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Virgin Islands Department of Education Coastal Consistency Determination Request Arthur R. Richards PreK-8th School Project – New Build, St. Croix, U.S. Virgin Islands Grant Manager: #86891 FEMA Applicant Id: #000-U6P8U-01 June 1, 2022 The Virgin Islands Department of Education (VIDE) hereby requests your permission to undertake the FEMA funded project – Arthur A. Richards PreK-8th School (AARPK8S) New Build Project. The Arthur A. Richards PreK-8th School is located at 13A Estate Mount Pleasant, Frederiksted, St, Croix, USVI 00820. Project Location Figure 1 – USVI, St. Croix – Location Map, New Arthur A. Richards K-8th School DESCRIPTION OF PROJECT The Arthur A. Richards Jr. High School was destroyed during Hurricanes Irma and Maria in September 2017. These Hurricanes required new conversations around resiliency and student and community needs. Coupled with new funding opportunities provided by the Bipartisan Budget Act of 2018. The VIDE was in a position to plan for the replacement of infrastructure. Hence, the new construction of the New Arthur A. Richards PreK – 8th School, on the existing site of the Evelyn M. Williams Elementary School site. 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. Providing relief space for Arthur R. Richards PreK-8th School currently being housed in modulars and accessory structures, 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 with all work completed and occupancy permits attained by December 31, 2024, or such date per any Contract amendment. New Arthur A. Richards PreK-8th School 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) with the demolition of Evelyn Williams Elementary School which is the existing site of the Arthur A. Richards PreK-8th School I. 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 Arthur R. Richards Jr. High School was damaged during the 2017 Hurricane Irma and Maria events and was deemed unsafe for students and faculty. Hence, the reconstruction of the new Arthur A. Richards K-8th School on existing site of the Evelyn M. Williams Elementary 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, demolition, minimal ground disturbance, asbestos abatement, air monitoring and site grading, on various sites of the ARPreK-8th Campus. The project was outlined in the PowerPoint presentation during a May 25, 2021, multi-agency pre-application meeting and again on May 19, 2022 at another pre-application meeting. ENVIRONMENTAL IMPACTS Climate/Weather Once completed, the reconstruction of the New Arthur A. Richards PreK-8th School will not be affected by climate or weather. During reconstruction, 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 reconstruction. 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. Croix is approximately 36.14 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 New Arthur R. Richards PreK-8th School site is Sion clay (SiA & SiB), 0 to 2 percent slopes and Arawak gravelly loam (ArC), 5 to 12 percent. The Sion series consists of very deep, well drained, moderately slowly permeable soils on side slopes and valley floors. They formed in alkaline marine deposits. Near the type location, the mean annual temperature is about 80 degrees F., and the mean annual precipitation is about 40 inches. Slopes range from 0 to 5 percent. The Arawak series consists of shallow, well drained, slowly permeable soils on summits and side slopes of limestone hills and mountains. They formed in material weathered from soft limestone bedrock. Near the type location, the mean annual air temperature is about 80 degrees F. and the average annual precipitation is about 40 inches. Slopes range from 2 to 70 percent. All work is being done in areas that have already been disturbed. Table 1: Archaeological resources within a half (1/2) mile of the APE boundary (Figure 2). Resource Direction (feet) Period Effect 12VAm1-080 Adventure NE Precontact No effect 12VAm1-162 Paradise SW Historic No effect 12VAm1-050 Mt. Pleasant NW Precontact No effect 12VAm1-280 Mt. Pleasant Estate NW Historic No effect 12VAm1-166/285 Plessen 2/Plessen Slave Village NWN Historic No effect 12VAm1-016 Plessen NWN Precontact No effect Soils According to the USDA Web Soil Survey, USDA Official Soil Series Description, and the 2000 Soil Survey of the United States Virgin Islands, the following soils occur in the APE (Table 2 and Figure 1). Table 2: Soils in APE. Unit Soil type Series Description SiA Sion clay, 0 to 2 percent slopes The Sion series consists of very deep, well drained, moderately slowly permeable soils on side slopes and valley floors. They formed in alkaline marine deposits. Near the type location, the mean annual temperature is about 80 degrees F., and the mean annual precipitation is about 40 inches. Slopes range from 0 to 5 percent. SiB Sion clay, 2 to 5 percent slopes ArC Arawak gravelly loam, 5 to 12 percent slopes, very stony The Arawak series consists of shallow, well drained, slowly permeable soils on summits and side slopes of limestone hills and mountains. They formed in material weathered from soft limestone bedrock. Near the type location, the mean annual air temperature is about 80 degrees F. and the average annual precipitation is about 40 inches. Slopes range from 2 to 70 percent. Arthur R. Richards PreK-8th School Web Soil Survey map showing soils in the vicinity of the APE (in red) Figure 1. Drainage, Erosion Control, and Maintenance As the construction project begins, 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 existing topography for the site generally slopes west to east to a swale and then flows south off site. Positive drainage will be designed away from proposed buildings to route storm-water runoff to a detention pond that will be in the southeast corner of the site. A swale containing storm drains with surface inlets will surround the exterior of the site. Storm drains with surface inlets are also anticipated in parking areas and between buildings. Because more than one acre will be disturbed during this project, a Drainage & Erosion Control Plan will be prepared that will be used by the Contractor to obtain a Storm water Discharge Permit prior to commencing construction. 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 Arthur A. Richards 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 reconstruction of the existing Arthur A. Richards 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 No 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, no endangered species, critical habitat, or migratory birds are expected to be found within the proposed project site area. There is an endangered ground lizard (Ameiva polops) found on the island of St. Croix, but this lizard is only found on Buck Island, Green Cay, Ruth Cay and Protestant Cay, locations outside of the proposed project site. There are also three endangered plant species located on St. Croix (Agave eggersiana, Buxus vahlii and Catesbaea melanocarpa), but these are primarily located in exposed, dry areas - Five (5) known populations of Agave Eggersianai on St. Croix, all are well removed from the proposed project site. - Three (3) known populations of Buxus Vahlii on St. Croix and all are well removed from the proposed project site. - One (1) known population of Catesbaea Melanocarpa on St. Croix and it is also located outside the proposed project site. Neither the endangered ground lizard nor any of the endangered plants species are found within the proposed project footprint. Air Quality All of St. Croix is designated Class II by the Environmental Protection Agency, in compliance with National Ambient Air Quality Standards. In Class II air quality regions open burning, visible air contaminants, particulate matter emissions, volatile petroleum products, sulfur compounds and internal combustion engine exhaust are all regulated (Virgin Islands Code Rules and Regulations). 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 New Arthur R. Richards PreK-8th School that was destroyed by Hurricane Maria. Visual Impacts The New Arthur R. Richards PreK-8th School 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 New Arthur R. Richards PreK-8th School will only involve 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. 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 identified resulting from the reconstruction of the New Arthur R. Richards 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 the New Arthur R. Richards PreK-8th School 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 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 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. 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 previously disturbed areas associated with the removal of the existing buildings. The lot will become the New Arthur A. Richards, which will not negatively affect the social and economic needs of USVI residents for the immediate 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 previously disturbed areas. The project New Arthur A. Richards PreK-8th School 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 existing topography for the site generally slopes west to east to a swale and then flows south off site. Positive drainage will be designed away from proposed buildings to route storm-water runoff to a detention pond that will be in the southeast corner of the site. A swale containing storm drains with surface inlets will surround the exterior of the site. Storm drains with surface inlets are also anticipated in parking areas and between buildings. Because more than one acre will be disturbed during this project, a Drainage & Erosion Control Plan will be prepared that will be used by the Contractor to obtain a Storm water Discharge Permit prior to commencing construction. 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. 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 #: 01052 GPS Coordinates: 17.708307, -64.814216 Project Description: The New Arthur A. Richards PreK-8th School will be re-constructed at the site of the Evelyn M. Williams Elementary School. The Guiding Principle for the New Arthur A. Richards PreK-8th School is Cultural, Local and Economic Competence and Resilience. The planning, design and construction efforts will embody cultural, local and economic competence and resilience by:  Vernacular architecture being incorporated into designs  Local and M/WBE participation in design and construction being encouraged and tracked with goals.  Vocational programs and opportunities for certification The design of the New Arthur A. Richards PreK-8 School campus is the result of divergent thinking that explored ways of recreating historic shapes, forms and materials through modern interpretations of key design principles exhibited in the historic Danish architecture of the islands. The following design values for the built environment informed the solutions and outcomes for the New Arthur A. Richards PreK – 8th School  Equity and Inclusion o Space model that supports Inquiry-Based Learning at all grade levels. o Site design that provides equitable access to campus resources and outdoor learning.  Health and Comfort o Diversity of spaces for collaboration and respite. o Sustainable design for natural cooling and daylighting.  Resiliency and Systems o Thoughtful use of materials for hurricane resistance and reduced maintenance. o Net zero ready infrastructure.  Spaces and Resources o Flexible spaces that can change to accommodate different activities. The gross square footage of the project is 141,479 sq. ft. with outdoor learning included. Arthur R. Richards PreK – 8th School Program Summary: Planning Program: 1.0 Administration 2.0 Core Academics 3.0 Elective Space 4.0 Media Center 5.0 SPED Services 6.0 Food Service 7.0 Physical Education 8.0 Building Support 1.0 Administration 1.1 Administration Office Main School Lobby (w/Restrooms) Reception Secretary/Bookkeeper Office Principal Office (w/Restroom) Assistant Principal Office Conference Room Staff Work/Mail Faculty Lounge SRO Office Monitor’s Office Supply Room Restrooms Mother’s Room Office Supply Storage Parent Center 1.2 Student Services Reception/Guidance Clerk Counselor’s Office Registrar’s Office Time-Out/Tardy Room Speech Therapy Record’s Room Conference Room Storage/Work area 1.3 Health Clinic Exam/Cot Office Infirmary Restroom 2.0 Core Academics 2.1 PreK Core Academics Pre-K/Kinder Learning Suite – Studio (w/Restroom CoLab/Gross Motor Skill Outdoor Learning Space 2.2 Elementary Core Academic Learning Suite 1 – (w/RR) (Kinder) Learning Suite 1 – (1st. – 5th) Open Collaboration Space Small Group Instruction Distance Learning Teacher planning Learning Suite Storage Student Restrooms Staff Restroom Custodial Shared outdoor Learning Space #1 Learning Suite 2 – (w/RR) (Kinder) Learning Suite 2 – (1st. – 5th) Open Collaboration Space Small Group Instruction Distance Learning Teacher planning Learning Suite Storage Student Restrooms Staff Restroom Custodial Shared outdoor Learning Space #2 Learning Suite 3 – (w/RR) (Kinder) Learning Suite 3 – (1st. – 5th) Open Collaboration Space Small Group Instruction Distance Learning Teacher planning Learning Suite Storage Student Restrooms Staff Restroom Custodial Learning Suite 4 – (w/RR) (SPED) Learning Suite 4 – (1st. – 5th) Open Collaboration Space Small Group Instruction Distance Learning Teacher Planning Learning Suite Storage Student Restrooms Staff Restroom Custodial 2.3 Middle School Core Academics Learning Suite – Studio (6th -8th) Learning Suite – W/RR (SPED) Learning Suite – Science Lab Learning Suite – Science Maker Space Learning Suite – Science CoLab Flex Studio Open Collaboration Space Small Group Instruction Distance Learning Teacher Planning Learning Suite Storage Student Restrooms Staff Restroom Custodial 3.0 Elective Spaces 3.1 Fine Arts Art/Culture Lab Storage Choir Storage Band/Orchestra Steel Pan Drums Storage Outdoor Learning Space 4.0 Media Center 4.1 Media Center Media Center Book/General Storage Office Workroom (w/sink) 5.0 Special Education Services (SPED) 5.1 Special Education Services ** see learning suite programs for incorporation of SPED 6.0 Food Service 6.1 Food Service PreK – 5th Dining Area PreK – 5th Outdoor Covered Dining/Play Area Shared Stage Chair Storage (300 Chairs) Boys Restroom w/changing room Girls Restroom w/changing room 6th – 8th Dining Area 6th – 8th Outdoor Covered Dining /Play Area Serving Area Kitchen Office (w/Restroom) Dishwashing Room Dry Storage Cooler/Freezer Restroom/Lockers Locker Room (w/restroom) Laundry/Chemical Storage 7.0 Physical Education 7.1 Physical Education Gymnasium (seats 600) Physical Education/Health Classroom Locker Room/Restroom PE/Coach Office PE Storage Indoor Exercise Room (weight) 8.0 Building Support 8.1 Maintenance & Custodial Receiving Storage/Locker Area Office/Planning Area Custodial Equipment/Supply Restroom 9.0 Site 9.1 Site Shared PK & K Playground 1st – 5th Playground Multi-Purpose Field Basketball Courts Gardens Parking Lot (for XXX Cars) Landscape Design Objectives:  Develop a plant palette consisting of island appropriate, low water use, low maintenance, disease and pest resistant plant materials that are visually interesting and attractive.  To create a school site that is accessible to students and staff of all levels of mobility so that all site users are afforded a fair and equitable experience.  To develop a theme that encompasses a sustainable environment and incorporates local and native materials.  To have the site design and landscape work hand in glove with the architecture and civil engineering to create a visually strong project with a unique “sense of place.”  To create a school site that is cost effective, easy to maintain and whose visual impact builds off of the architecture and greater site design.  To create shade at the nodes where students gather through the use of trees and built shade.  To develop a safe, functional and visibly accessible site through landscape view corridors.  To use plant materials that are tough enough to resist the stresses inherent to schools. Landscape Development Areas: 1. Tapestry Walk 2. Front Entry 3. Parent/Bus Drop-off 4. Outdoor Learning Classrooms 5. Permaculture Gardens 6. Amphitheater 7. General Landscape Areas (Throughout) 8 Outdoor Playground Areas Swimming Pool: At the northeast corner of the site, a swimming pool will be constructed in the area where the photovoltaic structure is shown. The photovoltaic panels will be incorporated in to shade structures covering the pool or on other parts of the site. An alternate placement will be the southwest corner of the site. . Photos Thank you for your careful consideration of this request. Your approval and support of this matter is greatly appreciated. If you have any questions or concerns, please contact the Chaneel Callwood, Architect New Schools at chaneel.callwood@vide.vi or 340.774.0100 ext. 8107.