Reviewer Name: June R. Griffin Applicant: Jefferson Parish Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start -Classroom Trailer Record of Environmental Consideration See44Codeof FederalRegulationPart 10. Proiect Name/Number: Gretna Head Start -Classroom Trailer / PW 9206 Proiect Location: 2850 S. Monterey Court, Gretna, Louisiana, Jefferson Parish (N29.8898,W-90.01777) Proiect Description: Project activities include removing and installing 2,500 SF of metal roof panels, 3,474 SFof gypsum wallboard, 2,270 SFof plywood sub-flooring, and30LF4" diameterofflexible insulated HVAC duct work. Hazard Mitigation is achieved through compliance with current codes and standards.Installtwodoublewidetrailers; footprintwillincreasefrom40X60to48X72.In compliance withAmericanDisabilities Act (ADA)a46 FT long 3FTwide ramp and3 FThighX5 FT widedeckwillwraparound3sidesofthebuilding,and 178LFofstairswith6stepswillbeinstalled. Documentation Requirements Lj (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) National Environmental Policy Act (NEPA) Determination l~~l 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? • Yes (see section V) • No (Review Concluded) I I Extraordinary Circumstances exist (See Section IV). Q Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) I I Environmental Assessment D Supplemental Environmental Assessment (Reference EA or PEA in comments) Environmental Impact Statement Comments: This project meets thecriteria for anAlternative Arrangement for (Permanent Schools) type ofproject. This project has conditions and requires mitigation under other EHP laws. Record of Environmental Consideration 1 07/10/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish J Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start -Classroom Trailer j Reviewer and Approvals O Project is Non-Compliant (See attached documentation justifying selection). f I I FEMA Environmental Reviewer. I Name: June^/Griffin, Environmental Specialist Signature \H^^ (A >W^T /^^ . Date 7-10-06 FEMA Regional Environmental ^Trjncer ordelegated approving official. Name: Donald Fairley, ELO Signature /—^ A^~—1*^ ._ Date 7-10-06 , ! I. Compliance Review for Environmental Laws (other than NEPA) [ A. National Historic Preservation Act I E3 Not type ofactivity with potential to affect historic properties. (Review Concluded) I • Applicable executed Programmatic Agreement . Otherwise, conduct standard Section 106 review. 1 O Activity meets Programmatic Allowances . 1 Are project conditions required? O Yes (see section V) • No (Review Concluded) j HISTORIC BUILDINGS AND STRUCTURES ^ No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) jCD Building or structure listed or 45/50 years or older in project area and activity not exempt from review. f • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) j Are project conditions required? fj Yes (see section V) • No (Review Concluded) j • Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence on file) 1 C3 Property aNational Historic Landmark and National Park Service was provided early notification I duringtheconsultationprocess.Ifnot,explainincomments I • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). f Are project conditions required? • Yes (see section V) • No (Review Concluded) I • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) I Q Resolution of Adverse Effect completed. (MOA on file) jAre project conditions required Q Yes (see section V) • No (Review Concluded) j ARCHEOLOGICAL RESOURCES ^ Project affects only previously disturbed ground. (Review Concluded) | O Project affects undisturbed ground. I CD Project area has no potential for presence ofarcheological resources { O Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or j consultation on file). (Review Concluded) I O Project area has potential for presence ofarcheological resources I • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) 1 Are project conditions required O Yes (see section V) • No (Review Concluded) f O Determination ofhistoric properties affected [ • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). | Are project conditions required OYes (see section V) O No(Review Concluded) I • NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on I file) [ • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) j Areproject conditions required? • Yes (seesection V) • No (ReviewConcluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) O Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required? • Yes(seesection V) O No Record of Environmental Consideration 2 07/10/06 Reviewer Name: June R.Griffin Applicant: Jefferson Parish Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start -Classroom Trailer (Review Concluded) Comments: 7/7/2006 -Historic review complete: The structure does not meet the 50-year-criterion, nordoes it possess the levelofexceptional importancerequiredbycriteriaconsiderationgoftheNational RegisterGuidelinestobeconsidered eligiblefortheNationalRegisterofHistoricPlaces. Therefore,theproposedworkwillhavenoeffectonhistoric properties. -KatherineZeringue,HistoricPreservation Specialist 7/7/2006 -Archaeological review complete: Scope of work indicates ground disturbing activities associated with the demolitionandrebuildofthetrailerclassrooms. UponconsultationofSHPOdata,therearenoknownarchaeologicalsites within.5milesoftheprojectarea. Demolitionmustfollowthelowerimpactdemolitionstipulations&additionalprotocols whichareattached. Thestipulationsandprotocolsshouldbeexplicitinthedemolitioncontract. Failuretocomplywith these stipulations & additional protocols will jeopardize receipt of federal funding. If during the course of work, archaeological artifacts (prehistoric orhistoric) orhuman remains arediscovered, theapplicant shall stop work inthe vicinityofthediscoveryandtakeall reasonablemeasurestoavoidorminimizeharmtothe finds. Theapplicantshall inform their Public Assistance (PA) contacts FEMA, who will in turn contact FEMA Historic Preservation Staff. The applicant willnot proceed with workuntil FEMA Historic Preservation Staffhave completed consultation with the Louisiana State Historic Preservation Officer (SHPO). In addition, if unmarked graves are present, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act(R.S. 8:671 etseq.)is required. Theapplicant shall notify the lawenforcementagencyofthejurisdictionwheretheremainsare locatedwithintwenty-fourhoursofthediscovery.The applicantshallalsonotifyFEMAandtheLouisianaUnmarked BurialSitesBoard(calltheLouisianaDivisionof Archeologyat225-342-8170) withinseventy-twohoursofthe discovery. Ifthisscopeofworkand/orthe locationofthe newbuildingschange,thisprojectwillneedtoberesubmittedforfurthersection 106reviewpriortogrounddisturbing activities taking place. -Katherine Zeringue, Historic Preservation Specialist/Archaeologist Correspondence/Consultation/References: B. Endangered Species Act ^ 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. 1~1 No effect tospecies ordesignated critical habitat. (See comments for justification) Are project conditions required? • Yes (see section V) • No(Review Concluded) 0 May affect, but not likely toadversely affect species ordesignated critical habitat (FEMA deterrnination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? • Yes (see section V) • No(Review Concluded) 1 ILikelytoadverselyaffectspeciesordesignatedcriticalhabitat O Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) • NO (ReviewConcluded) Comments: None C. Coastal Barrier Resources Act £3 Project isnot onor connected toCBRA Unit orOtherwise Protected Area (Review Concluded). • Project is on orconnected toCBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on file) O Proposed action an exception under Section 3505.a.6? (Review Concluded) CH Proposed action not excepted under Section 3505.a.6. Areproject conditions required? • YES (seesection V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 07/10/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start -Classroom Trailer D. Clean Water Act ^ 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 isnotinoradjacenttoanywaterways ofthe U.S. Correspondence/Consultation/References: £. Coastal Zone Management Act • Project is not located ina coastal zone area and does not affect a coastal zone area (Review concluded) ^ Project islocated ina coastal zone area and/or affects thecoastal zone ^ State 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 and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ^ Project does not affect, control, ormodify awaterway/body ofwater. (Review Concluded) [~1 Project affects, controls ormodifies 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: Project is not in or adjacent to any waterways of the U.S. Correspondence/Consultation/References: G. Clean Air Act E3 Project will not result in permanent air emissions. (Review Concluded) • Project islocated inanattainment area. (Review Concluded) O Projectislocatedina non-attainmentarea. O Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: Project will not result in permanent air emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act £3Projectdoesnotaffectdesignatedprimeoruniquefarmland. (ReviewConcluded) 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: Record of Environmental Consideration 07/10/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start -Classroom Trailer 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) ^ No (Review Concluded) • Project has potential totake migratory birds. • Contact made with USFWS 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 orother fish and wildlife reserves. These determinations are based onthe understanding that the conditions outlined in the Louisiana EndangeredSpecies Summaryare met. Correspondence/Consultation/References: http://pacificflywav.gov/Documents/Mississippi marxpdf, J. Magnuson-Stevens Fishery Conservation and Management Act KlProject not located inor near Essential Fish Habitat. (Review Concluded) • Project located in or near Essential Fish Habitat. • 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) CD NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? • Yes (see section V) • No(Review Concluded) l~~l NOAA Fisheries provided recommendation(s) O Written reply to NOAA Fisheries recommendations completed. Areproject conditions required? • YES (seesection V) • NO (ReviewConcluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act E3 Project is not along and does not affect Wild orScenic River (WSR) -(Review Concluded) • Project isalong oraffects WSR • Project adversely affects WSR as determined by NPS/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 (see section V) • NO (ReviewConcluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 07/10/06 Reviewer Name: June R.Griffin Applicant: Jefferson Parish Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start-Classroom Trailer 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) 13 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) Q No (Review Concluded) • Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). KlPossible adverse effects associated with investment in floodplain, occupancy or modification offloodplain environment [X] 8Step Process Complete-documentation onfile Are project conditions required? ^ YES (see section V) • NO(Review Concluded) Comments: 06/26/2006 -The CityofNew Orleans/Orleans Parish isenrolled intheNational Flood Insurance Program (NFIP)asof 8/3/1970. PerFloodInsuranceRateMap(FIRM)PanelNumber2252030160Edated03/01/1984,projectis locatedwithinan"A4"Zone,areaof100-yrflooding, BaseFloodElevationsandFloodHazardFactorsas determined. Projectisreplacementofbuildingandreplacementofcontents. ApplicantisrequiredtocoordinatewithlocalFloodplain Administratorregardingfloodplainpermit(s)priortothestartofanyactivities. Applicantisresponsibleformeetingall requirementsofthepermit(s). Allcoordinationpertainingtothesepermit(s),shouldbedocumentedtothelocalFloodplain AdministratorandcopiesprovidedtoLAGOHSEPandFEMAaspartofthepermanentprojectfiles. Incompliancewith EOl 1988, a completed 8-step process showing considered alternatives is attached. Per 44 CFR 9.11 alternatives were reviewed. Per44 CFR9.11(d)(9), thereplacementofbuildingcontents, materials and equipment, where possible, disaster proofingofthebuildingand/oreliminationofsuchfuture lossesbyrelocationofthosebuildingcontents,materialsand equipmenttoor abovetheadvisorybasefloodplain.Per44 CFR9.12,applicantmustpublishafinalpublicnotice 15days priortothestartofconstructionactivities. FinalpublicnoticeistobeforwardedtotheLAGOHSEPandFEMAfor inclusion inthe permanentprojectfiles. Correspondence/Consultation/References: B. E.0.11990-Wetlands £3 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) O Located inWetland oreffects Wetland(s) • Beneficial Effecton Wetland-(Review Concluded) O Possible adverse effect associated with constructing in ornear wetland O Review completed aspart offloodplain review O 8 Step Process Complete -documentation onfile 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 ^ NoLowincomeorminoritypopulationin,nearoraffectedbytheproject-(ReviewConcluded) l~l Low income orminority population in ornear project area O No disproportionately high and adverse impact on low income or minority population-(Review Concluded) d Disproportionately high or adverse effects on low income orminority population Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 07/10/06 Reviewer Name: June R. Griffin Applicant: Jefferson Parish Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/Gretna Head Start -Classroom Trailer III. Other Environmental Issues Identifyotherpotentialenvironmentalconcernsinthecommentboxnotclearly falling underalawor executiveorder (see environmental concerns scopingchecklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Basedonthereviewofcompliance with otherenvironmentallawsandExecutiveOrders,andin consideration of other environmental factors, review the project for extraordinary circumstances. *A"Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of(ii) which should be applied inconjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, please explain in comments. If no, leave blank. Yes CI (i) Greater scope or size than normally experienced for aparticular category ofaction IZI (ii)Actionswithahighlevelofpubliccontroversy • (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; O (vi) Presence ofhazardous ortoxic substances at levels which exceed Federal, state orlocal regulations or standards requiring action or attention; CI (vii) Actions with the potential to affect special status areas adversely orother critical resources suchaswetlands, coastal zones, wildlife refugeandwilderness areas,wildand scenic rivers, sole or principal drinking water aquifers; • (viii) Potential for adverse effects on health orsafety; and D (ix) Potential to violate afederal, state, local or tribal law or requirement imposed for the protection ofthe environment. CH (x) Potential for significant cumulative impact when the proposed action is combined with other past, present andreasonably foreseeable future actions, even though theimpacts ofthe proposed action may not be significant by themselves. Comments: None Record of Environmental Consideration 7 07/10/06 Reviewer Name: June R. Griffin Disaster/Emergencv/Program/Projec^^ V. Environmental Review Proiect Conditions Project Conditions: 1. Demolition must follow the lower impact demolition stipulations &additional protocols which are attached. The stipulations and protocols should be explicit in the demolition contract Failure to comply with these stipulations &additional protocols will jeopardize receipt of federal funding. If during the course of work, archaeological artifacts (prehistoric or historic) or human remains are discovered, the applicant shall stop work in the vicinity of the discovery and take all reasonable measures to avoid or minimize harm to the finds. The applicant shall inform their Public Assistance (PA) contacts FEMA, who will in turn contact FEMA's Historic Preservation Staff. The applicant will not proceed with work until FEMA's Historic Preservation Staff have completed consultation with the Louisiana State Historic Preservation Uiiicer (SHPO). In addition, ifunmarked graves are present, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is required. The applicant shall notify the law enforcement agency of the jurisdiction where the remains are located within twenty-four hours of the discovery. The applicant shall also notify FEMA and the Louisiana Unmarked Burial Sites Board (call the Louisiana Division of Archeology at 225-342-8170) within seventy-two hours of the discovery. If this scope of work and/or the location of the new buildings change, this project will need to be resubmitted for further section 106 review prior to ground disturbing activities taking place 2. Applicant is required to coordinate with local Floodplain Administrator regarding floodplain pemut(s) prior to the start of any activities. Applicant is responsible for meeting all requirements of the permit(s). All coordination pertaining to these permit(s), should be documented to the local Floodplain Administrator and copies provided to LA GOSEPH and FEMA as part of the permanent project files. In compliance with EOl 1988, acompleted 8-step process showing considered alternatives is attached. Per 44 CFR 9.11 alternatives were reviewed. Per 44 CFR 9.11(d)(9), the replacement of building contents, materials and equipment, where possible, disaster proofing of the building and/or elimination of such future losses by relocation of those building contents, materials and equipment to or above the Advisory Base Floodplain. Per 44 CFR 9.12, applicant must publish afinal public notice 15 St0l^jf* of construction activities. Final public notice is to be forwarded to the LA LrUrikbF and FEMA for inclusion in the permanent project files. Monitoring Requirements: None Record of Environmental Consideration 8 07/10/06