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Virgin Islands Department of Education Coastal Consistency Determination Request Bertha C. Boschulte Prek-8th School Renovation/Modernization Project, St. Thomas, U.S. Virgin Islands Grant Manager: #242933 FEMA Applicant Id: #000-U6P8U-00 January 17, 2023 The Virgin Islands Department of Education (VIDE) hereby requests your permission to undertake the FEMA funded project – Bertha C. Boschulte PreK-8th School Renovation/Modernization Project. The Bertha C. Boschulte PreK-8th School is located at 9-1 & 12A, Bovoni Road, Estate Bovoni, St, Thomas, USVI 00802. Project Location Figure 1 – USVI, St. Thomas – Location Map, Bertha C. Boschulte PreK-8th School DESCRIPTION OF PROJECT The Bertha C. Boschulte Jr. High School was damaged during the 2017 Hurricane Irma and Maria events and deemed unsafe for students and faculty. The Bertha C. Boschulte Jr. High School has been assessed and approved for renovation and modernization by FEMA. The purpose of the project is to design and construct a renovated and modernized school – The Bertha C. Boshulte PreK-8th School, to including existing classrooms, new PreK-5th classrooms, administrative offices, library, cafeteria, kitchen, bathrooms, stairways, balconies, theater, hallways and all fixtures, equipment and contents to renovate and modernize the campus to fulfill 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 renovate and modernization the existing buildings, also to include in the renovation a PreK-5 classroom wing. Site Work 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 Bertha C. Boschulte Jr. High School was damaged during the 2017 Hurricane Irma and Maria events and has been assessed and deemed to be renovation/modernization, which once renovated will become the Bertha C. Boschulte PreK-8th School. 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, minimal ground disturbance, asbestos abatement if needed, air monitoring and site grading, on various sites of the BCB Campus, if needed. The project was outlined in the PowerPoint presentation during a May 25, 2021, multi-agency pre-application meeting and again on July 21, 2022 at another pre-application meeting. ENVIRONMENTAL IMPACTS Climate/Weather Once completed, the renovation/modernization of the Bertha C. Boschulte Prek-8th School will not be affected by climate or weather. During renovation/modernization phase, rainfall will influence the open areas. Sedimentation and erosion controls will be implemented to ensure rainfall will not affect the nearby drainage way. 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 has 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 Bertha C. Boschulte Prek-8th School Project site is (CbB) Cinnamon Bay loam, 0-5% slopes, occasionally flooded. (CgC) Cinnamon Bay gravely loam, 5 to 12 % slopes, occasionally flooded, (SrD) Southgate-Rock outcrop complex, 12 to 20% slopes, (SrE) Southgate-Rock outcrop complex, 20-40 % slopes, (SrF) Southgate-Rock outcrop complex, 40 to 60 % slopes, (SrG) Southgate-Rock outcrop complex, 60 to 90 % slopes, (W) water. Bertha C. Boschulte Prek-8th School Web Soil Survey map showing soils in the vicinity of the project Figure 1. Drainage, Erosion Control, and Maintenance During the renovation/modernization phase drainage and erosion prevention best management practices (BMPs) shall be implemented throughout the 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 renovation/modernization of the Bertha C. Boschulte Prek-8th 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 renovation/modernization of the existing Bertha C. Boschulte PreK-8th 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 a minor increase in emissions. 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 renovation/modernization of the Bertha C. Boschulte Prek-8th School that was destroyed by Hurricane Maria. Visual Impacts The proposed renovation/modernization 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 renovation/modernization of the Bertha C. Boschulte Prek-8th School project only involves already impacted areas that have already been developed and will have no impact on any known historical or archeological resources. 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 renovation/modernization of the Bertha C. Boschulte Prek-8th 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 Bertha C. Boschulte Prek-8th 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 renovation/modernization of the buildings will repair 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 renovation/modernization of 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. The facility will be renovated and modernized to meet all code requirements, which 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 of 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 BCB Renovation/Modernization 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. 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. Building A/B Theater Building C/D Classrooms Building E/F Administration Building G/H Classrooms Building J/K Classrooms Building L Gym Building M Cafeteria Building N/P Classrooms