Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0372-Jefferson Community School Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number; EJE 0372-Jefferson Community School / PW 13834 Project Location: 3528 Montford Street, Jefferson, Louisiana Jefferson Parish 70121 (N29.58035 W90.09401) Project Description: Project activities include replacing 2,830 SF of vet floor, 4,680 SF of built up roof and insulation, 207 LF of gutter, 30 LF of downspout, 820 SF of carpet, 12 fluorescent light fixtures, 5 SF of window glass and 500 SF of acoustical ceiling tiles. Hazard mitigation will be achieved by compliance with codes and standards. Documentation Requirements I I No Documentation Required (Review Concluded) I I (Short version) All consultation and agreements implemented tocomply 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) E<3 (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 No Extraordinary 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 IV comments) Are project conditions required? Q Yes (see section V) D No (Review Concluded) I I Environmental Assessment I I Supplemental Environmental Assessment (Reference EA orPEA incomments) 1X1 Environmental Impact Statement Comments: Although this project would have qualified as a CATEX (xv) 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 of work will require submission to, and evaluation and approval by, the state and FEMA prior to initiation of any work, for compliance with the National Environmental Policy Act. The applicant is required to obtain and comply with all local, state and federal permits and requirements. Non-compliance with the requirements noted above may jeopardize the receiptof federal funding. Record of Environmental Consideration 09/08/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School Disaster/Emergency/Program/Project Title: DR1603LA/Hurricane Katrina/Public Assistance Program/EJE 0372-Jefferson Community School Reviewer and Approvals f~l Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Catherine Jones, Environmental Specialist V i&L . 09/08/2006 SignatureJ/2sz^2U4_/ jn^T Date FEMA Regional Environn*ejttal Officer or delegated approving official. Name: Howard R. Bush, ELO Signature /^^St /^ f^* . Date 09/08/2006 . I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act f~l Not type ofactivity with potential toaffect historic properties. (Review Concluded) 13 Applicable executed Programmatic Agreement 12/03/04 Otherwise, conduct standard Section 106 review. E3 Activity meets Programmatic Allowance # {II-E1, II-A2, II-C2} Are project conditions required? [3 Yes (seesection V) fj No (Review Concluded) fflSTORIC BUILDINGS AND STRUCTURES l~lNohistoricpropertiesthatare listedor45/50yearsorolderinprojectarea. (Review Concluded) O Building orstructure listed or45/50 years orolder in project area and activity not exempt from review. Q Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required? O Yes (see section V) Q No (Review Concluded) r~l Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence onfile) O Property a National Historic Landmark and National Park Service was provided early notification during the consultation process. If not, explain in comments • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence onfile). Are project conditions required? Q Yes (see section V) O No (Review Concluded) f~1 Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence onfile) l~l ResolutionofAdverseEffectcompleted.(MOAonfile) Are project conditions required O Yes (see section V) O No (Review Concluded) ARCHEOLOGICAL RESOURCES 13 Project affects only previously disturbed ground. (Review Concluded) D Project affects undisturbed ground. l~lProject area has nopotential for presence ofarcheological resources O Determination ofnohistoric properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) l~lProjectareahaspotential for presenceofarcheologicalresources n Determinationofnohistoric properties affected (FEMA finding/SHPO/THPO concurrenceonfile) Are project conditions required O Yes (see section V) Q No(Review Concluded) l~l Determination of historic properties affected I~l NReligible resources notpresent (FEMA finding/SHPO/THPO concurrence onfile). Are project conditions required OYes (seesection V) • No (ReviewConcluded) [~1 NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on file) l~lNo Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence onfile) Are project conditions required? O Yes (see section V) Q No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence onfile) l~l ResolutionofAdverseEffectcompleted.(MOAonfile) Are project conditions required? d Yes (see section V) Q No Record of Environmental Consideration 2 09/08/06 I j | I I j ! | { j J I | J I I I f I } | j I j | J { | j f I J ? | j I | I | { I I I Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0372-Jefferson Community School (Review Concluded) Comments: 09/07/2006 -FEMA's Programmatic Agreement (PA), dated December 3,2004, provides forexpedited project review under Section 106oftheNational Historic Preservation Act(NHPA). Thescopeofworkas submitted inthispwhas beenreviewedandmeetsthecriteriaoutlinedinAppendixA,ProgrammaticAllowances, section {II-E1,II-A2,II-C2},of thedocument. InaccordancewiththePA,FEMAisnotrequiredto determinethenationalregistereligibilityof properties ortosubmitprojectstotheStateHistoricPreservationOfficer(SHPO)forreviewwheretheworkperformed meetsthese allowances. InkeepingwiththestipulationsofthePA,allproposedrepairactivitiesshouldbedone in-kindtomatch existingmaterialsand form. Anychangetotheapprovedscopeofworkwillrequireresubmissionforre-evaluationunder Section106andconsultationwiththeSHPO. Non-compliancemayjeopardizethereceiptoffederal 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 orindirectly by the Federal action. (Review Concluded) [H Listed species and/or designated critical habitat present inthe areas affected directly or indirectly by the Federal action. O No effect to species or designated critical habitat. (See comments for justification) Are project conditions required? • Yes (see section V) O No(ReviewConcluded) n May affect, but not likelytoadversely affect speciesordesignatedcritical habitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? Q Yes (see section V) O No (Review Concluded) l~l Likely to adversely affect species or designated critical habitat [~~l Formal consultation concluded. (Biological Assessment and Biological Opinion onfile) Areproject conditions required? • YES (see section V) O NO(Review Concluded) Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act 13 Projectisnotonor connectedtoCBRAUnitorOtherwiseProtectedArea(ReviewConcluded). I~l Projectisonor connectedtoCBRAUnitorOtherwiseProtectedArea. (FEMAdetermination/USFWSconsultationon file) l~l Proposed action an exception under Section 3505.a.6? (Review Concluded) l~lProposed action notexcepted under Section 3505.a.6. Are project conditions required? \Z\ YES (see section V) \Z\ NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act KlProjectwouldnotaffectanywatersoftheU.S. (ReviewConcluded) O Project would affect waters, including wetlands, oftheU.S. O Project exempted as in kind replacement or other exemption. (Review Concluded) l~lProject requires Section404/401/or Section 9/10 (Rivers andHarbors Act) permit, includingqualification under Nationwide Permits. Are project conditions required? \Z\ 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 |~1 Project isnotlocated ina coastal zone areaanddoes notaffect acoastal zone area(Review concluded) ^ Projectislocatedina coastalzoneareaand/oraffectsthecoastalzone 13 State administering agency does notrequire consistency review. (Review Concluded). I~lState administering agency requires consistency review. Record of Environmental Consideration 3 09/08/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0372-Jefferson Community School Are project conditions required? • YES (see section V) • NO (Review Concluded Comments: This project islocated within the Louisiana Coastal Management Zone. LaDNR has determined that receipt of federal assistance isconsistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still require a coastal use permit or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1800- 267-4019.). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ^ Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (Review Concluded) O Projectaffectscontrolsormodifiesawaterway/bodyofwater. • Coordination with USFWS conducted • No Recommendations offered by USFWS. (Review Concluded) d Recommendations provided by USFWS. Are project conditions required? • YES (see section V) • NO(Review Concluded) Comments: Projectisnot inoradjacenttoanywaterwaysoftheUS. Correspondence/Consultation/References: G. Clean Air Act ^ Project will not result inpermanent airemissions. (Review Concluded) [I] Project islocated inanattainment area. (Review Concluded) O Projectislocatedina non-attainmentarea. C] Coordination required with applicable state administering agency.. Are project conditions required? O YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act 03 Project does not affect designated prime orunique farmland. (Review Concluded) Q Projectcausesunnecessaryorirreversibleconversionofdesignatedprimeoruniquefarmland. I~l Coordination with Natural Resource Conservation Commission required. Q Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? O 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) ^ Project located within a flyway zone. £<] Project does not have potential totake migratory birds. (Review Concluded) Areprojectconditionsrequired? O Yes(seesectionV)[§]No (ReviewConcluded) l~l Project has potential to take migratory birds. • Contact madewithUSFWS Are project conditions required? • YES (see section V) O NO (Review Concluded) Comments: See letterfrom 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://pacificflywav.gov/Documents/Mississippi tnap.pdf, Record of Environmental Consideration 09/08/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School f Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0372-Jefferson Community School I J. Magnuson-Stevens Fishery Conservation and Management Act I £3 Project not located in ornear Essential Fish Habitat. (Review Concluded) j • Project located in or near Essential Fish Habitat. J Q Project does not adversely affect Essential Fish Habitat. (Review Concluded) | Are project conditions required? • Yes (see section V) • No(Review Concluded) I • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) | O NOAA Fisheries provided no recommendation(s) (Review Concluded). j Are project conditions required? O Yes (see section V) O No(Review Concluded) f O NOAA Fisheries provided recommendation(s) I O Written reply toNOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) • NO (Review Concluded) I Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act ^ ProjectisnotalonganddoesnotaffectWildorScenicRiver(WSR)-(Review Concluded) O Projectisalongoraffects 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 onfile) 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 [~lNo EffectonFloodplains/Flood levels and projectoutside Floodplain-(Review Concluded) Ex] LocatedinFloodplainorEffectsonFloodplains/Floodlevels Cx] Noadverse effect onfloodplain and not adversely affected bythe floodplain. (Review Concluded). Are project conditions required? \Z\ Yes (see section V) [X] No(Review Concluded) l~1 Beneficial Effect onFloodplain Occupancy/Values (Review Concluded). I~~l Possible adverse effects associated with investment infloodplain, occupancy ormodification offloodplain environment O 8 StepProcessComplete-documentationonfile Are project conditions required? D YES (see section V) O NO (Review Concluded) Comments: 08/30/06 -The Jefferson Parish is enrolled in the National Flood Insurance Program (NFIP) as of 10-01-71. Per Food Insurance Rate Map (FIRM) panel number 22051c0040e dated 03-23-95, site is located within a shaded "X" zone, areas of 500-year flood; areas of 100-year flood with average depths of less than one foot or with drainage areas protected by levees from 100-year flood. The project is the repair of buildings and the replacement of equipment and components, as per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, building contents, materials, and equipment (mechanical or electrical) must be elevated to or above advisory base flood elevations. A. Cramer FPM Specialist. Correspondence/Consultation/References: B. E.0.11990-Wetlands [x]NoEffects onWetland(s) andproject located outside Wetland(s) -(Review Concluded) I ILocated inWetland oreffects Wetland(s) l~l Beneficial Effect on Wetland -(Review Concluded) Record of Environmental Consideration 5 09/08/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0372-Jefferson Community School O Possible adverse effect associated with constructing in or near wetland • Review completed aspart 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 orminority population in, near oraffected by the project -(Review Concluded) Q Low income orminority population in ornear project area • No disproportionately high and adverse impact on low income or minority population-(Review Concluded) O 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 potentialenvironmentalconcernsinthecommentboxnotclearlyfallingunderalawor 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" underanycircumstance mayrequire anEnvironmental Assessment(EA) withtheexceptionof(ii)which should beapplied inconjunction with controversy onanenvironmental issue. Ifthe circumstance canbemitigated, please explain in comments. If no, leave blank. [U (i) Greater scope orsize than normally experienced for a particular category ofaction C] (ii)Actionswithahighlevelofpubliccontroversy O (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; O (iv) Employment ofunproven technology with potential adverse effects oractions involving unique or unknown environmental risks; O (v) Presence ofendangered orthreatened species ortheir critical habitat, or archaeological, cultural, historical or other protected resources; O (vi) Presence ofhazardous ortoxic substances atlevels which exceed Federal, state orlocal regulations or standards requiring action or attention; M (vii) Actions with the potential to affect special status areas adversely or other critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principal drinking water aquifers; O (viii) Potential for adverse effects on health orsafety; and CI (ix)Potentialtoviolateafederal,state,localortriballaworrequirementimposedforthe protection ofthe environment. I~l (x) Potential for significant cumulative impact when the proposed action iscombined with otherpast,presentandreasonablyforeseeable futureactions,eventhoughthe impactsofthe proposed action may not be significant by themselves. Comments: None Record of Environmental Consideration 6 09/08/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0372-Jefferson Community School V. Environmental Review Project Conditions Project Conditions: 1. Per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, buildingcontents, materials, andequipment (mechanical orelectrical) mustbeelevatedtoor above advisory base flood elevations 2. Allproposedrepairactivities shouldbedone in-kindtomatchexistingmaterialsand form. Anychangetotheapprovedscopeofworkwillrequireresubmissionforre-evaluation under Section106andconsultationwiththe SHPO. Non-compliancemayjeopardizethereceiptof federal funding. ThisconcludestheSection106reviewforthisproject. 3. Unusableequipment,debrisandmaterialshallbedisposedofinanapproved mannerand location. Intheeventsignificantitems(or evidencethereof)arediscovered during implementation oftheprojectapplicantshallhandle, manage, anddisposeofpetroleum products,hazardousmaterialsand/ortoxic wastein accordanceto the requirements andto the satisfaction ofthe governinglocal,stateandfederalagencies. 4. Thisprojectinvolvesthedemolitionorrenovationofapublicstructurethatmaycontain surfaces coatedwith Lead-Based Paint(LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with applicableprovisions of29CFRparts1910and 1926(OSHA-WorkerSafety), and40CFR 260 through 268 (EPA-Hazardous Waste). The applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department of Environmental QualityforAbatement Activities andisalsoresponsible forensuring proper disposal in accordance with the previously referenced regulations. 5. InaccordancewiththeFormosanTermiteInitiativeAct,(LAR.S.3:3391.1 thru3391.13)the LouisianaParishes ofCalcasieu,Cameron, JeffersonDavis,Orleans,Jefferson,Plaquemines, St. Bernard, St. Charles, St. John the Baptist, St. Tammany, Tangipahoa and Washingtonare under quarantine. The movement of wood or cellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure)may not leave the quarantined parishes without written authorization from the commissioner of the Louisiana Department of Agriculture and Forestry or his designee(s). 6. This project involves the demolition or renovation of a public structure. Regardless of the asbestos content, the applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department ofEnvironmental Quality (LDEQ) in accordance with the LDEQ "third amended Declaration of Emergency and Administrative Order" dated June 30, 2006, incorporating the provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.111.5151 and chapter 27. Should Asbestos Containing Materials (ACMS) be present at the project site, the applicant is also responsible for ensuring proper disposal in accordance with the previously referenced administrative order. 7. This project potentially involves the disposal of Metallic Mercury Containing Electronic Devices. The applicant is responsible for ensuring that these devices are recovered, recycled, reused or sequestered in accordance with the Louisiana Department of Environmental Quality (LDEQ) "Declaration of Emergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. Monitoring Requirements: None Record of Environmental Consideration 7 09/08/06