**Draft Environmental Assessment**

**Proposed new D'Iberville High School**

**Hurricane Katrina**

**FEMA-1604-DR-MS**

**[1.0 Introduction]{.underline}**

Hurricane Katrina made landfall on the southeastern coast of Louisiana
and the southwestern coast of Mississippi on August 29, 2005, with
maximum sustained winds of 140 mph. Hurricane-force winds extended
outward up to 105 miles from the center of the storm. Coastal storm
surge flooding of 20 to 30 feet above normal tide levels, along with
large and dangerous battering waves, occurred near and to the east of
where the center of the storm made landfall. Widespread damage occurred,
including beach erosion and damage and/or destruction of homes and
infrastructure.

Like many other public and private buildings on the Mississippi Gulf
Coast, the extraordinary storm surge associated with Hurricane Katrina
caused extensive damage to the D'Iberville Middle School, located at
1000 Gorenflo Street in D'Iberville, Mississippi. The school campus was
located approximately 400 meters north of the north shore of the Back
Bay of Biloxi. The facility consisted of four classroom buildings, a
cafeteria and a gymnasium, with a combined total space of 72,000 square
feet. Eight feet of water inundated the six school buildings on the
campus, causing complete destruction of all interior furnishings and
equipment, as well as plumbing, wiring and flooring. Due to the extent
of the damages, no repairs have been conducted and the buildings are
slated for demolition. Students previously attending D'Iberville Middle
School students are currently attending classes in trailers at
D'Iberville Elementary (fifth and sixth grades) and D'Iberville High
School (seventh and eighth grades).

FEMA proposes to provide assistance to repair, restore, or relocate the
school through the Public Assistance Program (PA) under Presidential
Disaster Declaration FEMA-1604-DR-MS. In accordance with 44 Code of
Federal Regulations (CFR) for FEMA, Subpart B, Agency Implementing
Procedures, Part 10.9, an Environmental Assessment (EA) was prepared
pursuant to Section 102 of the National Environmental Policy Act (NEPA)
of 1969, as implemented by the regulations promulgated by the
President's Council on Environmental Quality (40 CFR Parts 1500-1508).
The purpose of the EA is to analyze the potential environmental impacts
of the proposed project, and to determine whether to prepare an
Environmental Impact Statement (EIS) or a Finding of No Significant
Impact (FONSI).

**[2.0 Purpose and Need]{.underline}**

There is an immediate need to expand the capacity of the high school in
the D'Iberville area. Students previously attending D'Iberville Middle
School students are currently attending classes in trailers at
D'Iberville Elementary (fifth and sixth grades) and D'Iberville High
School (seventh and eighth grades). Housing trends indicate a rapid
expansion in population growth inland along the Mississippi Gulf Coast,
specifically north of Interstate 10.

**[3.0 Alternatives]{.underline}**

**[3.1 Alternatives Eliminated from Further Consideration]{.underline}**

*Repair/Re-construction of D'Iberville Middle School*

Re-construction of the existing D'Iberville Middle School buildings is
not possible because the site is located within the new 100-year
floodplain. The buildings were inundated with eight feet of water due to
storm surge from the Back Bay of Biloxi during Hurricane Katrina. Any
new buildings would be required to be elevated, and the school would be
located in a vulnerable location with respect to future hurricane storm
surges;

**[3.2 Alternatives Considered for Further Review]{.underline}**

*Alternative 1: No Action Alternative*

Under the No Action alternative, FEMA would not fund the proposed
project and no new school would be constructed. Students of D'Iberville
Middle School and D'Iberville High School would remain at their current
locations. This would result in further disruption of the Harrison
County School System, further personal hardships for students and school
staff, and would result in increased population growth in an area of the
county with no geographically proximate high school, resulting in longer
travel times for students and increased costs in busing.

*Alternative 2: Relocation of D'Iberville Middle School Function
(Proposed)*

The Harrison County School Board is proposing the permanent relocation
of the school as an improved project in the form of a new D'Iberville
High School. This new high school will replace the existing high school
which will be converted to serve as the new middle school.

The proposed project site for the new D'Iberville High School (the Lynam
site) consists of approximately 43 acres, as shown on the survey
attached as Figure 1 in Appendix A (Parcel 1, Parcel 2 and Parcel 3). It
is located on the west/northwest side of Lamey Bridge Road in Section
19, Township 6 South, Range 9 West in a rural area of Harrison County,
Mississippi. The street address for the existing house located on the
property is 15535 Lamey Bridge Road.

The subject property is bounded on the north by Lamey Bridge Road,
across which are located residences, Chester's Paint and Body Shop at
15592 Lamey Bridge Road, and a former dirt pit, former racetrack and the
closed (since 1991) Ollie Lamey sanitary landfill; on the east by vacant
wooded land; on the south by vacant wooded land; on the southwest by the
new Highway 67 which is under construction at this time; and on the west
by residences and vacant wooded land. The site is currently used as a
residential homestead. Parcels 1 and 2 are zoned as A-1 (agricultural
zoning district) with the following setbacks: 40 feet from the front, 30
feet from the rear and 25 feet from each side. Parcel 4 is zoned E-1
(large scale residential estate) with the following setbacks: 40 feet
from the front, 30 feet from the rear, and 15 feet from each side.
Construction of a high school within these zones is acceptable, with a
conditional use approval.

The proposed project site is outside the Advisory Base Flood Elevation
(ABFE); the former D'Iberville Middle School site is within the ABFE.

An aerial photograph of the property and a boundary survey map provided
by the Harrison County School District, which indicates three parcels
totaling 42.79 acres, are included in Appendix A of this report.

This location was selected based on information provided by Mr. Richard
Rose, City Manager for D'Iberville, on future housing trends. The
information provides that seven developers submitted water and sewer
service requests to the City of D'Iberville to accommodate over 10,000
new houses to be built within a 2.5-mile radius of the proposed
D'Iberville High School location.

The proposed new 150,000 square foot high school will be designed to
support 1,000 students.  The high school will be composed of three major
sections:  the classroom wings, the media center and cafeteria, and the
1,500 capacity gymnasium.  The two story classroom wings will meet FEMA
361 Shelter requirements. FEMA 361 Design & Construction Guidance for
Community Shelters provides for the design of engineered shelters that
will protect large numbers of people during a high-wind event. Shelters
designed by a professional according to the design and performance
criteria outlined in this manual (including a design wind speed) are
intended to minimize the probability of death and injury during a
high-wind event by providing their occupants with near-absolute
protection. These shelter projects are specifically funded through the
HMGP 404 program.

Based on these requirements, 2,710 evacuees can be housed in the
facility in the event of a natural disaster. The cafeteria, kitchen,
media center, and areas will serve as auxiliary spaces for the evacuees,
after the disaster event. 

The high school will be constructed of load-bearing, concrete masonry
and brick composite walls; structural integrity will be designed to
comply with FEMA 361 shelter wind load and impact resistance
requirements.  The load bearing composite walls will support structural
pre-cast hollow-core concrete slabs over the classroom wings and
structural, metal roof decking over the cafeteria, media center, and
gymnasium.   

The water and sewer for the school will tie into the public utilities.
As a FEMA 361 shelter, however, the facility is required to have
independent potable water supply and sewer treatment capabilities. The
potable water supply will be provided by an on-site water well tied into
the emergency backup generator. The sewage treatment plant will be
provided by a package system tied into the emergency backup generator.
Onsite waste water treatment will be similar to those manufactured by
Orenco Systems, Inc.

The following table summarizes the potential impacts of the Proposed
Action Alternative and conditions or mitigation measures to offset those
impacts:

  -----------------------------------------------------------------------
  **Affected         **Impacts**               **Mitigation**
  Environment**                                
  ------------------ ------------------------- --------------------------
  **Geology,         No impacts to geology;    Area soils would likely be
  Topography and     long-term minor impacts   disturbed during
  Soils**            to topography. Short-term construction. Soil loss
                     impacts to soils during   would occur directly from
                     the construction period.  disturbance or indirectly
                                               via wind or water. Best
                                               management practices will
                                               be developed and
                                               implemented, such as
                                               implementing an erosion
                                               and sedimentation control
                                               plan using silt fences or
                                               hay bales, revegetating
                                               disturbed soils, and
                                               maintaining site soil
                                               stockpiles, to prevent
                                               soils from eroding and
                                               dispersing off-site.

  **Water            Beneficial impact to      None
  Resources**        water resources due to    
                     the demolition of the     
                     existing D'Iberville      
                     Middle School and the     
                     return of natural         
                     floodplain processes to   
                     the existing D'Iberville  
                     Middle School site.       

  **Surface Water**  Temporary short-term      Appropriate BMPs, such as
                     impacts to surface water  installing silt fences and
                     are possible during       revegetating bare soils
                     construction activities.  would minimize runoff.

  **Floodplains**    Beneficial impact due to  None
                     relocation of the         
                     D'Iberville Middle School 
                     outside of the            
                     floodplain.               
  -----------------------------------------------------------------------

  -------------------- ------------------------- --------------------------
  **Groundwater**      Minimal impacts to        None
                       groundwater are           
                       anticipated, due to       
                       increased consumption     
                       from the aquifer.         

  **Biological         Approximately 19 acres of None
  Resources**          forested wildlife habitat 
                       would be converted to     
                       school use.               

  **Air Quality**      Short-term impacts to air Construction contractors
                       quality would occur       would be required to water
                       during the construction   down construction areas
                       period.                   when necessary and
                                                 fuel-burning equipment
                                                 running times would be
                                                 kept to a minimum and
                                                 engines would be properly
                                                 maintained.

  **Transportation**   There would be a minor    Construction vehicles and
                       temporary increase in the equipment would be stored
                       volume of construction    on-site during project
                       traffic on roads in the   construction and
                       immediate vicinity of the appropriate signage would
                       proposed project site.    be posted on affected
                                                 roadways.

  **Noise**            Short-term impacts to     Construction would take
                       noise would occur at the  place during normal
                       proposed project site     business hours and
                       during the construction   equipment and machinery
                       period.                   installed at the proposed
                                                 high school would meet all
                                                 local, state, and federal
                                                 noise regulations.

  **Cultural           No impacts to             None
  Resources**          archeological or historic 
                       resources are             
                       anticipated.              

  **Socioeconomic      No impacts to             None
  Resources**          socioeconomic resources   
                       would occur.              

  **Environmental      No disproportionately     None
  Justice**            high or adverse effect on 
                       minority or low-income    
                       populations would occur.  
  -------------------- ------------------------- --------------------------

  ------------------ ------------------------- --------------------------
  **Hazardous        No impacts to hazardous   Construction activities
  Materials**        materials or wastes are   could expose or otherwise
                     anticipated.              affect subsurface
                                               hazardous wastes or
                                               materials. However, a
                                               Phase I ESA has been
                                               conducted for the site and
                                               no recognized
                                               environmental conditions
                                               were discovered,
                                               indicating a minimal risk.
                                               Any hazardous materials
                                               discovered, generated, or
                                               used during construction
                                               would be disposed of and
                                               handled in accordance with
                                               applicable local, state,
                                               and federal regulations.

  ------------------ ------------------------- --------------------------

**[4.0 Affected Environment and Environmental
Consequences]{.underline}**

The environmental review process for the Proposed Action included
several field reconnaissance site visits, as well as background research
and regulatory agency consultation. Field investigations included a
Phase I environmental site assessment, a wetlands determination, a
threatened and endangered species survey, a cultural resources survey,
and a traffic study. Background research included a review of wetland
maps, census statistics, FEMA floodplain maps, environmental regulatory
records databases, archaeological and historic structures databases,
threatened and endangered species information, soil surveys, historic
aerial photographs, and other available information. Sections 4.1
through 5.0 below discuss the results of the environmental review
process, including the appropriate investigation, coordination and
consultation with regulatory agencies. When applicable, appropriate
mitigation measures that would reduce any potential adverse effects are
summarized.

**[4.1 Soils]{.underline}**

**[4.1.1 Soils Existing Conditions]{.underline}**

A soils classification of the site according to the National Cooperative
Soil Service on-line data base indicates that the following soils are
present on the subject property: Poarch fine sandy loam, 2 to 5 percent
slopes, Poarch fine sandy loam, 2 to 5 percent slopes, and Harleston
fine sandy loam, 2 to 5 percent slopes. The Poarch series consists of
deep, well and moderately well drained, moderately permeable soils on
uplands that formed in unconsolidated sandy and loamy marine sediments.
They are saturated in the lower part in late winter and early spring.
Slopes range from 0 to 8 percent.

The Harleston series consists of deep, moderately well drained,
moderately permeable soils. They formed in marine or stream deposits
consisting of thick beds of sandy loam. They are on terraces and uplands
of the Southern Coastal Plain. Slopes range from 0 to 12 percent.

The Farmland Protection Policy Act (FPPA) states that federal agencies
must "minimize the extent to which federal programs contribute to the
unnecessary conversion of farmland to nonagricultural uses." Although
the site was previously used for limited agricultural purposes including
crops and cattle, the recent history has been limited to strictly
residential. The property was used for the grazing of four head of
cattle until circa 1990 and a small area was used for growing corn until
1980.

**[4.1.2 Impacts to Soils]{.underline}**

*Alternative 1-No Action Alternative:*

Normal occurrences of soil erosion would be expected to occur if the
site is not developed. The site is not located within a 100-year
floodplain and is not subject to flooding, due to its elevation and
topography. \[

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

A Farmland Conversion Impact Rating worksheet (Form AD-1006) was
completed by Covington and Associates and the NRCS District
Conservationist (T. Harrington) on January 22, 2007. According to the
worksheet, forty-three (43) acres of prime farmland (based on soil
types) will be converted. Mr. Harrington stated that this program is
designed to monitor trends in prime farmland, not to approve or
disapprove of any conversions.

Area soils would likely be disturbed during construction. Soil loss
would occur directly from disturbance or indirectly via wind or water.
Best management practices will be developed and implemented, such as
implementing an erosion and sedimentation control plan using silt fences
or hay bales, revegetating disturbed soils, and maintaining site soil
stockpiles, to prevent soils from eroding and dispersing off-site.

Implementation of appropriate Best Management Practices (BMPs) would be
required at the construction locations. BMPs include, but are not
limited to; the installation of silt fences and revegetating bare soils
to minimize erosion. The proposed project site does not contain soils
classified as prime or unique farmland. []{.mark}

Beneficial long term impacts to soils would occur as a result of the
site being re-graded to natural conditions and being left to revegetate
naturally. Any vegetation that is planted as part of the demolition BMPs
or that establishes naturally will provide soil stabilization; thereby
reducing soil erosion.

**[4.2 Water Resources]{.underline}**

**[4.2.1 Groundwater Existing Conditions]{.underline}**

The proposed project site is located above the coastal lowlands aquifer
system. Recharge of the aquifer in the vicinity of the proposed project
site occurs in areas of higher elevations because water flows southwest
toward the Gulf of Mexico. Dissolved solids, such as salinity, increase
as the velocity of the water decreases approaching the sea. Freshwater
parts of the aquifer are typically located about 500 feet below sea
level. Depth of the on-site domestic water well is 518 feet, and it is
screened in the Pascagoula Formation. This well was sampled on December
11, 2006 as part of this investigation, and the groundwater samples were
analyzed for the following parameters: volatile organic compounds by
Method 8260; target compound list semivolatile organic compounds by
Method 8270C; polynuclear aromatic hydrocarbons by 8310; RCRA metals by
methods 7470A and 6010B; pesticides by Method 8081A; herbicides by
Method 8151; chloride, nitrate and sulfate by Method 9056; and
phosphate, ortho (soluble) by Method 4500P-E. Due to detections of
extremely low trace levels of several herbicides, the herbicides
analysis was re-run a second time on the same groundwater sample. It
should be noted that the herbicide concentrations reported are below
reported detection limits and are very close to the minimum detection
limits for these compounds, and may represent mathematical
interpretations. [None]{.underline} of the detected analytes in the
groundwater sample from the Lynam's well exceed the National Primary
Drinking Water Standards established by the Environmental Protection
Agency. A summary of the analytical results as well as the laboratory
reports and field sampling log are included under separate cover.

**[4.2.2 Impacts to Groundwater]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Alternative)*

The water supply for the school will tie into the public utilities. As a
FEMA 361 shelter, however, the facility is required to have independent
potable water supply, which will be provided by an on-site water well
tied into the emergency backup generator. Onsite waste water treatment
will be similar to those manufactured by Orenco Systems, Inc.

**There will be minimal impacts to the groundwater due to slight
increased demand on the potable aquifer at this location.**

**[4.2.3 Surface Water Existing Conditions]{.underline}**

Based on the local topography, the site drains towards the southeast,
towards a topographic low that eventually drains into the
Tchoutacabouffa River located to the south of the subject property.
There is one large pond on site, which also drains into the topographic
low.

**[4.2.4 Impacts to Surface Waters]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

The pond on site will remain intact and will not be filled. There are no
Wild and Scenic Rivers located on or adjacent to the site. There is the
potential for localized increase in sedimentation in local drainage
pathways during construction. Best management practices will be
developed and implemented, such as implementing an erosion and
sedimentation control plan using silt fences or hay bales to reduce
sedimentation. If fill is stored on site, the contractor will be
required to cover it appropriately.

The storm water drainage system will consists of both sheet and
sub-surface drainage. The system will be designed so that pre and post
storm water run-off will equal.

**There will be minimal impacts due to possible slightly increased
runoff to the Tchoutacabouffa River.**

**[4.3 Floodplains]{.underline}**

**[4.3.1 Floodplains Existing Conditions]{.underline}**

Executive Order (EO) 11988 (Floodplain Management) requires that a
Federal agency avoid direct or indirect support of development within
the 100-year floodplain whenever there is a practicable alternative.
FEMA uses Flood Insurance Rate Maps (FIRMs) to identify the regulatory
100-year floodplain for the National Flood Insurance Program (NFIP). The
site is located in Zone C which is not within a 100-year floodplain per
the FEMA Flood Insurance Rate Map Number 285255 0140E, dated August 4,
1988. The FIRM Map is located in Appendix A of this report.

The site is located in Zone C which is not within a 100-year floodplain
per the FEMA Flood Insurance Rate Map Number 285255 0140E, dated August
4, 1988.

**[4.3.2 Impacts to Floodplains]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

**No Impact**

**[4.4. Wetlands]{.underline}**

**[4.4.1 Wetlands Existing Conditions]{.underline}**

A wetland delineation was performed by Covington and Associates for the
43-acre site in April 2006, and is available under separate cover with
this report. The delineation recorded 0.862 acres of jurisdictional
wetlands, from four individual sites on the subject property. The
individual sites were 0.406, 0.14, 0.142, 0.174 acres respectively.

The CAC delineation found four wetland drainage patterns on the
perimeter of the subject property. Three of these features are
considered medium quality forest bayheads. They are essentially the
headwater drainage patterns which facilitate drainage off the subject
property and adjacent upland ridges. They are identified by species such
as Sweetbay magnolia (*Magnolia virginiana*), Laurel-leaf briar (*Smilax
laurifolia*), Southern Bayberry (*Myrica cerifera*) and bordered by
Gallberry (*Ilex glabra*).

**[4.4.2 Impacts to Wetlands]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

CAC is currently coordinating the necessary Joint Application and
Notification with the US Army Corps of Engineers, Mobile District,
Mississippi Department of Marine Resources (DMR), and Mississippi
Department of Environmental Quality (DEQ). At current, the project
proposes 0.72 acres of wetland impacts which is evaluated as an
Individual Permit. The project is consistent with the DMR Coastal Zone
Management Act by the nature of its size, impacts, and specific
location.

**[4.5 Biological Resources]{.underline}**

**[4.5.1 Biological Resources Existing Conditons]{.underline}**

The U.S. Fish and Wildlife Service lists 14 federally protected species
for Harrison County, Mississippi. However, further review of the list
shows that six of the species are directly related to the Mississippi
Sound, beach and associated riverine habitats. These six species are in
italics and are eliminated from further analysis.

Harrison County (source:
http://southeast.fws.gove/es/county%20lists.htm)

E -- Red-cockaded woodpecker [Picoides borealis]{.underline}

T -- Bald eagle [Haliaeetus leucophalus]{.underline}

T -- Eastern indigo snake [Drymarchon corais couperi]{.underline} (P)

E -- *Brown pelican [Pelecanus occidentalis]{.underline}*

T -- Gopher tortoise [Gopherus polyphemus]{.underline}

T -- Louisiana black bear [Ursus a. luteolus]{.underline}

T -- *Piping Plover [Charadrius melodus]{.underline}*

E -- *Kemp's ridley [Lepidochelys kempii]{.underline}*

T -- *Green turtle [Chelodania mydas (P)]{.underline}*

T -- *Loggerhead turtle [Caretta caretta]{.underline}*

T- *Gulf sturgeon, [Acipenser oxyrhynchus desotoi]{.underline}*

E -- Louisiana quillwort [Isoetes louisianensis]{.underline}

PE -- Mississippi gopher frog [(proposal under review)]{.underline}

C -- Black pine snake [Pituophis mealanoleucus]{.underline} ssp.
[Lodingi]{.underline}

The Threatened and Endangered Species survey was conducted on the
subject property on August 28, 2006. None of the listed species for
Harrison County were recorded during the survey. Concurrence from the
Mississippi Museum of Natural Science and U.S. Wildlife Service will be
provided in the final Environmental Assessment document. The Threatened
and Endangered Species survey report is available under separate cover
with this report.

**[4.5.2 Impacts to Biological Resources]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

**No Impact**

**[4.6 Air Quality]{.underline}**

**[4.6.1 Air Quality Existing Conditions]{.underline}**

Under the Clean Air Act, the U.S. Environmental Protection Agency (EPA)
establishes primary and secondary air quality standards. Primary air
quality standards protect the public health, including the health of
"sensitive populations, such as people with asthma, children, and older
adults." Secondary air quality standards protect public welfare by
promoting ecosystems health, preventing decreased visibility, and damage
to crops and buildings. EPA has set national ambient air quality
standards (NAAQS) for six of the following criteria pollutants; ozone
(0~3~), particulate matter (PM ~2.5\ and\ 10~), nitrogen dioxide
(NO~2~), carbon monoxide (CO), sulfur dioxide (SO~2~), and lead (Pb).
According to the MDEQ, the entire state of Mississippi is classified as
in attainment, meaning criteria air pollutants do not exceed the NAAQS.

**[4.6.2 Impacts to Air Quality]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

Increase in vehicle exhaust emissions and dust is anticipated during
construction. Federal and state air attainment levels would not be
exceeded. Best management practices would be developed and implemented
to cover and/or wet area soils during construction to minimize dust.
This project site is located in an attainment area.

**There will be negligible impacts to air quality.**

**[4.7 Traffic and Transportation]{.underline}**

**[4.7.1 Traffic and Transportation Existing Conditions]{.underline}**

The Mississippi Department of Transportation (MDOT) is responsible for
the design, construction and maintenance of the State of Mississippi's
Highway System as well as the portion of federal interstate highways
within Mississippi's boundaries. Arterials, connectors, rural roads, and
local roads are constructed and maintained by county or city
governments.

**[4.7.2 Impacts to Traffic Patterns]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

The project site is bordered by Lamey Bridge Road to the north and
Highway 67 to the south (currently under construction). Regional access
to the site is provided by Highway 67 and Highway 15. The project site
has frontage along the Highway 67 roadway project under construction,
which will connect Highway 49 with Interstate 110 with a limited access
four lane divided highway. The project site is not anticipated to have
direct driveway access to Highway 67. Therefore, a Traffic Analysis
Study was conducted by Neel-Schaffer (October 30, 2006), and was limited
to the site's two access driveways on Lamey Bridge Road, the
intersection of Lamey Bridge Road and Big John Road, and the future
intersection of Big John Road and Highway 67. A copy of the traffic
analysis is available under separate cover with this report.

Construction vehicles and equipment would be stored on-site during
project construction and appropriate signage would be posted on affected
roadways.

The public would access the proposed school's property from Lamey Bridge
Road, which is an east/west two lane roadway with approximately 60' of
right-of-way adjacent to the project site. The posted speed limit on
Lamey Bridge Road is 40 mph. Lamey Bridge Road has a current peak level
traffic count of 67 vehicles between 5:00-6:00 PM. South of the project
site, Lamey Bridge Road intersects with Highway 15 and continues south
into the City of D'Iberville. North of the project site, Lamey Bridge
Road curves south, intersects with Highway 67 (existing) and transitions
into Lorraine Road south into Biloxi and Gulfport.

Big John Road is a two-lane north/south roadway with a posted speed
limit of 30 mph. Big John Road extends north from Hudson-Krohn Road in
Biloxi and terminates at the intersection with Lamey Bridge Road. At the
completion of the Highway 67 roadway project, Big John Road will be
realigned to intersect the new highway at a ninety degree angle.

Highway 67 is a limited access four-lane divided highway that is
currently under construction. When completed in 2008, the roadway will
connect Interstate 110 in D'Iberville to U.S. Highway 49 in Saucier.
Access to the project site from Highway 67 will be limited to the access
provided by Lamey Bridge Road and Big John Road. Although the project
has frontage along the new highway, there is no direct access to Highway
67 from the project site.

Existing traffic volumes were counted at the study area intersection of
Lamey Bridge Road and Big John Road. Peak-hour turning movement counts
were conducted on October 4^th^ and 5^th^, 2006 to identify the existing
traffic volumes. The traffic counts revealed that within the project
area the a.m. peak hour is from 7:15 a.m. -- 8:15 a.m. and the p.m. peak
hour from 5:00 -- 6:00 p.m. The peak hour volumes were used in this
analysis to determine capacity and level of service at the study
intersections.

The traffic study concluded that:

> "Redevelopment of the project site with a new high school facility is
> impacted by the construction of the limited access Highway (67). The
> channelization of the site traffic to Big John Road and resulting
> operating speeds and volumes forecast on Highway 67 is shown to
> warrant installation of a traffic signal at the intersection of Big
> John Road with Highway 67. The operating characteristics of school
> buses being slower to accelerate to the high operating speeds
> anticipated on the Highway further reinforce the need for a traffic
> signal.
>
> The sections of roadways between Highway 67 with the site are
> recommended to be widened to three-lane sections to allow for left
> turn lanes entering the site and accessing the Highway. This includes
> widening both Big John Road and Lamey Bridge Road to accommodate the
> turning traffic accessing the project site.
>
> The widening of Lamey Bridge Road to three lanes is recommended to
> include maximizing the intersection sight distance at the west site
> driveway to meet the design requirement of 445 feet for a posted speed
> of 30 mph. The reduced posted speed is recommended to be signed with
> caution signs and flashing caution beacons, concurrent with the
> standard MUTCD school signing and striping."

**[4.8 Noise]{.underline}**

**[4.8.1 Noise Current Conditions]{.underline}**

Sound is most commonly measured in decibels (dB) on the A-weighted
scale, which is the scale most similar to the range of sounds that the
human ear can hear. The Day-Night Average Sound Level (DNL) is an
average measure of sound. The DNL descriptor is accepted by federal
agencies as a standard for estimating sound impacts and establishing
guidelines for compatible land uses.

Noise, defined herein as undesirable sound, is federally regulated by
the Noise Control Act of 1972 (NCA). Although the NCA gives the EPA
authority to prepare guidelines for acceptable ambient noise levels, it
only charges those federal agencies that operate noise-producing
facilities or equipment to implement noise standards. EPA guidelines,
and those of many other federal agencies, state that outdoor sound
levels in excess of 55 dB DNL are "normally unacceptable" for
noise-sensitive land uses such as residences, schools, or hospitals.

The proposed project site consists mainly of rural forested and
residential land. There are no noise-sensitive areas within a 4-mile
radius of the proposed project site. A noise ordinance does not exist
for Harrison County.

According to the Harrison County Zoning Department, there are currently
no noise laws, regulations, or ordinances in effect for the project
site. A county-wide noise ordinance is under consideration but has not
yet been approved.

**[4.8.2 Impacts to Noise Conditions]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

The impact of increased noise is considered to be TEMPORAL AND SPATIALLY
DISTRIBUTED AND minor IN NATURE.

Construction noise impacts would be short-term and limited to the
duration of construction activities. The vehicles from school use would
increase the level of vehicular noise in the area during school
transportation peak times in the morning and afternoon. There is no
noise ordinance in effect for the project location.

**[4.9 Cultural Resources and Historic Properties]{.underline}**

**[4.9.1 Cultural Resources and Historic Properties Current
Conditions]{.underline}**

A cultural resources survey has been completed for the project by Ms.
Rani A. Dormaier and Harriet L. Richardson Seacat, Center for
Archeological Studies, University of South Alabama. The field studies
were conducted during August 2006 and a final report was prepared on
August 17, 2006. This report is available under separate cover with this
report.

The investigation found evidence of one archeological site (22HR960)
with several surface features. The Scarborough Farm site is partially
intact but subsurface archeological deposits are not substantially rich.
The report concluded that the investigation served to document the
locally-interesting settlement, but that the site is not eligible for
listing on the National Register of Historic Places.

A letter of concurrence from the Mississippi Department of Archives and
History dated February 5, 2007 indicates that no cultural resources will
be impacted.

**[4.9.2 Impacts to Cultural Resources and Historic
Properties]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

**No Impact**

**[4.10 Socio-economics]{.underline}**

**[4.10.1 Socio-economic Current Conditions]{.underline}**

EO12898 is the Executive Order 12898 Environmental Justice in Minority
Populations. This requires federal agencies, departments, and often
their contractors to consider any potentially disproportionate human
health or environmental risks their activities, policies, or programs
may pose to minority or low-income populations.

[]{.mark}

EO 13045 (Protection of Children from Environmental Health Risks and
Safety Risks) required federal agencies to identify and assess health
risks and safety risks that may disproportionately affect children. As
with EO 12898, FEMA and most federal lead agencies determine impacts to
children as part of the NEPA compliance process. Agencies must ensure
that its policies, programs, activities, and standards address
disproportionate risks to children that results from environmental
health risks or safety risks.

Based on U.S. Census Bureau information for the year 2000, the percent
populations of zip code 39540 (which is the zip code for the destroyed
D'Iberville Middle School) are 74.7% White, 12.1% Black or African
American, 4.3% Asian, 14.5% Hispanic or Latino, and 0.8% American Indian
or Alaska Native. The median household income (in 2005 adjusted dollars)
for the area is \$46,242 and 10.2 % of families are below the poverty
level.

For the zip code 39532 (the zip code including the new proposed
D'Iberville High School) the percent populations are 85.8% White, 7.2%
Black or African American, 4.3% Asian, 2.2% Hispanic or Latino, and 0.4%
American Indian or Alaska Native. The median household income (in 1999
dollars) for the area is \$41,411 and 7.1 % of families are below the
poverty level. The median household income (in 1999 adjusted dollars)
for the area is \$46,472 and 9.3 % of families are below the poverty
level. []{.mark}

**[4.10.2 Socio-economics Impacts]{.underline}**

*Alternative 1-No Action Alternative*:

Although there is no requirement for compliance with EOs 12898 and 1304
when there are no federal actions, **low-income and minority families
and children would be adversely affected if the new school were not
constructed,** due to insufficient permanent educational facilities as
well as lack of the new 361 shelter facility that the school would
provide in the event of a natural disaster.

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action)*

**The proposed action will** **benefit the community** by providing the
middle school students with permanent educational facilities to replace
temporary trailers, and by providing high school students with a new
state-of-the art educational facility in a secure location. The
construction of the new D'Iberville High School Facility will be
designed in accordance of the "FEMA 361 Design and Construction Guidance
for Community Shelters" document. The facility, inclusive of these
requirements will consist of 54,695 square feet of hardened construction
designed to resist 200 mph wind speeds. By FEMA guidelines of 20 square
feet per person, this facility will benefit all citizens of east
Harrison County by safely housing 2,735 occupants during the event of a
natural disaster. The FEMA 361 Shelter requirements also call for the
inclusion of a hardened generator area and provisions for back-up for
water and sewer utilities. Low-income and minority citizens would be the
least likely to successfully implement a long-distance evacuation plan
to another state and therefore would benefit from the construction of a
FEMA 361 community shelter at this location.

[]{.mark}

**[4.11 Hazardous Materials]{.underline}**

**[4.11.1 Hazardous Materials Current Conditions]{.underline}**

CERCLA (commonly referred to as Superfund) is the Comprehensive
Environmental Response, Compensation, and Liability Act. It requires
community relations components during the assessment of hazardous
substances at inactive waste sites. Key communication pieces include a
community relations plan, public access to the complete administrative
record, an information repository, and advertisement of public
involvement opportunities. Health and ecological impact may be
determined requiring worker and public notification. Emergency removal
actions may be required.

RCRA is the Resource Conservation and Recovery Act, which establishes
regulatory standards for the generation, transportation, storage,
treatment, and disposal of hazardous wastes. In regulatory terms, a RCRA
hazardous waste is a waste that appears on one of the four hazardous
wastes lists (F-list, K-list, P-list, or U-list), or exhibits at least
one of four characteristics---ignitability, corrosivity, reactivity, or
toxicity. Hazardous waste is regulated under the Resource Conservation
and Recovery Act (RCRA) Subtitle C.

Hazardous material means as any material that, because of its quantity,
concentration, or physical and chemical characteristics, poses a
significant present or potential hazard to human health and safety or to
the environment if released into the workplace or environment.

A Phase I Environmental Site Assessment (ESA) was conducted by Covington
and Associates in April 2006, and the assessment has revealed no
evidence of *recognized environmental conditions* on the subject
property. The ESA included a site visit and regulatory database search,
conducted by EDR. This ESA did not indicate that the site was a CERCLA
site or a RCRA site, nor the presence of hazardous or toxic materials or
wastes on the subject property. The Phase 1 ESA report is available
under separate cover with this report.

A sanitary landfill (Ollie Lamey Sanitary Landfill) operated across
Lamey Bridge Road to the north of the site from 1978 until 1990. A file
for the landfill is located at the MDEQ offices in Jackson, Mississippi.
The file was reviewed to gain information concerning the history of the
landfill and the potential for impact to the proposed school site.

Prior to the Mississippi Department of Health issuing a permit for the
landfill, a test hole was drilled on the landfill property in 1976 to
determine site suitability. Clay was encountered to a depth of 27 feet
below ground surface, and Mr. Ollie Lamey stated that all former borrow
pits on the property were terminated in clay.

The file contains extensive documentation of site visits to the site by
regulatory officials, and the problems noted included odor, flies, and
lack of adequate cover. Wastes were reported to consist of household
garbage. There was no documentation in the file of improper wastes (such
as hazardous wastes) being deposited at the Ollie Lamey Sanitary
Landfill. Most site visits reports indicated no incidents of leachate
leaving the landfill property, but when noted, leachate was documented
as flowing into the wooded area to the north of the landfill site.

From 1990 until the landfill closed in June, 1991, allowed wastes were
restricted to rubbish only. A MDEQ memorandum dated November 9, 1992
documented that the site continued to be maintained in an adequate
condition, with no exposed waste, no illegal dumping problems and no
leachate streams noted. The former presence of the landfill is not
expected to have negative impacts to the proposed school site due to the
nature of the wastes reported (household garbage), the presence of a
27-foot (minimum) clay confining unit at the landfill site, and the
location of the landfill in a topographically downgradient location
relative to the proposed school site.

In order to preliminarily assess the quality of the potable aquifer at
the proposed school site, and to ensure that it has not been adversely
affected by the nearby former Ollie Lamey Sanitary Landfill, the
existing well on the proposed school site was sampled on December 11,
2006 as part of this investigation. The groundwater samples were
submitted to Environmental Science Corporation (ESC) Laboratories in Mt.
Juliet, Tennessee and were analyzed for the following parameters:
volatile organic compounds by Method 8260, semivolatile organic
compounds by Method 8270 and 8310; RCRA metals by methods 7470A and
6010B; pesticides by Method 8081A; herbicides by Method 8151; chloride
and sulfate by Method 9056; and phosphate, ortho (soluble) by Method
4500P-E. A groundwater sample from the Lynam well was also submitted to
the Mississippi Department of Health for analysis of total coliform
bacteria by Method SM9223 20^th^ edition.

Due to detections of trace levels of several herbicides, the herbicides
analysis was re-run by ESC a second time. None of the detected analytes
exceed the National Primary Drinking Water Standards established by the
Environmental Protection Agency. The total coliform bacteria analysis
run by the Mississippi Department of Health laboratory indicated Total
Coliform Absent (\<1/100 ml). The laboratory analytical data are
available under separate cover with this report.

**[4.11.2 Impacts from Hazardous Materials]{.underline}**

*Alternative 1-No Action Alternative:*

**No Impact**

*Alternative 2 -- Construct the new D'Iberville High School (Proposed
Action):*

There will be **No Impact** from the proposed action with respect to the
presence of hazardous materials and potential exposure, because no
hazardous or toxic materials or wastes have been identified at the site
location.

**[5.0 Agency Coordination and Permits]{.underline}**

All necessary permits and coordination with governing agencies will be
the responsibility of Guild-Hardy and/or the contractor selected for
site construction. All construction and required regulatory permits will
be maintained and posted at a kiosk at the construction site.

Building permits will be obtained from the Harrison County Code Office,
and permits to fill wetlands will be obtained from the U.S. Army Corps
of Engineers. An N.P.D.E.S. storm water discharge permit will be
obtained from the Mississippi Department of Environmental Quality.

The following agencies and organizations were contacted during the
preparation of this EA. Letters received to date are included in the
Appendix B.

Federal

-   U.S. Army Corps of Engineers, Mobile District, Regulatory Division
    will be contacted through joint application and notification to be
    submitted in January 2007, in accordance with Section 404 of the
    Clean Water Act.

-   U.S. Environmental Protection Agency, Region 4, Water Management
    Division will be contacted through the Corps joint application
    process to be submitted in January 2007, in accordance with Section
    404 of the Clean Water Act.

-   U.S. Fish and Wildlife Service, Jackson Field Office through the
    Corps joint application process to be submitted in January 2007, in
    accordance with Section 404 of the Clean Water Act.

> State

-   Mississippi Department of Archives and History report sent by
    University of South Alabama. Currently awaiting letter of
    concurrence.

-   Mississippi Department of Environmental Quality, Office of Pollution
    Control, Environmental Permits Division will be contacted through
    joint application and notification to be submitted in January 2007,
    in accordance with Section 404 of the Clean Water Act.

-   Mississippi Department of Marine Resources, Bureau of Wetlands
    Permitting will be contacted through joint application and
    notification to be submitted in January 2007, in accordance with
    Section 404 of the Clean Water Act.

-   Mississippi Department of Transportation, Environmental Division was
    contacted during the traffic study conducted by Neil Schaffer in
    October 2006.

In accordance with applicable local, state, and federal regulations, the
applicant would be responsible for acquiring any necessary permits prior
to commencing construction at the proposed project site.

**[6.0 Public Involvement]{.underline}**

The proposed project was discussed during regularly scheduled Harrison
County School District Board of Education meetings held on the following
dates: July 31, 2006; August 21, 2006; September 18, 2006; October 2,
2006; October 23, 2006; and December 4, 2006.

The proposed action will be publicized during a fifteen-day public
comment period. If no substantive comments are received, the Draft EA
will become final and this initial Public Notice will also serve as the
final Public Notice.

If no substantive comments are received, 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.

**[7.0 References]{.underline}**

**[www.apgea.army.mil/risk/PDF/LawReg.pdf]{.underline}**

**D'Iberville City Hall, personal interview regarding growth trends in
the area with Mr. Richard Rose, City Manager, on January 3, 2007.**

**Environmental Data Resources (EDR), Inc. 2006. EDR Report Number
1649199.2s (dated April 5, 2006)**

**[http:// www.epa.gov/safewater accessed 1/19/07]{.underline}**

**Geologic Map of Mississippi, Alvin R. Bicker, Jr., 1969**

**Harrison County E-911 Addressing, correspondence regarding flood zone
determination per Flood Insurance Rate Map 285255 0140E, dated 8/4/88,
date of request 12/13/2006.**

**Mississippi Department of Environmental Quality (MDEQ), Solid Waste
Files, Ollie Lamey Sanitary Landfill file, reviewed in person on
1/5/2007.**

**Mississippi Department of Health, Water Supply Division, personal
interview with Mr. Greg Caraway, Environmental Engineer on January 19,
2007.**

**Natural Resource Conservation Service (Gulfport Service Center),
personal interview with T. Harrington, District Conservationist**

**U.S. Census Bureau, http://factfinder.census.gov/servlet/SAFFFacts?-
Accessed 11/8/06.**

**U.S.Fish and Wildlife Service (USFWS). 2006.**

**[http://www.fws.gov/southeast/jackson/MsCo_TE.html]{.underline}.
Accessed 10/11/06.**

**U.S. Geological Survey (USGS). 2006.** *Ground Water Atlas of the
United States, Arkansas, Louisiana, Mississippi HA 730-F.*
**<http://capp.water.usgs.gov/gwa/ch_f/F-text3.html>. Accessed
12/15/06.**

**<http://websoilsurvey.nrcs.usda.gov/app/>. Accessed 4/20/2006**

**USGS. 2006c. <http://quake.wr.usgs.gov/prepare/factsheets/NewMadrid/>.
Accessed 12/4/06.**

**USGS 7.5-Minute Topographic Quadrangle Map for "White Plains, Miss."
(1992), reviewed April 21, 2006.**

**Appendix A**

**Site Location Map, Boundary Survey, Aerial Photograph, Proposed Site
Plan, Topographic Map, FEMA Map**

**Appendix B**

**Regulatory Agency Letters**