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Virgin Islands Department of Education Coastal Consistency Determination Request Charlotte Amalie High School Reconstruction Project, St. Thomas, U.S. Virgin Islands Grant Manager: #242933 FEMA Applicant Id: #000-U6P8U-00 June 1, 2022 The Virgin Islands Department of Education (VIDE) hereby requests your permission to undertake the FEMA funded project – Charlotte Amalie High School (CAHS) Reconstruction Project. The Charlotte Amalie High School is located at 8 & 9, Alton Adams Sr. Dr., Charlotte Amalie, St, Thomas, USVI 00802. Project Location Figure 1 – USVI, St. Thomas – Location Map, Charlotte Amalie High School DESCRIPTION OF PROJECT The Charlotte Amalie High School was damaged during the 2017 Hurricane Irma and Maria events and deemed unsafe for students and faculty. The Charlotte Amalie High School has been assessed and approved for replacement by FEMA. The demolition of five buildings (Buildings 8-12) is the precursor to the reconstruction of the new Charlotte Amalie High School in the same location. The purpose of the project is to design and construct a complete school, including classrooms, administrative offices, library, cafeteria, kitchen, bathrooms, stairways, balconies, hallways and all fixtures, equipment and contents to replace the campus with a new campus to fullfill the VIDE vision outlined in the Bridging Documents, under the Federal Emergency Management Agency (FEMA) Public Assistance (PA) program utilizing the flexibility afforded by the Bipartisan Budget Act (BBA). The general scope is primarily the safe identification, testing and abatement of any and all hazardous materials (including but not limited to asbestos and lead paint) that may be found at the site and design, construct, equip and furnish new buildings complete with steel frame, concrete foundations, slabs and suspended slabs, c.m.u. walls, windows, doors, roofs, skylights, finishes, fixtures, furnishings and equipment. The proposed project will begin as soon as the demolition project is executed and will take an approximately 12 months to complete the demolition. I. List all of the federal and territorial permits: VIDE Response: the project will obtain the required permits; seek and comply with Division of Fish and Wildlife recommendations; the VISHPO concurred and the FEMA’s determination of No Historic Properties Affected pursuant to 36 CFR 800.4(d)(1). (attached 1) Detailed analysis that the project and its effects are consistent with the goals and policies of the VI Coastal Zone Management Program (VICZMP): VIDE Response: The Charlotte Amalie High School was damaged during the 2017 Hurricane Irma and Maria events and was deemed unsafe for students and faculty. The Charlotte Amalie High School has been assessed and deemed to be fully rebuilt. The VIDE kindly seeks your review and approval for the required Consistency Determination certification process in accordance with the Virgin Islands Coastal Zone Management Program CZMP as required under the VI Code Section 1, VIR and Regs. Title 12, Subchapter 904, section 904-8. This project may include the security fencing, traffic control, dust control, demolition, minimal ground disturbance, asbestos abatement, air monitoring and site grading, on various sites of the CAHS Campus. The project was outlined in the PowerPoint presentation during a May 25, 2021, multi-agency pre-application meeting and again on May 12, 2022 at another pre-application meeting. ENVIRONMENTAL IMPACTS Climate/Weather Once completed, the reconstruction of the Charlotte Amalie High School will not be affected by climate or weather. During reconstruction phase, rainfall will influence the open areas created by the demolition of existing building and foundations. Sedimentation and erosion controls will be implemented to ensure rainfall will not affect the nearby drainage way during demolition. Prevailing Winds The Virgin Islands lie in the "Easterlies" or "Trade Winds" which traverse the southern part of the "Bermuda High" pressure area, thus the predominant winds are usually from the east-northeast and east. Precipitation The average annual precipitation on St. Thomas is approximately 17.87 inches. Rainfall usually occurs in brief, intense showers of less than a few tenths of an inch and major rainfall events are associated with weather systems. The Virgin Islands have no sharply defined wet seasons. The wettest period generally is from August to November, and the driest period is from January to June. Landform Geology, Soils and Historic Land Use The soil composition of the area of the Charlotte Amalie High School Demolition Project site is (FsF) Fredriksdal-Susannberg complex, 40 to 60 percent slopes, extremely stony. It is shallow and very deep, well drained, steep soils on summits and side slopes of volcanic and mountains. The map unit consists of rugged hills and mountains that are dissected by very narrow valleys that have a dendric drainage pattern. (UbD & UcC) Urban land-Ciinnamon Bay complex, 0 to 12 percent slopes. The map unit consists of Urban land and very deep, well drained alluvial soils that are so intermingled. Charlotte Amalie High School Web Soil Survey map showing soils in the vicinity of the project Figure 1. Charlotte Amalie High School Campus Drainage, Erosion Control, and Maintenance During the reconstruction phase drainage and erosion prevention best management practices (BMPs) shall be implemented throughout the construction site area to aid in the prevention of sediment-laden storm water runoff. These BMPs shall be focused on areas with potential of erosion, and areas preceding infiltration practices. The erosion prevention measures shall be selected on a site- specific basis. In addition, any materials requiring to be stockpiled shall be properly stored so as not to be susceptible to runoff. Examples of Erosion Prevention BMPs include, but are not limited to, silt fencing, construction entrance, concrete washout, surface roughening, erosion control blankets, turf reinforcement mats, and dust control. Guidance on the design and proper use of Erosion Prevention BMPs located in the Virgin Islands Environmental Protection Handbook, 2002 will be used. Drainage Patterns The proposed project will have no impact on existing drainage patterns. Coastal Floodplain The project is not located in a coastal flood plain. Sediment and erosion controls will be implemented in this area and any materials that need to be stockpiled overnight will be properly stored so as not to be susceptible to run off. Fresh Water Resources The proposed reconstruction of the Charlotte Amalie High School will have no impact on freshwater resources. No freshwater ponds or streams occur within the project footprint and groundwater resources within the area are deeper than 80 inches; meaning below the depth of the proposed project. Oceanography The proposed project occurs well inland and will not be affected by sea storm events. Marine Resources The property is located inland and will have no direct impact on the marine environment. Location Terrestrial Resources The proposed project will occur within existing previously developed areas. No natural terrestrial resources or any native flora or fauna will be impacted during the demolition of the existing Charlotte Amalie High School. Wetlands The U.S. Army Corps of Engineers defines wetlands as "those areas that are periodically inundated or saturated by surface or groundwater at a frequency and duration sufficient to support and under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, bogs, marshes and similar areas." (U.S. Army Corps of Engineers, 1986). The project will have no impact on wetlands, as there are no wetlands in, or adjacent to, the proposed project site. Rare and Endangered Species Endangered or threatened species or endangered species habitat exist within proposed project site. According to the U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC) project tool, endangered species, and critical habitat, are expected to be found within the proposed project site area. Prior to any construction activity, including removal of vegetation and earth movement, the boundaries of the project area must be delineated. Once areas are clearly marked, and prior to any construction activity, project personnel able to correctly identify a VI Tree Boa will survey the areas to be cleared to ensure that boas are present with the work areas Air Quality There will be minor increases in emissions during the demolition phase of the existing buildings due to the use of heavy construction equipment that will create combustion engine exhaust. Upon project completion, air quality will return to pre-construction conditions. IMPACT ON MAN’S ENVIRONMENT Land and Water Use Plans The project site is zoned R-2 Residential which complies with the Coastal Land and Water Use Plan, published 2004. Impacts on the existing site: The proposed reconstruction of the Charlotte Amalie High School that was destroyed by Hurricane Maria. Visual Impacts The proposed reconstruction project will thereby improve the visual appearance of the area and more. As a result, this project will have a positive impact on the existing landscape. Historical and Archaeological Resources The proposed reconstruction of the Charlotte Amalie High School project only involves already impacted areas that have already been developed and will have no impact on any known historical or archeological resources. No undisturbed area will be affected. An archaeological monitoring service will be placed to monitor the demolition area during the removal off the existing structures. A clearance letter was sent to FEMA from the State Historical Preservation Office (SHPO). (see attachment 1) Waste Disposal and Accidental Spills The Virgin Islands Waste Management Authority has specific guidelines and criteria for accepting construction debris. Any excess excavated material spoils and construction debris will be collected, taken off-site, and disposed of in accordance with all governing laws and regulations. Equipment will be kept in good operational condition during the proposed project timeline and will not be fueled on site. The selected contractor shall be certified in the procedural requirements for the handling, containment, and disposal of any hazardous materials if identified during the reconstruction of the Charlotte Amalie High School. The handling and disposal of any hazardous materials shall of in strict accordance with all governing laws and regulations. The following policies are set forth in the U.S. Virgin Islands Code Title 12. Conservation Chapter 21, Virgin Islands Coastal Zone Management [V.I. Code tit. 12 § 903(b)]. The proposed Charlotte Amalie High School Demolition Project meets each of the basic goals of the USVI for its coastal zone as follows: USVI Code Title Twelve Conservation, Chapter 21 § 903 (b) 1. Protect, maintain, preserve and, where feasible, enhance and restore, the overall quality of the environment in the coastal zone, the natural and man-made resources therein, and the scenic and historic resources of the coastal zone for the benefit of residents of and visitors of the United States Virgin Islands. Comment: - The proposed reconstruction of the buildings will replace the structures that were damaged by Hurricane Maria. The project will affect only previously disturbed areas, including the existing foundations. The project will not affect any natural resources and will improve the visual image of the site and enhance the overall quality of the environment in the area. This project is located outside the coastal area and is therefore consistent with this policy. 2. Promote economic development and growth in the coastal zone and consider the need for development of greater than territorial concern by managing: (1) the impacts of human activity and (2) the use and development of renewable and nonrenewable resources so as to maintain and enhance the long-term productivity of the coastal environment. Comment: The proposed project will have no impact on the economic development and growth in the coastal zone. 3. Assure priority for coastal-dependent development over other development in the coastal zone by reserving areas suitable for commercial uses including hotels related facilities, industrial uses including port and marine facilities, and recreation use. Comment: The proposed project involves the reconstruction of new buildings at the site. This project is located outside the coastal area and is therefore consistent with this policy. 4. Assure the orderly, balanced utilization and conservation of the resources of the coastal zone, taking into account the social and economic needs of the residents of the United States Virgin Islands. Comment: The proposed project will affect only previously disturbed areas. A new facility will be constructed, that will enhance the social and economic needs of the USVI students, school staff and residents for the area. 5. Preserve, protect and maintain the trust lands and other submerged and filled lands of the United States Virgin Islands to promote the general welfare of the people of the United States Virgin Islands. Comment: The proposed project will not impact trust lands or other submerged or filled lands pf the U. S. Virgin Islands. The project is not located within or near trust lands. 6. Preserve what has been a tradition and protect what has become a right of the public by ensuring that the public, individually and collectively, has and shall continue to have the right to use and enjoy the shorelines and to maximize public access to and along the shorelines consistent with constitutionally-protected rights of private property owners. Comment: The proposed project will in no way affect public access to, or use of, the shoreline. The project is located well inland. 7. Promote and provide affordable and diverse public recreational opportunities in the coastal zone for all residents of the United States Virgin Islands through acquisition, development and restoration of areas consistent with sound resource conservation principles. Comment: The proposed project will not affect public recreational opportunities in the coastal zone. 8. Conserve ecologically significant resource areas for their contribution to marine productivity and value as wildlife habitats, and preserve the function and integrity of reefs, marine meadows, salt ponds, mangroves and other significant natural areas. Comment: - The proposed project will impact only previously disturbed areas. The project CAHS Reconstruction Project will have no impact on natural resources and will utilize best management practices (BMPs) to minimize areas of disturbance, thereby protecting adjacent habitats. 9. Maintain or increase coastal water quality through control of erosion, sedimentation, runoff, siltation and sewage discharge. Comment: The proposed project will have no long-term change on sedimentation or erosion. Storm water will be directed to a gravel/ rock soak-away for percolation before any overflow into the existing drainage ways. II. An assessment relating to the probable effects of the proposed activity and its associated facilities on the VICZMP. Comment: The project will have No adverse effect. Best practices and measures for erosion control will be taken in compliance with all requirements approved by DPNR in the demolition permit process. After the buildings are removed, water will percolate where before water would have collected on the roofs of the buildings and been channeled to drains and overflowed onto impervious surfaces. The impact on the school storm water drainage system of this project will be less than the existing conditions. The proposed activity is consistent to the maximum extent practicable with the Virgin Islands Coastal Zone Management Program and will be conducted in a manner consistent with such program Thank you for your careful consideration of this request for Consistency Determination. FEMA Project Worksheet #: 1308 GPS Coordinates: 17.708307, -64.814216 Project Description: The design of the CAHS campus works to tie together the everyday experience of the students and faculty with the undertones of the culture that is always present within St. Thomas. The site is located at the base of the mountains overlooking Long Bay with views to downtown of Charlotte Amalie and the surrounding islands. The site slopes over 100 feet from the North-West side abutting the mountains to the low point adjacent to Alton Adams Sr Drive, parallel to the harbor to the South. This large change in elevation drew inspiration to create the Carnival, which forms the campus spine consisting of meandering spaces cascading down through the center of the campus. This spine celebrates opportunities for learning while also taking advantage of the views. The central Carnival is the driving factor for the careful placement of the buildings on the site. The Academic Forts flank the west side of the Carnival while the community buildings such as the Marketplace, Sports Arena and Center for Culture and Performing Arts reinforce the eastern edge. In addition to existing topography considerations, trade winds and solar exposure played a significant role in the formation of the campus design. The gross square footage of the project is 239,460 sq. ft. The number of individual buildings will be reduced and will not exceed the current maximum height of three (3) stories. Charlotte Amalie High School Planning Program: Program Area: 1.0 Administration 2.0 Core Academics 3.0 Elective Spaces 4.0 Media Center 5.0 Multi-Purpose Area 6.0 Special Education Department (SPED) 7.0 Food Service 8.0 Physical Education 9.0 Building Support 1.0 Administration 1.1 Administration Offices a. Main School Lobby b. Open Office Space c. Principal’s Secretary Office d. Principal Office e. Principal’s Conference Room f. Conference Room g. Workroom h. Break Room i. SRO Office j. Monitor’s Office k. ISS Room l. ISS Restroom m. Toilet n. Book Room o. Security (Technology) Room p. IT Office q. Mother’s Room r. Parent Center s. Family Restroom 1.2 & 1.3 Counselor’s Suites I & II a. Waiting Area b. Counselor’s Office c. Clerk Office d. Registrar’s Office e. Vault/Records Room f. Conference Room g. Storage Room h. Electrical i. IDF 1.4 Health Clinic a. Waiting Area b. Treatment/Cot Area c. Nurse Office d. Exam Room e. Storage Room f. Rest Room 2.0 Core Academic 2.1 Learning Suites a. Learning Suites – Classrooms – 6 b. Learning Suites – Lab 4 c. Chem Prep Room a. Flex Studio b. Open Collaboration Space/Maker Space c. Small Group Instruction d. Teacher Planning e. Learning Suite Storage f. Student Restrooms g. Family Restroom h. Staff Restroom i. Custodial Closet j. Assistant Principal Office k. Electrical l. IDF m. Outdoor Learning Space n. Covered Outdoor Learning Space 3.0 Elective Spaces 3.1 Fine Arts a. Multi Purpose Room b. Outdoor & White Box Storage c. Broadcast/Media Classroom d. Broadcast Studio e. Broadcast Control Room f. Auditorium g. Stage h. Makeup/Green Room i. Costume Storage j. Women’s Dressing Room k. Men’s Dressing Room l. Audience Restrooms m. Concessions n. Band Room o. Choir Room/Dance Studio a. Costume Storage p. Piano Studio a. Instrument Storage b. Band Booster Storage c. Practice Room d. Shared Ensemble Room e. Band Office f. Choir Office g. Piano Storage h. Shared Music Library i. Shared Costume/Robe Storage q. 2D Art Room a. 2D Art Storage r. 3D Art Room a. 3D Art Storage b. Kiln 3.2 CTE a. Low Intensity Labs b. High Intensity Labs 3.3 JROTC a. JROTC Classroom b. JROTC Armory c. JROTC Uniform Storage d. JROTC Office e. JROTC Dressing Room f. Outdoor Drill Space 4.0 Media Center 4.1 Media Center a. Media Center b. Conference Room c. Production/Publication/Print Space d. Study Room e. IT Help Desk f. Book/Supply Storage g. Office h. Staff Restroom i. Student Restroom j. Workroom(w/sink) 5.0 Multi-Purpose Area 5.1 Media Purpose a. Flex Lab b. Flex Classrooms c. Medium Group Rooms d. Small Group Rooms e. Digital Maker Space a. Digital Maker Space Storage b. Audio/Recording Space f. Career Center 6.0 Special Education Services 6.1 Special Education Services a. Self-Contained Classroom b. Shared Kitchenette c. Kitchenette Pantry d. Shared Laundry Room e. Shared Restroom f. Small SPED Classroom a. Small SPED Classroom Storage b. Small SPED Classroom Restroom 6.2 Special Education Support Suite a. SPED Clerk/Itinerant b. SPED Records Room c. SPED Chair Office d. SPED Office e. Conference Room 7.0 Food Service 7.1 Food Service a. Cafeteria b. Outdoor Eating Area c. Cafeteria Restrooms d. Serving Area e. Servery Storage f. Servery Custodial g. Grab & Go Serving Area h. Kitchen a. Office(w/restroom) b. Dishwashing Room c. Dry Storage d. Cooler/Freezer e. Restroom/Lockers i. Kitchen Receiving 8.0 Physical Education 8.1 Physical Education a. General Athletics Storage b. Shared Weight Room c. Training Room d. Laundry Room Competition Gym a. Concessions b. Spectator Restroom c. Spectator Family Restroom d. PE Storage e. General Atletics Storage f. Women’s Locker Room a. Women’s Shower/Restroom g. Women’s Coaches Office a. Women’s Coaches Restroom h. Men’s Locker Room a. Men’s Shower/Restroom i. Men’s Coaches Office a. Men’s Coaches Restroom 8.2 Concessions & Storage a. Concessions a. Custodial Room b. Tickets/Store c. Pantry b. Storage c. Public Restrooms d. Public Family Restroom e. Cooler Wash Area f. Officials Locker Room a. Officials Restroom g. Field Storage 9.0 Building Support 9.1 Maintenance & Custodial a. Maintenance Receiving b. Equipment Storage c. Custodial Storage d. Outsource Custodial Storage e. Water Heater Room f. Office g. Break Room a. Restroom h. Maintenance Room 10.0 Building Support 10.1 Site a. Parking b. Staff and Visitor Parking c. Field with Track FEMA Project Worksheet #: 1308 GPS Coordinates: 17.708307, -64.814216 Project Description: The design of the CAHS campus works to tie together the everyday experience of the students and faculty with the undertones of the culture that is always present within St. Thomas. The site is located at the base of the mountains overlooking Long Bay with views to downtown of Charlotte Amalie and the surrounding islands. The site slopes over 100 feet from the North-West side abutting the mountains to the low point adjacent to Alton Adams Sr Drive, parallel to the harbor to the South. This large change in elevation drew inspiration to create the Carnival, which forms the campus spine consisting of meandering spaces cascading down through the center of the campus. This spine celebrates opportunities for learning while also taking advantage of the views. The central Carnival is the driving factor for the careful placement of the buildings on the site. The Academic Forts flank the west side of the Carnival while the community buildings such as the Marketplace, Sports Arena and Center for Culture and Performing Arts reinforce the eastern edge. In addition to existing topography considerations, trade winds and solar exposure played a significant role in the formation of the campus design. The gross square footage of the project is 239,460 sq. ft. The number of individual buildings will be reduced and will not exceed the current maximum height of three (3) stories. Charlotte Amalie High School Planning Program: Program Area: 10.0 Administration 11.0 Core Academics 12.0 Elective Spaces 13.0 Media Center 14.0 Multi-Purpose Area 15.0 Special Education Department (SPED) 16.0 Food Service 17.0 Physical Education 18.0 Building Support 1.0 Administration 1.1 Administration Offices t. Main School Lobby u. Open Office Space v. Principal’s Secretary Office w. Principal Office x. Principal’s Conference Room y. Conference Room z. Workroom aa. Break Room bb. SRO Office cc. Monitor’s Office dd. ISS Room ee. ISS Restroom ff. Toilet gg. Book Room hh. Security (Technology) Room ii. IT Office jj. Mother’s Room kk. Parent Center ll. Family Restroom 1.2 & 1.3 Counselor’s Suites I & II j. Waiting Area k. Counselor’s Office l. Clerk Office m. Registrar’s Office n. Vault/Records Room o. Conference Room p. Storage Room q. Electrical r. IDF 1.4 Health Clinic g. Waiting Area h. Treatment/Cot Area i. Nurse Office j. Exam Room k. Storage Room l. Rest Room 2.0 Core Academic 2.1 Learning Suites d. Learning Suites – Classrooms – 6 e. Learning Suites – Lab 4 f. Chem Prep Room o. Flex Studio p. Open Collaboration Space/Maker Space q. Small Group Instruction r. Teacher Planning s. Learning Suite Storage t. Student Restrooms u. Family Restroom v. Staff Restroom w. Custodial Closet x. Assistant Principal Office y. Electrical z. IDF aa. Outdoor Learning Space bb. Covered Outdoor Learning Space 3.0 Elective Spaces 3.1 Fine Arts s. Multi Purpose Room t. Outdoor & White Box Storage u. Broadcast/Media Classroom v. Broadcast Studio w. Broadcast Control Room x. Auditorium y. Stage z. Makeup/Green Room aa. Costume Storage bb. Women’s Dressing Room cc. Men’s Dressing Room dd. Audience Restrooms ee. Concessions ff. Band Room gg. Choir Room/Dance Studio a. Costume Storage hh. Piano Studio a. Instrument Storage b. Band Booster Storage c. Practice Room d. Shared Ensemble Room e. Band Office f. Choir Office g. Piano Storage h. Shared Music Library i. Shared Costume/Robe Storage ii. 2D Art Room a. 2D Art Storage jj. 3D Art Room a. 3D Art Storage b. Kiln 3.2 CTE a. Low Intensity Labs b. High Intensity Labs 3.3 JROTC a. JROTC Classroom b. JROTC Armory c. JROTC Uniform Storage d. JROTC Office e. JROTC Dressing Room f. Outdoor Drill Space 4.0 Media Center 4.1 Media Center k. Media Center l. Conference Room m. Production/Publication/Print Space n. Study Room o. IT Help Desk p. Book/Supply Storage q. Office r. Staff Restroom s. Student Restroom t. Workroom(w/sink) 5.0 Multi-Purpose Area 5.1 Media Purpose g. Flex Lab h. Flex Classrooms i. Medium Group Rooms j. Small Group Rooms k. Digital Maker Space a. Digital Maker Space Storage b. Audio/Recording Space l. Career Center 6.0 Special Education Services 6.1 Special Education Services g. Self-Contained Classroom h. Shared Kitchenette i. Kitchenette Pantry j. Shared Laundry Room k. Shared Restroom l. Small SPED Classroom a. Small SPED Classroom Storage b. Small SPED Classroom Restroom 6.2 Special Education Support Suite f. SPED Clerk/Itinerant g. SPED Records Room h. SPED Chair Office i. SPED Office j. Conference Room 7.0 Food Service 7.1 Food Service j. Cafeteria k. Outdoor Eating Area l. Cafeteria Restrooms m. Serving Area n. Servery Storage o. Servery Custodial p. Grab & Go Serving Area q. Kitchen a. Office(w/restroom) b. Dishwashing Room c. Dry Storage d. Cooler/Freezer e. Restroom/Lockers r. Kitchen Receiving 8.0 Physical Education 8.1 Physical Education e. General Athletics Storage f. Shared Weight Room g. Training Room h. Laundry Room Competition Gym j. Concessions k. Spectator Restroom l. Spectator Family Restroom m. PE Storage n. General Atletics Storage o. Women’s Locker Room a. Women’s Shower/Restroom p. Women’s Coaches Office a. Women’s Coaches Restroom q. Men’s Locker Room a. Men’s Shower/Restroom r. Men’s Coaches Office a. Men’s Coaches Restroom 8.2 Concessions & Storage h. Concessions a. Custodial Room b. Tickets/Store c. Pantry i. Storage j. Public Restrooms k. Public Family Restroom l. Cooler Wash Area m. Officials Locker Room a. Officials Restroom n. Field Storage 9.0 Building Support 9.1 Maintenance & Custodial i. Maintenance Receiving j. Equipment Storage k. Custodial Storage l. Outsource Custodial Storage m. Water Heater Room n. Office o. Break Room a. Restroom p. Maintenance Room 10.0 Building Support 10.1 Site d. Parking e. Staff and Visitor Parking f. Field with Track Attachment 1 –