are project conditions required ClYes(see section V) • No (Review Concluded) I 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) j Are project conditions required? • Yes (see section V) • No (Review Concluded) j • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) f Record of EnvironmentalConsideration 2 08/11/06 I I Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System | DiMsttr/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0312 Gretna Park Elementary School I ResolutionofAdverseEffectcompleted.(MOAonfile) I Are project conditions required? Q Yes (see section V) C3 No | (Review Concluded) Comments: 8.8.06 FEMA's Programmatic Agreement (PA), dated December 3,2004, provides forexpedited project review under Section 106 of theNational Historic Preservation Act(NHPA). The scope of work as submitted inthis PW has beenreviewed and meetsthe criteriaoutlined in Appendix A, Programmatic Allowances, Sections II.A.1; II.A.2; II.A.4; II.A.6; II.B.l; II.D.l; II.D.2; II.E.l AND II.F.l of the document. Inaccordance with the PA, FEMA is notrequired to determine the National Register eligibility of properties or to submit projectsto the State HistoricPreservation Officer (SHPO) for review where the workperformed meets theseallowances. In keeping withthe stipulations of thePA, all proposed repair activities should be done in-kind to match existing materials andform. Anychange to theapproved scope of work will require resubmission forre-evaluation under Section 106 andconsultation with the SHPO. Non-compliance mayjeopardize the receipt of federal funding. Thisconcludes the Section 106review for thisproject. James Crouch, Historic Preservation Specialist Correspondence/Consultation/References: B. Endangered Species Act S No listed species and/or designated critical habitat present in areas affected directly orindirectly by the Federal action. (Review Concluded) • Listed species and/or designated critical habitat present in the areas affected directly orindirectly by the Federal action. • No effect tospecies ordesignated critical habitat (See comments for justification) Are project conditions required? • Yes (see section V) • No(Review Concluded) O May affect, but not likely toadversely affect species ordesignated critical habitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? • Yes (see section V) • No (Review Concluded) O Likely to adversely affect species ordesignated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (seesection V) • NO(Review Concluded) Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act ^ Project isnotonor connected to CBRA Unit or Otherwise Protected Area (Review Concluded). • Project ison orconnected to CBRA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on file) • Proposed action anexception under Section 3505.a.6? (Review Concluded) O Proposed action notexcepted 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 S Project would not affect any waters ofthe U.S. (Review Concluded) Q Project would affect waters, including wetlands, ofthe U.S. O Project exempted asinkind replacement orother exemption. (Review Concluded) O Project requires Section 404/401/or Section 9/10 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? O YES (see section V) O NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: E. Coastal Zone Management Act l~~l Project isnot located ina coastal zone area and does notaffect a coastal zone area (Review concluded) I { Record of Environmental Consideration 3 08/10/06 I I Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0312 Gretna Park Elementary School ^ Projectislocatedina coastalzoneareaand/oraffectsthecoastalzone 13State administering agency does not require consistency review. (Review Concluded). O 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 (CZMA) andtheLouisianaCoastalManagement Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act S Project does not affect, control, ormodify awaterway/body ofwater. (Review Concluded) • 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: Projectisnotinoradjacent toany waterways oftheUS. Correspondence/Consultation/References: G. Clean Air Act E<] Project will not result inpermanent airemissions. (Review Concluded) • Projectislocatedinan attainmentarea. (Review Concluded) LZI Project islocated ina non-attainment area. O 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 EE] Project does not affect designated prime orunique farmland. (Review Concluded) C]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 • Project not located within a flyway zone. (Review Concluded) Kl Project located within a flyway zone. [*3 Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) £3 No(Review Concluded) O Project has potential totake migratory birds. • Contactmadewith USFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: See letter from DonFairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has determined thatrestoration projects funded with federal resources will nothave adverse impacts onmigratory birds orother fish andwildlife reserves. These determinations arebased ontheunderstanding thatthe conditions outlined intheLouisiana Endangered Species Summary are met. Correspondence/Consultation/References: httpj//Eacificflywav.gov/Documents/Mississippi map.pdf. Record of Environmental Consideration 08/10/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School System | Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0312 Gretna Park Elementary School I J. Magnuson-Stevens Fishery Conservation and Management Act I [3Projectnotlocatedinor nearEssentialFishHabitat. (ReviewConcluded) I • Project located in or near Essential Fish Habitat. f • Project does not adversely affect Essential Fish Habitat. (Review Concluded) j Are project conditions required? • Yes (see section V) • No(Review Concluded) \ • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) i O NOAA Fisheries provided no recommendation(s) (Review Concluded). \ Are project conditions required? • Yes (see section V) • No(Review Concluded) [ O NOAA Fisheries provided recommendation(s) | d Written reply toNOAA Fisheries recommendations completed. I Are project conditions required? • YES (see section V) • NO (Review Concluded) j Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act [X] ProjectisnotalonganddoesnotaffectWildorScenicRiver(WSR)-(ReviewConcluded) d Project isalong oraffects WSR • Project adversely affects WSR asdetermined byNPS/USFS. FEMA cannot fund theaction. (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? • YES (seesection 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 C] No Effect on Floodplains/FIood levels and project outside Floodplain -(Review Concluded) EI Located inFloodplain orEffects onFloodplains/FIood levels Q No adverse effect onfloodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? O Yes (see section V) O No(Review Concluded) • Beneficial Effect onFloodplain Occupancy/Values (Review Concluded). ^ Possible adverse effects associated with investment in floodplain, occupancy ormodification offloodplain environment E3 8Step Process Complete-documentation onfile Are project conditions required? ^ YES (see section V) • NO (Review Concluded) Comments: 08/10/2006-TheCityofGretnaenrolledintheNationalFloodInsuranceProgram(NFIP)on06/18/1971. Per FloodInsuranceRateMap(FIRM)panel22051C0145 E,dated03/23/1995,projectis locatedinzoneAE,areaof 100-year flood;basefloodelevationsdetermined. Projectisforrepairofabuildingdamagedbywindandwind-drivenrainandisnot likelytoaffectthefloodplain. IncompliancewithEO11988,an8-stepprocesswascompletedandattached.Per44CFR 9.11 (D) (9), the replacement of building contents, materials, and equipment shall require,as appropriate, disaster proofing and/orelimination ofsuchfuturelossesbyrelocatingthosebuildingcontents,materials,andequipmentoutsideorabovethe advisorybasefloodelevation.Per44CFR9.12,applicantmustpublishafinalpublicnotice 15dayspriortothestartof constructionactivities. Finalpublicnoticeistobe forwarded totheLA GOHSEPandFEMAforinclusioninthe permanent project files. -Kimberly R. Rogers, Floodplain Management Specialist. Correspondence/consultation/references: 8-Step Process B. E.0.11990-Wetlands ^ No Effects onWetland(s) and project located outside Wetland(s) -(Review Concluded) % Record of Environmental Consideration 5 08/10/06 I Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0312 Gretna Park Elementary School • Located in Wetland oreffects Wetland(s) • Beneficial Effect on Wetland -(Review Concluded) Li Possible adverse effect associated with constructing inornear wetland • Review completed as part offloodplain review • 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) [H 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 Identify other potential environmental concerns in the comment box not clearly falling under a law or executive order(seeenvironmentalconcernsscopingchecklistfor guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based on the review of compliance with other environmental laws and Executive Orders, and in considerationofotherenvironmentalfactors, reviewtheprojectforextraordinary circumstances. • A"Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of(ii) which should beapplied inconjunction with controversy onan environmental issue. Ifthecircumstance can be mitigated, please explain in comments. If no, leave blank. Yes • (i) Greater scope or size than normally experienced for aparticular category ofaction • (ii) Actions with a high level ofpublic controversy • (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; • (iv) Employment of unproven 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 at levels which exceed Federal, state orlocal regulationsor standardsrequiringactionor attention; • (vii) Actions with the potential to affect special status areas adversely or other critical resources such aswetlands, coastal zones, wildlife refuge andwilderness areas, wild and scenic rivers, soleor principaldrinkingwateraquifers; • (viii) Potential for adverse effects on health or safety; and • (ix) Potential to violate afederal, state, local or tribal law or requirement imposed for the protection ofthe environment. Record of Environmental Consideration 6 08/10/06 Reviewer Name: Letha Dawson Applicant: Jefferson Parish Public School-System Disaster/Emergency/Program/ProjectTitle: DRI603LA/HurricaneKatrina/PublicAssistanceProgram/EJE0312GretnaParkElementarySchool • (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 ofthe proposed action may notbesignificant bythemselves. Comments: None V. Environmental Review Project Conditions General comments: None Project Conditions: 1. 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-compliancemayjeopardizethereceiptoffederal funding. 2. 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 a final public notice 15 days prior to the start of construction activities. Final public notice is to be forwarded to the LA GOHSEP and FEMA for inclusion inthe permanent project files. Monitoring Requirements: None Record of Environmental Consideration 08/10/06