ReviewerName: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina/ PublicAssistance Program/ ESB0088Transportation, Maintenance, Storage Building Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number: Transportation, Maintenance, Storage Building / PW 9486 Project Location: 2 Mustang Dr., Arabi, Louisiana, St. Bernard Parish 70032 (N29.972, W-89.99886) Project Description: Project activities include replacing the facility in kind to serve the same functions, in its current location, with mitigation being achieved through current codes and standards, including elevating to or above Advisory Base Flood Elevations. 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) 1X1 Programmatic Categorical Exclusion -Category (xv) (Review Concluded) I 1 Categorical Exclusion -Category 1 1 No Extraordinary Circumstances exist. Are project conditions required? [_] Yes (see section V) Q No (Review Concluded) I 1 Extraordinary Circumstances exist (See Section IV). 1 I Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? [_] Yes (see section V) \_J No (Review Concluded) Environmental Assessment Supplemental Environmental Assessment (Reference EA or PEA in comments) I 1 Environmental Impact Statement Comments: Refer to Programmatic Categorical Exclusion Restoration and/or Improvement of External Facility Systems and Components dated09/22/2005. See attached. Record of Environmental Consideration 1 07/03/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building Reviewer and Approvals LJ Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Letha Dawson, Environmental Specialist Signature (VJMAHJ(U %Jj£2±2. Date 07/03/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Donald Fairley, ELO nR^T^ ^ Signature f^Z-—^ /^* ^ Date 07/03/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act 0<] Not type ofactivity with potential to affect historic properties. (Review Concluded) • Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. I IActivity meets Programmatic Allowance # Are project conditions required? • Yes (see section V) • No (ReviewConcluded) HISTORIC BUILDINGS AND STRUCTURES [3 No historic properties that are listed or45/50 years or older in project area. (Review Concluded) • Building or structure listed or45/50 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) II 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). Areproject conditions required? • Yes (see section V) • No (Review Concluded) • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) [~1 Resolution ofAdverse Effect completed. (MOA onfile) Are project conditions required • Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES £3 Project affects only previously disturbed ground. (Review Concluded) I | Project affects undisturbed ground. I IProject area has no potential for presence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) I IProject area has potential for presence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) fj] No (Review Concluded) 11 Determination of historic properties affected • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required OYes (see section V) • No (Review Concluded) O 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? Q Yes (see section V) • No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Record of Environmental Consideration 2 07/03/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building dl Resolution ofAdverse Effect completed. (MOA on file) Areprojectconditionsrequired?[JYes(seesectionV)O No (Review Concluded) Comments: 7/3/2006-Historicreviewcomplete: the structuredoesnotmeetthe50-year-criterion,nordoes itpossessthe level ofexceptional importance required byCriteria Consideration GoftheNational Register guidelines tobeconsidered eligiblefortheNationalRegisterofHistoricPlaces. Therefore,theproposedworkwillhavenoeffectonhistoric properties. -ValerieGomez,HistoricPreservation Specialist 7/3/2006 -Archaeological review complete: scope of work indicates ground disturbing activities associated with the demolitionandrebuildofthe structurewithinitspre-disaster footprint. UponconsultationofSHPOdata,thereareno known archaeological sites within .5miles oftheproject area. Demolition must follow the lower impact demolition stipulations &additional protocols which are attached. The stipulations and protocols should beexplicit in the demolition contract. Failure to comply with these stipulations & additional protocols will jeopardize receipt of federal funding. If during the course of work, archaeological artifacts (prehistoric or historic) or human remains are discovered, the applicant shallstopworkinthevicinityofthediscoveryandtakeallreasonablemeasurestoavoidorminimizeharmtothe finds. The applicant shall inform their Public Assistance (PA) contacts FEMA, who will in turn contact FEMA Historic Preservation staff. The applicant will notproceed with work until FEMA Historic Preservation staffhave 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 ETSEQ.) isrequired. The applicant shall notify the law enforcement agency ofthejurisdiction where theremains arelocated within twenty-four hours ofthediscovery. The applicantshallalsonotifyFEMAandtheLouisianaUnmarked BurialSitesBoard(calltheLouisianaDivision of Archeology at 225-342-8170) within seventy-two hours of the discovery. If this scope of work and/or the footprint/location ofthe new building changes, thisproject will need tobe resubmitted forfurther Section 106review priorto ground disturbingactivitiestakingplaceoutsideofthepre-disaster footprint ofthe building. -KatherineZeringue, Historic Preservation Specialist/Archaeologist Correspondence/Consultation/References: B. Endangered Species Act ^ No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) LJ Listedspeciesand/ordesignatedcritical habitatpresentinthe areasaffecteddirectlyorindirectlybythe Federal action. O Noeffecttospeciesordesignatedcriticalhabitat. (Seecommentsforjustification) Are project conditions required? Q Yes (see section V) Q No(Review Concluded) • Mayaffect,butnotlikelytoadverselyaffectspeciesordesignatedcriticalhabitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? • Yes (seesection V) • No (Review Concluded) • Likely toadversely affect species ordesignated critical habitat • 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 £3Projectisnotonor connectedtoCBRA UnitorOtherwiseProtectedArea(Review Concluded). D Project is onorconnected toCBRA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on file) J Proposed action an exception under Section 3505.a.6? (Review Concluded) \_J Proposed action not excepted under Section 3505.a.6. Are project conditions required? • YES (seesection V) O NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 3 07/03/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building D. Clean Water Act [x] Project would not affect any waters ofthe U.S. (Review Concluded) O 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: Projectisnot inor adjacentto anywaterwaysoftheUS. 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) L>sl Project islocated ina coastal zone areaand/or affects the coastal zone 1X1 State administering agency does not require consistency review. (Review Concluded). I~~l State administering agency requires consistency review. Are project conditions required? O YES (see section V) • NO (Review Concluded) Comments: FEMA hasdetermined thatthisprojectisconsistent withtheCoastal Zone Management Act(CZMA) and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act £3Projectdoes notaffect, control,ormodifyawaterway/bodyofwater. (Review Concluded) 11 Project affects, controls or modifies a waterway/body of water. Ii Coordination with USFWS conducted I INo Recommendations offer ed by USFWS. (Review Concluded) (I Recommendations provided by USFWS. Are project 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 in permanent airemissions. (Review Concluded) "2 Project is located in an attainment area. (Review Concluded) 11 Project is located in a non-attainment area. I | Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act ^1 Project does not affect designated prime or unique farmland. (Review Concluded) I IProject causes unnecessary orirreversible conversion ofdesignated prime orunique farmland. I I Coordination with Natural Resource Conservation Commission required. I I Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? • YES (see section V) O NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 4 07/03/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DRI603LA / Hurricane Katrina/ Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building I. Migratory Bird Treaty Act J Project not located within a flyway zone. (Review Concluded) Kl Project located within a flyway zone. DJ3 Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) ^ No (Review Concluded) I IProject has potential to take migratory birds. • Contact made with USFWS Are project conditions required? • 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 nothave adverse impacts onmigratory birds orother fish andwildlife reserves. Thesedeterminations arebasedonthe understanding thattheconditions outlined inthe Louisiana Endangered Species Summary are met. Correspondence/Consultation/References: http://pacificflywav.aov/Documents/Mississippi map.pdf J. Magnuson-Stevens Fishery Conservation and Management Act Cj<] Project not located inor near Essential Fish Habitat. (Review Concluded) O Project located inor near Essential Fish Habitat. O Project does not adversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? • Yes (see section V) • No(ReviewConcluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) I INOAA Fisheries provided norecommendation(s) (Review Concluded). Are project conditions required? Q Yes (see section V) • No(Review Concluded) II NOAA Fisheries provided recommendation(s) [~1 Written reply toNOAA Fisheries recommendations completed. Are project conditions required? fj 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 or Scenic River (WSR) -(Review Concluded) [~1 Project is along or affects WSR • Project adversely affects WSR asdetermined 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? O 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 J No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) £3 Located in Floodplain or Effects on Floodplains/Flood levels I INo adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). Areproject conditions required? O Yes (see section V) • No(Review Concluded) J Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). Ex] Possible adverse effects associated with investment in floodplain, occupancy ormodification offloodplain environment Record of Environmental Consideration 5 07/03/06 ReviewerName: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building CJ3 8 Step Process Complete -documentation on file Are project conditions required? ^ YES (see section V) • NO (ReviewConcluded) Comments: 06/26/2006-TheParish ofSt. Bernard isenrolled inthe National Flood Insurance Program (NFIP) asof 03-13 70. As determined per Flood Insurance Rate Map (FIRM) panel number 2252040280C, dated 03-04-87, facility is located within an "A2"zone,areaof 100-yrflooding, basefloodelevationsandfloodhazardfactors.Theprojectisreplacement ofbuilding,equipment,andcomponents. Asper44CFR9.11,mitigationorminimizationstandardsmustbeapplied. Where possible, building contents, materials, and equipment (mechanical or electrical) must be elevated to or above advisory base flood elevations. Allnew construction must coordinate andcomply with local floodplain ordinances and be builttocodesandstandards. Incompliance with EO11988,an8-stepprocesswascompletedandis attached. Per44CFR 9.12,applicantmustpublishafinalpublicnotice 15dayspriortothestartof constructionactivities. Finalpublicnoticeis tobe forwardedtothe LAGOHS/OEPandFEMAforinclusioninthe permanentprojectfiles. ACramerFPMSpecialist. Correspondence/Consultation/References: B. E.0.11990 -Wetlands ^ No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) Q Located in Wetland or effects Wetland(s) I] Beneficial Effecton Wetland -(Review Concluded) I) Possible adverse effect associated with constructing in ornear wetland J Reviewcompletedas part of floodplain review I I8 Step Process Complete -documentation on file Are project conditions required? Q YES (see section V) Q NO (ReviewConcluded) 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) I ILow income orminority population inor near project area J No disproportionately high and adverse impact on low income or minority population-(Review Concluded) I IDisproportionately high or adverse effects on low income or minority population Are project conditions required? Q YES (see section V) Q 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 an Environmental Assessment (EA) with the exception of (ii) which should be applied in conjunction with controversy on an environmental issue. If the circumstance can be mitigated, please explain in comments. If no, leave blank. Record of Environmental Consideration 6 07/03/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR 1603LA / Hurricane Katrina / Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building Yes • (i) Greater scope or size than normally experienced for aparticular category ofaction (ii) Actions with a high level of public controversy D (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 of endangered or threatened species or their critical habitat, or archaeological, cultural, historical or other protected resources; f_] (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; • (vii) Actions with the potential to affect special status areas adversely or other critical resources suchaswetlands,coastalzones,wildliferefugeandwilderness areas,wildandscenicrivers, sole or principal drinking water aquifers; (viii)Potential foradverse effectson health orsafety; and • (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the protection of the environment. f~J (x) Potential for significant cumulative impact when the proposed action is combined with other past, present andreasonably foreseeable future actions, even though theimpacts ofthe proposed action may not be significant by themselves. Comments: None V. Environmental Review Project Conditions General comments: Project Conditions: 1. Thisprojectmust comply withallconditions oftheattached Programmatic Categorical Exclusion. 2. Per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, building contents, materials, and equipment (mechanical or electrical) must be elevated to or above advisory base flood elevations. All new construction must coordinate and comply with local floodplain ordinances and be built to codes and standards. 3. Per 44 CFR 9.12, 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. 4. Demolitionmustfollowthelowerimpactdemolitionstipulations&additionalprotocols which are attached. The stipulations and protocols should be explicit in the demolition contract. Failuretocomplywiththesestipulations&additionalprotocolswilljeopardize receipt 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 take all reasonable measures to avoid or minimize harmtothefinds. TheapplicantshallinformtheirPublicAssistance(PA)contactsat FEMA,whowill inturncontactFEMAHistoricPreservationstaff.Theapplicant will not proceed with work until FEMAHistoricPreservationstaff 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 Record of Environmental Consideration 7 07/03/06 Reviewer Name: Letha Dawson Applicant: St. Bernard Parish School Board Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / ESB0088 Transportation, Maintenance, Storage Building law enforcement agency ofthe 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. Monitoring Requirements: None Record of Environmental Consideration 8 07/03/06