ReviewerName: Catherine Jones Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0126 J.F. Gauthier School K.-5 Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number; ESBO126 J.F. Gauthier School K-5 / PW 11781 Project Location; 2214 Bobolink Drive St. Bernard Parish 70085 (N29.87043 W-89.88900) Project Description: Project activities include replacing the bookcases (4), cabinets (170), carpet (4,860 SF), counters (588 SF), cavity wall (1,152 SF), fiberglass insulation ceiling (4,178 SF), gypsum board(20,796 SF),metaltoiletpartitions (10stalls), aluminum windows (18),shelves (2016 LF), acoustical tileceiling(43,102 SF),plumbing fixtures (124), wooddoors(88), vinyl composite tile flooring (27,758 SF), havac system, electrical system and repaint wall andceiling (45,088 SF). Hazard mitigationwillbe achieved bycompliance with current codes andstandardsand5 hazardmitigation proposals: HMP1: replacing 5 each damaged toilet partitions (metal) with Solid Plastic HDPE (High Density Polyethylene) partitions with stainless steel fittings and hardware. HMP2: byraising thebasemounted gradient levelof39each HVAC compressor unitstoalevelone(1)foot above theABFE mandate. HMP3: by replacement of 27,758 SF of finished flooring with a 1/8" application of epoxy compositionflooring. HMP4:byreplacing88eachdamagedsolidwooddoorswith88hollowcore metal doors, size 3068, on metal frames and HMP5: by replacing 800 SF of plate glass with 800 SF of 3/8 inch thick Plexiglas. Documentation Requirements I | No Documentation Required (Review Concluded) | | (Shortversion) Allconsultationandagreementsimplementedtocomplywiththe NationalHistoric PreservationAct,EndangeredSpeciesAct,andExecutiveOrders11988,11990and 12898 are completed and no other laws apply. (Review Concluded) [X] (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 | Categorical Exclusion -Category [~~| No Extraordinary Circumstances exist. Are project conditions required? O Yes (see section V) O No (Review Concluded) I | Extraordinary Circumstances exist(See Section IV). O Extraordinary Circumstances mitigated. (See Section IVcomments) Are project conditions required? O Yes (see section V) O No (Review Concluded) Environmental Assessment Supplemental Environmental Assessment (Reference EA or PEA in comments) 1X1 Environmental Impact Statement Record of Environmental Consideration 1 07/28/06 Reviewer Name: Catherine Jones Applicant: St. Bernard Parish School Board DUaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina/ Public Assistance Program / ESB0126 J.F.Gauthier School K-5 Comments: Thisprojectmeetsthecriteriaforanalternative arrangement (Permanent Schools)typeofproject. Thisproject has conditions and requires mitigation under the other EHP laws. Reviewer and Approvals I I Project isNon-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Catherine Jones, Environmental Specialist Signature \UCAJj *Ul / \y' : Date 7/28/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Don Fairley, ELO Signature /£=^-y •» y/^ . Date 7/28/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act W\ Nottypeofactivitywithpotentialtoaffecthistoricproperties. (ReviewConcluded) |~1 Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. I IActivity meets Programmatic Allowance # Are project conditions required? O Yes (see section V) O No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES ^ No historic properties that are listed or45/50 years orolder inproject area. (Review Concluded) l~1 Buildingorstructurelistedor45/50yearsorolderinprojectareaandactivitynotexemptfromreview. O Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence onfile) Are project conditions required? O Yes (see section V) O No (Review Concluded) Q Determination of Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) |~| Property aNational Historic Landmark andNational ParkService was provided early notification during the consultation process. If not, explain in comments O No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? D Yes (see section V) fj No (Review Concluded) [~~1 Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) I I Resolution of Adverse Effect completed. (MOA on file) Are project conditions required Q Yes (see section V) fj No (Review Concluded) ARCHEOLOGICAL RESOURCES £<] Project affects only previously disturbed ground. (Review Concluded) l~1 Project affects undisturbed ground. [~l Project area has nopotential for presence ofarcheological resources l~1 Determination ofnohistoric properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) l~lProject areahaspotential forpresence ofarcheological resources O Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required fj Yes (see section V) LJ No (Review Concluded) [~1 Determination of historic properties affected I INR eligible resources notpresent (FEMA finding/SHPO/THPO concurrence onfile). Are project conditions required QYes (see section V) fJH No (Review Concluded) |~1 NReligible resources present inproject area. (FEMA finding/ SHPO/THPO concurrence on file) Record of Environmental Consideration 2 07/28/06 Reviewer Name: Catherine Jones Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0126 J.F. Gauthier School K-5 l~lNo Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? LI Yes (see section V) O No (Review Concluded) i~1 Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) C3 Resolution ofAdverse Effect completed. (MOA onfile) Are project conditions required? L~| Yes (see section V) [J No (Review Concluded) Comments: 07/28/2006 -Original construction was approximately 1964. Subsequent construction 1991 and 1999. Catherine Jones, Environmental Specialist. Correspondence/Consultation/References: B. Endangered Species Act E3No listed species and/or designated critical habitat present inareas affected directly orindirectly bytheFederal action. (Review Concluded) |~1 Listedspeciesand/ordesignatedcriticalhabitatpresentintheareasaffecteddirectlyorindirectlybytheFederalaction. I~lNoeffecttospeciesordesignatedcriticalhabitat (Seecommentsforjustification) Are project conditions required? LJ Yes (see section V) [j No (Review Concluded) l~1 May affect, butnot likelytoadversely affect species ordesignated critical habitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? Ql Yes (see section V) L~| No(Review Concluded) l~l Likely to adversely affect species or designated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? \Z\ YES (see section V) LJ NO(Review Concluded) Comments: None C. Coastal Barrier Resources Act E3 Projectisnotonor connectedtoCBRAUnitorOtherwiseProtectedArea(ReviewConcluded). [~1 Project isonor connected toCBRA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on file) j" Proposed action an exception under Section 3505.a.6? (Review Concluded) l~lProposed action notexcepted under Section 3505.a.6. Are project conditions required? L~3 YES (see section V) d NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act E*] Project would notaffect any waters oftheU.S. (Review Concluded) O Project would affect waters, including wetlands, ofthe U.S. j"Projectexemptedasinkindreplacementorotherexemption. (ReviewConcluded) 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~l YES (see section V) LJ NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: E. Coastal Zone Management Act j"Project isnotlocated ina coastal zone area and does not affect acoastal zone area (Review concluded) 1X1 Project islocated ina coastal zone areaand/or affects thecoastal zone ^ State administering agency does notrequire consistency review. (Review Concluded). I IState administering agency requires consistency review. Are project conditions required? L~j" YES (see section V) Q NO(Review Concluded Record of Environmental Consideration 3 07/28/06 Reviewer Name: Catherine Jones Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0126 J.F. Gauthier School K-5 Comments: FEMA has determined that this project is consistent with the Coastal Zone Management Act and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act [>3 Projectdoesnotaffect, control,ormodifyawaterway/bodyofwater. (Review Concluded) l~1 Project affects controls or modifies a waterway/body of water. O Coordination with USFWS conducted 1 No Recommendations offered by USFWS. (Review Concluded) LJ Recommendationsprovided by USFWS. Areproject conditions required? |__ YES (seesection V) [_] 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 inpermanent airemissions. (Review Concluded) J" Project islocated inan attainment area. (Review Concluded) l~1 Project islocated ina non-attainmentarea. I~l 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 ^ Project does not affect designated prime orunique farmland. (Review Concluded) 11 Projectcausesunnecessary or irreversible conversion of designated primeor unique farmland. LJ CoordinationwithNaturalResourceConservationCommissionrequired. n Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? \Z\ YES (see section V) |__ NO(Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act J Projectnotlocatedwithina flywayzone. (ReviewConcluded) E>\1 Project located within a flyway zone. £3 Project does nothave potential totake migratory birds. (Review Concluded) Are project conditions required? |__ Yes (see section V) ^ No(Review Concluded) LJ Project has potential to take migratory birds. • Contactmadewith USFWS Are project conditions required? CH YES (see section V) __ NO (Review Concluded) Comments: See letterfrom Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has determinedthatrestorationprojects fundedwithfederalresourceswillnot haveadverse impactsonmigratorybirdsorother 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://pacificflvway.Kov/Documents/Mississippi_map.pdf, Record of Environmental Consideration 4 07/28/06 Reviewer Name: Catherine Jones Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program /ESB0126 J.F. Gauthier School K-5 J. Magnuson-Stevens Fishery Conservation and Management Act E3 Project not located in or near Essential Fish Habitat. (Review Concluded) • Project located in ornear Essential Fish Habitat. • Project does not adversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? • Yes (see section V) D No (Review Concluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) • NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? • Yes (see section V) • No (Review Concluded) • NOAA Fisheries provided recommendation(s) • Written reply to NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) _j 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 is along oraffects 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) • 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 • No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) ^ Located in Floodplain or Effects on Floodplains/Flood levels 13 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? |3 Yes (see section V) • No (Review Concluded) • Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). • Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment D 8Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: 07/24/2006 The Parish of St. Bernard is enrolled in the National Flood Insurance Program (NFIP) as of 3/13/1970. Per Flood Insurance Rate Map (FIRM) panel number 2252040460b dated 5/1/1985, 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 largerfloods. Project is repair of building and replacement of equipment and electrical components. Ahazard mitigation proposalis attached. Per flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents should be elevated at least 3ft. above the highest adjacent grade elevation. K. Roof, floodplain management specialist. Correspondence/Consultation/References: Record ofEnvironmental Consideration 5 07/28/06 Reviewer Name: Catherine Jones Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0126 J.F. Gauthier School K-5 B. E.0.11990-Wetlands [|]No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland or effects Wetland(s) • Beneficial Effect on Wetland -(Review Concluded) • Possible adverse effect associated with constructing in or near wetland • Review completed as part offloodplain review LJ 8StepProcess 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 E3 No Low income or minority population in, near or affected by the project -(Review Concluded) • Low income or minority population in or near project area D No disproportionately high and adverse impact on low income or minority population-(Review Concluded) • Disproportionately 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 alaw 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 ofother 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 in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, please explain in comments. If no, leave blank. Yes • (i) Greater scope or size than normally experienced for aparticular category of action • (ii)Actionswithahighlevelofpubliccontroversy • (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; • (iv) Employment of unproven technology with potential adverse effects or actions involving uniqueor unknownenvironmental risks; • (v) Presence of endangered or threatened species or their critical habitat, or archaeological, cultural, historical or other protected resources; • (vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local regulationsor standardsrequiringactionorattention; Record ofEnvironmental Consideration 6 07/28/06 n*'™"™''-CteHneJT • APP""nt: St Bemar"***School Board Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program /ESB0126 J.F. Gauthier School K-5 • (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; • (viii) Potential for adverse effects on health or safety; 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 other past, present and reasonably foreseeable future actions, even though the impacts of the proposed action may notbe significant bythemselves. Comments: None V. Environmental Review Project Conditions Project Conditions: 1. Per flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents should be elevated at least 3ft. above the highest adjacent grade elevation. Monitoring Requirements: None Record ofEnvironmental Consideration 7 07/28/06