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 Longhorn Motocross 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 Longhorn Motocross Site with Mobile Homes/Park Models (Proposed Action) F. Additional Impact Analysis Socioeconomics Environmental Justice Hazardous Materials and Wastes G. Cumulative Impacts H. Public Involvement List of Figures Figure 1. Area Map showing location of Project Site Figure 2. Location Map on Aerial Photo Figure 3. Photograph of Project Site from Bancroft Rd. Figure 4. Site Layout from PBS&J Appendices Appendix A - Record of Environmental Consideration Appendix B - GeoSearch Radius Report With Geoplus Draft Environmental Assessment Longhorn Motocross Temporary Community Housing Site Orange, Orange County 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 13, 2008. Maximum sustained winds at landfall were estimated at 110 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 (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 DEA is to analyze potential environmental impacts of the proposed temporary community housing site at Longhorn Motocross, as part of an expedited review process. 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 Orange 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. To date, about 26,709 requests for federal assistance have been received for Orange County and of these requests, approximately 5,283 (total Pre-Placement Interviews) are for temporary housing assistance (FEMA Individual Assistance Program Summary Report 11/11/08). The estimated number of applications for direct housing assistance, provision of a manufactured housing unit on an available private, commercial park or community site location, is 1,555 for Orange County (FEMA Individual Assistance Program Manufactured Housing Activity Report 11/11/08). 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 many 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 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 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 private or 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 Orange County.  Although various alternatives have been and continue to be identified, the amount of needed housing has limited this Draft EA to analysis of one suitable site alternative at this time. The Longhorn Motocross site was selected for further detailed 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 Longhorn Motocross Site with Mobile Homes/Park Models (Proposed Action) The Proposed Action would provide temporary housing for eligible disaster victims displaced by Hurricane Ike in the greater Orange area. Disaster victims would be temporarily relocated to the site with an expected occupancy up to 24 months (which includes a site deactivation period) while they resolve their permanent housing solution Project Location and Site Description The proposed site is located off of Bancroft Road in the City of Orange in Orange County, Texas (see Figure 1 Area Map). It is bordered on the north and west by Bancroft Road and a lightly developed residential area, on the west by pasture land, on the south by a large pond and motocross track located along IH-10 (see Figure 2 Location Map). The site consists of 25 acres of pasture land with Coastal Bermuda, King Ranch Bluestem, Johnson Grass, Little Bluestem, Croton and Giant Ragweed (Figure 3 Site Photo). Approximately 1/4 of the site is being taken over by 3-5 feet tall Chinese Tallow Trees. An unnamed tributary to Adams Bayou is located in the northeast corner of the project site and is characterized as a jurisdictional stream by the US Army Corps of Engineers – Galveston District Regulatory Office. The creek covers approximately .55 acres of the property. This tributary will be avoided in the design and construction of the site and a vegetated 30 ft. buffer will be maintained from the normal high water mark of the stream. Project Description. The project description is based on the site preliminary design completed on November 12, 2008 by Post, Buckley, Schue, & Jernigan (Figure 4 Preliminary Site Layout). The proposed action would involve the construction of a mobile home community site (hereafter “community site”) which would accommodate approximately 100 units. In a letter dated November 10 , 2008, the Orange County Judge 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 clearing, grading, and removal of woody vegetation with the exception of the large trees along the creek which will be avoided. * Electrical services would be below ground and connected to existing utilities from Bancroft Road. * Potable water will be connected below ground to a water main located at the intersection of Sykes Road and Bancroft Road. 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 at the intersection of Sykes Road and Bancroft Road. * Access to the Park is planned from Bancroft Road. * Stormwater drainage will be accommodated by grading site to drain through roadside ditches and driveway culverts to a series of collection points located to the south end of the property. The runoff would then be collected and routed underground to the existing borrow pit to the south for peak flow attenuation. * Interior roadways and pads would be constructed of asphalt paving. * Site Uniform Federal Accessibility Standard (UFAS) features include 15% of the units meeting UFAS, and 15% of common areas and 100% of onsite essential services/facilities (such as mailbox kiosk) would be UFAS compatible. * The site will also have designated green space amongst the common areas. FEMA will operate and maintain the site during the term of occupancy. When the temporary housing need has ended, FEMA expects that the mobile homes would be hauled from the site and returned to a storage facility. The project site would then be seeded and reasonably restored to its previous conditions or per the lease terms with the landowner. 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 Longhorn Motocross Site with Mobile Homes/Park Models (Proposed Action) The Proposed Action would provide temporary housing for eligible disaster victims displaced by Hurricane Ike in Orange County, Texas. Disaster victims would be temporarily relocated to the 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 - The project site is in a developed urbanized area in the city limits of Orange, thus there are no prime and unique farmlands. There is 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 - Negligable Impact Summary - Project area is located in Zone C, outside of the 500-year floodplain per the FEMA Flood Insurance Rate Map for Orange County, Firm Panel # 480510-0075C. The nearest floodplain is located across Bancroft Road to the north. Site development and occupancy is not expected to affect nearby floodplains or local hydrology. Agency Coordination/Permits - None. Mitigation - None. Wetlands (Executive Order 11990) Impact Intensity - Negligable Impact Summary - On site wetlands were observed and are characterized as a jurisdictional. The creek covers approximately .55 acres of the property. This tributary will be avoided in the design and construction of the site. The open pasture area of the site is poorly drained with several low spots that hold water after rain events, however these areas would not be considered wetlands. Agency Coordination/Permits - US Army Corps of Engineers Galveston District. Mitigation - Avoidance and protection of wetland area with 30 ft. vegetative buffer from the normal high water mark of the stream. Coastal Zone Management Impact Intensity - Negligable Impact Summary - Project site is not located within the boundaries of the Coastal Zone. No impacts to the Texas Coastal Zone are anticipated. Agency Coordination/Permits - None. 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 - NPDES permits to be obtained by construction contractor. Mitigation - Contractor to implement requirements of NPDES 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 - Orange 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 consists mainly of a mixed grass field with Coastal Bermuda, King Ranch Bluestem, Johnson Grass, Little Bluestem, Croton and Giant Ragweed. Approximately 1/3 of the site is being taken over by 3-5 feet tall Chinese Tallow Trees. A creek runs along the northeast corner of the property and is surrounded by large Oak, Elm and Chinese Tallow trees. Wildlife identified during the site visit included Eastern Cottontail, Mourning Dove, Blue Jay and Turkey Vulture. 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. 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 - USFWS coordination 11/4/2008. Mitigation - None. Cultural Resources (National Historic Preservation Act, Section 106) Impact Intensity - Negligable Impact Summary - Through site pedestrian survey and review of the Texas Historical Commission’s Atlas database, FEMA has determined that there are no National Register listed or eligible historic properties in the Area of Potential Effect (APE). Agency Coordination/Permits - SHPO concurrence letter November 5, 2008. Mitigation - None. Socioeconomics. Impact Intensity - Negligable Impact Summary - Site occupancy is expected to be up to about 250 people [100 units x estimated 2.5 people per unit] maximum. It is expected the site residents are currently displaced residents of Orange County. See Section F. Agency Coordination/Permits - On November 10, 2008 the Orange County Judge issued a formal letter of no objection for the establishment of the 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 excessive noise sources; such as airports, railroads, and major highways; in close proximity to the proposed site. 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. The area is located in a lightly developed residential neighborhood and impact to the surrounding neighborhood from noise will be negligible. 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 7:00 a.m. to 7:00 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. Visual Resources Impact Intensity - Negligable Impact Summary - The proposed action would result in temporary conversion of a 25-acre field to a community housing site. The property is already zoned for residential use, but has been used in the past for cattle grazing. The proposed use of the site is consistent with surrounding land uses and local development plans. Upon de-activation of the site, it is anticipated that the area will be returned to its original condition Agency Coordination/Permits - None. Mitigation - None. 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 activities and traffic pattern changes. The contractor would provide 24-hour security during construction 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. There were no environmental conditions of concern identified. See Section F. Agency Coordination/Permits - Geo-Search report, job # 315, completed 28-October-2008 which searched 61 Federal, State and Tribal Databases. Pipeline Report from Texas Railroad Commission Website. 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. Additional Impact Analysis Socioeconomics The project site is located in the 77632 zip code of Orange County. According to the 2000 Census, zip code 77632 had 21,694 residents, and 8598 housing units. The median household income was estimated at about $48,520 (based on 1999 dollars) (Census 2000). The primary employment sectors were educational, health, and social services; manufacturing; retail trade; and construction. According to the 2000 census, about 3.4 percent of the zip code’s civilian labor force is unemployed. With the establishment of the site, up to approximately 250 residents could be temporarily relocating to the Orange, Grove City area (100 units x estimated 2.5 people per unit), most of the potential site residents will be from the area. The local community is aware of this action and may experience a slight localized increase in the need for public services, such as schools, fire and police services, child care, and medical services. However, the overall 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 77632 zip code is comprised of about 3.4 percent African American, 93.6 percent Caucasian, and approximately 9.6 percent of the families are living below the poverty level. In comparison to Orange County and Texas, the zip code has a lower percentage of families below the poverty level, a lower percentage of African American residents and a lower percentage other minorities (Table 2) (Census 2000). Table 2: Minority and Low Income Populations Summary Statistics (%) Demographics (percent). Caucasian: City - 90.4; County - 88; Texas - 71. African American: City - 0.3; County - 8.4; Texas - 11.5 Hispanic (of any race): City - 50.3; County - 3.6; State - 32. Families below poverty: City - 13.6; County - 11.4; Texas - 12.0 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. Geo-Search report, job # 315, completed on October 28, 2008; identified one leaking underground storage tank .45 miles southeast of the project site that was removed in 1994. The Geo-Search report also identified a Resource Conservation and Recovery Act corrective action at a business located .80 miles to the southwest of the project site, although no enforcement actions have been reported there since 2001. Because of the distance of these locations to the project site, there are no health and safety concerns to future site residents. No environmental conditions; such as distressed vegetation and historical soil contamination were observed during field reconnaissance. Accordingly, no on-site soil sampling was deemed necessary. At the southern edge of the project site is a 30 ft. wide pipeline easement that contains one 12’ nitrogen pipeline owned by Air Liquide America Corporation and two 10” high pressure ethelyne pipelines owned by Union Carbide (Dow Chemical). These pipelines are four to five feet below ground and thus pose no health and safety concerns to future site residents. Both the site’s sewer and water lines, which will be tied into existing utility lines along Sykes Road will have to cross the easement to reach the project site. 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 the Orange Leader and the Port Arthur News beginning on November 13, 2008. Due to the emergency nature of this action, the public comment period will be brief, from November 13 to November 15, 2008. Written comments on the DEA and Draft Finding of No Significant Impact (FONSI) can be faxed to FEMA’s Joint Field Office in Austin at (512) 465-3764. Verbal comments are being accepted at (866) 568-1260, and TTY for hearing or speech-impaired at (800) 462-7585; between 8:00 A.M. and 5:00 P.M. The Draft DEA and FONSI are available for public review at the FEMA Disaster Recovery Center (DRC) located at 3727 N. 16th St, Orange, TX 77632, and Orange Public Library, 220 5th St, Orange, TX 77630. The DRC hours are Monday to Saturday 9 a.m. to 5:30 p.m., and the Orange Public Library hours are Monday, Wednesday, Thursday, and Friday, 10 a.m. to 5 p.m.; Tuesday 10 a.m. to 8 p.m.; Saturday 10 a.m. to 2 p.m. The DEA and FONSI are also available for viewing and download from FEMA’s website at http://www.fema.gov/plan/ehp/envdocuments/ea-region6.shtm. Figure 1. Area Map from Map Quest Showing Major Roads and Streets in Project Area Figure 2. Location Map on Aerial Photo Figure 2. Location Map on Aerial Photo Figure 3. Photo of Project Site from Bancroft Road Figure 4. Site Layout from PBS&J FEMA-1791-DR-TX 28 Draft Environmental Assessment Longhorn Motocross Site