Reviewer Name: June R.Griffin Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number; EPL 0083 Buras Middle School Gymnasium / PW 12449 Proiect Location: 34191 SR-11, Buras, Louisiana, Plaquemines Parish 70041 (N29.36795, W-89.56855) Proiect Description: Projectactivitiesincludereplacing120LFof6"galvanizedpaintedgutter, 102 LFof6"X6"downsprout(front50LF&rearside52 LF), 180SFsections(front10'X8')+(rear side10'X10')of metalsidingribtype,and80LFof6" metalfascia. HazardMitigationwillbe achieved utilizing a replacement facility constructed with current codes and standards. Documentation Requirements f~~l (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) IaI (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) Q ProgrammaticCategoricalExclusion-Category (Review Concluded) I I Categorical Exclusion -Category l~1 No Extraordinary Circumstances exist. Are project conditions required? O Yes (see section V) O No (Review Concluded) [~1 Extraordinary Circumstances exist (See Section IV). [~l Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) I I Environmental Assessment l~l Supplemental Environmental Assessment (Reference EA or PEA in comments) E^l Environmental Impact Statement Comments: Thisprojectmeetsthe criteriaforanAlternativeArrangementfor(PermanentSchools)type ofproject.This projecthas conditionsand requiresmitigationunderother EHP laws. jj I I I j j | i Record of Environmental Consideration 1 07/25/06 I Reviewer Name: June R. Griffin Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium Reviewer and Approvals D Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: June R. Griffin, Environmental Specialist Signature . Date 7/25/06 FEMARegional Environmental Officerordelegated approvingofficial. Name: Donald Fairley, ELO Signature /~-^l 1^-—f^ . Date 7/25/06 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act I 13Not type ofactivity with potential to affect historic properties. (Review Concluded) f • Applicable executed Programmatic Agreement . Otherwise, conduct standard Section 106 review. j Q Activity meets Programmatic Allowances . f Areprojectconditionsrequired? • Yes(seesectionV) • No(ReviewConcluded) I HISTORIC BUILDINGS AND STRUCTURES | El No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) I • Building orstructure listed or45/50 years orolder in project area and activity not exempt from review. I • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) f Are project conditions required? • Yes (see section V) • No (Review Concluded) | • Determination of Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) j • Property aNational Historic Landmark and National Park Service was provided early notification f duringtheconsultationprocess.Ifnot,explainincomments | • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). j Areproject conditions required? • Yes (see section V) • No (Review Concluded) I • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) [ O Resolution ofAdverse Effect completed. (MOAonfile) \ Are project conditions required • Yes (see section V) • No (Review Concluded) I ARCHEOLOGICAL RESOURCES j E3 Project affects only previously disturbed ground. (Review Concluded) l~~l Project affects undisturbed ground. I~1 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) l~~l Project area has potential for presence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Areprojectconditionsrequired• Yes(seesectionV) • No(ReviewConcluded) O Determination ofhistoric properties affected f Q NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). I Areprojectconditionsrequired[IJYes(seesectionV) • No(ReviewConcluded) I O NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on jfile) [ • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) f Record of Environmental Consideration 2 07/25/06 I Reviewer Name: June R. Griffin Applicant: Plaquemines Parish School Board Duaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium 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. (MOA on file) Are project conditions required? • Yes (see section V) Q No (Review Concluded) Comments: 7/25/2006 -FEMA, inconsultation with theState Historic Preservation Office (SHPO), hasdetermined mat noneofthestructuresassociated withtheproposeddemolitionarelistedonor eligiblefortheNational RegisterofHistoric Places (see attached correspondence dated 03/27/06) and finds that this scope ofwork will have noeffect onstanding historicproperties. Scopeofworkindicatesgrounddisturbingactivitiesassociatedwiththedemolitionand rebuildofthe structurewithinitspre-disasterfootprintonly. UponconsultationofSHPOdata,therearenoknownarchaeologicalsites within .5miles ofthe project area. Demolition must follow the lower impact demolition stipulations &additional protocols whichareattached. Thestipulationsandprotocolsshouldbeexplicitinthedemolitioncontract. Failuretocomplywith thesestipulations&additionalprotocolswilljeopardizereceiptoffederalfunding. Ifduringthecourseofwork, archaeological artifacts (prehistoricorhistoric)orhuman remains arediscovered, theapplicant shall stop work inthe vicinityofthediscoveryandtakeall reasonablemeasurestoavoidorminimizeharmtothefinds. Theapplicantshall informtheirPublicAssistance(PA) contactsatFEMA,whowillinturncontactFEMA's HistoricPreservationStaff.The applicant will notproceed with work until FEMA's Historic Preservation Staffhave completed consultation with the LouisianaStateHistoricPreservationOfficer(SHPO). Inaddition,ifunmarkedgravesarepresent,compliancewiththe LouisianaUnmarkedHumanBurialSitesPreservationAct(R.S. 8:671 etseq.)isrequired. Theapplicantshallnotifythe law enforcement agency ofthejurisdiction where theremains arelocated within twenty-four hours ofthediscovery. The applicantshallalsonotifyFEMAandtheLouisianaUnmarked BurialSitesBoard(calltheLouisianaDivisionof Archeologyat225-342-8170)withinseventy-twohoursofthe discovery. Ifthisscopeofworkand/orthefootprint/location ofthenewbuildingchanges,thisprojectwillneedtobe resubmittedforfurtherSection 106reviewpriorto ground disturbing activities taking placeoutside ofthepre-disaster footprint ofthe building -Katherine Zeringue, Historic Preservation Specialist/Archaeologist. Correspondence/Consultation/References: B. Endangered Species Act £3No listed species and/or designated critical habitat present in areas affected directly orindirectly by the Federal action. (Review Concluded) O Listed species and/or designated critical habitat present in the areas affected directly orindirectly by the Federal action. I~l No effect tospecies ordesignated critical habitat (See comments for justification) Are project conditions required? • Yes (seesection V) • No(Review Concluded) • Mayaffect,butnotlikelytoadverselyaffectspeciesordesignatedcriticalhabitat(FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? • Yes (see section V) • No(Review Concluded) O Likely toadversely affect species ordesignated critical habitat O Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) • NO(Review Concluded) Comments: None C. Coastal Barrier Resources Act £3 Project isnotonor connectedtoCBRA Unit orOtherwise Protected Area(Review Concluded). • ProjectisonorconnectedtoCBRAUnitorOtherwiseProtectedArea.(FEMAdetermination/USFWSconsultationon file) • Proposed action an exception under Section 3505.a.6? (Review Concluded) O Proposed action notexcepted under Section 3505.a.6. Are project conditions required? O YES (see section V) O NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 07/25/06 ReviewerName: JuneR. Griffin Applicant: Plaquemines ParishSchool Board Disaster/Emergency/Program/Project Title: DRl603LA/ Hurricane Katrina /PublicAssistance Program/EPL 0083 BurasMiddle School Gymnasium D. Clean Water Act [3 Project would not affect any waters ofthe U.S. (Review Concluded) O Project would affect waters, including wetlands, ofthe U.S. • Project exempted as inkind replacement orother 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 or adjacent to any waterways ofthe U.S. Correspondence/Consultation/References: E. Coastal Zone Management Act Q Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) EI Projectislocated ina coastal zoneareaand/oraffectsthecoastalzone ^ State administering agency does notrequire consistency review. (Review Concluded). [~1 State administering agency requires consistency review. Are project conditions required? O YES (see section V) O NO(Review Concluded) Comments: FEMA hasdeterminedthatthisprojectisconsistentwiththeCoastalZone ManagementActandthe Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act 03Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (ReviewConcluded) Q Project affects, controls or modifies a waterway/body of water. • Coordination with USFWS conducted l~|No RecommendationsofferedbyUSFWS. (ReviewConcluded) C] Recommendations provided byUSFWS. Areproject conditions required? O YES (seesection V) O NO (Review Concluded) Comments: Project is not in or adjacent to any waterways ofthe U.S. Correspondence/Consultation/References: G. Clean Air Act 13 Project will not result inpermanent airemissions. (Review Concluded) d Projectislocatedinanattainmentarea. (ReviewConcluded) I"!Projectislocated ina non-attainmentarea. I~l Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: Project will not result in permanent air emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act [3Projectdoesnotaffectdesignatedprimeoruniquefarmland. (ReviewConcluded) l~1 Projectcausesunnecessaryorirreversibleconversionofdesignatedprimeoruniquefarmland. f~l Coordination with Natural Resource Conservation Commission required. I"! Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? fj YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 07/25/06 Reviewer Name: June R. Griffin Applicant: Plaquemines Parish School Board ! Disaster/Emergency/Program/Project Title: DRl603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium j t I. Migratory Bird Treaty Act O Project not located within a flyway zone. (Review Concluded) El Project located within a flyway zone. ^ Project does not have potential totake migratory birds. (Review Concluded) Are project conditions required? Q Yes (see section V) EI No(Review Concluded) • Project has potential totake migratory birds. • Contact madewithUSFWS Are project conditions required? • YES (see section V) • NO(Review Concluded) Comments: Seeletter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has determined thatrestoration projects funded with federal resources will nothave adverse impactsonmigratory birdsorother fishand wildlife reserves. These determinations arebasedonthe understandingthatthe conditions outlined inthe Louisiana EndangeredSpecies Summaryare met. Correspondence/Consultation/References: http://pacificflvwav.gov/Documents/Mississippi map.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act ^ Project not located inornear Essential Fish Habitat. (Review Concluded) • Projectlocatedinor nearEssentialFishHabitat. C] Project does notadversely 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) C] NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? O Yes (see section V) O No (Review Concluded) l~1 NOAA Fisheries provided recommendation(s) • Written reply toNOAA Fisheries recommendations completed. Areproject conditions required? • YES (seesection V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act \ E]ProjectisnotalonganddoesnotaffectWildorScenicRiver(WSR)-(ReviewConcluded) { Q Project is along or affects WSR j • 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) j Comments: None Correspondence/Consultation/References: L. Other Relevant Laws and Environmental Regulations II. Compliance Review for Executive Orders A. E.0.11988 -Floodplains dl No EffectonFloodplains/Flood levels and projectoutside Floodplain-(ReviewConcluded) E3 Located inFloodplainorEffectsonFloodplains/Flood levels O No adverse effect onfloodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? O Yes (see section V) • No(Review Concluded) O Beneficial Effect onFloodplain Occupancy/Values (Review Concluded). Record of Environmental Consideration 5 07/25/06 Reviewer Name: June R.Griffin Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/Project Title: DRl603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium ^ Possibleadverseeffectsassociatedwithinvestmentinfloodplain,occupancyormodificationoffloodplain environment El 8 Step Process Complete -documentation on file Are project conditions required? 13 YES (see section V) • NO(Review Concluded) Comments: 07/24/06-The Parish of Plaquemines isenrolled inthe National Flood Insurance 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 notdetermined asPer Flood Insurance Rate Map (FIRM) # 2201390880C dated 09-28-90. All new construction Per Flood Recovery Guidance, dated 04/12/2006, should, where possibleorelevatedtoanelevationofatleast3feetabovetheHighestAdjacentGroundLevel. IncompliancewithEO 11988, an 8-step process was completed and isattached. Per 44CFR 9.12, applicant must publish a final public notice 15 dayspriortothe startofconstructionactivities. Finalpublicnoticeistobe forwardedtotheLAGOHS/OEP andFEMAfor inclusion inthe permanent project files. A. Cramer FPM 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) • BeneficialEffecton Wetland-(ReviewConcluded) O Possible adverse effect associated with constructing in or near wetland LZ| Review completed as part of floodplain review • 8 Step Process Complete -documentation on file Areproject conditions required? • YES (see section V) • NO (ReviewConcluded) Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations ^ NoLowincomeorminoritypopulationin,nearoraffectedbytheproject-(ReviewConcluded) l~1 Low income or minority population in or near project area Q 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 Areproject conditions required? O YES (see section V) O NO (ReviewConcluded) Comments: None Correspondence/Consultation/References: III. 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: Record of Environmental Consideration 07/25/06 Reviewer Name: June R. Griffin Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium IV. Extraordinary Circumstances Based onthereviewofcompliancewithotherenvironmental lawsandExecutiveOrders,andin 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. Ifno, leave blank. Yes • (i) Greater scope or size than normally experienced for aparticular category ofaction • (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 regulationsor standardsrequiringactionor attention; • (vii) Actions with the potential to affect special status areas adversely orother critical resources suchaswetlands, coastalzones, wildlife refuge andwilderness areas,wildand scenic rivers, sole or principal drinking water aquifers; C] (viii) Potential for adverse effects on health orsafety; 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 otherpast,presentand reasonably foreseeable future actions, eventhoughtheimpacts ofthe proposed action may not be significant by themselves. Comments: None V. Environmental Review Proiect Conditions Project Conditions: 1. Demolitionmustfollowthelowerimpactdemolitionstipulations&additionalprotocols which are attached. The stipulations and protocols should be explicit in the demolition contract. Failure to complywiththesestipulations & additional protocols willjeopardizereceipt 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 takeallreasonablemeasurestoavoidor minimizeharmtothe finds. Theapplicantshallinform their Public Assistance (PA) contacts at 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 Officer(SHPO). Inaddition,ifunmarked gravesarepresent,compliancewiththeLouisiana UnmarkedHumanBurialSitesPreservationAct(R.S. 8:671 etseq.)isrequired. Theapplicant 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 SitesBoard(calltheLouisianaDivision ofArcheology at225-342-8170) withinseventy-twohoursofthe discovery. Ifthisscopeofworkand/orthe footprint/locationof the new building changes, this project will need to be resubmitted for further Section 106 review Record of Environmental Consideration 7 07/25/06 Reviewer Name: June R. Griffin Applicant: Plaquemines Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program/EPL 0083 Buras Middle School Gymnasium prior to ground disturbing activities taking place outside ofthe pre-disaster footprint ofthe building. 2. All new construction Per Flood Recovery Guidance, dated 04/12/2006, should, where possible orelevatedtoanelevationofat least3feet above the highestAdjacentGround Level. In compliance with EO 11988, an 8-step process was completed and isattached. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior to the start of construction activities. Finalpublic noticeistobe forwarded tothe LAGOHS/OEP andFEMAforinclusioninthe permanent project files. Monitoring Requirements: None Record of Environmental Consideration 8 07/25/06