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As the proposed project does not involve an activity for which even a slight chance of flooding might be too great <br />because such flooding might result in a loss of life, injury to persons, or damage to property, it is therefore not a <br />critical action. <br />According to the United States Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI), the <br />proposed project is located within approximately 0.03 acres of designated wetland code R4SBC wetland. The <br />natural and beneficial functions and values of the floodplain and wetland potentially affected by the proposed <br />activity include floodwater storage and conveyance, groundwater recharge, erosion control, surface water quality <br />maintenance, biological productivity, fish and wildlife habitats, harvest for wild & cultivated products, recreational, <br />educational, scientific, historic, and cultural opportunities. <br />The City of Paris has considered the following alternatives and mitigation measures to minimize adverse impacts <br />and to restore and preserve natural and beneficial functions and intrinsic values of the existing floodplain and <br />wetlands: locations outside and not affecting the FFRMS floodplain or wetlands, alternative methods to serve <br />the identical project objective, and a determination not to approve any action proposing the occupancy or <br />modification of a floodplain or wetland. The practicability of alternatives considered the natural, social, and <br />economic values of each alternative. The alternatives considered were not chosen because they would fail to <br />address the most deteriorated sewer lines in need of repair, would be economically prohibitive, and would allow <br />health, safety, and environmental violations to persist. The City of Paris has reevaluated the alternatives and <br />has determined that there is no practicable alternative to locating the proposed project in the FFRMS floodplain <br />and wetlands. The proposed project must be located within the floodplain and wetland due to the necessity of <br />aligning with existing infrastructure and to meet critical service requirements for the surrounding community. <br />The best action is to proceed with the project as planned utilizing the following mitigation measures to minimize <br />adverse impacts and to restore and preserve natural and beneficial functions and values of the FFRMS <br />floodplain: <br />• Sewer systems shall be designed to minimize or eliminate infiltration of flood waters into the systems and <br />discharges from the systems <br />• The project shall not lead to any significant increases in impermeable cover and shall have no negative <br />impacts on the floodplain, as all lines will be subsurface, and the project area will be restored to pre - <br />project conditions upon completion. <br />• The project shall meet any applicable, additional local floodplain requirements set forth by the <br />community's Floodplain Administrator prior to construction. <br />• All state, local, and NFIP floodplain protection procedures will be followed. Including manhole <br />elevation/floodproofing as necessary. <br />• The consulting engineer shall take into consideration additional specifications to minimize damage to <br />and/or restore the native plant species <br />• The project shall be implemented using best management practices designed to protect improvements <br />from flood damage. <br />• The proposed improvements that intersect the floodway will be installed underneath the floodway using <br />directional drilling <br />• The implementation of erosion and sediment control measures will be used wherever possible, such as <br />the installation of silt fences, sediment barriers, or erosion control blankets, using sediment basins to <br />capture runoff before it enters wetlands, or stabilizing exposed soils immediately after construction with <br />vegetation or mulch. <br />• The implementation of pollution prevention measures will be taken when possible, such as having spill <br />prevention and control plans with spill kits on-site, storing and handling hazardous materials away from <br />the wetlands, inspecting construction equipment for leaks and malfunctions before project work <br />commences, and using biodegradable hydraulic fluids in equipment when working near wetlands is <br />possible. <br />• Preventative construction techniques, such as ensuring that heavy machinery is inspected regularly for <br />potential oil leaks, malfunctioning parts, or other mechanical issues, will be used to reduce the availability <br />of construction -related pollutants that might contaminate runoff. <br />• Staging and operating heavy machinery within the wetland or riparian area will be avoided. <br />