Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number: St. Bernard High School / PW 11514 Project Location; 2601 Torres Dr., St. Bernard, Louisiana, St. Bernard Parish 70085 (N29.87328, W-89.87368) Project Description; Projectactivities include removing andreplacing the following: suspended ceiling tiles, suspended T-barceiling suspension system, solidwood coredoors, Type Mdouble doorwithhinges, motorized roll up door, glass store front door, metal doors, door hardware, gymnasium roof, school roofing,roofdraincovers,stainlesssteelroofedgeflashing, powerroofventilators,rooftopunitwith gasheat, steel exterior siding, fiberglass insulation, Armaflex insulation covering, VCT flooring tile, glazedtile, gymnasiumfloor,temperedglass,classroommarkerboards,tack boards, risers,wooden stadiumseats,lockers, flagpole,circuitbreakers, disconnectswitches, distribution panelboard, motor control center,ampfeederservice, lighting andbranchwiringsystem, simplexcontrol panel, temperature control panel, fire alarm panels, telephone panel, amplifier panel, breaker panels, fire alarm system,PA system,intercomsystem,securitysystem,energymanagementsystem,cableTV system,hot waterboiler,air handlingunits, hot waterheater,convectorunits, fan air handlingunit,fan coil units, electric water coolers, walk in cooler, cabinet heater, gas fired domestic water heaters, air cooled condensing units, air cooled chillers, transformers, water closets, air conditioning units, handicapped lift, hydraulic elevator drive, elevator cab, outside air intake ducts, Type B venting material, gas pressure regulating valves, gas solenoid valves, gas control valves, steel pipe connecting expansion tank, motors, Type L copper suction line, refrigeration distribution valve, copper pipe, shut off valves,PVC pipe, hot water baseboardradiationwith covers,urinals,partitions, sinkandpainting door frames, ceiling surfaces, wall surfaces, and concrete floor. Fivehazardmitigationproposals(HMP)aresuggestedforthisprojectaswell. HMP1proposes elevatingtheaircooledcondensingandchillerunitstoeliminateexposuretoflooding. Thisincludes elevating the equipment on a single 30' x 40' platform set on a 6" reinforced concrete slab, built at grade over thirty twenty foot long pilings for support. HMP 2 is to replace pump motors and electrical conduits with water tight components to eliminate the exposure to flooding. HMP 3 is to elevate transformersandcircuitbreakerpanelstomitigatetheexposuretofloodwater. Thisincludeselevating theunits5'abovethefinishedfloorelevation. HMP4suggestsreplacing48,436squarefeetof vinyl compositefloortileswithvinylsheetflooringwhichqualifiesas"wetfloodproofing." HMP5 proposes replacing 22,166 square feet of built-up roofing with fully adhered modified bitumen cap sheet roofing on the gymnasium and replacing 32,079 square feet on the school building. This will deter progressive failure of roofing during high velocity winds. Documentation Requirements I I 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) Record of Environmental Consideration 1 08/01/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School £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 Statutorily excluded from NEPA review. (Review Concluded) I Programmatic Categorical Exclusion -Category (Review Concluded) ll Categorical Exclusion -Category f~] No Extraordinary Circumstances exist. Are project conditions required? • Yes (see section V) • No (Review Concluded) • Extraordinary Circumstances exist (See Section IV). O Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) Environmental Assessment Supplemental Environmental Assessment (Reference EA or PEA in comments) [X] Environmental Impact Statement Comments: ThisprojectmeetsthecriteriaforanAlternativeArrangement(PermanentSchools)typeofproject. This projecthasconditionsandrequiresmitigationundertheotherEnvironmentalandHistoricPreservation(EHP) Laws. Reviewer and Approvals O Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Letha Dawson, Environmental Specialist Signature Q%J^MXJ§**l(\y {OSgr3 Yes (see section V) fj No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES [X] No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) [j 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) Record of Environmental Consideration 2 08/01/06 Reviewer Name: Letha Dawson Applicant: St.Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School • Property aNational Historic Landmark and National Park Service was provided early notification duringtheconsultation process. Ifnot, explain incomments • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? Q 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 [j Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES £3 Project affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. [j 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) LJ Project areahaspotential forpresence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) • No (Review Concluded) n 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? • 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? • Yes (see section V) fj No (Review Concluded) Comments: 8/1/2006-Historicreviewcomplete: Thestructuredoesnotmeetthe50-year-criterion,nor doesitpossessthe level ofexceptional importance required byCriteria Consideration GoftheNational Register Guidelinestobe considered eligiblefortheNationalRegisterofHistoricPlaces. Therefore,theproposedworkwillhavenoeffectonhistoric properties. Scopeofworkindicatesgrounddisturbingactivitiesassociatedwithreplacementof flagpole,repairtoutilities, andhazard mitigation fora/c units. Upon consultation ofSHPO data, there areno known archaeological sites within .25 miles oftheproject area. Therefore scope ofwork meets Programmatic Agreement (12/3/2004) Allowances, Appendix A, SectionI,AandI. Ifduringthecourseofwork,archaeologicalartifacts(prehistoricorhistoric)orhumanremainsare discovered, theapplicantshallstopworkinthevicinityofthediscovery andtakeallreasonablemeasuresto avoidor minimize harm to the finds. The applicant shall inform their Public Assistance (PA) contacts at FEMA, who will in turn contactFEMAHistoricPreservationstaff.The applicantwillnotproceedwithworkuntilFEMAHistoricPreservationstaff have 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 ET SEQ.) is required. Theapplicantshallnotifythelawenforcementagencyofthejurisdictionwheretheremainsarelocatedwithin twenty-four hours of the discovery. The applicant shall also notify FEMA and the Louisiana Unmarked Burial Sites Board (callthe LouisianaDivisionofArcheologyat225-342-8170)withinseventy-twohoursofthe discovery. Failuretocomply with these stipulations may jeopardize receipt of FEMA funding. -Katherine Zeringue, Historic Preservation Specialist/Archaeologist Correspondence/Consultation/References: B. Endangered Species Act [3 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 inthe areas affected directly orindirectly bythe Federal action. O No effect tospecies ordesignated critical habitat. (See comments for justification) Are project conditions required? Q Yes (see section V) • No (Review Concluded) O Mayaffect,butnotlikelytoadverselyaffectspeciesordesignatedcriticalhabitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Areproject conditions required? O Yes (see section V) • No(Review Concluded) l~lLikely toadversely affect species ordesignated critical habitat Record of Environmental Consideration 3 08/01/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act E3 Project is not on orconnected toCBRA Unit orOtherwise Protected Area (Review Concluded). • Project is on or connected to CBRA Unit orOtherwise 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 E<] Project would not affect any waters ofthe U.S. (Review Concluded) • Project would affect waters, including wetlands, ofthe U.S. J 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: Projectisnotinoradjacenttoany waterways oftheUS. Correspondence/Consultation/References: E. Coastal Zone Management Act O Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) £<] Projectislocatedina coastalzoneareaand/oraffectsthecoastalzone 0<] State administering agency does not require consistency review. (Review Concluded). I~l State administering agency requires consistency review. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: FEMAhasdetermined thatthisprojectisconsistentwiththeCoastalZone Management Act(CZMA) and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ^ Project does not affect, control, or modify a waterway/body ofwater. (Review Concluded) [J Project affects, controls ormodifies awaterway/body ofwater. 11 Coordination with USFWS conducted DNo Recommendations offered by USFWS. (Review Concluded) O Recommendations provided by USFWS. Areproject conditions required? • YES (see section V) Q NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: G. Clean Air Act £3 Project will not result inpermanent airemissions. (Review Concluded) J Project is located in an attainment area. (Review Concluded) 11 Project is located in a non-attainment area. • Coordination required with applicable state administering agency.. Record of Environmental Consideration 4 08/01/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act ^ Project does not affect designated prime orunique farmland. (Review Concluded) ' • Projectcausesunnecessaryorirreversibleconversionofdesignatedprimeoruniquefarmland. [j Coordination with Natural Resource Conservation Commission required. • Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? • YES (seesection V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act "2 Project not located within a flyway zone. (Review Concluded) E<] Project located within a flyway zone. [>3 Project does not have potential totake migratory birds. (Review Concluded) Areproject conditions required? • Yes (see section V) ^ No(Review Concluded) f_] Project has potential totake migratory birds. • Contact made with USFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: SeeletterfromDonFairleytoMr. RussWatsonwithUSF&WS,dated09/14/2005. Specifically,FEMAhas determined thatrestoration projects funded with federal resources will nothave adverse impacts onmigratory birds orother fishand wildlife reserves. Thesedeterminations arebasedontheunderstanding thattheconditions outlined inthe Louisiana Endangered Species Summary are met. Correspondence/Consultation/References: http://pacificflywav.gov/Documents/Mississippi map.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act ^ Projectnotlocatedinor nearEssentialFishHabitat. (Review Concluded) • Project located in or near Essential Fish Habitat. • Project does notadversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? • Yes (see section V) LJ No (Review Concluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) [U NOAA Fisheries provided norecommendation(s) (Review Concluded). Are project conditions required? • Yes (see section V) • No (Review Concluded) l~~l NOAA Fisheries provided recommendation(s) LJ Written replyto NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act ^ ProjectisnotalonganddoesnotaffectWildorScenicRiver(WSR)-(ReviewConcluded) l~l Project is along or affects 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) Q NO (Review Concluded) Comments: None Record of Environmental Consideration 5 08/01/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School Correspondence/Consultation/References: 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) S Located in Floodplain orEffects on Floodplains/Flood levels S 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) UBeneficial Effect on Floodplain Occupancy/Values (Review Concluded). O Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment • 8StepProcessComplete-documentationonfile Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: 07/25/2006-TheParishofSt. BernardisenrolledintheNationalFloodInsuranceProgram(NFIP)asof 3/13/1970. PerFlood Insurance Rate Map (FIRM) panel number 2252040460B dated 5/1/1985, project islocated in zone "B",areaprotectedfrom the 100-yrfloodbylevee, dikeorotherstructuresubjecttofailureorovertoppingduringlarger floods. Project isrepair ofbuilding and replacement ofequipment and electrical components. Ahazard mitigation proposal isattached. Perfloodrecoveryguidance,dated04/12/2006,wherepossible,allequipmentandcontentsshouldbeelevated atleast 3ft. above thehighest adjacent grade elevation. K.Roof, Floodplain Management Specialist. Correspondence/consultation/references: B. E.0.11990-Wetlands [3 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland or effects Wetland(s) H Beneficial Effecton Wetland -(Review Concluded) • Possible adverse effect associated with constructing in or nearwetland "2 Review completed aspart offloodplain review O 8 StepProcessComplete-documentationonfile 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) LJ Low incomeorminoritypopulationinornearprojectarea J Nodisproportionatelyhighand adverseimpactonlow incomeorminoritypopulation-(ReviewConcluded) LJDisproportionatelyhighor adverse effectsonlow incomeorminoritypopulation 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 a law or executive order (see environmental concerns scoping checklist for guidance). Comments: None Zl Record of Environmental Consideration 6 08/01/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School 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"underanycircumstancemayrequireanEnvironmentalAssessment(EA)withtheexceptionof(ii) whichshouldbeappliedin conjunctionwithcontroversyonanenvironmental issue. Ifthe circumstancecan be mitigated, please explain in comments. If no, leave blank. Yes LJ (i)Greaterscopeorsizethannormallyexperiencedfora particularcategoryofaction (ii)Actions withahighlevelof public 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 other protected resources; • (vi) Presence ofhazardous ortoxic substances atlevels which exceed Federal, state orlocal regulations or standards requiring action or attention; LJ (vii)Actionswiththepotentialtoaffectspecialstatusareasadverselyorothercriticalresources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principal drinking water aquifers; (viii) Potential for adverse effects on health or safety; and LJ (ix)Potentialtoviolateafederal,state,localortriballaworrequirementimposedforthe protection of the environment. LJ (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 of the proposed action may not be significant by themselves. Comments: None V. Environmental Review Project Conditions General comments: None Project Conditions: • Perfloodrecoveryguidance,dated04/12/2006,wherepossible,allequipmentandcontents should be elevated at least 3 ft. above the highest adjacent grade elevation. • 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 at FEMA, who will in turn contact FEMA Historic Preservation staff. The applicant will not proceed with work until FEMA Historic Preservation staff have completed consultation with the Louisiana State Historic Preservation Officer (SHPO). In addition, if unmarked graves are present, compliance with the Louisiana Unmarked HumanBurialSitesPreservationAct(R.S. 8:671 ETSEQ.)isrequired.Theapplicantshall notify the law enforcement agency of the jurisdiction where the remains are located within twenty-fourhours ofthediscovery. TheapplicantshallalsonotifyFEMAandtheLouisiana Record of Environmental Consideration 7 08/01/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0108 St. Bernard High School Unmarked Burial Sites Board (call the Louisiana Division of Archeology at 225-342-8170) within seventy-two hours of the discovery. Failure to comply with these stipulations may jeopardize receipt of FEMA funding. Monitoring Requirements: None Record of Environmental Consideration 8 08/01/06