Table of Contents A. Introduction B. Purpose and Need C. Environmental Review Process D. Site Selection Process and Alternatives Alternative 1- No Action Alternative Alternative 2 – Develop the Site with Mobile Homes/Park Models (Proposed Action) Project Location and Site Description Project Description E. Affected Environment and Environmental Consequences Alternative 1- No Action Alternative Alternative 2 - Develop the Site with Mobile Homes/Park Models (Proposed Action) F. Additional Impact Analysis G. Cumulative Impacts H. Public Involvement I. Conclusion List of Figures 1. Regional Map 2. Local Map 3. Aerial map 4. Site Photograph 5. Coastal Zone Map 6. Flood Zone Map 7. Watershed Map 8. Site Layout Appendices 1. Record of Environmental Consideration 2. Hazardous, Toxic, and Radiological Waste - Phase II Findings Draft Environmental Assessment Justice Center Temporary Community Housing Site Galveston Island, Galveston Texas Hurricane Ike FEMA-1791 DR -TX A. Introduction Hurricane Ike, a Category 2 hurricane with a storm surge above normal high tide levels, moved across the Texas coast on September 7, 2008. Maximum sustained winds at landfall were estimated at 125 miles per hour. President Bush declared a major disaster for the State of Texas due to damages from Hurricane Ike signing a disaster declaration (FEMA-1791-DR-TX) on September 13, 2005, authorizing the Department of Homeland Security’s Federal Emergency Management Agency (FEMA) to provide federal assistance in designated areas. FEMA proposes to administer this disaster assistance pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), PL 93-288, as amended. Section 408 of the Stafford Act authorizes FEMA’s Individual Households Program to provide emergency and temporary housing for eligible disaster victims whose homes are uninhabitable or destroyed as a result of the declared event. This Draft Environmental Assessment (Draft EA) has been prepared in compliance with the National Environmental Policy Act of 1969 (NEPA); the President’s Council on Environmental Quality regulations implementing NEPA (40 CFR 1500-1508); and FEMA’s regulations implementing NEPA (44 CFR 10.9). The purpose of this Draft EA is to analyze potential environmental impacts of the proposed temporary community housing site named “Justice Center.” FEMA will use the findings in this Draft EA to determine whether to prepare an Environmental Impact Statement (EIS) or issue a Finding of No Significant Impact (FONSI). B. Purpose and Need Catastrophic damage from Hurricane Ike has resulted in an extraordinary demand for housing assistance in Galveston County. The purpose of this action is to fulfill FEMA’s mandate under the Individual and Households Program to expeditiously provide temporary housing for eligible disaster victims. As of Jan. 2, 2009 about 72,000 requests for federal assistance have been received for Galveston County and of these requests, approximately 766 (total Pre-Placement Interviews) are for temporary housing assistance (FEMA Individual Assistance Program Summary Report January 1, 2009). The estimated number of applications for direct housing assistance that warrant provision of a manufactured housing unit on an available private, commercial park or community site location, is 904 for Galveston County (FEMA Individual Assistance Program Manufactured Housing Activity Report December 31, 2008). Most of this demand will be met by placing a mobile home on an applicant’s private site or providing them with a mobile home on an available pad leased in a commercial park. However, once these options are exhausted, FEMA estimates approximately 164 applicants still will remain in need of direct housing, thus supporting the need to develop a temporary community housing site, hereafter “community site.” C. Environmental Review Process In order to meet the urgent needs of disaster victims in need of temporary housing, FEMA has implemented an expedited environmental review process. The purpose of this document is to assist FEMA in fulfilling its environmental review responsibilities under NEPA and serve as a vehicle to document compliance under other applicable environmental laws. Laws and Executive Orders addressed through this Draft EA include: the Clean Air Act, Clean Water Act, Endangered Species Act, National Historic Preservation Act, Executive Order 11988 (Floodplain Management), Executive Order 11990 (Protection of Wetlands), Executive Order 12898 (Environmental Justice), and Farmland Protection Policy Act. Other resource areas or issues evaluated in this Draft EA include floodplain, coastal zone, noise, visual resources, traffic, socioeconomics, safety and security, and hazardous and toxic waste. Agency coordination/consultation is being conducted on a site by site basis as necessary. The scope of FEMA’s environmental review includes evaluating project alternatives, characterizing the affected environment, identifying potential environmental impacts, and outlining ways to reduce or minimize adverse affects. This Draft EA examines the site-specific environmental impacts associated with building a proposed FEMA community housing site on publicly owned land to be leased by the General Service Administration for this purpose. This Draft EA was prepared based on a site evaluation, document research, and resource agency information. An electronic version of the Draft EA will be provided to interested agencies prior to and during the public comment period. The public participation period will be brief, as necessitated by the emergency circumstances. Agency coordination and consultation will be deemed complete at the end of the public comment period. FEMA believes that this process will allow for sufficient action analysis and meet the goal of providing timely federal assistance to disaster victims. D. Site Selection Process and Alternatives NEPA requires investigation and evaluation of reasonable project alternatives as part of the project environmental review process. At a minimum, FEMA’s NEPA implementing regulations require the No Action and Proposed Action be evaluated. Concurrent to the Proposed Action; federally assisted housing options, including minor home repairs, rental assistance and installing a mobile home or Park model on a private site or in an existing mobile home park, are being exhausted first; for those requesting housing assistance in the impacted area.  These options rapidly deplete with the high demand, accordingly, a remaining alternative is to build an emergency and temporary community housing site where the above options do not satisfy the demand. In order to expedite the community housing site selection process, FEMA is working closely with local officials to identify potential sites followed by a cursory site reconnaissance and research to determine suitability. Important factors considered in choosing a site include: demand for temporary housing in that area, community acceptance, proximity of community services/amenities (schools, healthcare facilities, public transportation, etc), engineering and construction feasibility, access to utilities, land use compatibilities, property owner terms, costs to develop and maintain site, and environmental/cultural resource sensitivities. FEMA continues to evaluate alternative sites in Galveston County, and other counties within coastal southeast Texas. Although various alternatives have been and continue to be identified, the extraordinary amount of needed housing have limited this Draft EA to analysis of one suitable site alternative at this time. The Justice Center site was selected for further analysis because it meets the basic site feasibility and selection criteria. Alternative 1- No Action Alternative Under the No Action alternative, FEMA would not develop a temporary community housing site for this area. Displaced residents would continue to stay with relatives/friends, in hotels, or other temporary locations until they resolve their own long-term housing needs. Alternative 2 – Develop the Justice Center Site with Mobile Homes/Park Models (Proposed Action) The Proposed Action would provide temporary housing for eligible disaster victims displaced by Hurricane Ike in Galveston, Texas. Disaster victims would be temporarily relocated to the site with an expected occupancy up to 24 months while they resolve their permanent housing solution. Project Location and Site Description The proposed project would develop a community mobile home site with all infrastructure including roads and utilities and installation of approximately 120 mobile homes on this site located just south of the Justice Center complex on Galveston Island, in Galveston County, Texas. The proposed site is bordered on the north by the Justice Center complex, on the south by I-45/87 also know as Broadway, on the east by 59th St. and west by 54th St. The site is located in Galveston about 30 miles south of Houston. The site consists of approximately 17 acres of land, and is characterized by cleared land with little to no vegetation. . The site was formerly utilized as a commercial and industrial area. All of the debris has been removed but several trucks and other pieces of equipment remain in the northwest portion of the property. Historically the property supported equipment and warehouses for packaging and transporting cotton. Rail lines extended onto the property. Project Description The project description is based on the site preliminary design completed on December 4, 2008 (CH2MHill). The proposed action would involve the construction of a mobile home community site (hereafter “community site”) which would accommodate approximately 120 units (see Appendix 1 for preliminary site design). At this time, occupancy is not expected to exceed 24 months. In a letter dated November 13, 2008, the City Manager indicated that the community site is approved for development. The following specific site development components would be included with this project: * Site preparation would include minimal clearing, grading, and removal of debris. * Electrical services would be above ground and connected to existing utilities from Ball Street. * Potable water will be connected below ground to a water main located along Ball Street. New lines and hydrants will be installed on the property for all units. * A gravity flow sanitary sewer system will collect and transport effluent to an existing utility line. The tie-in to local sewer is located along Ball Street. * Access to the Park is planned from Ball Street. * Stormwater drainage will be accommodated by design. * Interior roadways and pads would be constructed of asphalt. * Uniform Federal Accessibility Standard features would be included in 15% of housing units, 15% of the common areas, and all onsite facilities and amenities such as mailboxes and kiosks. * Fencing as appropriate for safety will be provided. When the temporary housing need has ended, FEMA expects that the mobile homes would be hauled from the site. The Park would then be seeded and reasonably restored to its previous conditions or used by the landowner in a manner consistent with local zoning classifications. E. Affected Environment and Environmental Consequences Table 1 summarizes the results of the environmental review process for the Proposed Action. Potential environmental impacts that were found to be negligible are not evaluated further. Resource areas that have the potential for impacts of minor, moderate, or major intensity are further developed in Section F. When applicable, mitigation measures that would reduce potential adverse effects are incorporated in site development and required as conditions for the project to proceed. Definitions of the impact intensity are described below: Negligible: The resource area (e.g., geology) would not be affected, or changes would be either non-detectable or if detected, would have effects that would be slight and local. Impacts would be well below regulatory standards, as applicable. Minor: Changes to the resource would be measurable, although the changes would be small and localized. Impacts would be within or below regulatory standards, as applicable. Mitigation measures would reduce any potential adverse effects. Moderate: Changes to the resource would be measurable and have both localized and regional scale impacts. Impacts would be within or below regulatory standards, but historical conditions are being altered on a short-term basis. Mitigation measures would be necessary and the measures would reduce any potential adverse effects. Major: Changes would be readily measurable and would have substantial consequences on a local and regional level. Impacts would exceed regulatory standards. Mitigation measures to offset the adverse effects would be required to reduce impacts, though long-term changes to the resource would be expected. Alternative 1- No Action Alternative The No Action alternative will not impact the existing environment, as no site preparation or construction would occur for temporary community housing purposes. This alternative would preclude the federal government from adequately addressing the urgency of providing temporary and transient emergency housing. Consequently, displaced disaster victims would have to remain in the temporary housing they have acquired through their own resources and possibly far from their original home. The short and long term recovery of flood victims and their communities would be further compounded by fewer housing options. They would continue to suffer social and economic stresses related to the disaster recovery. Alternative 2 - Develop the Justice Center Site with Mobile Homes (Proposed Action) The Proposed Action would provide temporary housing for eligible disaster victims displaced by Hurricane Ike from Galveston County. Disaster victims would be temporarily relocated to the Justice Center site with an expected occupancy of up to 24 months (which includes a site deactivation period) while they resolve their permanent housing solution. Environmental impacts associated with implementation of Alternative 2 are discussed in Table 1 (Affected Environment and Environmental Consequences) and in Section F. Table 1. Affected Environment and Environmental Consequences Matrix. Geology and Soils Impact Intensity - Negligable Impact Summary - There are no prime and unique farmlands on the project site and the site is located in an urban center. Potential for localized increase in soil erosion during construction. Agency Coordination / Permits - Texas Pollutant Discharge Elimination System (PDES) stormwater construction permit to be obtained by construction contractor. Mitigation - Implement construction Best Management Practices (BMPs). Install silt fences/straw bales to reduce sedimentation. Area soils will be wetted during construction to minimize wind erosion. If fill is stored on site, the contractor would be required to cover it appropriately. Hydrology and Floodplains (Executive Order 11988) Impact Intensity - Minor Impact Summary - Project area is located in Zone AE inside the 100-year floodplain per the FEMA Flood Insurance Rate Map 4854690022 E revised 12/06/02 and must be considered through the 8-step process. Agency Coordination / Permits - 8-Step Process Mitigation - Compliance with the Eight Step process prepared for Galveston Island signed on December 15, 2008 Wetlands (Executive Order 11990) Impact Intensity - Negligable Impact Summary - No wetlands were observed at the project site during the field reconnaissance. No wetlands were shown on the USFWS National Wetland Inventory (NWI) maps. No impacts to wetlands are anticipated. Agency Coordination / Permits - None. Mitigation - None. Coastal Zone Management Impact Intensity - Negligable Impact Summary - Project site is located within the boundaries of the Coastal Zone, but temporary residential site development and occupancy has been determined consistent with the State’s coastal zone management plan. Agency Coordination / Permits - Notification to the Texas Coastal Coordination Council and letter of concurrence dated 11/03/08. Mitigation - None. Water Quality Impact Intensity - Negligable Impact Summary - There is potential for localized increase in sedimentation as a result of site preparation activities. Potential impact to water quality in downstream swales, ditches, and streams (e.g., turbidity, siltation, biological oxygen demand). Agency Coordination / Permits - Stormwater permits to be obtained by construction contractor. Mitigation - Contractor to implement requirements of stormwater permit. These include Best Management Practices such as installation of silt fences, straw bales, etc. to reduce sedimentation. If fill is stored on site, the contractor would be required to cover it appropriately. Air Quality Impact Intensity - Negligable Impact Summary - Galveston County is designated an area of Non-Attainment per the US Environmental Protection Agency. Residential site development and occupancy is consistent with the State Implementation Plan. Negligible impact would be anticipated from vehicle exhaust emissions and increased dust during construction. Agency Coordination / Permits - EPA Region 6 designation. Mitigation - Site soils would be covered and/or wetted during construction to minimize fugitive dust. Vegetation and Wildlife Impact Intensity - Negligable Impact Summary - The project site is primarily bare ground and concrete with sparse grass. Agency Coordination / Permits - None. Mitigation - Once the temporary housing need has ended, the site would be seeded and restored to previous conditions to the extent practical and/or used by the landowner in a manner consistent with local zoning. Threatened and Endangered Species (Endangered Species Act, Section 7) Impact Intensity - Negligable Impact Summary - No threatened or endangered species or designated critical habitat occurs at the site. No effect is anticipated to threatened or endangered species or their habitat as a result of site development and occupancy. Agency Coordination / Permits - The USFWS has been notified of this proposed action and the lack of endangered species and habitat, USFWS letter of 11/17/08 concurred. Mitigation - None. Cultural Resources (National Historic Preservation Act, Section 106) Impact Intensity - Minor Impact Summary - SHPO has determined that, due to the cotton presses nearby, this site is Eligible for listing in the National Register of Historic Places under Criterion A for and Agriculture at the local level of significances. However, the proposed undertaking will have No Adverse Effect. See Section F Agency Coordination / Permits - SHPO concurrence letter 11/20/08 and a subsequent memo dated 12/05/08. Mitigation - Fencing shall be erected around the temporary housing site to protect historic cotton compresses structures from construction activities and prevent access for the duration of the site’s use as temporary housing. Socioeconomics Impact Intensity - Negligable Impact Summary - Site occupancy is expected to be about 300 people (120 units x estimated 2.5 people per unit] maximum. It is expected the site residents are currently displaced residents of Galveston County/City. See Section F. Agency Coordination / Permits - On November 13, 2008 the City issued a formal letter of no objection for the establishment of the Justice Center temporary community housing site. Mitigation - None. Environmental Justice (Executive Order 12898) Impact Intensity - Negligable Impact Summary - The proposed action is not expected to pose disproportionately high and adverse public health or environmental effects on minority and low-income populations. See Section F. Agency Coordination / Permits - None. Mitigation - None. Noise Impact Intensity - Negligable Impact Summary - There are no railroads or major highways in close proximity to the proposed site. The site is near the airport but measured noise levels are anticipated to remain below 65 decibels and therefore acceptable. During the construction period residents immediately adjacent to the project site may temporarily experience elevated ambient noise levels. Due to the urgency of the situation, construction may occur on a 24-hour schedule until the site is completed. Construction noise impacts would be short-term and limited to the duration of construction activities. Agency Coordination / Permits - None. Mitigation - If necessary, the following noise reduction measures should be considered: (1) restricting the 24-hour schedule to the first two weeks of construction; (2) using a 7 a.m. to 7 p.m. construction schedule; (3) completing construction closest to adjoining residents first; and (4) completing noisier activities during the day if a 24-hour schedule is used. Safety and Security Impact Intensity - Negligable Impact Summary - No site safety or security concerns were observed during site reconnaissance. Agency Coordination / Permits - None. Mitigation - The contractor would post appropriate signage and fencing to minimize potential adverse public safety concerns, including placing fencing around the site perimeter. Appropriate signage and barriers should be in place prior to construction activities in order to alert pedestrians and motorists of project Hazardous Materials and Toxic Wastes Impact Intensity - Negligable Impact Summary - A Phase I Environmental Site Assessment has been completed through direct field observation and review of existing records and databases for potential site or adjacent site hazardous materials contamination. While 22 records were noted within .5 miles of the site, no significant environmental conditions were observed during fieldwork or noted during research. . See Section F. A Phase II study investigating soil contaminants was conducted and a comprehensive report received 12/20/08 stating that contaminants are present but within state acceptable levels for land use but with concerns for groundwater due to previous land use. Agency Coordination / Permits - GeoSearch Report #784 dated 11/10/08 and Texas Railroad Commission website search for oil and gas pipelines. Phase II report prepared by PBS&J dated 12/19/08. Memo from TCEQ agreeing soil test results are within state limits for short and long term exposure. Mitigation - None. Traffic and Transportation Impact Intensity - Negligable Impact Summary - Traffic volumes on the local road network in the immediate project area would increase during construction and occupancy. The existing infrastructure would be able to accommodate these increases without impacting local traffic patterns. Agency Coordination / Permits - None. Mitigation - None. F. Additional Impact Analysis Cultural Resources The area was recently used as a debris staging area for Hurricane Ike debris and is presently a vacant graded lot. The area has been heavily impacted by the removal of buildings (indicated on USGS topography maps) and use as a debris site. On November 11, 2008, FEMA Historic Preservation Specialist Jodi Lee Carpenter conducted a cultural records file search in the Texas Historical Commission Archaeological Sites Atlas through the Texas State Historic Preservation Office (SHPO). SHPO has determined that, due to the cotton compresses nearby, this site is Eligible for listing in the National Register of Historic Places under Criterion A for and Agriculture at the local level of significances. However, the undertaking will have No Adverse Effect. Per a Memorandum dated December 5, 2008, fencing shall be erected around the temporary housing site to protect historic cotton compresses structures from construction activities and prevent access for the duration of the site’s use as temporary housing. Socioeconomics The project site is located in the 77551 zip code. According to the 2000 Census, zip code 77551 had 20,997 residents, and 9073 housing units. The median household income was estimated at about $34,318 (based on 1999 dollars) (Census 2000). The primary employment sectors were management and professional, sales and office, and service. According to the 2000 census, about 3.9 percent of the zip code’s civilian labor force is unemployed (Census 2000). With the establishment of the site, up to approximately 300 residents would be temporarily relocating to the Justice Center area (120 units x estimated 2.5 people per unit), most of which are anticipated to be island residents before the disaster. The local community is aware of this action and would experience an increase in the need for public services, such as schools, fire and police services, child care, and medical services. However, the demand for public and commercial services is not expected to be greater than the pre-hurricane demand and potential impacts would be minimal. Environmental Justice Executive Order (EO) 12898 requires that each Federal agency identify and address the effects of its programs, policies, and activities on minority and low-income populations. The function of the EO is to avoid disproportionately high and adverse public health or environmental impacts to the target populations. Further, EO 12898 also tasks Federal agencies to ensure that public notifications regarding environmental issues are concise, understandable, and readily accessible. The population within the 77551 zip code is comprised of about 15.8 percent African American, 68.4 percent Caucasian, and approximately 13.6 percent of the families are living below the poverty level (Table 2) (Census 2000). Table 2: Minority and Low Income Populations Summary Statistics Demographics (percent). Caucasian: City - 58.7; County - 72.7; Texas - 75.1 African American: City - 25.5; County - 15.4; Texas - 12.3 Other: City - 13.4; County - 9.8; State - 10.1 Families below poverty: City - 17.8; County - 10.1; Texas - 9.2 Source: U.S. Census Bureau, Census 2000 The proposed action is not expected to pose disproportionately high and adverse public health or environmental effects on minority and low-income populations. The availability of Federal assistance, including temporary housing for displaced individuals, is consistent with EO 12898. All forms of FEMA disaster housing assistance are available to any affected household that meets the conditions of eligibility and demographics are not among the eligibility requirements. The specific demographics of community site occupants are not available at this time because specific individuals or families are in the process of being identified for this site. However, the demographic makeup of the future Park residents is expected to be similar to the community as a whole. Further, the availability of temporary housing would result in a positive impact to displaced individuals, regardless of whether they are minority and/or low income. Hazardous Materials and Wastes A database review of reported hazardous materials, contaminated sites and generators; and records review with the Texas Commission on Environmental Quality, yielded no known on-site or nearby location concerns related to historical contamination (GeoSearch, 11/10/08). No environmental conditions; such as distressed vegetation and historical soil contamination were observed during field reconnaissance. All of the 22 records noted within .5 miles of the site had been reconciled and not considered a threat. A search of the Texas Railroad Commission website noted no oil or gas lines nearby. A Phase II extensive soil contaminant study was conducted due to concerns about previous land uses. The test results for surface contaminants indicate soil contaminants are within state acceptable levels for short and long term exposure, and this was collaborated in the memo from the Texas Commission on Environmental Quality dated December 29, 2008. G. Cumulative Impacts Cumulative impacts are defined as environmental effects that are greater in magnitude, extent, or duration than the direct and indirect effects of the proposed FEMA-associated action when combined with the effects of other current and future actions, regardless of the proponent. Given the Proposed Action is temporary, long-term (up to 24 months) cumulative affects to the area surrounding the site as a result of site development and occupancy are not anticipated. H. Public Involvement Public involvement is being performed in compliance with NEPA, FEMA’s regulations implementing NEPA at 44 CFR 10.9(c), and Executive Orders 12898, 11988, and 11990. A Public Notice will be published in Galveston Daily beginning on Jan. 3, 2008. Due to the emergency nature of this action, the public comment period will be brief – the three-day comment period will end on Jan 5, 2008. Written comments on the Draft EA and Finding of No Significant Impact (FONSI) can be faxed to FEMA’s Joint Field Office in Austin at (512) 465-3764; or sent via email to FEMA-DR1791-Environmental@dhs.gov. When responding by email, enter the project name, “Temporary Housing – Justice Center Community Site” in the subject field. Verbal comments will be accepted between 8 a.m. and 5 p.m. at (866) 568-1260 or TTY 1-800-462-7585 for the hearing- or speech-impaired. The Environmental Assessment can be viewed and downloaded from FEMA’s website at http://www.fema.gov/plan/ehp/envdocuments/ea-region6.shtm. The Draft EA is also available for public review at the Galveston Island Disaster Recovery Center (DRC) located at the Galveston Island Community Center at 4700 Broadway, Galveston, TX, 77551. The DRC hours are Monday through Saturday, 9 a.m. to 5:30 p.m. The Draft EA is also available for review at the Rosenberg Library, 2310 Sealy Ave., Galveston, TX, 77550. The library hours are Tuesday through Saturday, 9 a.m. to 6 p.m. If no substantive comments are received relative to the proposed action’s environmental effects, the Draft EA and FONSI will become final and the initial Public Notice will also serve as the final Public Notice. Substantive comments will be addressed as appropriate in the Final documents. I. Conclusion This Draft EA was written to evaluate the potential impacts to the environment from the No Action and Proposed Action alternatives. The Draft EA has also addressed the compliance requirements of the National Historic Preservation Act, Endangered Species Act, Executive Orders 11988 (Floodplain Management), 11990 (Protection of Wetlands), and 12898 (Environmental Justice), and other related environmental statutes along with considering issues such as hazardous and toxic wastes, infrastructure, and socioeconomics. Based on fieldwork, proposed action scope of work and mitigation measures, research, and consultations; the findings of this Draft EA indicate that an Environmental Impact Statement is not required. A Finding of No Significant Impact has been prepared and is attached.