Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/Manual Arts Building Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Proiect Name/Number: Graphic Arts/Adult Education/Manual Arts Building / PW 9372 Proiect Location: 1100 E. Judge Perez Drive, Chalmette, Louisiana, St. Bernard Parish 70043 Proiect Description: Project activities include replacing this facility to its pre-disaster condition. 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) 1X1 (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) I I Categorical Exclusion -Category I I No Extraordinary Circumstances exist. Are project conditions required? O Yes (see section V) Q No (Review Concluded) 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) Q No (Review Concluded) Environmental Assessment Supplemental Environmental Assessment (Reference EA or PEA in comments) [X] Environmental Impact Statement Comments: ThisprojectmeetsthecriteriaforanAlternative Arrangement(PermanentSchools)typeofproject. This projecthasconditions andrequiresmitigationundertheotherEnvironmental andHistoricPreservation(EHP) laws. Reviewer and Approvals I I Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Letha Etewson, Environmental Specialist Signature^XWl^AL^Y fJUfl$\) BDate 06/30/2006 Record of Environmental Consideration 1 06/30/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/Manual Arts Building FEMA Regional Environmental Officer or delegated approving official. Name: Donald Fairley, ELO xt^l^ Signature 7?=--^-/ -* f , Date 06/30/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act ^ Not type ofactivity with potential toaffect historic properties. (Review Concluded) [J Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conductstandardSection 106 review. |~1 Activity meets Programmatic Allowance # Are project conditions required? f_J Yes (see section V) • No(Review Concluded) HISTORIC BUILDINGS AND STRUCTURES £3No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) l~l Building orstructure listed or45/50 years orolder in project area and activity not exempt from review. 0 Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) L~J No (Review Concluded) • Determination of Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) 11 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 onfile). Are project conditions required? O Yes (see section V) • No (Review Concluded) O Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence onfile) l~1 Resolution ofAdverse Effect completed. (MOA onfile) Are project conditions required O Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES D><] Project affects only previously disturbed ground. (Review Concluded) fl Project affects undisturbed ground. I~l Project area has no potential for presence ofarcheological resources LJ Determinationofnohistoricpropertiesaffected(FEMAfinding/SHPO/THPO concurrenceor consultation on file). (Review Concluded) 1 IProject area has potential for presence ofarcheological resources LJ Determinationofnohistoricpropertiesaffected(FEMAfinding/SHPO/THPOconcurrenceonfile) Are project conditions required Qj" Yes (see section V) L~J No (Review Concluded) LJ Determination of historic properties affected LT] NReligible resources notpresent (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required QYes (see section V) f_J No (Review Concluded) LJ NReligibleresourcespresentinprojectarea.(FEMAfinding/SHPO/THPOconcurrenceon file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence onfile) Are project conditions required? f_J Yes (see section V) I INo (Review Concluded) I IAdverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence onfile) I I Resolution of Adverse Effect completed. (MOA on file) Are project conditions required? L~J Yes (see section V) L~J No (Review Concluded) Comments: 06/12/2006 -Historic review complete: this structure does not meet 45-year-criterion or the level of exceptional importance required by Criterion G of the National Register guidelines to be considered eligible for the National Register of Historic Places. Therefore, the proposed demolition will have no effect on historic structures. -V. Gomez, Historic Preservation Specialist Record of Environmental Consideration 2 06/30/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katnna / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/Manual Arts Building 6/12/2006 -Archaeological review complete: scope of work indicates ground disturbing activities associated with the demolition and replacement of the structure within its pre-disaster footprint. Upon consultation of SHPO data, there are no known archaeological sites within .5 miles of the project area. Demolition must follow the lower impact demolition stipulations & additional protocols which are attached. The stipulations and protocols should be explicit in the request for proposal. Failuretocomplywiththesestipulations&additionalprotocolswilljeopardizereceiptofFederalfunding. 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 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 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 footprint/location of the new building changes, this project will need to be resubmitted for further Section 106 review prior to ground disturbing activities taking place outside of the pre-disaster footprint of the building. -Katherine Zeringue, Historic Preservation Specialist/Archaeologist Correspondence/Consultation/References: B. Endangered Species Act D*3No listedspeciesand/ordesignatedcriticalhabitatpresent inareasaffecteddirectlyorindirectlybythe Federal action. (Review Concluded) | IListed species and/or designated critical habitat present inthe areas affected directly orindirectly bythe Federal action. I INo effect to species or designated critical habitat. (See comments for justification) Are project conditions required? Q Yes (see section V) Q No (Review Concluded) | | May affect, but not likely to adversely affect species or designated critical habitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? [J Yes (see section V) [J No (Review Concluded) | ILikely to adversely affect species or designated critical habitat I I Formal consultation concluded. (Biological Assessment and Biological Opinion onfile) Areproject conditions required? O YES (seesection V) Q NO(Review Concluded) Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act £<] Projectisnotonor connectedtoCBRAUnitorOtherwise ProtectedArea(ReviewConcluded). |~lProject isonor connectedtoCBRAUnitorOtherwiseProtectedArea.(FEMAdetermination/USFWSconsultationon file) J Proposed action an exception under Section 3505.a.6? (Review Concluded) l~lProposed action not excepted under Section 3505.a.6. Are project conditions required? Q YES (see section V) O NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act 1X1 Project would notaffect any waters oftheU.S. (Review Concluded) I IProject would affect waters, including wetlands, oftheU.S. J Project exempted as in kind replacement or other exemption. (Review Concluded) I IProject requires Section 404/401/or Section 9/10 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? Q YES (see section V) O NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Record of Environmental Consideration 3 06/30/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/ManualArts Building Correspondence/Consultation/References: E. Coastal Zone Management Act J Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) £3 Projectislocated ina coastalzoneareaand/oraffectsthecoastal zone [>3 State administering agency does not require consistency review. (Review Concluded). I IState administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: FEMAhasdetermined thatthisprojectisconsistentwiththeCoastalZoneManagement Act (CZMA) and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ^ Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (Review Concluded) l~l Projectaffects, controlsormodifiesawaterway/bodyofwater. • Coordination with USFWS conducted UNo Recommendations offered byUSFWS. (Review Concluded) l~l Recommendations provided byUSFWS. Are project conditions required? O YES (seesection V) O NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: G. Clean Air Act ^ Project will not result in permanent airemissions. (Review Concluded) J Project is located in an attainment area. (Review Concluded) l~~1 Project is located ina non-attainment area. I | Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) [j NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act ^ Project does not affect designated prime or unique farmland. (Review Concluded) li Project causes unnecessary or irreversible conversion of designated prime or unique farmland. \] Coordination with Natural Resource Conservation Commission required. II Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act J Project not located within a flyway zone. (Review Concluded) £3 Project located within a flyway zone. £3 Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? Q Yes (seesection V) ^ No(Review Concluded) l~l Project has potential to take migratory birds. • Contact made with USFWS Are project conditions required? [ J 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 or other Record of Environmental Consideration 4 06/30/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/Manual Arts Building fish and wildlife reserves. These determinations arebased onthe understanding thatthe conditions outlined inthe Louisiana Endangered Species Summary are met Correspondence/Consultation/References: http://pacifictlvwav.Kov/Documents/Mississippi map.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act £3 Project not located inornearEssential Fish Habitat. (Review Concluded) LJ 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) Q No (Review Concluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) I INOAA Fisheries provided no recommendation(s) (Review Concluded). Areproject conditions required? O Yes (see section V) LJ No(Review Concluded) O NOAA Fisheries provided recommendation(s) I IWritten 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 [3 Project is not along and does not affect Wild orScenic River (WSR) -(Review Concluded) LJ" 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 (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 3 No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) £3 Located in Floodplain orEffects on Floodplains/Flood levels £3 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). Areproject conditions required? £3 Yes (see section V) • No (Review Concluded) J BeneficialEffectonFloodplain Occupancy/Values (ReviewConcluded). L~J Possible adverse effects associated with investment in floodplain, occupancy ormodification offloodplain environment I I8 StepProcessComplete-documentationonfile Areproject conditions required? • YES (see section V) • NO (Review Concluded) Comments: 06/07/06 The Parish of St. Bernard enrolled in the National Flood Insurance Program 03/13/1970. Per Flood Insurance Rate Map (FIRM) 225204 0290 B, dated 05/01/1985, project is located in Zone B, area protected from the 100-yr flood by levee, dike or other structure subject to failure or overtopping during larger floods, not regulated by the Local Floodplain Ordinance. Project is replacement of Adult Education Arts. Per Flood Recovery Guidance, dated 04/12/2006, repair/replacementshould,wherepossible,beelevatedoutsideorabovetheAdvisoryBaseFloodplain. Harriet Wegner, FPM Correspondence/Consultation/References: Record of Environmental Consideration 5 06/30/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DRI603LA / Hurricane Katrina / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/ManualArts Building B. E.0.11990-Wetlands ^ No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) J Beneficial Effect on Wetland -(Review Concluded) LJ Possible adverse effect associated with constructing in or near wetland J Review completed as part offloodplain review LJ 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 £3No Low income or minority population in, near or affected by the project -(Review Concluded) LJ" Low income or minority population in ornear project area LJ" No disproportionately high and adverse impact on low income or minority population-(Review Concluded) LJDisproportionately 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 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" under any circumstance may require anEnvironmental Assessment (EA) with the exception of(ii) which shouldbeappliedinconjunctionwithcontroversyonanenvironmentalissue. Ifthecircumstancecanbemitigated, please explain in comments. If no, leave blank. Yes (i)Greaterscopeorsizethan normally experienced foraparticular category ofaction (ii)Actionswitha highlevelofpubliccontroversy LJ (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; LI (iv) Employment ofunproven technology with potential adverse effects oractions involving unique or unknown environmental risks; L~J (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, cultural, historical or other protected resources; LJ (vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; LJ (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; LJ (viii) Potential for adverse effects on health orsafety; and Record of Environmental Consideration 6 06/30/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0095 Graphic Arts/Adult Education/Manual Arts Building • (ix) Potential to violate afederal, state, local or tribal law or requirement imposed for the 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 ofthe proposed action may not be significant by themselves. Comments: None V. Environmental Review Proiect Conditions General comments: None Project Conditions: 1. Per flood recovery guidance, dated 04/12/2006, repair/replacement should, where possible, be elevated outside or above the advisory base floodplain. 2. Demolitionmustfollowthelowerimpactdemolitionstipulations& additionalprotocols. The stipulationsand protocolsshouldbeexplicitinthe requestforproposal. Failuretocomplywith these stipulations & additional protocols will jeopardize receipt of Federal funding. If during thecourseofwork,archaeological artifacts (prehistoric orhistoric)orhuman 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 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 unmarkedgravesare present,compliancewith the LouisianaUnmarkedHuman BurialSitesPreservationAct (R.S.8:671 ETSEQ.)isrequired.Theapplicant shallnotifythe lawenforcement agency ofthejurisdiction where theremains arelocated withintwenty-four hoursofthediscovery. Theapplicantshallalso notifyFEMAandtheLouisiana Unmarked Burial SitesBoard (call theLouisianaDivision ofArcheology at225-342-8170) within seventy- two hours of the discovery. If this scope of work and/or the footprint/location of the new buildingchanges,thisprojectwillneedtoberesubmittedforfurtherSection 106reviewprior to ground disturbing activities taking place outside of the pre-disaster footprint of the building. 3. The scope of work to replace a structure to pre-disaster condition is not expected to change the originalfootprint. Intheeventtheserepairsresultinachangetotheoverallfootprint,a subsequentchangetothisscopeofworkwillberequired. Anychangetotheprojectscopeof work will require re-submission through the state to FEMA and consequently requires reevaluation for compliance with National Environmental Policies. Non-compliance with this requirement may jeopardize receipt of federal funds. Monitoring Requirements: None Record of Environmental Consideration 7 06/30/06