Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program /EJE 0356 West Jefferson High School Record of Environmental Consideration See44Codeof Federal Regulation Part10. Project Name/Number: EJE 0356 West Jefferson High School, / PW 13791 Project Location: 2200 8th Street, Harvey, Louisiana Jefferson Parish (N29.90367 W-90.07518) Project Description: Project activities include replacing 56,632 SF ofceiling tile, 600 LF ofpipe insulation, 22,540 SF offelt underlayment, 870 SF ofmetal flashing, 168 LF ofcupper gutters, 20 LF ofcoping, 16SFofstorefrontwindowsystem,94LFofvinylcovebase,4,800SFofmodifiedbitumen roof membrane, 300 SF ofcopper flashing and 200 LF ofmetal wall louvers. Hazard mitigation will be achieved by compliance with codes and standards. Documentation Requirements LZJ 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 completedandnootherlawsapply. (ReviewConcluded) ^ (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) 0 Programmatic Categorical Exclusion -Category (Review Concluded) 1 I Categorical Exclusion -Category l~l No Extraordinary Circumstances exist. Are project conditions required? • Yes (see section V) • No (Review Concluded) O Extraordinary Circumstances exist (See Section IV). • Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) I I Environmental Assessment • Supplemental Environmental Assessment (Reference EA or PEA in comments) 1X1 Environmental Impact Statement Comments: This project meets the criteria for an alternative arrangement (Permanent Schools) type ofproject. This project has conditions and requires mitigation under the other EHP laws which are listed under the NEPA level of environmental reviewintheprojectworksheet. Anychangestothisapprovedscopeofworkwillrequiresubmissionto,andevaluationand approval by, the state and FEMA priortoinitiationofany work, for compliance withthe National Environmental Policy Act.Theapplicantisrequiredtoobtainandcomplywithalllocal,stateandfederalpermitsandrequirements. Noncompliance with the requirements noted above may jeopardize the receipt offederal funding. Record of Environmental Consideration 08/31/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0356 West Jefferson High School Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: CatherineJones, Environmental Specialist Signature \rjffd7UJ f fX> Yd , Date 8/31/2006 FEMA Regional Environmental officeror delegatedapproving official. Name: Howard R. Bush, ELO Signature f^^-/ ^ ,<^ 1Date 8/31/2006 T.Compliance Reviewfor Environmentai Laws (other than NEPA) A. National Historic Preservation Act [3 Not type ofactivity with potential to affect historic properties. (Review Concluded) • Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. f~l Activity meets Programmatic Allowance # Are project conditions required? • Yes (see section V) • No(Review Concluded) HISTORIC BUILDINGS AND STRUCTURES ^ No historic properties that are listed or 45/50 years or older 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 finding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) DNo (Review Concluded) • Determination of Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) • Property aNational Historic Landmark and National Park Service was provided early notification duringtheconsultation process. Ifnot,explain in comments • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? • Yes (see section V) DNo (Review Concluded) • 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 [3 Project affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. Q 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) d 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 (seesection V) • No (Review Concluded) O 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? Q Yes (see section V) • No (Review Concluded) • 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 Record of Environmental Consideration 2 08/31/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DRl 603LA / Hurricane Katrina / Public Assistance Program / EJE 0356 West Jefferson High School (Review Concluded) Comments: 08/31/2006 -Themain building was constructed in 1972. Correspondence/Consultation/References: B. Endangered Species Act 03 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? • 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 or designated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) d?~D YESTsee Section VTff^TTafRe^ewroliclugeai Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act El Project is not on orconnected toCBRA Unit orOtherwise Protected Area (Review Concluded). • Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on file) • Proposed action an exception under Section 3505.a.6? (Review Concluded) O 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 C3 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 isnotinor adjacent toanywaterways ofthe US. Correspondence/Consultation/References: E. Coastal Zone Management Act • Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) E3Project islocated ina coastal zone area and/or affects the coastal 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: This project islocated 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 requireacoastalusepermitorotherauthorizationfromDNR. ProjectsmaybecoordinatedbycontactingLADNRat1800- 267-4019.). Correspondence/Consultation/References: Record ofEnvironmental Consideration 3 08/31/06 I | I Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0356 West Jefferson High School I 1 F. Fish and Wildlife Coordination Act ! S Project does not affect, control, or modify awaterway/body ofwater. (Review Concluded) I d Projectaffectscontrolsormodifiesawaterway/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) I Comments: Project isnotinor adjacenttoanywaterways ofthe US. Correspondence/Consultation/References: G. Clean Air Act ^ Project will not result in permanent air emissions. (Review Concluded) • Projectislocatedinanattainmentarea. (Review Concluded) (~1 Projectislocatedina non-attainmentarea • 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) O 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 O Project not located within a flyway zone. (Review Concluded) E3 Project located within a flyway zone. 13Projectdoes not have potentialtotake migratorybirds. (Review Concluded) Are project conditions required? • Yes (see section V) ^ No (Review Concluded) O Project has potential totake migratory birds. • Contact made withUSFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: See letter from Don Fairley toMr. 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 orother fish and wildlife reserves. These determinations arebased ontheunderstanding that theconditions outlined inthe Louisiana Endangered Species Summary are met. Correspondence/Consultation/References: http://pacificflvwav.gov/Documents/Mississippi map.pdf J. Magnuson-Stevens Fishery Conservation and Management Act ^ Projectnotlocatedinor nearEssentialFishHabitat. (Review Concluded) O Projectlocatedinor nearEssentialFishHabitat. • Project does not adversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? • Yes (see section V) • No (ReviewConcluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) O NOAA Fisheries provided no recommendation(s) (Review Concluded). Record of Environmental Consideration 4 08/31/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0356 West Jefferson High School Are project conditions required? • Yes (see section V) • No(Review Concluded) • NOAA Fisheries provided recommendation(s) • 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 or Scenic River (WSR) -(Review Concluded) • Project is along 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? • YES (see section V) • NO (Review Concluded) Uommeriis: 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). 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: 08/29/2006-TheParishofJeffersonisenrolledintheNationalFloodInsuranceProgram(NFIP)asof 10/01/1971. PerFloodInsuranceRateMap(FIRM)panelnumber22051c0135edated03/23/1995,siteislocated withina shaded"X"zone,areasof500-yearflood; areasof100-yearfloodwithaveragedepthsoflessthan 1footorwithdrainage areas less than 1square mile; and areas protected by levees from 100-year flood. Project isrepair ofbuildings, including electrical components. Per hurricane Katrina surge inundation and Advisory Base Flood Elevation (ABFE) maps, dated June 2006, building contents, components, and equipment must beelevated three feet above thehighest existing adjacent grade. K. Roof, Floodplain Management Specialist Correspondence/Consultation/References: B. E.0.11990-Wetlands ^ No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located inWetland oreffects Wetland(s) • Beneficial Effecton Wetland -(ReviewConcluded) CD Possible adverse effect associated with constructing in or near wetland O Review completed aspart offloodplain review l~1 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 08/31/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0356 West Jefferson High School C. E.0.12898 -Environmental Justice For Low Income and Minority PopulationsE3 No Low income or minority population in, near or affected by the project -(Review Concluded) LJ Low income orminority population in ornear project area LJNo disproportionately high and adverse impact on low income orminority 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 Identifyother potentialenvironmentalconcernsinthecomment boxnotclearly falling underalaw or executiveorder (see environmentalconcernsscopingchecklistforguidance). 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. If no, leave blank. O (0Greater scope or size than normally experienced for aparticular category ofaction C] (ii) Actions with a high level ofpublic controversy Q (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 atlevels which exceed Federal, state orlocal regulations or standards requiring action or attention; d (vii) Actions with the potential to affect special status areas adversely orother critical resources suchaswetlands, coastalzones, wildlife refugeandwilderness areas,wildand scenic rivers, sole or principal drinking water aquifers; CH (viii) Potential for adverse effects on health orsafety; and • (be) 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 otherpast,presentand reasonably foreseeable filture actions, eventhough theimpacts ofthe proposed action may not be significant by themselves. Comments: None V. Environmental Review Project Conditions Record of Environmental Consideration 6 08/31/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program / EJE 0356 West Jefferson High School Project Conditions: 1. Per hurricane Katrina surge inundation and Advisory Base Flood Elevation (ABFE) maps, dated June 2006, building contents, components, and equipment must beelevated three feet above the highest existing adjacent grade. 2. Unusable equipment, debris and material shall be disposed ofinan approved manner and location. In the event significant items (or evidence thereof) are discovered during implementation ofthe project applicant shall handle, manage, and dispose ofpetroleum products, hazardous materials and/or toxic waste in accordance tothe requirements and to the satisfaction ofthe governing local, state and federal agencies. 3. In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana Parishes ofCalcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement ofwood or cellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure) may notleavethequarantinedparisheswithoutwrittenauthorization fromthecommissionerof the Louisiana Department ofAgriculture and Forestry orhis designee(s). Monitoring Requirements: None Record of Environmental Consideration 7 08/31/06