Reviewer Name: Catherine Jones Applicant: Plaquemines Parish School Board Disaiter/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EPL 0084 Buras High School & Boiler Building Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number: EPL 0084 Buras High School & Boiler Building / PW 12383 Project Location; 35655 SR-11 Buras, Louisiana Plaquemines Parish 77041 (N29.3538 W-89.5265) Project Description; Projectactivitiesincludereplacing alldamaged finishes andequipment throughout the building and all 1st floor electrical and mechanical systems. Hazard mitigation will be achieved by compliance with current codes and standards. Documentation Requirements (~1 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) Ex] (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 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? 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) [j| No (Review Concluded) I I Environmental Assessment ["I Supplemental Environmental Assessment (Reference EA orPEA in comments) ^ Environmental Impact Statement Comments: This project meets the criteria for an alternative arrangement (Permanent Schools) type of project. This project has conditions and requires mitigation under the other EHP laws. Record of Environmental Consideration 1 07/29/06 Reviewer Name: Catherine Jones Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA/ HurricaneKatrina/ PublicAssistanceProgram/ EPL0084 BurasHighSchool&Boiler Building Reviewer and Approvals [~1 Project isNon-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Catherine Jones, EnvironmentaLSpecialist Signature, Date 7/29/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Don Fairley, ELO Signature A^~aJ X-2-^^ . Date 7/29/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act ^ Nottype of activity with potential to affect historic properties. (Review Concluded') • Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. O Activity meets Programmatic Allowance # Are project conditions required? • Yes (see section V) • No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES • Nohistoricpropertiesthatare listedor45/50yearsorolderinprojectarea. (Review Concluded) £3 Buildingorstructure listedor45/50 years orolder inprojectareaandactivity notexempt from review. £3 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 of Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) • 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 on file). Are project conditions required? • Yes (see section V) • No (Review Concluded) • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) • Resolution of Adverse Effect completed. (MOA on file) Are project conditions required Q Yes (see section V) O No (Review Concluded) ARCHEOLOGICAL RESOURCES ^ Project affects only previously disturbed ground. (Review Concluded) O Project affects undisturbed ground. Q Project area has nopotential for presence ofarcheological resources • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) |~1 Project areahaspotential forpresence ofarcheological resources • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required O Yes (see section V) • No (Review Concluded) l~1 Determination of historic properties affected • NReligible resources notpresent (FEMA finding/SHPO/THPO concurrence onfile). Are project conditions required OYes (see section V) Q No (Review Concluded) • NReligible resources present inproject area. (FEMA finding/ SHPO/THPO concurrence on file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? O Yes (see section V) O No (Review Concluded) • Adverse EffectDetermination. (FEMA finding/ SHPO/THPO concurrence onfile) Record of Environmental Consideration 2 07/29/06 Reviewer Name: Catherine Jones Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/ProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EPL0084BurasHighSchool&Boiler Building [U Resolution ofAdverse Effect completed. (MOA onfile) Are project conditions required? Q Yes (see section V) O No (Review Concluded) Comments: 07/27/2006 -The property has been determined by FEMA to be not eligible for listing in the National Register or located within the boundaries of a National Register District. Concurrance with this determination was received from the SHPOdated 11/08/05(seeattached).Inkeepingwiththisdetermination,the proposed projectwillhavenoeffectonhistoric resources. This concludes the Section 106 review for this project. V. Gomez, Historic Preservation Specialist. Correspondence/Consultation/References: B. Endangered Species Act £3Nolistedspecies and/or designatedcritical habitat present inareas affected directlyorindirectlybythe Federalaction. (Review Concluded) O Listedspeciesand/ordesignatedcriticalhabitatpresentintheareasaffecteddirectlyorindirectlybytheFederalaction. |~1Noeffecttospeciesordesignatedcriticalhabitat (Seecommentsforjustification) Are project conditions required? Q Yes (see section V) Q No (Review Concluded) O Mayaffect,butnotlikelytoadverselyaffectspeciesordesignatedcriticalhabitat(FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? Q Yes (see section V) Q No (Review Concluded) O Likely to adversely affect species or designated critical habitat • Formalconsultationconcluded.(BiologicalAssessmentandBiologicalOpiniononfile) Are project conditions required? O YES (see section V) O NO (Review Concluded) Comments: None C. Coastal Barrier Resources Act (3 Projectisnotonor connectedtoCBRA UnitorOtherwise Protected Area (Review Concluded). • Projectisonor connectedtoCBRAUnitorOtherwiseProtectedArea.(FEMAdetermination/USFWSconsultationon file) O Proposed action anexception under Section 3505.a.6? (Review Concluded) O Proposed action notexcepted under Section 3505.a.6. Are project conditions required? Q YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act 13 Project would notaffect any waters oftheU.S. (Review Concluded) O Project would affect waters, including wetlands, ofthe U.S. O Project exempted as in kind replacement or other 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 ofthe US. Correspondence/Consultation/References: E. Coastal Zone Management Act O Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) E3Projectislocatedina coastal zoneareaand/or affectsthecoastal zone 13 State administering agency does notrequire consistency review. (Review Concluded). O State administering agency requires consistency review. Are project conditions required? O YES (see section V) Q NO (Review Concluded 07/29/06 Record of Environmental Consideration Reviewer Name: Catherine Jones Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/ProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EPL0084BurasHighSchool&Boiler Building Comments: FEMAhasdeterminedthatthisprojectisconsistentwiththeCoastalZone ManagementActandtheLouisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act __ Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (ReviewConcluded) |~| Projectaffects controlsormodifies awaterway/bodyofwater. • Coordination withUSFWS conducted • NoRecommendations offered byUSFWS. (Review Concluded) _D Recommendations provided byUSFWS. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Project isnot inoradjacentto anywaterwaysoftheUS. Correspondence/Consultation/References: G. Clean Air Act 13 Project will notresult inpermanent airemissions. (Review Concluded) |~1Projectislocatedinanattainmentarea. (ReviewConcluded) _D Projectislocatedina non-attainmentarea. __ Coordination required with applicable state administering agency- Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Project will not result in permanent air emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act __ Projectdoesnotaffectdesignatedprimeorunique farmland. (ReviewConcluded) [~1 Project causes unnecessary or irreversible conversion of designated prime or unique farmland. • Coordination withNatural 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 notlocated within a flyway zone. (Review Concluded) 13 Project located within a flyway zone. __Projectdoesnothavepotentialtotakemigratorybirds. (ReviewConcluded) Are project conditions required? • Yes (see section V) |3 No (Review Concluded) O Project has potential to take migratory birds. • Contact madewith USFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: See letterfromDonFairleytoMr.RussWatsonwithUSF&WS,dated09/14/2005. Specifically,FEMAhas determined thatrestorationprojectsfundedwithfederalresourceswillnothaveadverseimpactsonmigratory birdsorother 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://pacificflvwav.gov/Documents/Mississippi_map.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act Record of Environmental Consideration 4 07/29/06 ReviewerName: Catherine Jones Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/ProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EPL0084BurasHighSchool&Boiler Building _3Projectnotlocatedinor nearEssentialFishHabitat. (ReviewConcluded) • Project located inornear 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) CD NOAA Fisheries provided norecommendation(s) (Review Concluded). Are project conditions required? • Yes (see section V) • No (Review Concluded) 0 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 isalong oraffects WSR • Projectadverselyaffects WSRasdeterminedbyNPS/USFS. FEMAcannotfund theaction. (NPS/USFS/USFWS/BLM consultation on file) (Review Concluded) • Project does notadversely affect WSR. (NPS/USFS/USFWS/BLM consultation onfile) Are project conditions required? d YES (see section V) O 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 O NoEffectonFloodplains/FloodlevelsandprojectoutsideFloodplain-(ReviewConcluded) [3 Located inFloodplain orEffects onFloodplains/Flood levels O Noadverseeffectonfloodplainandnotadverselyaffectedbythefloodplain. (ReviewConcluded). Are project conditions required? Q Yes (see section V) O No(Review Concluded) d Beneficial Effect onFloodplain Occupancy/Values (Review Concluded). ^ Possibleadverseeffectsassociatedwithinvestmentinfloodplain,occupancyormodificationoffloodplain environment E38 Step Process Complete -documentation onfile Are project conditions required? £3 YES (see section V) Q NO (Review Concluded) Comments: 07/25/2006 TheParish ofPlaquemine isenrolledintheNationalFloodInsurance Program(NFIP)as of05-01 85. Project is located within an "A99" zone, areas of 100-year flood to be protected by flood protection system under construction, base flood elevations and flood hazard factors not determined as Per Flood Insurance Rate Map (FIRM) 2201390885c dated 09-28-90. Project is repair of buildings, and replacement of equipment and components, which per flood recovery guidance, dated 04/12/2006, should, where possible, be elevated to an elevation of at least 3 feet above groundlevel.IncompliancewithEO 11988,an8-stepprocesswascompletedandisattached.Per44CFR9.12,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 LAGOHS/OEP and FEMA for inclusion in the permanent project files. A. Cramer, FPM Specialist. Correspondence/Consultation/References: Record of Environmental Consideration 07/29/06 Reviewer Name: CatherineJones Applicant: PlaqueminesParishSchoolBoard Disaster/Emergency/Program/ProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EPL0084BurasHighSchool&Boiler Building B. E.0.11990-Wetlands ED No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located inWetland oreffects Wetland(s) O Beneficial Effect on Wetland -(Review Concluded) O Possibleadverseeffectassociatedwithconstructinginor nearwetland • Reviewcompletedaspartoffloodplainreview O 8 StepProcessComplete-documentationonfile Are project conditions required? Q YES (see section V) O NO (Review Concluded) Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations £3NoLow incomeorminoritypopulation in, nearoraffected bythe project-(ReviewConcluded) l~~l Low incomeorminority populationinornearprojectarea O No disproportionately high and adverse impact onlow income orminority population-(Review Concluded) Q Disproportionately high oradverse effects onlow income orminority population Are project conditions required? O YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: HI. Other Environmental Issues Identify other potential environmental concerns in the comment box not clearly falling under a law or 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 mayrequireanEnvironmental Assessment(EA)withthe exception of(ii) which shouldbeappliedinconjunctionwithcontroversyonanenvironmental issue. Ifthecircumstancecanbe mitigated, pleaseexplainincomments. Ifno,leaveblank. Yes l~l (i)Greaterscopeorsizethannormallyexperiencedforaparticularcategoryofaction [~l (ii) Actions with a high level ofpublic controversy l~l (iii)Potentialfordegradation,eventhoughslight,ofalreadyexistingpoorenvironmental conditions; l~l (iv) Employment ofunproven technology with potential adverse effects oractions involving unique or unknown environmental risks; l~l (v) Presence ofendangered or threatened species or their critical habitat, orarchaeological, cultural, historical orother protected resources; l~l (vi) Presence ofhazardous ortoxic substances atlevels which exceed Federal, state orlocal regulations or standards requiring action or attention; [~1 (vii) Actions with the potential to affect special status areas adversely orother critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principal drinking water aquifers; Record of Environmental Consideration 6 07/29/06 I | f I j i I | i I | J | f | f f Reviewer Name: Catherine Jones Applicant: Plaquemines Parish School Board Ditaster/Emergency/Program/Project Title: DRI603LA / Hurricane Katrina / Public Assistance Program / EPL 0084 Buras High School &Boiler Building • (viii) Potential for adverse effects on health or safety; and D (ix)Potentialtoviolateafederal,state,localortriballaworrequirementimposedforthe 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 not be significantby themselves. Comments: None V. Environmental Review Project Conditions Project Conditions: 1. Per Flood Recovery Guidance, dated 04/12/2006, should, where possible, be elevated to an elevationofat least3feetabovegroundlevel. IncompliancewithEO11988,an8-step processwascompletedandisattached.Per44CFR9.12,applicantmustpublishafinal I public notice 15 days prior to the start ofconstruction activities. Final public notice is to be jj forwarded to the LAGOHS/OEP and FEMA for inclusion in the permanent project files. | I Monitoring Requirements: None Record of Environmental Consideration 7 07/29/06