Reviewer Name: June R. Griffin Applicant-CitvofW tw Disaster/Emergency/Program/Project Title: DR1603LA/Hurricane Katrina/Public Assistance Program/City Hall ' * **" Record of Environmental Consideration See44Codeof Federal Regulation Part10. Project Name/Number: City Hall / PW 7815, Version 1 Project Location: 419 Avenue A, Westwego, Louisiana, Jefferson Parish (N29.9114,W-90.14368) Project Description: Project activities include removing and replacing 6SF offlooring in men's room offmeetingroom,456SFofwoodpaneling8' fromfloor, andinsulate 1,088SFofwall8'highfrom floor. Hazard mitigation #1 will be achieved by fastening down sprout to the building facade with stronger material. Hazard Mitigation #2 will be achieved by installing stronger roof vent fasteners to secure the mechanical fan ventilators to prevent future damage from wind. Hazard Mitigation #3 will be achieved by increasing the number offasteners on roof, using proper spacing offasteners, secure flashing at corners and along hips, valleys, and ridges; improve the shingles on the roof and better securingtheroofsheathing withscrewsandadhesive. • (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 andnootherlawsapply. (Review Concluded) El (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) • Programmatic Categorical Exclusion -Category (Review Concluded) C] Categorical Exclusion -Category C] No Extraordinary Circumstances exist. Are project conditions required? • Yes (see section V) |~1 No (Review Concluded) • Extraordinary Circumstances exist (See Section IV). • Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) \_j Environmental Assessment D Supplemental Environmental Assessment (Reference EA or PEA in comments) £3 Environmental Impact Statement Comments: This project meets the criteria for an Alternative Arrangement for (Government &Court Administration Buildings) type ofproject. This project has conditions and requires mitigation under other 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 ofany 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 receipt of federal funding. Record of Environmental Consideration 08/21/06 Reviewer Name: June R. Griffin Applicant-City of Westw Disaster/Emergeiicy/Program/ProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/CityHall ' ^ Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: June/R. Griffin, Environmental Socialist Signature I)///**' K. y^M^f^f^^ ._ Date 8/21/06 FEMA Regional Environmental fliflfcer or delegated approving official. Name: Howard R. Bush, ELO Signature 7^^/^— ^=> Date 8/21/06 I-Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act D Not type ofactivity with potential to affect historic properties. (Review Concluded) ^ Applicable executed Programmatic Agreement, 12/03/04. Otherwise, conduct standard Section 106 review. 13 Activity meets Programmatic Allowances, Appendix A, Sections II (Al, A2, Bl, B2, El F2 &H) IX (A&B). Are project conditions required? 03 Yes (see section V) • No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES D 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) • 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 duringtheconsultationprocess.Ifnot, explainincomments • 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) • Resolution ofAdverse Effect completed. (MOAon file) Are project conditions required D Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES MProject affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. • Project area has no potential for presence of archeological resources • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) • Project area has potential for presence ofarcheological 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) • 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) • 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? D Yes (see section V) • No (Review Concluded) Record ofEnvironmental Consideration 2 08/21/06 ReviewerName: JuneR.Griffin ağĞh.._Ğ. r •„ n.. .. ,,. .„, „ _ Applicant: City of Westweeo Disaster/Emergency/Program/Project Title: DR1603LA/Hurricane Katrina/Public Assistance Program/City Hall • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) • Resolution of Adverse Effect completed. (MOA on file) Are project conditions required? • Yes (see section V) • No (Review Concluded) Comments: 8.17.06 -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 as submitted in this PW has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Sections II.A.l; II.A.2; II, II.B.l; II.B.2; II E.l; II.F.2; II.H; IX.Aand IX.B of the document. In accordance with the PA, FEMA is not required to determine the National Register eligibility ofproperties or to 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. James Crouch, HistoricPreservation Specialist. Correspondence/Consultation/References: B. Endangered Species Act G3 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) • Listedspecies 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 onfile) (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) Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Zl C. Coastal Barrier Resources Act P| Project is not on or connected to CBRA Unit or Otherwise 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) • 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 E3 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 is not in oradjacent toany waterways ofthe U.S. Correspondence/Consultation/References: Record of Environmental Consideration 08/21/06 Reviewer Name: June R. Griffin Applicant: City ofWestwego Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/City Hall £. Coastal Zone Management Act • Project is not located in acoastal zone area and does not affect acoastal zone area (Review concluded) ^ Projectislocatedina coastalzoneareaand/oraffectsthecoastalzone 03 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) • NO (Review Concluded) Comments: Thisproject islocated withintheLouisiana Coastal Management Zone. LaDNRhas determined that receipt offederal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the Coastal Zone may still require a Coastal Use Permit orother authorization from DNR. Projects may be coordinated by contacting LA DNR at 1-800-267-4019. June R. Griffin, Environmental/Floodplain Specialist. Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act E3 Project does not affect, control, or modify awaterway/body ofwater. (Review Concluded) • Project affects, controls or modifies 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: Projectisnotinor adjacenttoanywaterways ofthe U.S. Correspondence/Consultation/References: G. Clean Air Act ^ Project will not result in permanent air emissions. (Review Concluded) O Projectislocatedinanattainmentarea. (ReviewConcluded) Q Projectislocatedina non-attainmentarea. • Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: Projectwillnotresultinpermanent air emissions. 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 ofdesignated prime or unique farmland. • Coordination with Natural Resource Conservation Commission required. • Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? D 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) ^ Project located within a flyway zone. ^ Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) g] No (Review Concluded) • Project has potential to take migratory birds. • Contactmadewith USFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Record of Environmental Consideration 4 08/21/06 Reviewer Name: June R. Griffin Applicant: City of Westwego Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/City Hall 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: httPj//pacificflvwav.gov/Documents/Mississippi map.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act ^ Project not located inornear Essential Fish Habitat. (Review Concluded) • Project located inor near 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) CH NOAA Fisheries provided recommendation(s) C] 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 E 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) Comments: None Correspondence/Consultation/References: L.Other RelevantLawsand EnvironmentalRegulations 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 or Effects 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). £3 Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment Kl 8 Step Process Complete -documentation on file Are project conditions required? £3 YES (see section V) • NO (Review Concluded) Comments: 08/14/2006 -The City ofWestwego is enrolled in the National Flood Insurance Program (NFIP) as of 12/28/1976. Per Flood Insurance Rate Map (FIRM) Panel Number 22051C0020E dated 03/23/1995, project is located withinashaded"X"Zone,areasof500-yearflood; areasof100-yearfloodwithaveragedepthsoflessthan1footorwith drainage areas less than 1square mile; and areas protected by levees from 100-year flood. Project is repair ofbuilding with mitigation, and replacement ofelectrical components. In compliance with EO 11988, acompleted 8-Step Process showingconsidered alternatives is attached. Per Hurricane Katrina surge inundation and Advisory Base Flood Elevation (ABFE) maps dated June 2006, where possible, building contents, materials, and equipment (mechanical or electrical) must be Record of Environmental Consideration 08/21/06 Reviewer Name: June R. Griffin Applic-t: City of Westwego Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program/City Hall elevated to or above the ABFE, 3feet above the Highest Existing Adjacent Grade. Per 44 CFR 9.12, applicant must publish afinal public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOHSEP and FEMA for inclusion in the permanent project files. K. Roof, Floodplain Management Specialist. Correspondence/Consultation/References: B. E.0.11990-Wetlands S No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland or effects Wetland(s) • Beneficial Effect onWetland -(Review Concluded) • Possible adverse effect associated with constructing in or near 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 £>3 No Low income or minority population in, near or affected by the project -(Review Concluded) LJ Low incomeorminority population inor near project area D 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 alaw or executive order (see environmental concerns scoping checklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based on the review ofcompliance with other environmental laws and Executive Orders, and in considerationofotherenvironmental factors, reviewtheproject forextraordinarycircumstances. *A"Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of (ii) which should be applied in conjunction with controversy on an environmental issue. Ifthe 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 • (ii) Actions with ahigh levelofpublic 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 otherprotectedresources; Record of Environmental Consideration 08/21/06 Reviewer Name: June R. Griffin Applicant-CityofW rw Disaster/Emergency/Program/Project Title: DR1603LA/Hurricane Katrina/Public Assistance Program/City Hall ' ^ D (vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local regulations orstandards requiring action orattention; • (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; U (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 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 the impacts ofthe proposed action may notbe significantbythemselves. Comments: None V. Environmental Review Project Conditions Project Conditions: 1. All proposed repair activities should be done in-kind to match existing materials and form. Anychangetothe approved scopeofwork willrequire resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt of federal funding. This concludes the Section 106 review for this project. 2. Where possible, building contents, materials, and equipment (mechanical or electrical) must be elevated to or above the ABFE, 3feet above the Highest Existing Adjacent Grade. Per 44 CFR 9.12,applicantmustpublishafinalpublicnotice 15dayspriortothestartofconstruction activities. Final public notice isto be forwarded to the LA GOHSEP and FEMA for inclusion in the permanent project files. 3. Unusable equipment, debris and material shall be disposed ofin an approved manner and location. In the event significant items (or evidence thereof) are discovered duringimplementation ofthe project applicant shall handle, manage, and dispose of petroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. 4. The movement of wood or cellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from astructure) may not leave the quarantinedparishes without written authorization from the commissioner of the Louisiana Department of Agriculture andForestryorhisdesignee(s). Monitoring Requirements: None Record ofEnvironmental Consideration 7 08/21/06