FEDERAL CONSISTENCY DETERMINATION REQUEST TABOR & HARMONY HEAD START & EARLY HEAD START 14-2 East End, Annas Retreat, East End QTR, St. Thomas, U.S. Virgin Islands USVI DEPARTMENT OF HUMAN SERVICES HEAD START & EARLY HEAD START PROGRAM ST. THOMAS, US VIRGIN ISLANDS Prepared by: CPH, Inc. 950 Ponce de Leon Avenue San Juan, PR 00907 JUNE 2022 2 INTRODUCTION The US Virgin Islands Department of Human Services is proposing the demolition of an existing two-story structure to construct a new head start facility. The existing structure is approximately 1,904 square feet. The existing structure was severely damaged by Hurricane Irma in September 2017. The storm produced strong destructive winds, power outages, down power lines, structure and property damage and fallen trees. The structure is currently abandoned. The existing building was constructed 40+ years prior to the major hurricanes in the late 80’s from Hurricane Hugo to the more recent hurricanes, Irma and Maria. Since the time of Hurricane Hugo in 1989, the Virgin Islands has adopted, first the Uniform Building Code for structures, and more recently, the International Building Code (IBC). The existing building will be rebuilt per IBC code requirements to accommodate the program requirements for a functional facility. PROJECT LOCATION This project area comprises 0.60 acres track of land owned by the Government of the V.I. and is located at 14-2 East End, Annas Retreat, St. Thomas, U.S. Virgin Islands. The property ID# is 103104041100. Figure 1: USVI GIS online MapGeo 3 The property is limited: to the North by Mandal Road and 14-1 Annas Retreat New QTS owned by Elliott, Cecil S. & Roselyne E (CO-Trustees) with property ID# 103104042500; to the South by 14- 6 Annas Retreat New QTRS owned by Pinney, David A, & Pearline D with Property ID# 105602010500; to the East by 14-7 Annas Retreat New Quarters owned by Sylvia Williams with Property ID# 103203015700; and to the West by a road. Project GPS coordinates are: latitude 18.348540 / longitude -64.883235. Figure 2: Site Location – USGS Charlotte Amalie VI Quadrangle - Topo Map 4 SITE DESCRIPTION GENERAL The site is mostly developed and occupied by a two-story structure, concrete floor outside concrete pads and a septic tank. The site has no parking spaces. This building is constructed of 8” concrete masonry unit (CMU) walls with corrugated galvanized roofs and reinforced concrete floors. The property is currently abandoned. Figure 3: Existing Conditions Survey of Site 5 PHOTOS Photo 1: Front View Photo 2: Rear Corner View (North to South) 6 ENVIRONMENTAL IMPACTS TOPOGRAPHY AND DRAINAGE PATTERNS The existing topographic contours range from approximately 485 feet MSL at the south western limit of the property to 435 along the northern limit. Roughly, the property drains topographically from the south toward the north into Mandal Road which drain toward the east through sheet flow condition. There is no public storm sewer system available in the area. SOILS According to the USDA online Soil Survey, soils within the project area are classified as Fredriksdal-Susannaberg complex, 40-60 percent slopes, extremely stony (FsF). The Fredriksdal-Susannaberg complex consists of extremely stony, well drained, slow permeable soils on summits and side slopes of volcanic hills and mountains. According to the USDA – Natural Resources Conservation Service, these soils are not considered as hydric, nor has hydric inclusions. Figure 4: USDA Soil Survey Map 7 FLOOD ZONES According to Panel 0013 of the US Virgin Islands Advisory Base Flood Elevation Maps, the project area is not located within flood zones. Finished floor elevation for the proposed building is 482 feet. Figure 5. FEMA Flood Advisory Map COASTAL FLOODPLAIN, OCEANOGRAPHY AND MARINE RESOURCES The project is located approximately 0.324 miles (1,710 feet) south inland away from Sunsi Bay in the northern coast of St. Thomas. No impacts are anticipated to the marine environment or from sea storm events. COASTAL BARRIERS According to the USFWS IPaC (Information for Planning and Consultation) webtool, there are no coastal barriers at this location FRESH WATER RESOURCES There are no freshwater resources on or in the vicinity of this property. 8 TERRESTRIAL RESOURCES The project area comprises a complete developed track covered mainly by opportunistic vegetation that has grown in the area since it was abandoned and remains of former landscaping. The northeastern part of the property is a steep slope that wasn’t developed before and might include more typical vegetation of the islands. This slope will be impacted and will be part of the proposed project. WETLANDS According to the National Wetlands Inventory Maps, published by the US Fish and Wildlife Service, the project area is not affected by Wetlands. Figure 6: National Wetlands Inventory Maps RARE AND ENDANGERED SPECIES According to IPaC the project area is located within the endangered Virgin Islands Tree Boa (Chilabothrus granti) range. According to the USFWS General Project Design Guidelines for this species, the following conservation measures are to be follow; Conservation Measures for the USVI: 1. Contact Government of the Virgin Islands, Department of Planning and Natural Resources, Division of Fish and Wildlife (DFW) at (340) 775-6762, for consultation. 2. DFW will come out for an on-site discussion. They will need a copy of your building plans or a narrative of your intended project. DFW will coordinate via email so that all developers, owners, contractors, and other agencies, can follow along and provide input. 9 3. DFW will conduct a short VI boa training session for all individuals conducting hand clearing. This will involve discussions on what to do if a boa is encountered as well as boa identification. This can be done any time prior to hand clearing but is often preformed the first day on site. Photographs of the VI boa are to be prominently displayed at the site. 4. At least 5 days prior to the use of heavy equipment on the site, the site vegetation may be cut by hand. Any stone walls or naturally occurring rock piles must be carefully dismantled by hand as these are refuges for the snake. This will allow any boas present to vacate the site without injury. 5. Only hand clearing of vegetation is to be performed. This allows the use of chainsaws cutting vegetation down to less than 36 inches off the ground. 6. If a VI boa is found within any of the working or construction areas, activities should stop at the area where the VI boa is found. If boas need to be captured immediately to continue work and avoid harming the boa during the project activities, designated personnel shall immediately contact the DFW for safe capture and relocation 7. DFW should be notified of any snakes observed. 8. Another site visit will be performed by DFW to confirm that hand clearing has been completed to our standards. The waiting period clock starts after inspection. 9. The site is to be left undisturbed for 5 days prior to the use of heavy machinery. However manual work may continue to be performed during this time and any vegetation may be moved by hand. 10. Use of heavy equipment is only permitted to start after the agreed upon date The project site is not affected by natural wildlife refuge lands or fish hatcheries at this location. There are no migratory birds of special concern expected to occur at this location. AIR QUALITY All of the U.S. Virgin Islands is designated Class II by the Environmental Protection Agency, in compliance with National Ambient Air Quality Standards. In Class II air quality regions, the following air pollutants are regulated: open burning, visible air contaminants, particulate matter emissions, volatile petroleum products, sulfur compounds, and internal combustion engine exhaust (Virgin Islands Code Rules and Regulations). It is expected that excavation equipment will be used during project construction and will create combustion engine exhaust during on site use. Air quality will return to pre-construction conditions upon the completion of the construction process An emergency stand-by generator that meets EPA clean air standards is proposed for this project. All permit applications will be filled for this equipment at the appropriate time prior to installation. 10 PROPOSED PROJECT DESCRIPTION The proposed project comprises the demolition of the existing structure and the construction of the new facilities. The proposed design proposes one structure with approximate construction area of 35,300 square feet area. The design incorporates 7 parking spaces including 1 for handicap. Project will include emergency electric generator, potable water cistern and small waste water treatment plant. The new facility’s structure is designed to be resistant as required by updated design criteria for hurricanes and other seismic activity. The structure will consist of poured concrete walls and roofs. The entire project is designed to resist up to 180 mph wind forces per current code requirements which is equivalent to a Category 5 hurricane and higher. Figure 7: Proposed Master Site Plan 11 IMPACT ON MAN’S ENVIRONMENT VISUAL IMPACTS The proposed Head Start Facility will be a visual improvement over the existing severely damaged and abandoned facility it is replacing. The new design considered the V.I. Architecture and includes sloped concrete roofs and walls, impact resistant windows and doors for resisting hurricane and seismic forces. The buildings will be insulated per the new building code standards at the roof and walls. The metal roofs will provide long lasting weather protection. The high efficiency plumbing, HVAC and light fixtures will provide savings in water and electricity consumption. The interior finishes will include recycled and low VOC materials. Thus, the buildings will be less burden to environment meanwhile providing better setting for its occupants. Figure 8: Aerial View Rendering 12 Figure 9: Eye level View Rendering LAND AND WATER USE PLANS The project parcel is zoned R-1 which complies with current Coastal Land and Water Use Plan and meets use requirements for the zoning district as set forth in Title 29 of the Virgin Islands Code. Project needs a variance for proposed setbacks for proposed structure and accessory uses. HISTORICAL AND ARCHAEOLOGICAL RESOURCES The proposed project comprises a completely developed track of land with no known archaeological relevance. The property is not within any declared historical zones. There is also no documentation in regards to historical ruins found at or near the site. Standard procedures will be used if any items of Archaeological relevance are observed during the excavation activities on the site. WASTE DISPOSAL AND ACCIDENTAL SPILLS The Virgin Islands Waste Management Authority has specific guidelines and criteria for accepting construction debris. Demolition waste will be disposed of in accordance with all governing laws and regulations. Any excess excavated material will be collected, taken off- site and properly disposed of. An assessment was conducted by GEC Corp. and all Asbestos and Lead testing results will be submitted to DPNR. An abatement plan will be submitted to the Virgin Islands Waste Management Authority (VIWMA) prior to the commencement of demolition work. 13 The handling and disposal of any hazardous materials, such as the used oil from the motor pool area, and the fuel from existing generator fuel storage will be done in strict accordance with all governing laws and regulations. The equipment will be kept in good operational condition during the proposed project timeline and refueling on site will be kept to a minimum. EROSION AND SEDIMENTATION CONTROL PLANS Sedimentation and erosion controls will be implemented to ensure rainfall will not impact the adjacent properties and streets during construction. This will include silt fencing, gravel entrances, at the entry gate, and check dams. GRADING AND STORMWATER MANAGEMENT Proposed site will be improved by means of earthwork, that includes cut on existing slope, deposit of fill material and grading activities. Pre and post drainage condition will be evaluated and an internal storm sewer system will be designed as the project site has no existing public storm sewer system available. This internal drainage system will be connected to an open detention area which will be included as part of final design. Preliminarily, this open detention area will be located along the northeastern green area. stabilized with rock with an outfall that will allow storm water to sheet flow on to the lowest point of the site and maintain its existing drainage path. To reduce site runoff due to reduction in pervious areas, the open retention area will be sized to manage the increased potential for stormwater runoff. Additionally, all parking areas will be designed with pervious concrete to mitigate any additional increase of runoff. Any difference will be managed through the proposed open retention and green areas. No stormwater runoff from the road is expected as the site is above the roadway elevation. As such, the proposed design will allow for the existing flow to follow its existing drainage path. 14 UTILITIES ELECTRIC POWER The project site has a connection to WAPA system with a 120/240V at 100A electrical meter. The project required electrical load has been determined to be150kva. An electrical emergency generator with a capacity of 120 kw is also being proposed. A consultation with Virgin Islands Water and Power Authority (WAPA) will be conducted, to determine requirements to connect the project to existing electrical system. WATER There is no public water supply available at the project site. The proposed project design makes use of water harvesting by means of collecting roof runoff into a cistern. Cistern will have a pump system and UV system to treat water for human consumption. A water demand of 2,400 gallons per day have been determined for the specific use. Potable water cistern will be provided with additional storage capacity, to be determined in coordination with the Head Start Program. A water cistern of 60,000+ gallons with a UV-Light, filtration and pumps system for potable use has been estimated since the project is for non-residential use. WASTE WATER - SEWAGE Public Sewer is not available at the site. The sewer water discharge has been determined 1,920 gallons per day and will be managed by the installation of a small waste water treatment (WWTP) plant on site. The treated effluent will then be utilized to irrigate the project’s vegetated areas due to the area’s dry nature. An approved maintenance plan will be provided as specified by the WWTP’s manufacturer to ensure it is run within the required parameters when in operation. 15 FEDERAL CONSISTENCY DETERMINATION The proposed project consists of two main phases; Demolition of the existing structures and facilities and construction of the new head start facilities. The project site is approximately 0.324 miles (1,710 feet) south inland from coastal waters. It is expected that both, the demolition of the existing building and the new construction might have the potential of impacting environmental resources, air and water quality during both demolition and construction activities. Preventive and mitigation measures, such as sedimentation and erosion control plans, will be implemented to minimize the risks for these potential environmental impacts to occur. The proposed project occurs only within previously disturbed areas and excavation of historical or cultural resources is not anticipated. Project activities will stop if historic remains or resources are encountered, and SHPO will be contacted to determine the best course of action. The Coastal Zone Management Act of 1972 requires that federal actions, within and outside the coastal zone, which have reasonably foreseeable effects on any coastal use (land or water), or natural resources of the Coastal Zone be consistent with the enforceable policies of a state's federally approved Coastal Management Program. The proposed facility at 14-2 East End, Annas Retreat, East End Qtr., St. Thomas, U.S. Virgin Islands is designed to fall within existing roadways and previously disturbed areas. The project will not impact any natural resources and will improve the visual landscape in the area. As proposed, it will be undertaken in a manner consistent with the enforceable policies of the U.S. Virgin Islands’ CZM Program. This Federal Consistency Determination demonstrates the proposed project’s compliance with the U.S. Virgin Islands’ CZM Program. The project meets each of the basic goals of the USVI for its coastal zone as set forth in the Virgin Islands Code Title 12, Conservation Chapter 21, Virgin Islands Coastal Zone Management [V.I. Code tit. 12, § 903(b)]. Additional details are as follows: USVI Code Title Twelve Conservation, Chapter 21 § 903 (b) 1. Protect, maintain, preserve and, where feasible, enhance and restore, the overall quality of the environment in the coastal zone, the natural and man-made resources therein, and the scenic and historic resources of the coastal zone for the benefit of residents of and visitors of the United States Virgin Islands. The proposed facility at 14-2 East End, Annas Retreat, East End Qtr., St. Thomas, U.S. Virgin Islands is designed to be within existing roadways and previously disturbed areas. The project will not impact any natural resources and will improve the visual landscape in the Area. The new design considers the V.I. Architecture such as sloped roofs and walls, impact resistant windows and doors for resisting hurricane and seismic forces. The new buildings will be less burden to the environment while providing a better setting for its occupants. 2. Promote economic development and growth in the coastal zone and consider the need for development of greater than territorial concern by managing: (1) the impacts of 16 human activity and (2) the use and development of renewable and nonrenewable resources so as to maintain and enhance the long-term productivity of the coastal environment. The proposed project promotes the economic development and growth in the area by providing a necessary public service on the island through the development of a facility that meets the early childhood needs of the children and their parents within the greater community. The development will be within a previously developed parcel avoiding new impacts on undeveloped areas. 3. Assure priority for coastal-dependent development over other development in the coastal zone by reserving areas suitable for commercial uses including hotels and related facilities, industrial uses including port and marine facilities, and recreation uses. The proposed project does not impact coastal dependent development within the coastal zone area. The project site is approximately 0.324 miles (1,710 feet) south inland from coastal waters. 4. Assure the orderly, balanced utilization and conservation of the resources of the coastal zone, taking into account the social and economic needs of the residents of the United States Virgin Islands. The proposed Head Start Facility is designed to be within existing roadways and previously disturbed areas. The project will not impact any natural resources and will improve the visual landscape in the area. The proposed project will provide critical public services and therefore will meet the economic and social needs of the residents of the area and the community of Anna’s Retreat and St. Thomas on a whole. 5. Preserve, protect and maintain the trust lands and other submerged and filled lands of the United States Virgin Islands so as to promote the general welfare of the people of the United States Virgin Islands. The proposed project will not impact trust lands or other submerged or filled lands of the U.S. Virgin Islands. 6. Preserve what has been a tradition and protect what has become a right of the public by ensuring that the public, individually and collectively, has and shall continue to have the right to use and enjoy the shorelines and to maximize public access to and along the shorelines consistent with constitutionally-protected rights of private property owners. The proposed project will in no way affect public access to, or use of, the shoreline. The project is located well inland. 7. Promote and provide affordable and diverse public recreational opportunities in the coastal zone for all residents of the United States Virgin Islands through acquisition, development and restoration of areas consistent with sound resource conservation principles. The proposed project will not affect public recreational opportunities in the coastal zone. The project will serve a public need of child care and development within the area served. 8. Conserve ecologically significant resource areas for their contribution to marine productivity and value as wildlife habitats, and preserve the function and integrity of reefs, marine meadows, salt ponds, mangroves and other significant natural areas. 17 The project will have no impact on natural resources and will utilize best management practices (BMPs) to minimize areas of disturbance, thereby protecting adjacent habitats. 9. Maintain or increase coastal water quality through control of erosion, sedimentation, runoff, siltation and sewage discharge. The proposed project will have no long-term change on sedimentation or erosion. The proposed Head Start Facility at 14-2 East End, Annas Retreat, East End Qtr., St. Thomas, U.S. Virgin Islands is designed to be within existing roadways and previously disturbed areas. The project will not impact any natural resources and will improve the visual landscape in the Lindberg area. It will maintain coastal water quality through control of erosion, sedimentation, runoff, and siltation. As designed, it protects, maintains, preserves, and enhances the overall quality of the environment in the zone, the natural and man-made resources therein, and the scenic and historic resources of the coastal zone for the benefit of residents of and visitors of the USVI. It is therefore consistent with the policy set forth in the Virgin Islands Code Title 12, Conservation Chapter 21, Virgin Islands Coastal Zone Management [V.I. Code tit. 12, § 903 (b)]. END COASTAL CONSISTENCY DETERMINATION REQUEST