u.s. Department of Housing 1. Project Number: Environmental Assessment and Urban Development HUD Program:and Compliance FindIngs 2. Date Received: for the Related Laws RMS: HI-00487R Findings and Recommendations are to be prepared after the environmental zmalysls Is completed. Complete Items 1 through 15 as ~ppropr1ate for all projects. For projects requiring an environmental assessment, also complete Parts A and B. For projects categorically excluded under 24 CFR 50.20, complete Part A. Attaeh notes and source documentation that support the findings. 3. Project Name and Location: {Street, City, COUnty, state} 14. Applicant Name and Address (Street, City, State, Zip Code), and Phone lafitte Housing Development Housing Authority of New Orleans Bounded by Orleans Ave, North Claiborne Ave, North ~100 Touro Street Rochblave St, and lafitte Ave ~ew Orleans, LA 70122 504-670-3426 New Orleans LA Orleans Parish 5. I8IMultlfamlly DElder1y Dother 16. Number of: 812 Dwelling Units Buildings p. Displacement: UNo ~Ves Explain Other L Stories Acres lSee Introduction 8. ~New Construction DRehabilitation DOther 10. Planning Findings: Is the project In compliance or conformance with the following See Introduction plans?Local Zoning: I8Ives DNo DNot Applicable -----------~...,.......--:--:-----~-:':"-I coastal Zone: 9. Has an environmental report (feder~ State, or 'local) Air Quality (SIP): I8Ives I8Ives DNo DNo DNot ApplicableDNot Applicable been used in completing this form? \2SIVes DNo See Introduction See Appendices for Reports Are there any unresolved conflicts Dyes I8lNo concerning the use of the site? Explain 'Ves" 11. Environmental Finding; (check one) Dcategorlc~al exclUsion is made in accordance with § 50.20 or I8IEnvironmental Assessment and a Finding of No Significant Impact (FONSI) Is made in accordance with·§ 50.33 or DEnvlronmental Assessment and a Finding of Significant Impact is made, and an Environmental Impact Statement Is required in accordance with §§ 50.33(d) and 50.41. 181 Project IS recomm"ended for approval (List any conditions and o Project Is recommended for rejection (State reasons): requirements): /16/07 /unlts) Follow the flo roofing measur ments identified in the FloodPlain AnalysiS. Implement the requirements set forth In'the Section 106 Memorandum of Agreement that addresses historic preservation issues. ECO: {signature} ~~/'-\ (/)/ ~P--­ 15. Comments (It any) by HUD ApproVing Officl!!l: HUO Approving Official: (signature) revlous editions are obsolete Pa e 1 of 4 ~.-.~ --...-..-.-'·.............~... ~-..........,-...·y-~--....----.........-"!'·----·.....-...~--I......-...··~-------··----.....,---.-.----...-.-"'--....---.-.-. ~.-. --.----~--­ . . . ; i, §50.4 Laws and Authorities 16. Coastal Barrier Resources 17. Floodplain Management (24 CFRPart 55) 18. Historic Preservation (36 CFR Part 800) 19. Noise Abatement (24 CFR Part 51 Subpart B) 20. Hazardous Operations (24 CfR Part 51 Subpart C) 21. Airport Hazards (24 CFR Part 51 Subpart D) 22. Protection of Wetlands (E. O. 11990) 23. Toxic Chemicals & Radioactive Materials (§ 50.3(1» 24. Other § 50.4 authorities (e.g., endangered species, sole source aquifers, farmlands protection, flood, Insurance, environmental justice) Previous editions are obsolete Page 2 of 4 form-HUD-4128 (1/200 Ref. 24 CFR Part 50 ~ww.epa.gov/arkansas/6wq/swp/ssa/ssa.htm (See Appendix M). armlands Protection: AccordIng to the US Department of Agriculture, Natural Resources ~onservlltion Service web soil survey (websollsurvey.nrcs.usda.gov), the soli mapped Is ~chreiver clay (formerly Sharkey clay), which Is classified as prime farmland. The project site ~as been commercially or residentially developed for over 100 years and committed to urban ~se, therefore this project does not Involve the conversion of prime or unique farmland. ~ource: websollsurvey.nrcs.usda.gov Flood Insurance -The site Is located In a Special Flood Hazard Area, therefore, Flood Insurance must be taken In all properties. Source: FEMA's Flood Insurance Rate Map (FIRM) Community Panel Number 225 203-0160 E ~ated 1984. (See AppendIx E). nvironmental Justice -The proposed project will not adversely Impact environmental conditions ~ffecting low income or minority populations residing In the Target Area. ~ource: The Environmental Justice Study prepared by USRM. (See Appendix N). Part B. Environmental/Program Factors - AntJclpated Factors Impact! Deficiencies Source Documentation and Requirements for Approval 'None Minor Malor 25. Unique Natural Features Unique Natural Features -No unique natural features such as cliffs or bluffs are In and Areas 0 181 0 the vicinity of the subject property. Further, there Is no resource extraction activity In the affected area. 26. Site Suitability, Access, 0 rrhe site will retain Its original residential land use whIch is compatible wIth the land and Compatibility with 181 0 use of the surrounding development. Surrounding Development !source: PPM Phase I Environmental Site Assessment (See Appendix K) 27. Soli Stability, ErosIon, and 0 No slope was Identified on the subject property during site reconnaissance. . Oralnage 181 0 According to the US Geological Survey (USGS) 1998 topographic map titled "New Orleans East, LA", the property is relatively flat and at or just below sea level. No evidence of soil erosion was observed in the subject area. The Target Area Is ully developed. During redevelopment, Best Management Practices will be utilized o minImize or eliminate any erosion during ground work. 50115 within the Target Area are suitable for residential development. The Target Area has been developed with residential properties since prior to the 19405. 28. Nuisances and Hazards 0 IThe project Site currently contains vandalized and hurricane damaged boarded up (natural and built) 0 181 ~tructures that present a safety hazard to the Immediate site and neighborhood. ~he bulldlngs contain asbestos ahd lead-based paint. The proposed redevelopment will remove all blighted buildings. During demolition and reconstruction, the project will be fenced to restrict access to the local po..pulation. 29. Water Supply/ Sanitary Waste Water -Existing municipal sewage systems will be able to adequately service Sewers 181 0 0 he proposed development. Construction run off will be controlled by BMPs. Source: Bryan Jones, New Orleans Sewerage and Water Board.) Storm Water -Existing munldpal stormwater disposal systems will be able to adequately service the proposed development. Construction run off will be controlled by BMPs. (Source: Bryan lones, New Orleans Sewerage and Water Board.) Water Supply -Existing municipal water supply systems will be able to adequately ~rvlce the proposed development. The area received little damage to the existing infrastructure, and nearby facilities have suffICient utilities. According to the City of New Orleans website www.cltvofno.com the site Is In the current service area. 30. Solid Waste Disposal U [The existing municipal solid waste disposal system will adequately service the proposed development. The contractor will manage the removal of construction ~ebris. The site is in the current garbage collection route according to the City of New Orleans website www.cltvofno.com. ~ 0 Previous editions are obsolete Page 3 of 4 form-HUD-4128 (1/2002) Ref. 24 CFR Part 50 -~~'"l1-''~-'''--'''-------'''-'''-~''~''!------~'~''-''''--V'''~'''''''''''''''~""-------"-------"--"-'--'!---"--"--'~""'-'---"---_..__ ._....._._. 31. Schools, Parks, Recreation, and Social Services ~ U 0 ppen Space -Open space In the densely developed neighborhoods surrounding the J>roperty consists mostly of lawns. Adequate open common space is planned In the proposed redevelopment. Recreation -Armstrong Park, Hunter's FIeld Park and Warren Easton Park are located less than 1 mile southeast of the subject property. Cultural Facilities -The Carrolton Community Home, Gert Town Community Center and YMCA are a few of the community facilities located within two miles of the subject property. Cultural Facilities exist In surrounding areas. Several churches are in the vicinity, as well as Xavier University, are nearby. Education Facilities -Sufficient primary, secondary and higher educational facilities exist In the Target Area surrounding the subject property. The number of school ~ged students returning to the Target Area will not exceed the capacity of the ~xlstlng schools. The immediate area contains the James Johnson Elementary, ocated 4 blocks from the site, which offers k-8 Instruction as of 8/2006. McMaln High School is the closest High School, and is open as of 8/2006. Source: www.nolapublicschools.net. 32, Emergency Health Care, Fire and Police Services ~ 0 U ::.ocial Services -Numerous social services, including Volunteers of America, Daughters of Charity Services, and Gert Town Community Center are located within two miles of the subject property. City of New Orleans social services are readily available throughout the city. According to the New Orleans Neighborhoods Rebuilding Plan website (www.nolanrp.com), multiple churches and parks exist within the surrounding community. Representatives for the Association of Retarded rjtlzens CASA Catholic Charities and the Children's Bureau were Interviewed. Public Safety, Police -New Orleans Police Department facilities are located less than ~me mile south of the subject property. Response time Is within five minutes. (Source: the City of New Orleans website) Public Safety, Fire -New Orleans Fire Department facilities are located less than one mile south of the subject property. Response time Is within five minutes. {Source: Interview with Officer on duty at Police Station and City of New Orleans website.} mergency Health Care -Ochsner Hospital is located approximately four miles west of the subject property. Touro Hospital Is located approximately three miles south C! he subject property, Children's Hospital Is located approximately four miles south he subject property. Memorial Medical Center, which Is partially open since Hurricane Katrina, Is located two miles south of the subject property. Katrina related events have reduced the city capacity for medical care, but as the population returns, services return. Ochsner Foundation Hospital is four (4) miles west from the site. Emergency health care will be readily available at the completion of the project. Response time within five minutes. Source: Interview with Medical Center of New Orleans officials, September 11, 2006, 33. Commercial! Retail and Transportation 181 0 0 Commercial Facilities -Orleans Avenue Is a heavily commercially-developed roadway, and Is located 0.2 mile north of the subject property. The proposed project will have no negative Impact on commercial facilities, ransportation -The New Orleans Regional Transit Authority {RTA} has numerous bus lines that run along Orleans Avenue and North Claiborne Avenue, Customer demand diminished following Hurricane Katrina with the loss of population n the City, Bus service will Increase as people return to the neighborhood. ~onstructlon traffic will be restricted to the major roadways. 34. Other 181 0 0 ,source: the Regional Transit Authority's website www. norta.com/routes.php Energy Consumption -The 77 structures slated for demolition were built in the 1940s and 1950s. The structures will be replaced with energy-efficient units peslgned to the current building codes, Additionally, fewer units will be built thereby educing the demand for energy, Previous editions are obsolete Page 4 of 4 fonm-HUD-4128 {1/200' Ref. 24 CFR Part 50 sent ~ 3123531378 HUD 89-13-87 89:81 Pg: 2/5 I I I I . . j september 13.2007 MEMORANDUM FOR: Dominique Blom, Depu~Assistant Sec I etary for Public Housing Investments, PI FROM: Robert Goulka, Disaster Recovery Coordinator, 5 SUBJECT: Environmental Assessment Lafitte Housing Development I , Project Number; LA-OO-I005 i I .An environmental assessment, using HUD form 4128 and Jssociated appendices . was written by·U.S. Risk management for the Housing Authority dtNew Orleans (HAND) and the U.S. Department ofHousing and Urban Developfuent (lflJD) to satisfy the environmental review requirements of 24 CFR Part 50. I have ~onal1yseen the project site and reviewed the docwnents for sufficiency and adequ cy. Based on my oversight review. I have concluded that the documents satisfY the quirements ofthe National Envirorunental Policy Act and justify a conclusion that t proposed project will have "No Significant Iinpact" oIfthe environment. I recommend at a program official approve the environmental assessment by Signing block # IS of The environmental assessment identified the following tw i 1. That all newly constructed buildings must be built at an elevati I than its present elevation according to the April 2006 FEMA Rocolrery Guidance i pUblication to remove the structures from future flooding. r 2. That HUD 8ruI'HANO comply with the stipulations listed in tbi Section 106 Historic I. I. Preservation Memorandum ofAgreement. 1 I I I I I i I -r---____.~__~...._ ...___ ~-'-~-'-~-~~:"----"-.~'-~'-----"---~-'--'-.-.~.~.-.-._----­ Project Name: Project Number: Applicant Name: Project Representative: Preparer: u.s. Department of Housing and Urban Development Environmental Assessment and Compliance Findings for the Related Laws [24CFR Part 50] Lafitte Housing Development LA-00I005 Housing Authority ofNew Orleans [HANO] 4100 Touro Street New Orleans, LA 70122 Judith Jones Moran (504) 670-3426 United States Risk Management, L.L.C. Tracey D. Dodd, Principal 365 Canal Street, Suite 2760 New Orleans, LA 70130 (504) 561-6563 Table of Contents Project Summary Environmental Assessment (form HUD-4128) Summary of Findings and Conclusions Appendix A: Coastal Zone Letter Appendix B: Air Quality LetterlMap Appendix C: Coastal BarrierslFloodplain Map Appendix D: 8 Step Floodplain Analysis Appendix E: Section 106 Historic Preservation Review Appendix F: Noise Analysis Appendix G: Existing Land Use Map Appendix H: Runway Clear Zone Map Appendix I: Wetlands Map Appendix J: Phase I Environmental Site Assessment Appendix K: Endangered Species Letter Appendix L: Sole Source Aquifer Map Appendix M: Environmental Justice Study Appendix N: Other Reports Appendix 0: 30 Day FONSI Notice Project Summary Project Description: The u.s. Department of Housing and Urban Development (BUD) proposes to fund the Housing Authority of New Orleans (HANO) using Section 14 Capital Fund Program, Replacement Housing Factor Funds and Section 901 funds to redevelop the Lafitte Housing Development. The State of Louisiana, Office of Community Development will use Community Development Block Grant funds to fund infrastructure improvements for the proposed project. The redevelopment will consist of the demolition of 77 vacant existing buildings (896 units) on project site, to be replaced by the construction of 556 units on the Lafitte site, and 256 additional units on the surrounding target neighborhood, for a total of 812 new units. The project has two components: the existing Lafitte Housing Development site and the target neighborhood surrounding the Lafitte Housing Development site. The following activities will be undertaken at the Lafitte Housing Development: • Demolish 896 public housing units; • Construct 100 public housing units designated for seniors;; • Construct 176 public housing units for families; • Construct 100 Low Income Housing Tax Credit only units; • Construct 40 homeownership units on-site for low-income families; • Construct 140 homeownership units on-site for moderate income families. The following activities will be undertaken in the target area surrounding the Lafitte site: • Acquire and construct 192 Section 8 assisted units; • Acquire and construct 64 homeownership units for moderate income families HANO will hire a private developer to plan and redevelop the site. Completion of all facets of the undertaking will occur within three to five years. Site Boundaries: The Lafitte Housing Development site is located near the New Orleans central business district in an area generally bounded by Lafitte Street, Orleans Avenue, North Claiborne Avenue, and North Rocheblave Street. Target Neighborhood Boundaries: The target neighborhood extends 1.5 miles outside of the Lafitte Housing Development site. The area is bounded by Interstate 610, Franklin A venue, Decatur Street, Earhart Boulevard, Washington Avenue and Carrollton Avenue. A map of the area is included in Figure l. Project Background: Lafitte is a conventional site public housing development owned by the Housing Authority of New Orleans (HANO). It was constructed in 1941 with 896 units. All units remain on the 27.2 acre site and have been vacant since Hurricane Katrina. The redevelopment plan is comprised of two phases. Phase One (Lafitte) proposes to construct 556 housing units on the Lafitte housing site and 256 housing units in the target area. Phase Two (Lafitte II) proposes to construct 688 off-site housing units. Existing Conditions and Trends: The property is currently developed with abandoned and hurricane-damaged structures. The neighborhood of the subject property was impacted by three to five feet of floodwaters from Hurricane Katrina which caused flooding of the first floor units by approximately six inches to twelve (12) inches. It also flooded the crawl spaces, causing damage to plumbing and piping due to possible salt water intrusion, leading to corrosion and ultimately damage the piping. Hurricane force winds and vandalism also caused damage to the building's exteriors. A number of windows were broken, and need to be replaced. The exterior and unit entry doors were damaged throughout the site. The primary area of wind damage was the roof of each building. A 2006 inspection from a qualified roofing contractor found significant damage due to tile being uplifted, causing nails and substrate to be damaged. It was observed that a number of locations had extensive water damage to the plaster ceilings at the third floor attic locations. This condition is prevalent throughout the site and would indicate there is possible damage to the substrate and trusses supporting the roof. The copper roof flashing at walls and chimneys were, in most instances, found to be damaged or missing due to theft. An area of concern regarding damage is the moisture barrier, which is an important part of the wall system of the exterior wall construction. Flooding on the first floor and extensive water intrusion through the roof and broken windows has partly caused moderate to extensive mold growth in most of the walls and ceilings. There is no central air conditioning system in the buildings and this has contributed to mold growth in these apartments. It appears that some tenants have incorporated "window-type" air conditioners in a number of the units. However, these window units violate the egress code that requires a means of escape from each of these spaces. This also does not pass HUD's UPCS for inspection. The kitchen appliances have been damaged due to flooding and the year-plus of inoperability and being open to the environmental conditions. The property is also historically known to contain lead based paint and asbestos containing material. Abatement had been performed on some building components, but the hazards still exists in numerous areas. The surrounding area is a mix of residential neighborhoods, unsubsidized privately owned rental property, commercial sites, single family homeownership units, vacant commercial buildings, and vacant rental property. The site itself is unoccupied and will remain so in the absence of the project. The site and surrounding area were inundated with floodwaters related to Hurricane Katrina. Displacement: The development structures were damaged due to Hurricane Katrina and residents were displaced. Although the redevelopment and rehabilitation plans will temporarily prolong the displacement of the development residents, the plans will ultimately provide residents with an improved quality of life by eliminating clear and present environmental hazards currently found in the development buildings and on the grounds as well as provide improved housing and a safer community environment. HANO is also currently working with the displaced residents to alleviate any issues they may face during their period of displacement and has included residents' participation in the redevelopment planning process. HANO estimates that units will be developed and/or rehabilitated at Lafitte and other sites in sufficient quantity to be compatible with the number of former of residents returning to the City. Air Quality The proposed project will not have an adverse effect on the ambient air quality. Asbestos abatement will occur in accordance with all Louisiana Department of Environmental Quality (LDEQ) regulations. Air sampling will be conducted during asbestos abatement to ensure the safety of the surrounding area. Demolition and construction dusts impact on air quality will be eliminated or minimized using Best Management Practices (BMPs). The project site is located within an attainment area, according to the US EPA and the Louisiana Department of Environmental Quality. The project requires no individual NESHAP permit or notification. Estimated total project cost The total project is estimated at $100 million. Approximately $45 million in federal funds will be contributed to the redevelopment of Lafitte through Capital Funds, Replacement Housing Factor and Section 90 I housing funds for demolition, rehabilitation and construction. In addition $27 Million will be allocated from Community Development Block Grants (CDBG) funds for infrastructure and a community center. It is projected that these funds will be leveraged with tax credit funding and conventional financing to complete the project budget. U.S. Department of Housing 1. Project Number: Environmental Assessment and Urban Development HUD Program : and Compliance Findings 2. Date Received: for the Related Laws RMS: HI-00487R Findings and Recommendations are to be prepared after the environmental analysis Is completed. Complete Items 1 through 15 as appropriate for all projects. For proJects requiring an environmental assessment, also complete Parts A and B. For projects categorically excluded under 24 CFR 50.20, complete Part A. Attach notes and source documentation that support the findings. 3. Project Name and Location: (Street, City, County, State) 14. Applicant Name and Address (Street, City, State, Zip Code), and Phone Lafitte HOUSing Development Housing Authority of New Orleans Bounded by Orleans Ave, North Claiborne Ave, North 1'1100 Touro Street Rochblave St, and Lafitte Ave New Orleans, LA 70122 504-670-3426 New Orleans LA Orleans Parish 5. I8IMultifamily DElderly DOther 16. Number of: 812 Dwelling Units Buildings 17. Displacement: DNo I8IVes Explain Other 1 Stories Acres lSee Introduction B. [gINew Construction DRehabilitation DOther lO. Planning Findings: Is the project in compliance or conformance with the following See Introduction plans?Local Zoning: ---------.,--------::-----,--:-:--1 Coastal Zone : 9. Has an environmental report (Federal, State, or local) Air Quality (SIP) : been used in completing this form? [gIYes DNo See Introduction I8IVes I8Ives I8Ives DNO DNo DNo DNot Applicable DNot Applicable DNot Applicable See Appendices for Reports Are there any unresolved conflicts DVes concerning the use of the site? Explain "Ves" 11. Environmental Finding: (check one) DCategorical exclusion is made in accordance with § 50.20 or I8IEnvironmental Assessment and a Finding of No Significant Impact (FONSI) is made in accordance with § 50.33 or DEnvironmental Assessment and a Finding of Significant Impact is made, and an Environmental Impact Statement is required in accordance with §§ 50.33(d) and 50.41. 181 Project Is recommended for approval (List any conditions and o Project Is recommended for rejection (State reasons): requirements): 12. Preparer: (signature) pate: IDate: 8/16/07 8/16/07 14. Comments by Environmental Clearance Officer (ECO): (required for projects over 200 lots/units) Follow the floodproofing measurements identified in the FloodPlain Analysis. Implement the requirements set forth in the Section 106 Memorandum of Agreement that addresses historic preservation issues. ECO: (signature) 15. Comments (if any) by HUD Approving Official: HUD Approving Ornclal : (signature) Date: Previous editions are obsolete Page 1 of 4 form-HUD-412B (1/2002) Ref. 24 CFR Part 50 Part A. Compliance Findings for §50.4 Related Laws and Authorities Project is In Compliance §50.4 Laws and Authorities Isource Documentation and Requirements for Approval Yes No 16. Coastal Barrier Resources 0 fThe site is not located in a Coastal Barrier Resource System. (Source: FEMA's Flood Insurance Rate Map (FIRM) Community Panel Number 225 203-0160 E dated 1984, and the 8 Step Floodplain Analysis. See Appendix C.) 18I 17. Floodplain Management (24 he Target Area is located in a Zone A3 100 year floodplain identified as a ponding area. The 8­CFR Part 55) 181 0 step Floodplain Management review required by E.O. 11988 and found in 24 CFR 55.20 oncluded that there was no practical alternative to the project as proposed. All newly onstructed buildings must be built at an elevation three feet higher than its present elevation according to the April 2006 FEMA Flood Revocery Guidance publication. The project owner(s) must also obtain flood insurance for the life of the mortgage or the life of the improvement. (Source: FEMA's Flood Insurance Rate Map (FIRM) Community Panel Number 225 203-0160 E ~ated 1984 and the 8 Step Floodplain Analysis. See Appendix D.) 18. Historic Preservation HUD, the State Historic Preservation Officer (SHPO) and the Advisory Council on Historic (36 CFR Part 800) 0 181 Preservation (ACHP) agree that the demolition of the Lafitte Housing Development would onstitute an adverse effect on an historic property per 36 CFR 800.4 and 800.5(b). Furthermore, the SHPO stated that there is a potential for intact archaeological deposits to be !encountered during redevelopment. The Section 106 Consultation Process was completed and a Memorandum of Agreement as described in 36 CFR Part 800 was signed by all parties. The MOA identifies measures required of HANO to protect historic preservation interests within the isite. See Appendix E for a copy of the MOA.) 19. Noise Abatement 0 fThe noise analysis indicates that the noise levels created by the streets that border the site are (24 CFR Part 51 Subpart B) 181 less than 65 DNL (Acceptable). Noise levels will not increase due to traffic generated within the project site. Demolition and construction noise will temporarily increase ambient noise levels wor a brief period of time. This increase in noise levels will be restricted to the daytime hours. ~onstruction traffic will be routed to the site using major arteries, specifically Claiborne Avenue ~nd Interstate 10. Noise levels from roads, railroads and aircraft do not exceed the 65 DNL limit. (Source: Noise Analysis (See Appendix F». 20. Hazardous Operations 0 rrhe project is located at an Acceptable Separation Distance from any above-ground explosive or (24 CFR Part 51 Subpart C) 181 ~ammable fuels or chemicals containers according to "Siting of HUD-Assisted Projects Near Hazardous Facilities." Source: Existing land use map. (See Appendix G) 21. Airport Hazards 0 rrhe project is not within an FAA-designated civilian airport Runway Clear Zone or Runway (24 CFR Part 51 Subpart D) t8I Protection Zone, or within a military airfield Clear Zone or Accident Potential Zone or Approach Protection Zone. (Source: Glen Whittaker, Operations Supervisor, Louis Armstrong International ~irport; Joel Jenkinson, Airport Operations Mgr, Lakefroflt Airport; Thomas Garntham, Architect Planner Naval Air Station. See also Runway Clear Zone Maps in Appendix H). 22. Protection of Wetlands 0 !The project is/was previously developed. No wetlands, marshes, wet meadows, mud flats or 181 (E. O. 11990) natural ponds located on site as per field observation and maps issued by the U.S. Fish & ~ildlife Service (USFWS). Source: National Wetlands Inventorv (NWI) maD (ecos.fws.Qov). (See Appendix I). 23. Toxic Chemicals & 0 !The subject and adjacent properties are free of hazardous materials, contamination, toxic Radioactive Materials 181 hemicals, gasses and radioactive substances which could affect the health or safety of (§ 50.3(i» pccupants or conflict with the intended use of the subject property. ~fter Hurricane Katrina, the NRDC and the USEPA collected sediment samples from the Lafitte ~nd Treme area and detected elevated levels of lead In the soil. Source: Phase I Environmental Site Assessment prepared by PPM Consultants in June 2006 and CERCLIS List. (See Aooendix J) Endangered Species: The proposed project is located in a densely developed urban setting. The (e.g., endangered species, 24. Other § 50.4 authorities 181 0 Louisiana Department of Wildlife and Fisheries (LDWF) determined that the proposal will not sole source aquifers, hreaten any Federally or state approved (listed or proposed) species. farmlands protection, flood, insurance, environmental ~ource: Finding by LDWF (See Appendix K) . justice) ~ole Source Aquifers: The project is not located within a U.S. Environmental Protection (EPA) designated sole source aquifer watershed area. Source: Region 6 Ground Water Office Sole Source Aquifer MaD and Previous editions are obsolete Page 2 of 4 form-HUD-4128 (1/2002) Ref. 24 CFR Part 50 www.epa.gov/arkansas/6wq/swp/ssa/ssa.htm (See Appendix L). Farmlands Protection: According to the US Department of Agriculture, Natural Resources Conservation Service web soil survey (websoilsurvey.nrcs.usda.gov), the soil mapped is Schreiver clay (formerly Sharkey clay), which is classified as prime farmland . The project! has been commercially or residentially developed for over 100 years and committed to urb use, therefore this project does not involve the conversion of prime or unique farmland. Source: websoilsurvey.nrcs.usda.gov Flood Insurance -The site is located in a Special Flood Hazard Area, therefore, Flood Insurance must be taken in all properties. ::,ource: FEMA's Flood Insurance Rate Map (FIRM) Community Panel Number 225 203-0160 E dated 1984. (See Appendix D). Environmental Justice -The proposed project will not adversely impact environmental conditions affecting low income or minority populations residing in the Target Area. Source: The Environmental Justice Study prepared by USRM. (See Appendix M). Part B. Environmental/Program Factors Anticipated Impact/ Deficiencies Source Documentation and Requirements for ApprovalFactors None Minor Maior 25. Unique Natural Features Unique Natural Features -No unique natural features such as cliffs or bluffs are in and Areas 18I 0 0 he vicinity of the subject property. Further, there is no resource extraction activity in the affected area. he site will retain its original residential land use which is compatible with the land and Compatibility with 26. Site Suitability, Access, 18I U D use of the surrounding development. Surrounding Development ~ource: PPM Phase I Environmental Site Assessment (See Appendix J) 27. Soil Stability, Erosion, and No slope was identified on the subject property during site reconnaissance. Drainage 18I D D ~ccording to the US Geological Survey (USGS) 1998 topographic map titled "N prleans East, LA", the property is relatively flat and at or just below sea level. No evidence of soil erosion was observed in the subject area. The Target Area is ully developed. During redevelopment, Best Management Practices will be utilized o minimize or eliminate any erosion during ground work. ::,oils within the Target Area are suitable for residential development. The Target Area has been developed with residential Dro~erties since prior to the 1940s. 28. Nuisances and Hazards he project site currently contains vandalized and hurricane damaged boarded up (natural and built) 18I D 0 JStructures that present a safety hazard to the immediate site and neighborhood. r-he buildings contain asbestos and lead-based paint. The proposed redevelopment will remove all blighted buildings. During demolition and reconstruction, the project twill be fenced to restrict access to the local population. 29. Water Supply/ Sanitary 0 [Waste Water -Existing municipal sewage systems will be able to adequately service Sewers 18I 0 he proposed development. Construction run off will be controlled by BMPs. (Source: Bryan Jones, New Orleans Sewerage and Water Board.) Istorm Water -Existing municipal stormwater disposal systems will be able to ~dequately service the proposed development. Construction run off will be ontrolled by BMPs. (Source: Bryan Jones, New Orleans Sewerage and Water Board.) lWater Supply -Existing municipal water supply systems will be able to adequately ~ervice the proposed development. The area received little damage to the existing infrastructure, and nearby facilities have sufficient utilities. According to the City of New Orleans website www.cityofno.com the site is in the current service area. 30. Solid Waste Disposal 0 rrhe existing municipal solid waste disposal system will adequately service the proposed development. The contractor will manage the removal of construction ~ebris. The site is in the current garbage collection route according to the City of New Orleans website www.cityofno.com. I8l 0 Previous editions are obsolete Page 3 of 4 form-HUD-4128 (1/2002) Ref. 24 CFR Part 50 31. Schools, Parks, Recreation, 181 D ppen Space -Open space in the densely developed neighborhoods surrounding the D and Social Services property consists mostly of lawns. Adequate open common space is planned in the proposed redevelopment. Recreation -Armstrong Park, Hunter's Field Park and Warren Easton Park are located ess than 1 mile southeast of the subject property. ~ultural Facilities -The Carrolton Community Home, Gert Town Community Center ~nd YMCA are a few of the community facilities located within two miles of the ~ubject property. Cultural Facilities exist in surrounding areas. Several churches are in the vicinity, as well as Xavier University, are nearby. Education Facilities -Sufficient primary, secondary and higher educational facilities ~xist in the Target Area surrounding the subject property. The number of school ~ged students returning to the Target Area will not exceed the capacity of the ~xisting schools. The immediate area contains the James Johnson Elementary, located 4 blocks from the site, which offers k-8 instruction as of 8/2006. McMain High School is the closest High School, and is open as of 8/2006. Source: ~ww.nolapublicschools.net. ~ocial Services -Numerous social services, including Volunteers of America, Daughters of Charity Services, and Gert Town Community Center are located within wo miles of the subject property. City of New Orleans social services are readily ~vailable throughout the city. According to the New Orleans Neighborhoods Rebuilding Plan website (www.nolanrp.com). multiple churches and parks exist r-vithin the surrounding community. Representatives for the Association of Retarded ritizens CASA Catholic Charities and the Children'S Bureau were interviewed. 32. Emergency Health Care, Fire and Police Services o D Public Safety, Police -New Orleans Police Department facilities are located less than pne mile south of the subject property. Response time is within five minutes. Source: the City of New Orleans website) Public Safety, Fire -New Orleans Fire Department facilities are located less than one mile south of the subject property. Response time is within five minutes. (Source: nterview with Officer on duty at Police Station and City of New Orleans website.) Emergency Health Care -Ochsner Hospital is located approximately four miles west pf the subject property. Touro Hospital is located approximately three miles south of he subject property. Children'S Hospital is located approximately four miles south of he subject property. Memorial Medical Center, which is partially open since Hurricane Katrina, is located two miles south of the subject property. Katrina related events have reduced the city capacity for medical care, but as the population returns, services return. Ochsner Foundation Hospital is four miles west from the ~ite. Emergency health care will be readily available at the completion of the project. Response time within five minutes. ~ource: Interview with Medical Center of New Orleans officials. September 11, ~006. 33. Commercial! Retail and Transportation D D ~ommercial Facilities -Orleans Avenue is a heavily commercially-developed roadway, and is located 0.2 mile north of the subject property. The proposed project r-vill have no negative impact on commercial facilities. Irransportation -The New Orleans Regional Transit Authority (RTA) has numerous bus lines that run along Orleans Avenue and North Claiborne Avenue. ~ustomer demand diminished following Hurricane Katrina with the loss of population in the City. Bus service will increase as people return to the neighborhood. ~onstruction traffic will be restricted to the major roadways. 34. Other D D Source: the Regional Transit Authority's website www.norta.com/routes.php Energy Consumption -The 77 structures slated for demolition were built in the 1940s and 1950s. The structures will be replaced with energy-efficient units tJesigned to the current building codes. Additionally, fewer units will be built thereby reducinq the demand for energy. Previous editions are obsolete Page 4 of 4 form-HUD-4128 (1/2002) Ref. 24 CFR Part 50 SUMMARY OF FINDINGS AND CONCLUSIONS Alternatives and Project Modifications Considered (Identify other reasonable courses of action that were considered and not selected such as other sites, design modifications, or other uses of the subject site. Describe the benefits and adverse impacts to the human environment of each alternative and the reasons for rejecting it.) No Action The Lafitte Housing Development suffered extensive wind and flood damage from Hurricane Katrina. The properties functionally obsolete, contain asbestos and lead-based paint, energy inefficient, not ADA compliant and uninhabitable in their current state. Adopting a "no action" alternative would preserve buildings that are eligible for listing on the National Register of Historic Places but perpetuate physical blight in the site and surrounding neighborhood. Without demolition, the buildings are a safety threat, pose environmental hazards and are a nuisance to the surrounding community. Further, no replacement housing (new or rehabilitated) would be placed in the neighborhood. Consequently, the "no action" alternative is not feasible, as the continued physical blight would threaten the recovery of the area. Demolition Only Demolition of the project site would remove all physical blight but would not provide housing for displaced residents to return to. The lack of new/replacement housing units would negatively impact the City of New Orleans' effort to recover from the destruction of Hurricane Katrina. This alternative, therefore, is undesirable. To avoid this housing loss HANO developed a Recovery Plan for affordable housing for its residents that: (l) follows the broad goals of the HOPE VI program to de-concentrate poverty and provide mixed income communities; (2) provides housing that meets newly adopted City building codes, FEMA Advisory Base Flood Elevations and HUD standards for safe, decent housing; and (3) is cost effective and achievable within existing financial resources. HANO has selected Providence/Enterprise to redevelop the Lafitte Housing Development site into a vibrant, mixed income community that will provide both affordable and market rate housing. Providence/Enterprise plans to redevelop the property providing 556 housing units on-site and, in later phases, an additional 256 units in the neighborhood (scattered sites). ECM performed three cost estimates to evaluate the most cost effective option for the development: (J) repair and minor rehabi litation, (2) major rehabilitation and (3) new construction. The option of doing partial rehabilitation and new construction was not 5 considered a viable option because it was felt that the existing structures would retain the stigma of the "projects" including the association of crime, poverty and social distress. Even with complete rehabilitation, the existing structures would not match the scale and massing of the new construction which would be designed to integrate into the surrounding historic neighborhood. Repair and Minor Rehabilitation The first cost estimate addresses the immediate needs of the development in its current condition and involves simply improving the development to its condition before Hurricane Katrina and repairing other non-Katrina related deficiencies. The cost is approximately $29,516,444.00, but does not include any cost to correct the observed code violations and other critical deficiencies indicated below: • The receptacles in the bathrooms and kitchens are not GFCI type. The bedroom electrical circuit breakers are not AFCI, which is also code compliant. There are no outdoor weather-proof GFCI outlets. Power panels (inside and outside) are heavily corroded and should not be energized, this represent a severe fire hazard. • Porches without railings (porches are thirty-four (34) inches from the ground) Refer to IBC (2003) -1012.1 and NFPA 101-7.1.8 for the code requirement. • Windows do not meet hurricane impact requirement per IBC (2003) -1609.1.4 for the code requirement. • The property does not meet the Uniform Federal Accessibility Standard (UFAS), which requires a minimum of five (5) percent of the units to be compliant with Section 504 of the Housing Act of 1973. Only demolition and new construction will ensure UFAS is complied with. • Repair/Replacement of the roof substrate and wood trusses installed in a manner complying with IBC (2003) -1507.2.7 for the wind speed requirements in this hurricane region. • Lead Based Paint (LBP) Assessment. An assessment to specifically identify building components containing lead-based paint would be required in conjunction with a major repair or rehabilitation effort. The exterior iron balcony and porch rails have previously been identified as containing LBP and were encapsulated in the 1990s. However, the effects of Hurricane Katrina further deteriorated the encapsulation, such that additional remediation is required. The assessment may identify additional buildings containing lead-based paint that would require proper remediation. • All walls separating the dwelling units shall be a fire-rated wall partition per IBC 708.1, # I (2003). These fire-rated walls must extend to the underside of the roof decks. Addressing the of the Lafitte Development will require an expenditure of over $29 million. after this expense, the buildings will still remain obsolete, still be present, the buildings would fail to meet the codes and safety would remain ADA noncompliant to HUD level of limited improvement to be considered only as of last within community. issues would continued ",v,,,p,,,r! limited PHA Intf'n!l11(,f' funds while providing only marginal these reasons, this is not recommended. Major Rehabilitation The second cost of approximately $148,122,602.00 involves modernization buildings in order to meet current building the Uniform Federal ,o,'v'v,","""U Physical Condition This level of ...... ",riA.·... would involve all buildings, producing In order for the of the buildings to demolished, the costs also be added to costs for bringing the bui up to the federal evaluated the costs with lead abatement, which are additional costs associated with modernization developments. lead abatement costs with modernization is estimated to be $970,549.00, which does not include build-back of removed components. The costs were on the out! ined in a lead prepared the amount of units, bedrooms, the units and of after the completion abatement activities. The total modernization cost is to be $149,093,151.00. asbestos containing are present in buildings that must be abated, which will include additional costs for removal, and disposal. The estimated to the roof of each building, as provided following inspections by a roofing contractor will likely cost approximately million. However, the repairs of these roofs may a problem due to non-availabi lily of At present approximately of the existing have fiberglass Modern ization will not address ofthe defensible past has made and security significant problems on this configuration it difficult and to secure, hinders pedestrian circulation, and provides areas without the natural Ilance of the residents. physical constraints of site undermine the families and children I on the site. The inability to basic site configuration problems will maintenance and security to provide basic security for residents at site. In the deficiencies have mandated HANO to and prevention. The buildings themselves make reconfiguration inefficient and difficult due to the shallow building depth and awkward configuration of units and staircases. Repairing the buildings would not correct all deficiencies and rehabilitation would leave substrate and structural problems yet to be identified and be prohibitively expensive. Further, the unit sizes are no longer sufficient for today's family living needs in terms of space for families to appropriately interact and space needs of modern furniture and appliances. There is no technically feasible way to increase the size of the units without complete rehabilitation. The buildings do not meet the FEMA Advisory Base Flood Elevations putting them at risk for future flooding and substantially increasing insurance costs. The site also does not provide adequate parking for residents. The housing units would remain functionally obsolete, energy inefficient and noncompliant with ADA requirements. As a result of the additional costs and physical drawbacks of modernization, this alternative is not recommended. New Construction The third cost estimate involves demolishing the entire development and constructing an entirely new development including site work, residences, infrastructure, sidewalks, parking, tighting and landscaping. This includes the development of scattered site units in the adjacent neighborhood Target Area. The third cost estimate would be approximately $121,140,271.50. The cost of modernization is about 23 percent higher than the cost of total demolition and new construction. During demolition, the potential for the generation of dust (particulate matter) exists as the structures are demolished and as site activities proceed to include site grading, leveling and associated construction activities. To ensure that the potential dust generation does not impact the surrounding area, Best Management Practices (BMPs) wilt be drafted and utilized in all demolition and construction phases of the project. Additional environmental programs which incorporate the BMPs are the stormwater regulations. These regulations detail what practices should be followed for any construction site, which involves greater than 0.5 acres of land. Some of the BMPs proposed include, utilization of wetting agents and the use of silt fences to control dusts and erosion. Additional issues involved in the demolition are the presence of asbestos and lead containing building materials. All asbestos abatement activities will be performed in accordance with LDEQ regulatory requirements. Lead removal measures will be required to be performed in accordance with HlID regulations and occupational laws. The proper documentation will be completed with the Louisiana Department of Environmental Quality (LDEQ) prior to the asbestos abatement, as well as for any lead abatement activities. It should be noted that environmental regulations regarding demolition activities for lead-based paint containing surfaces will likely not result in significant abatement activities as it wit! for modernization, but wit! result in dust control activities to be followed for loading, transportation, and disposal. All asbestos abatement, transport and disposal will be conducted in accordance with all local, state and federal regulations. Air monitoring will be conducted during abatement activities to ensure the safety of the surrounding areas. No detrimental atmospheric effects on historic properties are expected from the proposed undertaking. Based on the three cost estimates provided by ECM and the cost estimate for lead abatement and clearance added to the cost for modernization, the most cost effective and environmentally sound alternative is to demolish and rebuild these structures. The alternative to raze and redevelop the project site and provide housing in the Target Area is considered the best option for the following reasons: 1. It is less costly to tear down the existing public housing units and build replacement units that modernize the project site. 2. New construction will eliminate the functional obsolescence and presence of lead and asbestos hazards from the project site. 3. New construction will enable the buildings to be energy efficient and ADA compliant. 4. New construction will result in larger floor space per unit that the existing public housing buildings have. 5. New construction will enable the developer to raise the elevation of the buildings to the recommended height as protection against the potential impact of future flooding. 6. The redevelopment option will decrease unit density and increase automobile and pedestrian access to the site. 7. The redevelopment option will decrease the concentration of low income residence in the area by providing mixed-income units in the Target Area, as well as to provide the opportunity for home ownership. 8. The amount of time needed to redevelop the site and Target Area is not significantly longer that modernizing the project site. Consequently, the length of time that the former residents will experience in being displaced until replacement units become available is appreciably similar. The redevelopment plans will allow for the living area of the structures to be raised above the base flood elevation, thereby minimizing the risk of damage from future flooding events. Another significant issue is the absence of required handicapped accessible units in the development. By federal law, five percent (or 45 units) of the total number of units (896) must be accessible units. The residential units scattered around the development will also be handicapped accessible. Accessible units should be of all unit types such as one, two, and three bedrooms. A minimum of sixteen (16) buildings would have to be gutted and completely rehabilitated because of the current interior layout of the units and the masonry wall construction. Gutting and completely rehabilitating the units will provide the proper layouts to meet the requirements of accessible units. There are also 34 buildings that have exit egress stairs that do not meet the code requirements for an egress stair. It would be necessary to gut the interior of the 34 buildings to provide the space required for egress stairs. Due to these existing conditions, 50 out of the 79 buildings need to be gutted and rebuilt to meet UF AS and current code requirements. Additional Studies Performed (Attach Study or Summary) • A limited Phase I Environmental Site Assessment (ESA) was prepared for the Housing Authority of New Orleans by PPM Consultants, Inc. on June 15, 2006. (Appendix F). • A comprehensive sediment investigation by the United States Environmental Protection Agency (USEPA), the Louisiana Department of Environmental Quality (LDEQ) and the National Resource Defense Council (NRDC) • Historical testing and abatement of units at the Lafitte Housing Development for Lead Based Paint (LBP) provided by the Housing Authority ofNew Orleans. • Section 106 Historic Preservation Review. • Executive Order 11988 "Floodplain Management" analysis (8-Step Analysis) Mitigation Measures Needed: The Housing Authority of New Orleans proposes substantial improvements to the subject property. HANO has selected Providence/Enterprise to redevelop the Lafitte Housing Development site into a vibrant mixed income community to provide both affordable and market rate housing. Providence/Enterprise plans to redevelop the property providing 556 housing units on-site and, in later phases, an additional 256 units in the neighborhood (scattered sites). The redevelopment of the Lafitte Housing Development will not require the acquisition of any additional land for the first funded phase of development, but land will be acquired for subsequent development of scattered sites, which will be evaluated on a case-by-case basis for each property acquired. No impact to zoning or land use is expected from the proposed project. The goal of the project is to convert a conventional public housing development into a new, mixed-income and mixed-use community that includes rentals and home ownership units in New Orleans. Rehabilitation cost is $148,122,602.00 with an additional $970,549.00 for abatement, and new construction cost is $121,140,271.50. Rehabilitation cost is about 23% more than the new construction cost. As to the lead abatement and clearance costs these are not costs that would be incurred if demolition of the units were performed, as abatement of lead from the units would not be necessary. Historically, this site has had a concentration of poverty and distress compounded by small cramped housing units with outdated mechanical systems and site design which exacerbated severe maintenance and security issues. This distress put public housing families at risk and spilled over into the adjoining neighborhood causing disinvestment and undermined property values. Demolition and rebuilding is the logical and most cost effective remedy to ensure the viability of the Lafitte Housing Development. This site and all other HANO sites will soon be operated on Asset Based Management principles. Repairs would not correct all deficiencies. Rehabilitation would leave substrate and structural problems yet to be identified and be prohibitively expensive. Demolition is the correct remedy to ensure that the future residents and management of this site will live in safe, decent and sanitary housing. The Louisiana Speaks Pattern Book may serve as a planning and design guide for the new community. The Louisiana Vernacular, Victorian, and Classical styles will be featured in a combination of double and mUltiplex buildings. Reconnecting the property with the surrounding neighborhood by re-establishing the public street grid and blending with the community character is a priority. In addition, all proposed construction design will be have prior approval from the SHPO and ACHP. This review will ensure that the new construction maintains the visual integrity of the neighborhoods and a positive visual impact will be afforded. List of Sources, Agencies and Persons Consulted [40 CFR lS0S.9(b)] I. Louisiana State Historic Preservation Office. State historic Preservation Officer, Laurel Wyckoff. 2. Federal Emergency Management Agency. www.fema.gov 3. United States Department of Wildlife and Fisheries. wetlandsfws.er.gov. 4. Louisiana Department of Natural Resoucres, Coastal Management Division. Tim Killeen, Coordinator for Support Services for the Eastern Region. 5. United States Environmental Protection Agency. www.epa.gov. 6. Louisiana Department of Wildlife and Fisheries. 7. National Park Service. www.nps.gov/rivers/wildriverlist.html. 8. "Criteria Pollutant Area Summary Report." USEPA. www.epa.gov/oar/oaqps/greenbk/ancI2.html. May 21, 2004. 9. "Soil Survey of Orleans Parish, Louisiana." United States Department of Agriculture, Soil Conservation Service. 1987. 10. Naval Air Station, Joint Reserve Base, New Orleans, Louisiana. Public Works Department. Thomas Grantham, Architect/Facilities Planner. II. Lakefront Airport. Joel Jenkinson, Airport Operations Manager. 12. Louis Almstrong International Airport. Glen Whittaker, Operations Supervisor. 13. PPM Consultants 14. Housing Authority of New Orleans. Judith Moran. 15. New Orleans Police Department. 16. City of New Orleans website, \\ww.cilyorIlO.Clllll. 17. Regional Transit Authority website, www.n.:gi{nallrallsit.org. 18. New Orleans Public Schools website, \\ ",w.llolapliblicscilools.llct. 19. Bryan Jones, New Orleans Sewerage and Water Board. ~ ~ 0 ~ 'i ~ C> ..... ;;s E ". .., § ! § (!) ~ tJ '" ~I ! 8 SCALE: 1 : 24,000 .5 0 MILES 8 (!) 1000 0 1000 5000 10,000 ~ FEET o KILOMETER 2 E 8 o METER 1000 2000 ~ Target Property * • Sites at elevations higher than or equal to the target property Indian Reservations BIA • Sites at elevations lower than Oil & Gas pipelinesthe target property 100-year flood zone ~ !. Manufactured Gas Plants • SOO-year flood zone Sensitive Receptors l~ J ! D 0 a National Priority Ust Sites Landfi" Sites This report Includes Interactlve Map layers to Dept. Defense Sites display and/or hide map Information. The legend 'Includes 0nly those Icons for the default map view. SITE NAME: ADDRESS: LAT/LONG: Lafitte 2101 Lafitte Street New Orleans LA 70116 29.9655/90.0778 CLIENT: CONTACT: INQUIRY #: DATE: PPM Consultants Inc. Monica Holston 1695900.25 June 14, 2006 Copynghi c:02006 EDR.lnc. c:02006 T,1o Atlu All. 0112005. Housing Authority of New Orleans Housing Development Major Highways Orleans Parish, Louisiana L.L.I:. Minor Highways Housing Authority of New Orleans Housing Development Orleans Parish, Louisiana Major Highways Minor Highways j chimento tdodd UNITI:D STATl::!:i: RISK MANAI:ii I!ME NT.. L.L_C. 08.14.07 APPENDICES APPENDIX A COASTAL ZONE LETTER 06/2812006 14:05 FAX 225 342 9439 LDNR-Coastal Management I4J 001 Coastal Management Division Office of Coastal Restoration and Management Deparbnent of Natural Resources LaSalle Office Building 617 North 3rd St., Suite 1048 Baton Rouge, LA 70802 OR: P. O. Box 44487 Baton Rouge, LA 70804-4487 Phone: 1-800a 267·4019 or 225-342-7591 Fax: 225-342-9439 ----~~~--~~--------~--~--~~--------------~ LOCATION: DATE: ([~-V%, () FAX No. _2_0_S_-_g_3~(----.;~:.....-e~o....::;....5_ NUMBER OF PAGES (including cover sheet): _~_ COMMENTS: _-=C_J-_r)_O_6"-o~~.-...:ro~_-":"" __ FROM: ~fI1~ TELEPHONE: 225-342-713? 06/2.812006 14:05 FAX 225 342 9439 LDNR-coastal Management @002 KATBl..EEN BAlRNEAUX BLANCO scorrA.ANGEU.E GOVERNOR SECREl'AltY Jillle 28, 2006 Michael D. McCown, P.G. PrincipallSfmior Geologist PPM Consultants. Inc. 5555 Bankhead Highway Birmingham, AL 35210 RE: C20060280, Coastal Zone Consistency HOD Direct Federal Action Proposed Refurbishing/DemolitionlConstruction ofvarious Public Housing Projects, Project No. 2GOOI-ESAI. New Orleans, Louisiana Dear Mr. McCown: The above referenced projects have been reviewed for consistency with the approved Louisiana Coastal Resource Program (LCRP) as required by Section 307 ofthe Coastal Zone Management Act of 1972. as amended. I have determined that activities will be deemed to be consistent with the Louisiana Coastal Resources Program, and thus will require no further clearance from our office, if the proposed project meets anyone ofthe following criteria: • it is not within one ofthe 19 coastal parishes (see attached list); • it is simply a loan to allow business operations to continue; • it is to provide services such. as administration, planning or technical expertise; • it is for the repair ofexisting infrastructure and will not expand the footprint ofthe existing structures; • it is within a Corps of Engineers-constructed hurricane protection levee~ If a proj ect does not meet one of these criteria, or ifthe proj ect: • is within the Louisiana Coastal Zone and involves dredging (any sort ofdigging), fill or land clearing (other than removal ofstonn debris) then additional coordination with this office will be necessary. Information on the Coastal Use Permit application process can be found at http://dnr.louisiana.gov/crmlcoastmgtlcoastmgLasp. COASTAL MANAGEMENT DIVISION • P. o. BOX 44487 • BATON ROUGE. LA 70804-4487 PHONE (225) 342-7591 • PAX (22S) 342-9439 • WEB htlp:/IWww.d!u::.alate.IaJlS AN EQUAL oPPORTUNITY EMPLOYER 06/28/2006 14:06 FAX 225 342 9439 LDNR-Coaatal Management ~003 Ifyou have any questions concerning this detemrinatioD please contact JeffHanis, Consistency Analyst at (225) 342-7591 or 1-8()()"267-4019. Sincerely, J41L Alty'r Jim Rives Acting Administrator JR/JHIbgm cc: Venise Ortego, LDWF Wynecta Fisher. Orleans Parish Ron Ventola. COB-NOD Raquel Murphy From: Gregory DuCote [GregDu@dnr.state.la.us] Sent: Tuesday, August 14, 20073:38 PM To: Raquel Murphy Cc: Jeff Harris Subject: RE: Coastal Zone Management Plan Impacts Raquel I appreciate your prompt response to our conversation. Based on what I understand, i.e. that HUD and/or the City ofNew Orleans is going to raze several existing developments w/in the leveed/developed area of the City and the rebuild housing, I do not foresee any problems. I am forwarding your email, and this response, as a copy to Jeff Harris who will ask for any further infonnation we need in order to fully respond to your inquiry. Gregory J. DuCote Interagency Affairs Section Coastal Management Division P.O. Box 44487 Baton Rouge, La 70804-4487 Phone: 225.342.5052 800.267.4019 Facsimile: 225.242.3458 CONFIDENTIALITY STATEMENT The information contained in this electronic message from the Interagency Affairs Program, Coastal Management Division, Louisiana Department of Natural Resources is privileged and confidential. If you are not the intended recipient, the disclosure, copying, distribution, or use ofany of the transmitted information, or any other action based on the contents of this information, is strictly prohibited. If you have received this transmission in error, please inunediately notify the transmitter bye-mail or telephone at 225.342.5052 and destroy/delete the electronic mail and any attachments. --Original Message---­From: Raquel Murphy [mailto:rmurphy@us-risk.com] Sent: Tuesday, August 14,20073:31 PM To: Gregory DuCote Cc: Tracey Dodd Subject: Coastal Zone Management Plan Impacts Mr. Ducote: The Housing Authority of New Orleans is proposing to undertake the task of demolishing four existing housing developments within Orleans parish and rebuilding new housing units on each development site as well as in the surrounding neighborhoods. The developments in question include the St. Bernard Housing Development, the C.J. Peete Housing Development, the B.W. Cooper Housing Development and the Lafitte Housing Development. All developments are located within New Orleans city limits. Since the project will be partially sponsored by HUD, we have been requested to recieve confirmation from the Department of Natural Resources that the projects in question will not impact the State of Louisiana's Coastal Zone Management Plan. We would appreciate if you can reply to this email as confirmation of the above referenced activity. Please don't 8/14/2007 hesitate to contact me if you have any questions or require additional information. Sincerely, RAQUEL JUMONVILLE MURPHY US RISK MANAGEMENT 365 CANAL STREET SUITE 2760 NEW ORLEANS. LA 70130 504.561 .6639 (WORK) 504.561.6624 (FAX) 504.481.7667 (CELLULAR) WWW.U$-RISK.COM 8/14/2007 APPENDIXB AIR QUALITY LETTER/MAP Jump-to main content. Region 6 Multimedia Programs Serving Louisiana, Arkansas, Oklahoma, New Mexico, Texas and 65 Tribes Contact Us Search: oAll EPA @This Area • You are here: EPA Home • Region 6 • Air • Air Nonattainment Area Redesignations Multimedia Quick Finder Air Programs Asbestos Children's Health Hazardous Waste Lead-based Paint (ReRA) Non-hazardous & Solid Wastes Pesticides Radiation Radon Scrap Tires Toxic Release Inventory (TRI) Underground Storage Waste-To-Energy Tools for Schools More Topics .... Tanks A ..~' N' ...* "rt A.a A. "'.?' " I,II, "Nil: .a.'••" , ' Section 107(d)(3) of the Clean Air Act (CAA) specifies procedures and requirements for changing an area's designation. These conditions are as follows: • The Administrator has determined that the National Ambient Air Quality Standards (NAAQS) have been attained. • The area in question has a fully approved implementation plan under Section HO(k) of the CAA. • A determination has been made that the improvement in air quality is due to permanent and enforceable reductions in emissions. • An approvable maintenance plan has been submitted as specified under Section 175A. This demonstration of maintenance includes continued ambient monitoring, retention of current control strategies, an emissions budget, and contingency measures to be implemented should the area experience future air quality problems. In some cases, the requirements for an emissions budget may be waived if certain criteria are met. This relaxed approach is known as a limited maintenance plan. • All applicable requirements have been met under Section 110, concerning general SIP requirements, and Part D, concerning nonattainment plans. Current Status: Region 6 has redesignated the following areas to attainment for ozone since 1990: Texas -Victoria County Louisiana -the parishes of Beauregard, Grant, Lafayette, Lafourche**, St. James, St. Mary, Jefferson, Orleans, St. Charles, and St. Bernard, Pointe Coupee, and Calcasieu. **Note! On November 18, 1994, the State of Louisiana submitted a maintenance plan and redesignation request for Lafourche Parish to EPA for approval. On August 12,1995, EPA issued a direct final notice approving Louisiana's request. The EPA's redesignation policy includes language to address how EPA will respond to a monitored violation of the NAAQS prior to the effective date of a redesignation action. The ozone monitor in Lafourche Parish recorded a fourth exceedance of the ozone standard on August 27, 1995, during the 30-day comment period of EPA's approval action on the redesignation request. The EPA did not withdraw its approval of the redesignation action, and it took effect on October 10, 1995. The fourth exceedance waS validated on January 10, 1996. EPA's action to allow the redesignation to move forward in light of the fourth exceedance was in conflict with the statute and EPA policy, as well as other notices of disapproval promulgated by EPA for areaS that had violated the NAAQS while their redesignation requests were pending. EPA, therefore, proposed to correct this error by changing the designation of Lafourche Parish to an ozone nonattainment area, and classifying it as an incomplete data area (62 FR 38237, July 17. 1997). Section Chief -Thomas Diggs (214) 665-7214; E-Mail: Diggs.Thomas@epamail.epa.gov Section address: U.S. EPA Region 6, 6PD-L 1445 Ross Avenue Dallas TX 75202-2733 EPA Headquarters Home pages 1. U.S. Environmental Protection Agency (EPA) .2. EPA Office of Air and Radiation (OAR) 3. EPA Office of Air Quality Planing and Standards (OAQPS) 4. EPA Office of Transportation and Air Quality 5. EPA Ozone transport assessment group (OTAG) 6. Technical Transfer Network State Web Sites_'EXlTolsc,aimeri 1. Texas Commission on Environmental Quality (TCEQ): http://www.tceq.state.tx.us/ 2. Louisiana Department of Environmental Quality (LDEQ): httg!/www.deq.state.la.us 3. Oklahoma Department of Environmental Quality (ODEQ): http://www.deq.state.ok.us 4. New Mexico Environment Department (NMED): http://www.nmenv.state.nm.us 5. Arkansas Department of Environmenatal Quality (ADEQ): http://www.adeq.state.ar.us 6. City of Albuquerque, New Mexico: http://www.cabq.gov Local Navigation • Region 6 Home • Air Programs • Asbestos • Children's Health • Indoor Air Quality • Lead-Based Paint • Pesticides • Radiation • Radon • RCRA Hazardous Waste • Solid Waste • Tools for Schools • Toxic Release Inventory • Underground Storage Tanks • EPA Home • Privacy and Security Notice • Contact Us Last updated on Tuesday, August 14th, 2007. http://www.epa.gov/earthlr6/6pd/air/pd-Vnon.htm Print As-Is Jump to main content. U.S4 Environmental Protection Agency Green Book .\ .-/ Contact Us I Erint Version Search: m!l ~p.~>Air & Radiation> AicQ!J.a!i.ty Planning & Stand~rQli > Green.62Qk > Criteria Pollutant Area Summary Report Criteria Pollutant Area Summary Report As of March 02, 2006 State: Simple Name Population Number of Pollutant Nonattainment Area Name (1000s) Counties Classification AK: Anchorage PM-10 Eagle River, AK 195 1 Moderate AKI Juneau PM-10 Juneau, AK 14 1 Moderate ALI Birmingham 8-Hr Ozone Birmingham, AL 805 2 Subpart 1 PM-2.S Birmingham, AL 808 3 Nonattainment AZ: Ajo PM-10 Ajo (Pima County), AZ 8 1 Moderate AZ: Douglas (Cochise county) PM-10 Douglas (Cochise County), AZ 16 1 Moderate 802 Douglas (Cochise County), AZ 16 1 Primary AZI Hayden/Miami PM-10 Hayden/Miami, AZ 4 2 Moderate S02 Hayden (Pinal County), AZ 2 1 Primary S02 Miami (Gila County), AZ 2 1 Primary AZ: Nogales PM-10 Nogales, AZ 25 1 Moderate AZ: Paul Spur (Cochise County) PM-10 Paul Spur, AZ 1 1 Moderate AZ: Phoenix-Mesa 8-Hr Ozone Phoenix-Mesa, AZ 3,086 2 Subpart 1 PM-10 Phoenix, AZ 3,112 2 Serious AZI Rillito (pima County) PM-10 Rillito, AZ 1 1 Moderate AZ: San Manuel S02 San Manual (Pinal County), AZ 8 1 Primary AZ, Yuma PM-I0 Yuma, AZ 82 1 Moderate CAl Amador and Calaveras Cos (Central Mtn), 8-Hr Ozone Amador and Calaveras Cos (Central Mtn), CA 76 2 Subpart 1 CAl Chico 8-Hr Ozone Chico, CA 203 1 Subpart 1 CAl Imperial County 8-Hr Ozone PM-10 Imperial Co, CA Imperial Valley, CA 142 120 1 1 Marginal Serious CAl Kern Co (Eastern Kern) 8-Hr Ozone Kern Co (Eastern Kern), CA 99 1 Subpart 1 CA: Los Angeles-San 8-Hr Ozone PM-10 PM-10 Bernardino Cos{W Mojave) Los Angeles-San Bernardino COB(W Mojave) ,CA Coachella Valley, CA San Bernardino Co, CA 656 182 199 2 1 1 Moderate Serious Moderate CAl Los Angeles-South Coast Air Basin Carbon Monoxide Los Angeles South Coast Air Basin, 8-Hr Ozone Los Angeles South Coast Air Basin, CA CA 14,594 14,594 4 4 Serious Severe 17 PM-10 PM-2.5 Los Angeles South Coast Air Basin, Los Angeles-South Coast Air Basin, CA CA 14,594 14,594 4 4 Serious Nonattainment CAl Mariposa and 8-Hr Ozone Tuolumne Cos (Southern Mtn) Mariposa and Tuolumne Cos (Southern Mtn),CA 72 2 Subpart 1 CAl Mono County PM-IO Mono Basin, CA o 1 Moderate CAl Nevada Co. 8-Hr Ozone {Western Part) Nevada Co. (Western Part), CA 78 1 Subpart 1 CAl Owens Valley PM-10 Owens Valley, CA 7 1 Serious CAl Riverside Co, (Coachella Valley) 8-Hr Ozone Riverside Co, (Coachella valley), CA 325 1 Serious CAl Sacramento Metro 8-Hr Ozone Sacramento Metro, CA 1,978 6 Serious PM-10 Sacramento Co, CA 1,223 1 Moderate CAl San Diego 8-Hr Ozone San Diego, CA 2,813 1 Subpart 1 CAl San Francisco-Bay 8-Hr Ozone Area San Francisco Bay Area, CA 6,542 9 Marginal CA: San Joaquin Valley 8-Hr Ozone PM-10 PM-2.5 San Joaquin Valley, San Joaquin Valley, San Joaquin Valley, CA CA CA 3,191 3,080 3,191 8 7 8 Serious Serious Nonattainment CAl Searles Valley PM-10 PM-10 Coso Junction, Trona, CA CA 7 4 1 1 Moderate' Moderate CA: Sutter Co (Sutter Buttes) 8-Hr Ozone Sutter Co (Sutter Buttes), CA o 1 Subpart 1 CAl ventura County 8-Hr Ozone Ventura Co, CA 753 1 Moderate COl Denver-Boulder-Greeley-Ft Collins-Love. 8-Hr Ozone Oenver-Boulder-Greeley-Ft Collins-Love., CO 2,812 9 Subpart 1 EAC CTI Greater Connecticut 8-Hr Ozone Greater Connecticut, CT 1,544 5 Moderate DC-MO-VA: Washington 8-Hr Ozone Washington, OC-MO-VA 4,452 15 Moderate PM-2.5 Washington, OC-MO-VA 4,378 14 Nonattainment GAl Atlanta 8-Hr Ozone Atlanta, GA 4,228 20 Marginal PM-2.5 Atlanta, GA 4,232 22 Nonattainment GA: Macon 8-Hr Ozone Macon, GA 154 2 Subpart 1 PM-2.5 Macon, GA 155 2 Nonattainment GA: Murray County (Chattahoochee Nat. Forest Mtns) 8-Hr Ozone Murray Co (Chattahoochee Nat Forest), GA 1 1 Subpart 1 GA: Rome, GA PM-2.5 Rome, GA 91 1 Nonattainment GUI Piti Power Plant S02 Piti, GU 1 1 primary GU: Tanguieson Power Plant S02 Tanguisson, GU 1 1 Primary IDI Bonner County (Sandpoint) PM-10 Bonner Co (Sandpoint), 10 37 1 Moderate ID: Pocatello PM-10 Portneuf Valley, ID 66 2 Moderate PM-10 Fort Hall Reservation, 10 1 2 Moderate ID: Shoshone County PM-lO Shoshone Co, ID 10 1 Moderate PM-10 Pinehurst, 10 2 1 Moderate IL-IN: Chicago-Gary-Lake County 8-Hr Ozone Chicago-Gary-Lake County, IL-IN 8,758 10 Moderate PM-2.5 Chicago-Gary-Lake County, IL-IN 8,758 10 Nonattainment IN: Evansville PM-2.5 Evansville, IN 277 6 Nonattainment IN: Fort Wayne 8-Hr Ozone Fort Wayne, IN 332 1 Subpart 1 INI Indianapolis 8-Hr Ozone Indianapolis, IN 1,607 9 Subpart 1 PM-2.5 Indianapolis, IN 1,329 5 Nonattainment IN: La Porte County 8-Hr Ozone La Porte, IN 110 1 Marginal IN: South Bend-Elkhart 8-Hr Ozone South Bend-Elkhart, IN 448 2 subpart 1 KY-IN: Louisville 8-Hr Ozone Louisville, KY-IN 968 5 Subpart 1 PM-2.5 Louisville, KY-IN 939 5 Nonattainment LA: Baton Rouge 8-Hr Ozone Baton Rouge, LA 636 5 Marginal MA: Boston-Lawrance-Worcester (E. Mass) 8-Hr Ozone Boston-Lawrence-Worcester (E. MA), MA 5,534 10 Moderate MA: Springfield (Western Mass) 8-Hr Ozone Springfield (Western MA), MA 815 4 Moderate MOl Baltimore 8-Hr Ozone Baltimore, MD 2,512 6 Moderate PM-2.5 Baltimore, MD 2,512 6 Nonattainment MO: Kent County and Queen Anne's County 8-Hr Ozone Kent and Queen Anne's Cos, MD 60 2 Marginal MO: Washington County 8-Hr Ozone (Hagerstown), Me Washington Co (Hagerstown), MD 132 1 Subpart 1 EAC PM-2.5 Martinsburg, WV-Hagerstown, MD 208 2 Nonattainment ME: Hancock, Knox, Lincoln & Waldo Cos 8-Hr Ozone Hancock, Knox, Lincoln & Waldo Cos, ME 92 4 Subpart 1 ME: Portland 8-Hr Ozone Portland, ME 457 4 Marginal 1.fI: Allegan County 8-Hr Ozone Allegan Co, MI 106 1 Subpart 1 MI: Benton Harbor 8-Hr Ozone Benton Harbor, MI 162 1 Subpart 1 MIl Benzie County 8-Hr Ozone Benzie Co, MI 16 1 Subpart 1 MI: Cass County 8-Hr Ozone Cass Co, MI 51 1 Marginal MIl Detroit-Ann Arbor-Flint 8-Hr Ozone Detroit-Ann Arbor, MI 4,932 8 Marginal PM-2.5 Detroit-Ann Arbor, MI 4,833 7 Nonattainment MIl Flint 8-Hr Ozone Flint, MI 524 2 Subpart 1 MI: Grand Rapids 8-Hr Ozone Grand Rapids, MI 813 2 Subpart 1 MIl Huron County 8-Hr Ozone Huron Co, MI 36 1 Subpart 1 MI: Kalamazoo-Battle Creek 8-Hr Ozone Kalamazoo-Battle Creek, MI 453 3 Subpart 1 MIl Lansing-East Lansing 8-Hr Ozone Lansing-East Lansing, MI 448 3 Subpart 1 MI: Mason County 8-Hr Ozone Mason Co, MI 28 1 Subpart 1 MIl Muskegon 8-Hr Ozone Muskegon, MI 170 1 Marginal MO-IL: St. Louis 8-Hr Ozone St Louis, MO-IL 2,505 9 Moderate Lead Jefferson County (part)i Herculaneum, MO 2 1 PM-2.5 St. Louis, MO-IL 2,487 9 Nonattainment MT: Billings/Laurel S02 Laurel Area (Yellowstone County), MT 6 1 Primary MT: Butte PM-10 Butte, MT 35 1 ~1oderate MT: Columbia Falls (Flathead County) PM-10 columbia Falls, MT 4 1 Moderate MT: East Helena Lead East Helena Area (Lewis and Clark Co.), MT 2 1 S02 East Helena Area (Lewis and Clark Co.), MT 2 1 Primary, Second MT: Kalispell (Flathead County) PM-10 Kalispell, MT 15 1 Moderate MT: Lame Deer PM-10 Lame Deer, MT 1 1 Moderate MT: Libby PM-10 Libby, MT 3 1 Moderate PM-2.5 Libby, MT 3 1 Nonattainment MT: Missoula Carbon Monoxide Missoula, MT 52 1 Moderate <= 12. PM-10 Missoula, MT 52 1 Moderate MT: Polson (Lake County) PM-10 Polson, MT 4 1 Moderate MT: Ronan (Lake County) PM-10 Ronan, MT 3 1 Moderate MT: Thompson Falls PM-10 Sanders County (part)iThompson Falls and vicini 1 1 Moderate MT: Whitefish (Flathead County) PM-10 Flathead CountYi Whitefish and vicinity, MT 5 1 Moderate NC: Fayetteville 8-Hr Ozone Fayetteville, HC 303 1 Subpart 1 EAC NC: Greensboro-Winston-salem-High Point 8-Hr Ozone Greensboro-Winston Salem-High Point, NC 1,286 8 Marginal EAC PM-2.5 Greensboro-Winston Salem-High Point, NC 568 2 Nonattainment NC: Haywood and Swain Cos (Great Smoky Mtn NP) 8-Hr Ozone Haywood and Swain Cos (Great Smoky NP), NC o 2 Subpart 1 NC: Hickory-Morganton-Lenoir 8-Hr Ozone PM-2.5 Hickory-Morganton-Lenoir, Hickory, NC NC 310 142 4 1 Subpart 1 EAC Nonattainment NC: Raleigh-Durham-Chapel Hill 8-Hr Ozone Raleigh-Durham-Chapel Hill, NC 1,244 8 Subpart 1 NCI Rocky Mount 8-Hr Ozone Rocky Mount, NC 143 2 Subpart 1 NC-SC: Charlotte-Gastonia-Rock Hill 8-Hr Ozone Charlotte-Gastonia-Rock Hill, NC-SC 1,477 8 Moderate NH: Boston-Manchester-portsmouth(SE} 8-Hr Ozone Boston-Manchester-Portsmouth(SE),NH 697 4 Moderate NMI Anthony PM-10 Anthony, NM 3 1 Moderate NY: Las Vegas Carbon Monoxide 8-Hr Ozone PM-10 Las Vegas, NV Las Vegas, NV Clark Co, NY 479 1,349 1,376 1 1 1 Serious Subpart 1 Serious NY: Reno Carbon Monoxide PM-10 Reno, NV Washoe Co, NV 179 339 1 1 Moderate Serious <= 12. NY: Albany-Schenectady-Troy 8-Hr Ozone Albany-Schenectady-Troy, NY 924 7 Subpart 1 NY: Buffalo-Niagara Falls 8-Hr Ozone Buffalo-Niagara Falls, NY 1,170 2 Subpart 1 NY: Essex County; 8-Hr Ozone Whiteface Mountain Essex Co (Whiteface Mtn), NY 1 1 Subpart 1 NY: Jamestown 8-Hr Ozone Jamestown, NY 140 1 Subpart 1 NY: Jefferson County 8-Hr Ozone Jefferson Co, NY 112 1 Moderate NY: Poughkeepsie 8-Hr Ozone poughkeepsie, NY 717 3 Moderate NY: Rochester 8-Hr Ozone Rochester, NY 1,098 6 Subpart 1 NY-NJ-CT: New York-No 8-Hr Ozone PM-10 PM-2.5 New Jersey-Long Island New York-No New Jersey-Long Island,NY-NJ­CT New York Co, NY New York-No New Jersey-Long Island,NY-NJ-CT 19,634 1,537 19,803 24 1 22 Moderate f;1oderate Nonattainment OH: Canton-Massillon 8-Hr Ozone PM-2.5 Canton-Massillon, Canton-Massillon, OH OH 378 378 1 1 Subpart 1 Nonattainment OH: Cleveland-Akron-Lorain 8-Hr Ozone PM-2.5 Cleveland-Akron-Lorain, Cleveland-Akron-Lorain, OH OH 2,946 2,775 8 7 Moderate Nonattainment OH: Columbus 8-Hr Ozone Columbus, OH 1,542 6 Subpart 1 PM-2.S Columbus, OH 1,449 5 Nonattainment OH: Dayton-Springfield 8-Hr Ozone Dayton-Springfield, OH 951 4 Subpart 1 PM-2.5 Dayton-Springfield, OH 852 3 Nonattainment OH: Lima 8-Hr Ozone Lima, OH 108 1 Subpart 1 OH: Toledo 8-Hr Ozone Toledo, OH 576 2 Subpart 1 OH-KY-IN: Cincinnati-Hamilton 8-Hr Ozone Cincinnati-Hamilton, OH-KY-IN 1,892 9 Subpart 1 PM-2.S Cincinnati-Hamilton, OH-KY-IN 1,851 8 Nonattainment OH-PA: Youngstown-Warren-Sharon 8-Hr Ozone Youngstown-Warren-Sharon, OH-PA 715 4 Subpart 1 OH-WV: Steubenville-Weirton 8-Hr Ozone Steubenville-Weirton, OH-WV 132 3 Subpart 1 PM-2.5 Steubenville-Weirton, OH-Irv 132 3 Nonattainment OR: Eugene-Springfield PM-10 Eugene-Springfield, OR 179 1 Moderate OR: LaGrande PM-10 LaGrande, OR 12 1 Moderate OR: Lakeview PM-10 Lake Co, OR 3 1 Moderate OR: Medford PM-10 Medford-Ashland, OR 78 1 Moderate OR: Oakridge PM-10 Lane Co, OR 3 1 Moderate OR: Salem Carbon Monoxide Salem, OR 135 2 Not Classified PAl Allentown-Bethlehem-Easton 8-Hr Ozone Allentown-Bethlehem-Easton, PA 638 3 Subpar-t 1 S02 Warren Co, NJ 102 1 Primary, Second PAl Altoona 8-Hr Ozone Altoona, PA 129 1 subpart 1 PAl Clearfield and Indiana Cos 8-Hr Ozone Clearfield and Indiana Cos, PA 173 2 Subpart 1 PAl Erie 8-Hr Ozone Erie, PA 281 1 Subpart 1 PAl Franklin County 8-Hr Ozone Franklin Co, PA 129 1 Subpart 1 PAl Greene County 8-Hr Ozone Greene Co, PA 41 1 Subpart 1 PAl Harrisburg-Lebanon-Carlisle 8-Hr Ozone Harrisburg-Lebanon-Carlisle, PA 629 4 Subpart 1 PM-2.S Harrisburg-Lebanon-Carlisle, PA 586 3 Nonattainment PAl Johnstown 8-Hr Ozone Johnstown, PA 153 1 Subpart 1 PM-2.5 Johnstown, PA 164 2 Nonattainment PAl Lancaster 8-Hr Ozone Lancaster, PA 471 1 Marginal PM-2.S Lancaster, PA 471 1 Nonattainment PAl Pittsburgh-Beaver 8-Hr Ozone PM-2.5 Valley Pittsburgh-Beaver Liberty-Clairton, Valley, PA PA 2,431 22 7 1 Subpart 1 Nonattainment PM-2.S Pittsburgh-Beaver Valley, PA 2,195 8 Nonattainment S02 Armstrong Co, PA 5 1 Primary PAl Reading 8-Hr Ozone PM-2.S Reading, Reading, PA PA 374 374 1 1 Subpart 1 Nonattainment PAl Scranton-Wilkes-Barre 8-Hr Ozone Scranton-Wilkes-Barre, PA 699 4 Subpart 1 PAl State College 8-Hr Ozone State College, PA 136 1 Subpart 1 PAl Tioga County 8-Hr Ozone Tioga Co, PA 41 1 Subpart 1 PAl York 8-Hr Ozone PM-2.5 York, York, PA PA 473 382 2 1 Subpart 1 Nonattainment PA-NJ-MC-DE: Philadelphia-Wilmin-Atlantic City 8-Hr Ozone Philadelphia-Wilmin-Atlantic Ci,PA-NJ-MD-DE PM-2.5 Philadelphia-Wilmington, PA-NJ-DE 7,333 5,537 18 9 Moderate Nonattainment PR: Guaynabo County PM-I0 Mun. of Guaynabo, PR 92 1 Moderate RI: Providence 8-Hr Ozone (all of RI) Providence (All RI), RI 1,048 5 Moderate SCI Columbia 8-Hr Ozone Columbia, SC 495 2 Subpart 1 EAC SC: Greenville-Spartanburg-Anderson 8-Hr Ozone Greenville-Spartanburg-Anderson, SC 799 3 Subpart 1 EAC TN: Johnson City-Kingsport-Bristol B-Hr Ozone Johnson City-Kingsport-Bristol, TN 207 2 Subpart 1 EAC TN: Knoxville 8-Hr Ozone PM-2.S Knoxville, Knoxville, TN TN 714 599 7 5 Subpart 1 Nonattainment TN: Nashville B-Hr Ozone Nashville, TN 1,098 5 Subpart 1 EAC TN-AR: Memphis 8-Hr Ozone Memphis, TN-AR 948 2 Marginal TN-GAl Chattanooga 8-Hr Ozone Chattanooga, TN-GA 372 3 Subpart 1 EAC PM-2.S Chattanooga, AL-TN-GA 424 4 Nonattainment TN-KYI Clarksville-Hopkinsville 8-Hr Ozone Clarksville-Hopkinsville, TN-KY (TN portion) 135 1 Subpart 1 TX: Beaumont-Port Arthur 8-Hr Ozone Beaumont-Port Arthur, TX 385 3 Marginal TXI DallaS-Fort Worth 8-Hr Ozone Dallas-Fort Worth, TX 5,031 9 Moderate TXI El Paso Carbon Monoxide El Paso, TX 62 1 Moderate <= 12. PM-I0 El Paso Co, TX 564 1 Moderate TX: Houston-Galveston-Brazoria 8-Hr Ozone Houston-Galveston-Brazoria, TX 4,670 8 Moderate TXI San Antonio 8-Hr Ozone San Antonio, TX 1,560 3 Subpart 1 EAC UTI ogden PM-I0 Ogden, UT 77 1 Moderate UTI Provo PM-I0 Utah Co, UT 369 1 Moderate UTI Salt Lake City PM-I0 Salt Lake Co, UT 898 1 Moderate S02 Salt Lake Co, UT 898 1 Primary, Second UTI Tooele County S02 Tooele Co, UT 41 1 Primary, Second VAl Frederick County 8-Hr Ozone Frederick Co, VA 83 2 Subpart 1 EAC VA: Norfolk-Virginia Beach-Newport News (Hampton Roads) 8-Hr Ozone Norfolk-Virginia Beach-Newport News (HR),VA 1,542 13 Marginal VA: Richmond-Petersburg 8-Hr Ozone Richmond-Petersburg, VA 919 9 Marginal VA: Roanoke 8-Hr Ozone Roanoke, VA 236 4 Subpart 1 EAC WI: Door County 8-Hr Ozone Door Co, WI 28 1 Subpart 1 WI: Kewaunee County 8-Hr Ozone Kewaunee Co, WI 20 1 Subpart 1 WI: Manitowoc County 8-Hr Ozone Manitowoc Co, viI 83 1 Subpart 1 WI: Milwaukee-Racine 8-Hr Ozone Milwaukee-Racine, WI 1,839 6 Moderate WII Sheboygan 8-Hr Ozone sheboygan, WI 113 1 Moderate WV: Berkeley and Jefferson Counties 8-Hr Ozone Berkeley and Jefferson Counties, WV 118 2 Subpart 1 EAC WV: Charleston 8-Hr Ozone Charleston, WV 252 2 Subpart 1 PM-2.5 Charleston, WV 252 2 Nonattainment WV: Weirton PM-10 ~leirton, WV 15 2 Moderate WV-KY: Huntington-Ashland 8-Hr Ozone Huntington-Ashland, lVV-KY 189 3 Subpart 1 PM-2 . S Huntington-Ashland, WV-KY-OH 341 9 Nonattainment S02 Boyd County (part) , KY 50 1 Primary WV-OHI Parkersburg-Marietta 8-Hr Ozone Parkersburg-Marietta, WV-OH 151 2 Subpart 1 PM-2.5 Parkersburg-Marietta, WV-OH 153 3 Nonattainment WV-OH: Wheeling 8-Hr Ozone Wheeling, WV-OH 153 3 Subpart 1 PM-2.S Nheeling, WV-OH 153 3 Nonattainment WY: Sheridan PM-10 Sheridan, 'NY 16 1 Moderate ]:PA Home IPrivacY and Security Notice IContact Us Last updated on Wednesday, March 15th, 2006 URL: hltp:/Iwww.epa.gov/oar/oaqps/greenbk/ancl2.html Executive Summary The New Orl~s Ozone Maintenance Areal, which includes the parishes of Jefferson, Orleans, St. Bernard and St. Charles, was designated under section 107 of the 1977 Clean Air Act as nonattainment for the National Ambient Air Quality Standard (NAAQS) for ozone on September 11, 1978. Following the federal Clean Air Act Amendments (CAAA) of 1990, the New Orle2ns Ozone Maintenance Area was classified as a "transitional" ozone nonattainment area pursuant to sections 107(d) and 181(a) of the CAAA (56 FR 56694). Following the collection of the required ambient ozone air monitoring data needed for redesignation of the New Orleans Ozone Maintenance Area, an ozone maintenance plan was developed in accordance with section 17SA of the CAAA. On October 15, 1994, a redesignation request and an ozone maintenance plan were submitted to the Environmental Protection Agency (EPA). The EPA redesignated the New Orleans Ozone Maintenance Area to attainment for the one-hour ozone standard and approved the ozone maintenance plan effective December 1,1995. (60 FR 51354) On April 15, 2004, EPA designated and classified areas for the 8-hour ozone NAAQS of 0.08 parts per million (ppm) (69 FR 23858, April 30, 2004). For most areas these designations became effective June 15, 2004. EPA designated the New Orleans Ozone Maintenance Area as attainment/unclassifiable for the 8-hour ozone standard effective June 15,2004. Section 110(a)(1) of the CAAA requires that each state adopt and submit to EPA a plan which provides for implementation, maintenance and enforcement of the primary pollutant standard following the promulgation of a NAAQS for any air pollutant. States must submit Section 110(a)(1) I The New Orleans CMSA at the time ofthe 1994 maintenance plan submission was comprised ofsix parishes: Jefferson, Orleans, St. Bernard, St. Charles, St. John the Baptist and st. Tammany. Maintenance and contingency plans were not included in the action for the parishes St. John the Baptist and St. Tammany. St. John the Baptist Parish was previously redesignated to attainment and St Tammany Parish was never designated as nonattainment. New ()r1can.~ (h.one Maintenance Area Section 110(:\)(1) Maintenance Irma! June 2007 maml;t:Ulllll(;C plans no later than three (3) years the pttprt1v,," date of the area's S-how: ozone NAAQS designation. On May 20. 2005, EPA issued "Maintenan&e Plan Guidan&e Dommen! for Ctrlain 8-hollr Ozone Anas Section 110(0)(1) of the Clean AirAcl'. The gullJ.alll:::e specifies States include the fonowing components in the maintenance plan: ... Attainment inventory; ... Maintenance demonstration; ., Ambient ait quality monitoring; ., of continued and ., Contingency plan. the ozone Ull'LUI1LCUaIl'(;t;: plan for Maintenance Area which is a revision to the Louisiana State Implementation Plan .UoU.uJJJ'UE; the requirements 11O(a)(1) under the 8~hour ozone standard. This plan IS based on 2002 inventory was before the devastation to the area by Hut:ricaoe r..:65 dBA YES Par ExceUence Christian Academy 924 N Prieur St, New Orleans, LA 70112 700 62 66 >65 dBA YES Sixth enion Baptist Church 2(119 Orleans Ave, New Orleans, LA 70112 50 70 89 ~65 dBA YES Gr<'2tcr Galillee Baptist Church 2013 Saint Ann St, New Orlcans LA 70112 250 51 75 >65 dBA YES Mount Zion Baro.. Church 2200 Dumaine St, New Orleans, LA 70112 550 61 68 >65 dBA YES I New Creation Spiritual Church 2429 Saint Ann St, New Orleans, LA 70112 300 51 73 >65 dBA YES Nazarene Baptist Church 2510 Orleans A,'e, New Orleans, LA 70112 50 62 89 >65 dBA YES Greater Old Zion Missionary Baptist Church 655 N Roehcbla\'c St, New Orleans, LA 70112 50 53 89 >65 dBA YES Old Zion Baptist Church 430 N Johnson St, New Orle ..ns, LA 70112 600 56 67 >65dBA YES , Southern Scrap Material Compam' (General Laundn-) 2525 Lafitte St, New Orlcans, LA 70112 200 53 77 >65 d13A YES Esplanade Ridge Historical District Esplanade Ave bit Rampan and Bavou St. John FEMA Trailer Park Galvcz/ Claiborne / Latine/ St_ Loui, . NW Comer 200 60 77 >65 dBA YES NEComer 50 60 89 ~65 d13A )l~S SWComer 300 76 76 >65d13A )~S SE Comer 50 75 89 ~65dBA YES Community Center 2201 Lafinc St, New Orleans, LA 70112 100 64 83 >65 dBA )1~ Public S,,;mminR Pool N Prieur/Lafitte 100 61 83 ~65 dBA YES I Elevated noise level due to [-10 EIe,-arcd noise level due to '·10 ·Bascd on an estimated on-sire average construction noise level of 89 dBA. Noise level is an estimate of the consrrucuon noise at the closcst boundary of the senSIQ\'e property SECI"ION 106 REVIEW AND DOCUMENTATION LAF1TI"E HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUTIIORITY OF NEW ORLEANS JANUARY 2007 FIGURES 15060165 Lafine Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. SECllON 106 REV IEW AND DOCUMENTA'nON LAf'ITTE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA r lOUSING AUllIORIl1' Of' NEW ORLEANS JANUARY 2007 FIGURE 1 AREA OF POTENTIAL EFFECT 15060165 Lafitte Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. SECTION 106 REVIEW AND DOCUMENTATION LAFITIE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUlll0RITY OF NEW ORLEANS JANUARY 2007 FIGURE 2 BASELINE NOISE LEVELS 15060165 Lafinc Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. SECTION 106 REVIEW AND DOCUMENTATION LAFITTE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AU1l-rORllY OF NEW ORLEANS JANUARY 2007 FIGURE 3 CONSTRUCTION NOISE LEVELS 15060165 Lofinc Section 106 Hcport.doc U. S. RISK MANAGEMENT, L.L.C. SECTION 106 REVIEW AND DOCUMENTATION LAFITTE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA I·IOUSING AUUIORllY OF N EW ORLEANS JANUARY 2007 FIGURE 4 PROPOSED CONSTRUCTION TRAFFIC FLOW 15060165 Lafitte Section 106 Rcport.tloc U. S. RISK MANAGEMENT, L.L.C. SECfION 106 REVIEW AND DOCUMENTATION LAFI1TE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUTI-IORITY OF NEW ORLEANS JANUARY 2007 APPENDICES 15060165 Lafitte Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. SECTION 106 REvIEW AND DOCUMENTATION LAFITI"E HOUSING DeVELOPMENT, New ORLEANS, LOUISIANA HOUSING AU'll-IORlTI' OF NEW ORLEANS JANUARY 2007 APPENDIX A NRHP LISTING DOCUMENTATION GENERAL LAUNDRY BUILDING ESPLANADE RIDGE HISTORIC DISTRICT 15060165 Lafitte Section \06 Report.doc U. S. RISK MANAGEMENT, L.L.C. DESCRIBE THE PRESENT AND ORIGINAL (if known) PHYSICAL APPEARANCE Only the facade is of concern here, that is, an area one room deep, about 20 feet. It is still in very good condition, except for some graffiti near the base of the walls. Most importantly, the terra-cotta motifs still retain their full colors. It is hoped the color photographs enclosed will enter into the consideration, as the building's colorful motifs are one of its strongest selling points. The building has two shallow projecting pavilions at either end for the entrances. The zigzag colored motifs at the cornice and the sun-burst and arrow shaped tiles on top remind one of Aztec Indian motifs. The roof line is undulating, with blue tiles embossed with arrows and flower motifs. Beneath this cornice is a course of red oblong openings. Between the end bays noted above is a aeries of pilasters, four larger ones reaching to the cornice, and with two inside each section created by the larger ones. Each is capped off with green capitals of terra-cotta Art Deco motifs. The larger pilasters are capped with a square cap-like device with a sunrise effect surrounded with floral swirls. Half way down the facade are fluted panels at the demarcation line between the two stories. A string course of diamond motifs in red terra cotta runs above these panels, and a green acroterian-like motif in terra-cotta is set at the base of the panels, serving as an enframement for the windows of the lower floor. The building, itself appears to be plaster over brick or blocks, and the colorful Art Deco motifs appear to be terra-cotta. The building is two stories, one room deep, about 20 feet in depth a one story garage having a few of the colorful motifs stands at the left of the building and is relatively unimportant. A metal shed behind this facade is even less important. The building appears intact with all the Art Deco motifs in their original unfaded color as it was when erected in 1939. The effect of colors, zigzag, undulations, Aztec-temple motifs, diamonds, sun rises and rhythmic effect of the pilasters has an arresting appearance. It epitomizes, as does no other Art Deco building in New Orleans (there are only about three intact examples left), the Art Deco approach of geometric patterns, rich colors and reliance on Indian motifs. STATEMENT OF SIGNIFICANCE This building is one of a handful -three at most -of intact Art Deco buildings surviving in New Orleans. It along has the architectural detail in still-vivid color which the others do not. It could appropriately be called the Aztec Style because of the motifs of this particular brand of Art Deco. One of the other two surviving outstanding Art Deco buildings is slated for demolition soon (the National American Bank Building.). It is requested that only the facade be preserved. The Postoffice Dept. has planned to demolish the building for a Parking lot at the rear for a new Mid-City Station which will be on the street behind the Gen. Laundry Bldg. Thus, the station will run through the block. It is hereby proposed that the facade ­one room deep -be saved for some useful purpose for the Postoffice , about 20 feet deep, and the rear, which is a metal shed, be demolished for the parking lot and the new Postoffice. At the N. Rocheblve St. side of the Laundry is what was a garage. This could also be demolished to give access to the parking lot, leading in from St. Peter St. The architects for the Postoffice, Curtis & Davis, are somewhat favorable to this idea, but the Postoffice has not given its approval. The choice is this: if we demolish the facade of only a 30 foot depth, we have gained a slightly larger parking lot; but if we preserve the facade, we have provided a little more working area for the Postoffice and saved this really unique Art Deco building for future generations to marvel at. MAJOR BIBLIOGRAPHCAL REFERENCES New Orleans States-Item newspaper August 7, 1974 " " " August 14,1974 September 11, 1974 Letter from La. Landmarks SOciety Letter from Prof. Bernard Lemann, Tulane Univ. Architecture School Inspection made by Samuel Wilson, Jr., Architect and Henry Krotzer of Koch & Wilson, Architects at request of U. S. Dept. of Interior; their report was favorable for preservation of facade. Koch & Wilson phone no. is 504-581-7023 Letter from Raymond Boudreaux, Architect to Postmaster to protest demolition Describe the present and original (if known) physical appearance Esplanade Ridge is generally residential with scattered neighborhood commercial strips. The residential structures are mostly one and one-half story buildings, with some two-story structures, especially on and around the major boulevards. The majority of the buildings are wooden, and colors are often a variety of pastels. Designs range from houses by noted architects such as Henry Howard, James Gallier, Sr. , and Jr., William Fitzner, Alexander Castaing, and William and James Freret, to carpenter-designed shotguns. Late nineteenth and early twentieth century houses have filled in the once large lots of earlier buildings. These later houses were built closely together so that the distance between two houses was often less than the width of one house. As a result, the residential back streets throughout the district have an enclosed, spatially defined character. Major boulevards, such as Esplanade Avenue, Broad Street, and Ursuline Street, are wide and generally tree-lined with park.-like neutral grounds in the center. Some of the most pretentious residences in the city are set along these boulevards. The few commercial structures in the area are located in remodeled residential structures. There are seven major house types in the district: 1. The creole cottage: This pre-Civil War house type, which accounts for about 34% of the buildings in the area, makes the district unusual among 19th century extensions of the original city of New Orleans. Other areas were almost completely dominated by English and American house types. The creole cottage occurs in about 10 variations. These include sub-types based upon different materials of construction, details, and variations in plan. 2. The large creole house, which is simply an enlarged and often later version of No.1. Houses of this type account for approximately 2% of the district's buildings. 3. The three bay two story house with a side hall plan. These mid and late 19th century houses show the Anglo-American influence. Most (approx. 75%) have galleries. Houses of the type account for approximately 7% of the district's buildings. 4. The raised villa: These are one and a half story, five-bay gallery fronted houses with Greek or Renaissance Revival details. Account for approx. 6% of the district buildings. 5. The single and double shotgun, with late Renaissance Revival or Eastlake details. 6. Side hall shotgun both single and double. Shotgun houses as a whole represent approximately 43% of the district's structures. 7. The early 20th century eclectic mode. These are mainly bungalow colonial Revival, or mission style structures representing approximately 8% of the district's buildings. It is the mixture of these building types, and in particular the mixture with French Creole architecture, which gives the district its identity and character. There is no one period or style that predominates. As such the district represents many generations of New Orleans architecture. Boundaries were drawn to encompass the area to which this character extends. Areas of purely 20th century character have been excluded. In addition boundaries were drawn to respect the historical boundaries of growth and development in the area traditionally known as Esplanade Ridge. Typical Examples: House Type #1 Creole Cottages. The house at 1234 N. Rocheblave embodies many of the typical features. These include its hall-less plan, two rooms wide and two rooms deep, its central chimney set between the rooms with wrap-around mantels, its beaded exposed beams, and its four bay front with multiple entrance doors. The house also has handsome pilastered formers, board and batten shutters, gable parapets, and brick construction covered with scored stucco. This is an 18th century house type which appeared throughout the 19th century in various forms including Greek Revival and heavily bracketed turn-of-the-century Renaissance Revival. House Type #2 Large Creole Houses. The house at 2701 DeSoto Street is a larger version of the creole house plan, a hall-less plan two rooms wide and two rooms deep with central chimneys, and a four bay front which has multiple entrance doors. However, unlike house type #1 the rooms are about 50% larger and are pretentiously articulated. The House dates from the late 19th century and has scroll saw ornamentation, moveable louvre shutters and plate glass French doors. Type #3 The Three Bay Two Story House. The house at 1244 Esplanade Avenue is a mid 19th century two and a half story frame building which has ionic columns on the lower story and Corinthian columns upstairs. Though its details, including mantels, columns, and fenestration were mainly inspired by the Greek Revival the house also features a Renaissance Revival parapet, and double consoles over the columns. Later examples have more elaborate Renaissance Revival scroll work including large brackets and cast iron balconies. These two story buildings are found almost exclusively along Esplanade Avenue and Urseline Street and in the more urban southeastern portion of the district. In many cases the lower stories have been converted to commercial space, though the fenestration usually remains. House Type #4 The Raised Villa. Like its fellows, the house at 1347 Moss Street represents a mid 19th century Anglo-Americanized version of the Creole house type. It has the traditional one and a half story raised form, but with the addition of a central hall. a five bay symmetrical articulation, and a single front door in the center. In addition chimneys are placed against the end walls of the house rather than in the center. The frame house is noteworthy for its rusticated board front, and its Greek Revival details. Later examples have elaborate Renaissance Revival details, with parapets, Corinthian columns, scrollwork, and shall arch fenestration. House Type #5 Double Shotgun. The house at 1481 and 1479 N. Villere is a typical double shotgun house. It has a four bay front with two linear sets of rooms running from front to rear of the house. The frame building has a rusticated board front, with intricate brackets, full length windows, central chimneys, and a long narrow hip roof. Examples in the Queen Anne revival style are often treated with an ornamented front gables. House Type #6 Side Hall Double Shotgun House. The house at 1562 and 1564 Columbus Street is typical of the side hall double shotgun house. This six bay gables fronted house is ornamented with corner block fenestration, rusticated boards, inbricated shingles and scroll brackets. House Type #7 The Early 20th Century Eclectic Mode. The house at 1219 Lopes Street is a huge sprawling bungalow on a rusticated concrete base, with colonial style sash windows elliptical arches and ionic columns, on the porches. The tiled hip roof has dormers with Paladian windows and Spanish baroque gables. The house displays a mixture of styles often seen in early 20th century buildings in the district. St. Louis Cemetery #3 at the northern end of the is noteworthy for its many elaborately ornamented above ground tombs, burial vaults, and funerary sculpture. It makes a distinct architectural contribution to the district and is the final resting place for some of the district's most historically prominent citizens. It was therefore decided to include the cemetery within the district boundaries. Landmarks The following buildings are given as examples of outstanding architectural landmarks within the district. (This list is not comprehensive.) 1707 Esplanade Avenue (rear) -Dufour-Baldwin House 2275 Bayou Road -Chauffe-Reeves House 924 Moss Street -Plantation style house 1300 Moss Street -Spanish Custom House 1342 Moss Street -Evariste Blanc House 1206 North White Street -Italianate mansion with cornstalk fence 2863 Grande Route St. John -Josie Arlington House Note: Included with the nomination are maps showing the percentage concentration of each of the building types. The maps are of course approximate and do not consider intrusions as a percentage of the total. Intrusions The District has only 303 (about 7%) intrusions. The following buildings and structures are presented as samples. 1037 Broad Street 1233 Esplanade 1341 Esplanade 1500 block Esplanade 2401 Esplanade End of 2500 block Esplanade 3000 block Esplanade 1900 block Ursuline North Claiborne Avenue corner of St. Phillip Within the district are approximately 4,146 structures. These 4,146 structures are rated for architectural significance by the New Orleans District Landmarks Commission as follows: 8 Purple -Major National Importance 71 Blue -Major Local Importance 1421 Green -Local Historic or Architectural Importance 672 Red -Important but Altered Building 1671 Gold -Important to the Scene 303 Unrated -Detrimental to the Scene or Neutral 4146 Total Specific dates Builder/Architect Statement of Significance (in one paragraph) Criteria A & C The Esplanade Ridge Historic District represents an aspect of the city's French social and architectural heritage which parallels the American development of the Garden District. This can be seen in its almost 1500 creole style residence. It contains an even greater number of late-19th and early-20th century buildings. Taken as a whole, the area represents the architectural history of Louisiana from 1830 to 1930. More importantly it represents one of the largest and most impressive concentrations of fifty to one hundred and fifty year old buildings in the nation, with over four thousand buildings and only about three hundred intrusions. The history of the district is an important aspect of the history of the expansion of New Orleans from the 1830's through the 1920's. Development of the district occurred in a northwesterly direction from the Vieux Carre to Bayou St. John, and it took place in stages. Each time Esplanade Avenue was extended further into the outlying plantation lands, a new flurry of construction ensued. The Tr©m© area (see map), with its townhouses and small creole cottages, developed as a suburb of New Orleans in the early nineteenth century. The development of Esplanade Avenue past Rampart Street (the boundary of the present district1 occurred about 1835. By the mid-1850's, the wealth and cultural influence of American society dominated the architectural expression of the entire city. The sons of the early Creoles generally built structures of Anglo-American style. Many massive houses, often lavishly decorated, were built along and near Esplanade Avenue during this period. The Seventh Ward, downriver from Esplanade Avenue and above Rampart Street, developed as a suburb during the middle and late nineteenth century. Faubourg St. John and Faubourg Pontchartrain, both located near Bayou St. John, began to be settled in the mid-nineteenth century, but most of its structures date from 1880 to the 1930's. There are several plantation houses from the late eighteenth and early nineteenth centuries along Bayou St. John, but since full-scale development occurred only after 1900, early twentieth century eclectic buildings predominate. Major Bibliographical References Christovich, Mary Louise, Sally Kittredge Evans, and Roulhac Toledano, New Orleans Architecture. Volume 5: The Esplanade Ridge. Gretna: Pelican Publishing Co., 1977. New Orleans Chapter of the American Institute of Architects, A Guide to New Orleans Architecture. New Orleans, 1974. Pp. 56-61,112-115, 160-167. Research Report prepared by Esplanade Civic Association and Faubourg St. John Association, especially Christine Moe, Mercedes Whitecloud, Joanne Whitley, Christopher Freidrichs, Helen Rosenburg, Ray Nussbaum, Susann Gandolfo, Melinda Malik, and Joseph Newell. Copy in National Register file for Esplanade Ridge Historic District, State Historic Preservation Office, Baton Rouge. All boundaries are not exact. I. Boundaries follow rear property lines of the properties lacing Bayou SI. John. SECTION 106 REVIEW AND DOCUMENTATION LAFllTE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUll-IORITY OF NEW ORLEANS JANUARY 2007 APPENDIXB CORRESPONDENCE 15060165 Lafitte Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. HouslngAuthorltyofNewOrleans November 20, 2006 Mr. Robert J. Collins Deputy State Historic Preservation Officer Office of Cultural Development Department of Culture, Recreation & Tourism 1051 N. 31ll Street, Room 318-A Baton Rouge, LA 70804 Re: Redevelopment of Lafitte, St. Bernard, C.J. Peete and B.W. Cooper New Orleans, Louisiana Dear Mr. Collins: f In the aftermath of Hurricane Katrina, the Housing Authority of New Orleans (HANO) has undertaken an ambitious program to redevelop affordable housing units for the residents of New Orleans. The hurricane caused the evacuation of residents from nearly all of HANO's housing sites as most were damaged by flooding and hurricane force winds. HANO's goal is to redevelop its housing inventory in phases that are strategically planned to compliment property conditions; available resources including CDBG Road Home funds and GO Zone Low Income Housing Tax Credits from the Louisiana Housing Finance Agency; and redevelopment in the projects' neighborhood. On November 15, 2006, Roma Campanile and Jose Cintron from my staff met with you, Mike Varnado and Cheraki Williams to provide information on HANO's early planning efforts and to get your recommendations and guidance as HANO moves forward with the Section 106 Process in the redevelopment of the Lafitte, St. Bernard, B.W. Cooper and C.J. Peete public . housing sites with a mixture of rental and affordable homeownership units. Each redevelopment project will have a unique development program, different development partners and is located in a different New Orleans' neighborhood. Based upon the above, HANO would like to have this redevelopment effort considered as four separate projects. The projects included in this undertaking were constructed between 1941 and 1955. They are all located in Orleans Parish and in close proximity to the New Orleans Central Business District. HANO has procured an environmental consultant who is in the process of completing an environmental assessment for each project in accordance with 24 CFR 58. Moving forward, HANO has procured the services of a Section 106 consultant to work with us on conducting the Section 106 Process in accordance with 36 CFR 800. HANO plans to foster public participation and engage local residents and community stakeholders in the process including assistance in determining the Area of Potential Effect (APE) for each project. We have received a list of potential consulting parties from your Office and will be requesting their participation in this process. We will be meeting with representatives from the City of New Orleans' Historic Landmarks Commission this week to bring them up to date on our redevelopment efforts and to request their participation as a consulting party in this process. 4100 Touro Street· New Orleans, LA 70122 • (504) 670·3300 • FAX (504) 286-8778 The Housing Authority of New Orleans is an equal opportunity employer. Mr. Robert J. Collins November 20, 2006 Page 2 Based upon the proceeding information including the fact that HANO's redevelopment efforts are dependent upon extremely time-sensitive funding sources, we are requesting an expedited consultation with your Office (per 36 CFR 800.3(g) to enable HANO to negotiate a Memorandum of Agreement, if required, with the consulting parties identified during the Section 106 Process. Please advise by email or fax whether or not you agree with an expedited consultation approach for these four projects. We look forward to your reply and to working with your Office. HANO is committed to bringing back residents displaced by Katrina to safe, well-designed, affordable housing in a timely manner. We deeply appreciate your help and guidance in expediting this process and look forward to working with you on the redevelopment of New Orleans. Please feel free to contact Roma Campanile at 202-708-0614, extension 4880 with any concerns or questions you may have. Sincerely, CC: Mike Varnado, Architectural Historian Cheraki Williams, Archaeologist ANGELE DAVIS SECRET... RY §tat.e of tuout.stana MI'TCHI!:LL J. LANORIEU L.IEUTEN·...NT GOVERNOR OFFICE OF THE LIEUTENANT GOVERNOR PAM BREAUX DEPARTMENT OF CULTURE, RECREATION Be TOURISM ASSIST...NT SECRET...RY OFF'ICE OF CULTURAL. DEVELOPMENT DIVISION OF HIS"i"ORIC PRESERVATION December 1, 2006 Mr. WilHam C. Thorson Executive Administrator Housing Authority of New Orleans 4100 Tomo Street New Orleans, LA 70122 VIA EMAIL AND VIA US MAIL Re: Expedited Section 106 Review for the Redevelopment of Lafitte, St. Bemard, C.J. Peete, and BW. Cooper Housing Developments New Orleans, Orleans Parish, LA Dear Mr. Thorson: Thank you for your letter of November 20,2006, requesting an expedited Section 106 review for the above­referenced properties, as provided for in the federal regulations under 36 CFR 800.3(g). Ever since Hurricane Katrina, our office has worked hard to do away with unnecessary delays in the Section 106 process in the rebuilding of New Orleans. As we stated in our letter of June 26, 2006, to PPM Consultants and in our recent informal consultations with HUD, it is our opinion that the four referenced housing developments meet the criteria for listing in the National Register of Historic Places (NRHP). Actually, one of the four devetopments, C.J. Peete, is currently listed in the NRHP. All four developments and the neighborhoods in which they are located contribute to the history and culture of Louisiana and the City of New Orleans. We agree with your judgment that each of these properties should be treated individually using adevelopment program that would engage local residents, community stakeholders, and the preservation community in the Section 106 process... We look forward to working with you in restoring affordable housing in New Orleans and preserving the city's important history. If you have any questions, please contact Mike Vamado of our staff at (225) 342-8160. Sincerely, P~/f;u~ Pam Breaux State Historic Preservation Officer PB:MV:s c: Don Klima, Advisory Council on Historic Preservation Charlene Vaughan, Advisory Council on Historic Preservation David Blick, HUD Roma Campanile, HUD P.O. BOX 44~47 • BATON ROUGE, LOU1SIANA 70804-4247. PHONE (225) 342-8160. FAX (225) 342-8173. WWW.CRT.STATE.LA.US AN EQUAL OPPO·RTUNITY EMPLOYER C:\MyFilesISectlon 106 2004IHUD Housing Prof. 11·27-06IHUD Request for Exped. RW rev 12-1-06.doc w. D. Scott . group, Inc. November 20, 2006 Ms. Pam Breaux State Historic Preservation Officer Louisiana Division of Archaeology PO Box 44247 Baton Rouge, LA 70804 RE: Historic Status of Lafitte Housing Project and Adjacent Properties Our File #2947 Dear Ms. Breaux: The Scott Group would like to inquire about the historic status of the Lafitte Housing Project and adjacent properties. The above mentioned property is bounded by Orleans A venue to the north, Interstate 10 to the east, Lafitte A venue to the south and Rocheblave Street to the west. This information is necessary for completion of the Environmental Assessment required by the U.S. Department of Housing and Urban Development. Specifically, the following information is necessary: I. If the above mentioned Property is either listed or eligible for listing on the National Register of Historic Places. 2. If the above mentioned Property is located within or directly adjacent to an historic district. 3. If the above mentioned Property's area of potential effects includes an historic district or property. Please contact me if you have any questions or if I can be of any further assistance. I look forward to your response. Sincerely, W. D. SCOTT GROUP, INC. Operations Manager 29471WyckoffSHPO.It.lafitle.wpd 1117 Wright Avenue • Gretna, Louisiana 70056 Telephone (504) 393-7338 • Fax (504) 393-7311 SECTION 106 REVIEW AND DOCUMENTATION LAFITTE I-lOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA I lOUSING AUTIIORITY or Nav ORLEANS JANUARY 2007 APPENDIXC REFERENCES 15060165 Lafine Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. SECTION 106 REVIEW AND DOCUMENTATION LAFITTE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUTI-IORITY OF NEW ORLEANS JANUARY 2007 REFERENCES Cal trans Experiences. 2002. Transportation Related Earthbome Vibrations. California Department of Transportation. City of New Orleans. 2006. Central City Neighborhood Planfling District 2 Rebuilding Plan. www.nolanrp.com. CTC & Associates LLC and WisDOT RD&T Program. 2003. Constmction Vibration and Historic Bllildings. www.dot.state.wi.us/library / research/ docs / tsrs/ tsrcons tructionvibra tion. pd f. ECM Consultants, Inc. 2006. Reportfor Demolition Application Assistance for Lafitte Housing Development (LA 1-02). Prepared for the Housing Authority of New Orleans, New Orleans, Louisiana. Henwood, Justin T. and K Y Haramy. 2002. Vibrations Indllced J:y Constmction TrtifJic: A Historic Case Stllr/y. Prepared for the Federal Highway Administration, Denver, Colorado. Harris, Miller, Miller and Hanson, Inc. 1995. Transit Noise and Vibration Impact Assessment. Prepared for the Office of Planning, Federal Transit Administration, Washington, D.C. Housing Authority of New Orleans. 2006. ReqllCstfor Qualificationsfor Development Partnerfor Lafitte. RFQ Number: 06-120-10-16. PPM Consultants, Inc. 2006. Mold Inspection and Sampling Report (for Lafitte Housing Development). Prepared for the U.S. Department of Housing and Urban Development. United States Risk Management (USRM). Draft 2006. Section 106 Noise Evalllationfor Lafitte HOllsing Development. Prepared for the Housing Authority of New Orleans. 15060165 Lafitte Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. List of Federally and State Recognized Native American Tribes and Other Contacts -State of Louisiana Federal: Chitimacha Tribe of Louisiana Alton LeBlanc, Chairman P.O. Box 661 Charenton, LA 70523 Phone (337) 923-7215 Fax (337) 923-6848 www.chitimacha.com • Kimberly Walden Cultural Director Phone (337) 923-9923 kswalden@chitimacha.gov Alabama Coushalla Tribe of Texas Kevin Battise, Chairman 571 State Park Rd. 56 Livingston, TX 77351 Phone (936) 563-1181 Fax (936) 563-1183 • Beryl Ilallise histpres@actribe.org Adai Caddo Indians of Louisiana Rufus Davis, Jr., Chairman Route 2, Box 246 Robeline, LA 71469 Phone (318) 472-8680 Fax (318) 472-8684 cheirdavl Four-Winds Cherokee Tribe Billy Sinor, Council 139 Sinor Drive Leesville, LA 71446 Phone (337) 537-8318 Fax (337) 537-2611 h!!sillur({,! wllonI i lie. net Coushalla Tribe of Louisiana Kevin Sickey, Chairman P.O. Box 818 Elton, LA 70532 Phone (337) 584-1545 Fax (337) 584-2998 www.coushattatribela.org Caddo Nation LaRue Parker, Chairperson P.O. Box 487 Binger, OK 73009 Phone (405) 656-2344 Fax (405) 656-2892 • Robert Cast, THPO or Ilobby Gonzales Phone (405) 656-290 I IJiloxi Chitimacha Conrederation of Musl(ogee P. O. 130x 856 Zachary, LA 70791 \\.\\ " ·.hiloxi-dlilim;lcila.l'Olll Point au Chien Tribe 177 Aragon Road Montegut, LA 70377 Ii \I !l:llpa~lrihc. 11 ipod.colll Jena Iland of Choctaw Indians Christine Norris, Tribal Chier P.O. Box 14 Jena, LA 71342 Phone (318) 992-2717 Fax (318) 992-2771 www.jenachoctaw.org • Christine Norris Mississippi Band of Choctaw Indians Phillip Martin, Chief P.O. Box 6257 Philadelphia, MS 39350 Phone (60 I) 656-5251 Fax (601) 656-1992 • Kenneth Carleton Tribal Archaeologist & THPO Phone (60 I) 650-7316 Fax (601) 650-7454 kcarleton@choctaw.org Choctaw-Apache Tribe of Ebarb Tommy W. Bolton, Chairman P.O. Box 1428 Zwolle, LA 71486 Phone (318) 645-2588 Fax (318) 645-2589 cate@cp-tel.net United Houma Nation I3renda Dardar Robichaux, Principal Chier 20986 Highway I Golden Meadow, LA 70357 Phone (504) 475-6640 Fax (504) 475-7109 Tuinca-Biloxi Tribe of Louisiana Earl J. Barbry, Sr., Chaimwn P.O. 130x 1589 Marksv ille, LA 7135 I Phone (318) 253-9767 Fax (318) 253-9791 www.tunicaorg • Earl J. Ilarbry, Jr., THPO Alln: Museum Division Offiees Phone (318) 253-8174 Fax (318) 253-7711 Quapaw Tribe of Oklahoma John Berrey, Chair P.O. Box 765 Quapaw, OK 74363-0765 Phone (918) 542-1853 Fax (918) 542-4694 • Carrie Wilson Phone (479) 442-7576 Fax (479) 575-5453 nagpra.106@earthlink.net Clifton Choctaw Tribe of Louisiana Roy L. Tyler, Chairman 13 12 Clitton Road Clinon, LA 71447 Phone (3 18) 793-8236 Fax (318) 793-8236 Apalachee Talimali Band of Louisiana Gilmer Bennett P.O. Box 84 Libuse, LA 71348 Phone (318) 473-4412 Fax (318) 561-2333 * Contact Person(s) Governor's Office ofIndian Affairs Paige Ashby, Director P.O. Box 94004 Baton Rouge, LA 70804 Phone (225) 219-7556 Fax (225) 219-7551 Inter-Tribal Council of Louisiana, Inc. Kevin Billiot, Director 5723 Superior Dr., Suite B-1 Baton Rouge, LA 70816 Phone (225) 292-2474 SECTION 106 REVIEW AND DOCUMENTATION L\FITTE HOUSING DEVELOPMENT, NEW ORLEANS, loUISIANA I lOUSING AUTIIORITY OF NEW ORLEANS APPENDIXD OF CONSULTING PARTIES 15060165 Lafitte Section 106 Report,doc U. S. RISK MANAGEMENT, L.L.C. Consulting Parties Lafitte Name Walter W. Gallas National Trust for Historic Preservation C/o PRC 923 Tchoupitoulas St., NO, LA 70130 0: 504-636-3048 F: 504-636-3074 Walter galas@ntbp.org James Dugan Louisiana Landmarks Society 1440 Moss St. NO, LA 70119 504-482-0312 idugan@louisianalandmarks.org Patricia Gay Preservation Resource Center 923 Tchoupitoulas St. NO, LA 70130 0: 504-581-7032 F: 504-636-3073 pgay@prcno.org K. Carleton Mississippi Band of Choctaw Indians kcarleton@choctaw.org K. Carleton Mississippi Band of Choctaw Indians kcarleton@choctaw.org Charlene Vaughn Ass't. Director Federal Licensing, Pennitting, & Assistance Section ACHP 1100 Pennsylvania Ave. NW, Rm. 803 Washington, DC 20004 0: 202-606-8533 C: 301­cvauglm@achp.gov Robert Collins Deputy State Historic Preservation Officer Office of Cultural development Dept. of Culture, Recreation & Tourisum 1051 N0I1h 3rd Street Baton Rouge, LA 70804 reo llins@crt.state.la.lls Ujamma CDC -Amy Brown amybrown@ujamaa.org 1910 Urslliines Ave New Orleans LA 70116 822-8059 Tulane-Canal CDC (not Tulane Gravier) Sf. Vera Butler vbutler7({v.bellsouth.net 1802 Tulane Ave. New Orleans, LA 70112 522-3186 x25 Ann Herring Environmental Officer LAOCD 225-342-9914 Ann.Herring@LA.GOV Julie Tweeter Environmental Officer City of New Orleans 504-658-4364 jatweeteruv.cityofno.com Jim Kelly Providence Community Housing 1000 Howard Ave, 81h Floor NO, LA 70113 0: 504-592-5683 F: 504-596-3098 C: 504-975-0650 jkelly@archdiocese-no.org Emelda Paul, President 43476 West Colvy Dr. Mearicopa, AZ 85239 C: 602-301-5419 PIF: 520-568-5419 tme151334@aol.com Odessa Lewis/Cynthia Wiggins Residents of Public Housing 0: 504-913-9537 Judith Moran HAN0 0: 504-670-3426 imoran@,hano.org Marie Marcal Esplanade Ridge/Treme Civic Assoc. imarcal@,nocoxmail.com Sign-in Consulting Parties Lafitte Robert Tannen Ehcene Ben Michael Lane Patricia Gay Walter GaUas James Dugan Thomas Kelly Lamj Hirst L. Worlfis Sharon Jasper DNIA Housing Committee Benroe Housing Initiatives Shields Mott Land LLP Preservation Resource Center National Trust LA Landmarks AFL CIO Investment Trust REAL, CJ Peete Self& Scutting Resident St.Bemard SeCfION 106 REVIEW AND DOCUMENTATION LAFln'E I-lOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUTI-IORITY OF NEW ORLEANS JANUARY 2007 APPENDIXE HANO RESPONSE TO PUBLIC COMMENTS 15060165 Laline Section 106 Report,doc U. S. RISK MANAGEMENT, L.L.C. HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUIREMENTS FOLLOWING GENERAL COMMENTS APPLY TO ALL 4 PROJECTS Advisory Council on Historic Preservation (ACHP), letter dated 2128/07: Agency official. • Federal funding sources for these projects are 1) CDBG disaster funds from State of LA/Office of Community Development (OCD) Road Home Program (Piggyback program with GO Zone Low Income Housing Tax Credits), and 2) Public Housing Capital Funds to HANO. OCD is the responsible entity (RE) per 24 CFR 58.4 for the CDBO funds, and HANO has designated the City of New Orleans as the RE for the Capital Funds (in accordance '\ith 24 CFR 58.1 (b)(6). OeD and. the City chose not to designate a lead agency. 111crefore, both OeD and the City are the agency officials for the purposes of Section 106 compliance. ACHP: Identification and involvement ofconsulting parties. • Besides ne\\'spaper legal ads, HANO used a list of potential consulting parties provided by SHPO to send out invitations to the public meetings. At the public meetings, individuals and organizations were encouraged either to sign up to be consulting parties or to write HANO ,,,ith consulting party requests. HANO is currently in the process of coordinating, in consultation ,,;th SHPO, who to recognize as consulting parties, based on requests received to date. Developers, once selected by HAi'\!O, \\Iill be consulting parties. RFPs contain criteria related to required Section 106 experience, as ACHP recommended back in Oct 2006. Developer responsibilities will be spelled out in the contracts as well as in the MOAs, once they are fmalized. City is an RE and ",ill be a consulting party/signatory. ACHP: Tribal consultation. • Per SHPO direction, HAND imited 5 Indian tribes to the public meeting and to be consulting parties. To date, only the lvtississippi Band ofChoctaw has replied. Copies of all correspondence will be forv.arded. HANO has not yet received \\Titten comments from any tribes. ACHP: Definition ofthe APEs. • HANO is in the process ofconsidering public and written comments regarding the APEs and will consult further \\ith SHPO before rewmmending APE boundaries. ACHP: Identification and evaluation ofhistoric properties. • HANO will take your recommendation under consideration. rnitial surveys ofproperties in the proposed APEs and vicinities were conducted, and HAi'lO "ill consider doing additional Slln'ey work based on further consuitatiOrL ACHP: Assessment ofeffects at each project site. 1 HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUIREMENTS • I-IANO intends to consult wilh consulting parties over the effects at each site. It also intends to provide adequate documentation per §800.1 l(e) at the appropriate time. ACHP: Consultation to resolve adverse effects. • H~ANO and I-IUD intend to expedite consultation by submiuing multiple findings/detenninations to SHPO and consulting parties in one package per project at the appropriate time. These 4 submissions \\ill each reflect consultation and public participation up to that date with the intent of moving the process to MOA negotiations as quickly as possible, in order to meet project deadlines. ACHP: Public participation. • HANO will email copies oftranscripts of the public meetings held in Jan and Feb to ACHP. HANO is working to involve dislocated families. Meetings were held during the weeks ofMarch 12, and March 19~ 2007, for out-ot:to\\·n residents at which Section 106 infonnation was provided and additional public comments solicited. ACHP: Adequacy ofdocumentation per §800.1 I (e). • HANO will provide additional documentation, per your comments! as the consultation process moves forward. ACHP: Neighborhood character and effects. • HANO will take these recommendations under consideration as the consultation process moves forward. ACHP: Consideration ofalternatives. • Alternatives analysis reports for each site ,,,ill be provided and discussed at future consultation meetings. ACHP: General information not provided. • RFQs set criteria for developers to have experience 'with Section 106 issues. How the City and HDLC will administratively oversee the 4 projects is to be determined. • HANO is considering phased redevelopment at the request ofCongress and other parties. • Each housing complex will be addressed on its 0\\11 merits, ,vith separate studies and analyses performed. Each redevelopment project will have its o\\-n set ofconsultation meetings to ensure each site is given adequate, individual analysis. • Scattered site housing ",ill be developed with HANO and its chosen developer over time. CDBG money from the city is not anticipated at this time. • HUD has verified the hazards and contaminants on site and documented in HANO's environmental assessment. . • HANO considers the 2002 CJ Peete MOA expired. TIle project did not go fOD'Jard because HAl'\iO temlinated the developer. There are no other Section 106 agreements in place for the other 3 complexes. 2 HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUIREMENTS State Historic Preservation Officer (SHPO), letter dated 2/13/07: Does HANO intend to invite ACHP to participate in MOA consultation? • HA.!'JO, on behalfof OeD and the City, will formally invite ACHP to participate at the appropriate time. SHPO: Consult with us to identify additional consulting parties (individuals and organizations). • I--IA.t'JO plans to contact SHPO regarding identification and recognition of consulting parties. SHPO: Need for alternatives to be brought to the table. • An alternatives analysis for each project \vill be available for review and comment. SHPO: 1) Lafitte housing project should include Vieux Carre district and other historic props, 2) • HANO disagrees with including Vieux Carre in the APE for Lafitte·. HANO feels there will be no temporary or permanent effects to lhe Vieux: Carre due to redevelopment actions. An elevated portion ofI-1O and the Imver Treme are located between Lafitte and the VC. The Vieu.x Carre is a mile away. See also the APE justifications. SHPO: Need for archaeology before demolition and additional testing after demo/prior to initiation ofconstruction • HANO intends to do targeted archaeological testing, based on further consultation with SHPO and others. SHPO: Clarify which Indian tribes with whom you will consult • HANO has contacted various tribes by letter, based on information provided by SHPO. See correspondence. National Trust for Historic Preservation (NTHP), letter dated 2n.4/07: Public notice and location ofpublic meetings were inadequate. • HANO published notice in the Times-Picayune 2 weeks prior to the meetings. The meeting location was the only space HANO had available at the time. For future meetings, HANO will make every attempt to hold them near the public housing complexes. NTHP: Failure to notify consulting parties. 3 HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUIREMENTS • Since the public meetings were the first time HANO reached out to consulting parties and public. on these projecls~ it is learning who to invite. Based on previous guidance from SHPO, HANO sent individual letters to a number of preservation organizations and interested parties. See correspondence. NTHP: Failure to make documentation reasonably available to the public. • As an initial step to start the public participation process, HANO hosted meetings to introduce the proposed projects to the public and interested parties. Materials on the projects were made available at hano.org for download,. and hardcopies were available for pick up a1 HANO headquarters on Touro St. HANO made a presentation to the parish­wide resident advisory council (RA.B) and presidents ofthe individual public housing projects on the 106 process, information available on HANO \vebsite and printed copies available for pick-up at the HANO oftlces. HANO will continue this and also explore how to make copies available at other public facilities, i.e. public libraries. NTHP: Failure to notify the ACHP. • HANO has consulted "i1h ACHP since Oct 17, 2006, when it hosted a site visit ofall 4 sites for HUD and ACHP. ACHP has been involved in several phone conversations v.ith HANO and has verbally said it wants to participate. ACHP was invited to attend the meetings but was unable to travel. NTHP: Failure to engage in consultation. • The public meetings were intended to introdm:e the proposed projects to the public and allow initial public conunent. HANO fully intends to engage in consultation at the appropriate time in the process. • See SHPO comment above. NfHP: APEs are inadequate NTHP: Failure to identify historic properties. • HANO ""ill define the APEs in consultation with SHPO, and will identify historic properties within the APEs during consultation set forth at §800.4. HAt"JO has not reached that point yet. NTHP: NT disagrees with implied ''No Adverse Effect" detenninations. • HANO has not made any detenninations ofeffect yet. That will be done in consultation with consulting parties during §800.5. NnIP: Inadequate consideration ofalternatives to demolition.. 4 HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUIREMENTS • See response above. N1BP: Selection ofa developer prior to Section 106 consultation could foreclose the ACHP's opportunity to comment. • Based on advice from ACHP, I{Al'>JO put together RFPs for developers that clearly set criteria for knowledge of Section 106 matters and historic preservation requirements. Selection of developers by HA1"\fO is subject to established procurement requirements. Michael Lane (MI.), letter dated 2114/07: Inadequate public notification. • See response above. ML: Poor choice ofmeeting location. • See response above. ML: Failure ofHANO to reach out to dislocated residents. • See response above. ML: HANO unclear about period oftime to submit comments and when responses would be available. • HANO stated that public comment would be taken verbally at the public meetings, and that written comments could be submitted by Feb 16. HAi"JO later e>..'tended the public comment period for written comments to Feb 23. Both email and mailing addresses were provided. Comments are still being accepted from relocated residents. MI.: Why did HANO not respond to verbal comments at public meetings? • The public meetings were held to introduce the proposed projects to the public and to get initial comments. To maximize time for public conunent" HANO decided in advance to respond in writing to the comments received by a later established date. ML: Public comment period is woefully inadequate. • HANO has just initiated Section 106 review and will provide additional opportunities for consulting pru.1ies and the public to conunent. ML: What are the next steps? 5 HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 10& REQUIREMENTS • HANO, in consultation willl I-IUD and SHPO, are determining how to proceed and coordinate Section 106 rC\'iews for these projects. Consulting parties will be contacted at the appropriate time. ML: Sect 106 documentation inadequate. • See response above. ML: Need to consider alternatives, make alternatives known. • See response above. ML: HANO has not made available any cultural resource information it has undertaken. • HANO has only performed initial historic property searches at SHPO and "'reconnaissance" surveys ofthe project areas, results ofwhich are in the Section 106 documents. No archaeology has been done. Additional survey work \\>;11 be negotiated \vith consulting parties. ML: HANO misrepresented the facts on the conditions ofthe public housing complexes. • HANO disagrees; the presentations w'cre based on its studies and assessments. ML: HANO has not adequately responded to ML's FOIA request. • FOIA requests are handled according to established procedure. MI.: Inadequate notice to consulting parties. • See response above and correspondence. ML: Inviting Indian tribes to be consulting parties is "troubling." • As required by the NHPA and 36 CFR 800, Indian tribes with a known interest in Orleans Parish were invited to be consulting parties. ML: Objects to HANO handling the 4 projects as separate projects; HANO has failed to consider each project on its own merits. • HANO. in consultation with SHPO, decided to handle these as 4 separate proje{:ts, due primarily to the fact that different players will be involved in each. HANO disagrees with the latter statement. ML: Objects to HANO's descriptions ofproperties. New low-densitywill introduce suburban context to city. 6 HAND RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUIREMENTS • Planned densities are not suburban densities. ML: HANO's selection of a developer for Lafitte and lack of an alternatives analysis violates Section 106. • See responses above. ML: Consultation should occur throughout the decision-making process. • HANO agrees and intends (0 consult with consulting parties before a final decision is made. ML: Disagrees with HAND's assessment of buildings, cites MIT professor's report. • Again, HANO stands by its assessment. ML: Objects to using mold as a reason to shut down projects. • HAND stands by its assessment. ML: Objects to US rusk Management's structural stability comments in the Section 106 documents. • HANO stands by its consultant's assessment. ML: What is the status ofarchaeological investigations? Also reiterates concerns about inviting Indian tribes to consult • See response above. ML: Wants specifics about HABS survey. • HABS documentation is a standard mitigation measure performed prior to demolition of historic buildings. HANO is considering HABS as possible mitigation and will discuss this further \"\ith consulting parties at the appropriate time. ML: Wants clarification ofcost analysis. • Cost analyses to be pro\lided in future. ML: HANO needs to consider additional long-term direct and indirect effects. • Through further consultation, HANO will consider additional effects. ML: APEs are inadequately defined. 7 HANO RESPONSE TO COMMENTS RELEVANT TO SECTION 106 REQUfREMENTS • See response above. ML: HANO's consultation efforts to date are inadequate. • See response above. ML: HANO has done Section 106 process backwards. • HANO disagrees. The process bas just started and 110 final decisions have been made. 8 ANGELE DAVIS SECAItTARY §tatc of llimtisimm MITCH!:L.L J .. LANDRII!.U L''£UT&NANT GO'VERNOR OFFICE OF THE LIEUTENANT GOVERNOR PAM BREAUX DEPARTMENT OF CULTURE, RECREATION 8< TOURISM A.SSISTANT SECRETARY OFFICE OF CULTURAL DEVELOPMENT DIVISION OF HISTORIC PRESERV"TI.ON February 13, 2007 Ms. Judith Moran Housing Authority of New Orleans 4100 Touro Street New Orleans, LA 70122 Re: Section 106 Comments on the Redevelopment of the Lafitte, SL Bemard, C.J. Peete, and BW. Cooper Housing Projects New Orleans, Orleans Parish, LA Dear Ms. Moran: Thank you for inviting our office to participate in the public meetings held on January 30 and February 1, 2007 conceming the redevelopment of the above-referenced housing projects. As a follow-up to your request for public comment, we wish to the offer our comments for the proposed demolition and redevelopment of the Lafitte, Sl Bemard, C.J. Peete, and B.W. Cooper Housing Projects: • To date we have not received any formal notice of the Advisory Council on Historic Preservation's (Advisory Council) role in the Memorandum of Agreement (MOA) consultation for the four projects. Though Ms. Charlene Vaughn, Assistant Director, Federal Permitting, Ucensing, &Assistance Section of the Advisory Council has participated informally in most of our MOA consultation, as recently as last v.reek she informed us that HANO-HUD has not formally invited the Advisory Council to participate in the MOA consultation process per 36 CFR 800.6(1}. Does HANO-HUD intend to formally invite the Advisory Council to participate in the MOA consultation? • Based on our observation of the public comments that were made in last week's meetings, we recommend that HANO-HUD consult with our office on identifying additional individuals and organizations that have a vested interest in the preservation of the four developments. These parties should be invited to serve as consulting parties to any MOA that is developed for the four housing projects. P.O. BOX 44247 • BATON ROUGE. LOUISIANA 70804·42.47 • PHONI£ (225) 342·8160, FAX (225) 342·8173' \VWW.CllT.STATE.LA.US AH EQUAL OPPORTUNITY E .... PLOYER C:II-.iyfie:sISecIion 105 2C()4\HUo HoosiIY.! Proj. 11·27.oow.Q. HUll Den-05 Fr.aI teller 12-5-00.sHPO Coovneols FIIlaiiP2. 2-9-U7.00c Ms. Judith Moran February 13, 2007 Page 2 • To date HANO-HUD has not offered any alternatives to ifs proposed demolition of the tour housing projects. As stated in 36 CFR 800.1 (a) 'The goal of consultation is to identify historic properties potentially affected by the undertaking, assess its effects and seek ways to avoid, minimize or mitigate any adverse effects on historic properties. In the spirit of historic preservation. we feel that alternatives that avoid or minimize the adverse effects that may occur from the redevelopment of these properties should be brought to the table. • On November 20, Z006 our office received aletter from the W.o. Scott GrouP. Inc. representing HANO requesting that we identify historic properties within the Areas of Potential Effects for each of the four housing projects. The APE boundaries were not identified. Only descriptions of the roadways that bounded each of the projects were given. Based on those road boundaries. we identified several historic districts and individual properties including the C.J. Peete Housing project that were listed in the National Register of Historic Places (National Register). RecenHy. HANO-HUD provided our office with a defined APE for each of the referenced projects. Based on the current APEs, we recommend that HANO-HUD include the following historic properties in the consultation process: 1. Lafitte Housing Project APE -National Historic Landmaf1( Vieux Carre Historic District, and the National Register-listed Mid-City, Parkview, Esplanade Ridge. New Marigny and Faubourg Marigny Historic Districts, General laundry Building, Congo Square, Sl Louis Cemetery No.1, Sl Louis Cemetery No.2, Sanger Theatre, and Perseverance Hall. 2. B. W. Cooper Housing Project APE -Central City Historic District and Booker T. Washington High School and Auditorium. 3. C.J. Peete Housing Project APE -Central City Historic District, C.J. Peete Housing Development and F1int-Goodridge Hospital. 4. Sl Bernard Project APE -National Register-eligible New Orleans City Parle • Based on the information supplied on your website and at the public meetings, our office believes that a large portion of the archaeological investigations at these four housing projects should be conducted prior to demolition. Additional testing will need to be conducted after demolition and prior to any redevelopment activities at these housing project sites. Ms. Judith Moran February 13, 2007 Page3 • Neither the documents supplied on your website, nor the information given at the public meetings identified the Native American Tribes who were contacted. The website documents reference an appendix containing the Native American consultation letters, yet this appendix is labeled incorrectly or not included at all. We look forward to working with HANO-HUD and all interested parties in restoring public housing to New Orleans and in seeking ways to avoid, minimize, or mitigate any adverse effects that result from their redevelopment If you have any questions, please contact Mike Varnado in the Division of Historic Preservation at (225) 342-8160 or Cheraki Williams in the Division of Archaeology at (225) 342-8170. Sincerely. Pam Breaux State Historic Preservation Office PB:MV:s Preserving America's HefJ/c:g<~ February 28, 2007 Mr. Jeffrey Riddel Acting Executive Administrator Housing Authority ofNew Orleans 4100 Touro SI. New Orleans, LA 701 22 RE: Redevelopment ofC.J. Peele. SI. Bernard. Laliae. and B.W Cooper Public HOllSingSites Using Fundingfrom fire Us. Department ofHOllsing and Urban Development (HUD) New OrleaJlS. LOllisiana Dear Mr. Riddel: We are in receipt ofyour correspondence, dated January 17.2007, regarding the initiation ofSection 106 review for the referenced undertakings and the public meetings that HANO hosted to begin its consultation efforts. Although HANO has not yet made an official effect finding, we feel that the importance of tllese undertakings dictate that we participate at this juncture. Nevertheless, when the Louisiana Office ofCommunity Development (OCD)lHANO has made an official determination regarding adverse effects, you should notify us accordingly. Agency Official We understand that funding for the redevelopment ofC.J. Peete, St. Bernard, Lafitte, and B.W. Cooper is being provided in part by OCD through Community Development Block Grant funds in the Road Home program. Please clarify ifOCD will serve as the responsible entity for HUD's environmental review process and the agency official for this undertaking pursuant to HUD's regulations at 24 CFR Part 58. What coordination has taken place between HANO and OCD for Section 106 consultation to date? Also, please clarify whether there will be any other federal involvement in these undertakings. rdentification and Involvement of Consulting Parties HANO has sent letters inviting the participation ofseveral consulting parties and also asked those who wish to be consulting parties to indicate their desire at the recenl public meetings held concerning these undertakings. The ACHP has been copied on correspondence from several organizations that wish to be involved in consultation. Please inform us which consulting parties HANO has invited to participate. Also, please inform us ifsub-recipients (such as developers applying for Low Income Housing Tax Credits in connection with the redevelopment of these sites) will carry out any project activities on HANO's behalf and, ifso, what specific responsibilities they will be assigned. Infom13tion about the City ofNew Orleans' (City's) role in these projects and a point ofcontacl at the City will be helpful since, pursuant to Section 8002 ofour regulations, "Protection of Historic Properties" (36 CFR Part 800). local governments are entitled to participate as consulting parties. ADVISORY COUNCIL ON HISTORIC PRESERVATION 1100 Pennsylvania Avenue NW. Suite 0Cfi • Washington. DC 20004 Phone: 202-606-8503· Fax: 202~-8647 • achp@achp.qov • \WJW.achp.qov 2 Tribal Consultation HANO states in the draft Section 106 rcports that it has sent lellers inviting the participation of Indian tribes who may attach religious and cultural significance to properties that may be affected by the undertakings. Regrettably, copies of this correspondence are missing from Appendix C in the reports. Have any tribes indicated their desire to participate in consultation to date? How will HUD fulfill its govemment-to-governmem responsibilities ifit is not directly involved? Please provide copies or summaries of any comments provided to date by tribes or Tribal Historic Preservation Officers (THPOs). Definition of the Area of Potential EfTects (APE) Based on any comments received from the public and the Louisiana State Historic Preservation Office (SHPO), the designation ofthe APEs for each undertaking has yet. to be resolved. We are particularly concerned about how HANO will address indirect and cumulative effects on adjacent properties listed on or eligible for listing on the National Register of Historic ptaees (National Register). [t also would be useful to know how HANO will handle the creation of replacement housing required under HUD's guidelines. Identifi~tion and E\raluation of Historic Propertirs HANO should describe how all historic properties within all APEs will be identified and evaluated, recognizing that the passage oftime may warrant the reevaluation ofcertain historic properties or their previous evaluation ofsignificance. Assessment of Effects at Each Proje.ct Site TIle unique effects at each of the sites needs to be examined in detail so that all consulting parties will understand the consequences the proposed actions will have to the characteristics that qualify these properties for listing on the National Register. This level ofdetail is also necessary to assess options for avoiding, minimizing, or mitigating adverse effects. Once I-IANO has evaluated the efTeds ofthe undertaking on historic properties within the APEs in consultation with the SHPO and Indian tribes, it should notify the ACHP and all consulting parties ofany findings ofadverse effect and provide the documentation included in 36 CR Part 800.11 (e)_ This information should be available to the public. Clearly defining the proposed undertaking and its effects on historic properties in complete documentation will also ease communication and understanding among the large number of consulting parties anticipated to be a part ofthe resolution ofadverse effects. Consultation to Resolve Alh'erse Effects We understand that HANO has requested expediting consultation with the Louisiana SHPO pursuant to 36 CFR 800.3(g). Expediting the consultation process does not presume that limits can be put on exploring the resolution ofadverse effects. Given the diversity and number ofconsulting parties, the Section 106 consultation should allow adequate opportunities for parties to exchange information and share their views. Please share any conclusions concerning how this expedited consultation process will be structured and how other consulting parties and the public will be afforded an opportunity to express their views within the timefrallles agreed upon by HANO and the SHPO. Public Participation We are pleased that HANO is beginning its Section 106 consultation with public outreach in the form ofa series of public meetings. We regret that we were not able to participate in the meetings scheduled for January 30 and February I. We would appreciate receipt ofany transcripts thar were developed from the meetings. We also recommend that HANO determine how best to solicit the views of parties that remain dislocated and are geographically removed from New Orleans. 3 With regard to the infonnalion posted on HANO's website for the undertakings we offer the followina ~ , '" observations: Adequacy ofDoclIIneutatioll per 800.1 J(e) The background infonnation included in the draft reports does not meet tht! requirements outlined in Section 800.11(e) ofthe ACHP's regulations. Specifically, the [ollowing additional infonnation should be included in each ofrhe four reports: • information about all historic properties located within the APEs, • maps showing the location of historic properties in relationship to planned project activities, including the location ofdemolitions and new construction. • maps showing the location ofor a description of the site selection plan for scattered site housing, • copies or summaries ofany views provided by consulting parties and the public, • copies ofHANO's request for proposals to redevelop each site, and • the Lafitte graphics, including the map of the APE, were 110t available on the website this date. Neighborhood Character alld Effects We recommend that HANO characterize the neighborhoods surrounding each site and discuss the effects of the change in density and land ownership on historic neighborhoods that will accompany the transition from a traditional public housing development to mixed-income, partially owner-occupied units. What economic development impact will such broad plans have on the community in general and historic preservation in particular? HANO should also discuss and provide the views of consulting parties on the relevance of the LOllisiana Speaks pattern book to the historic character of those historic neighborhoods present within the APEs and the design of new development. COlISiduatioll ofAlteruatil·es The four reports present cost differentials between rehabilitation of all the buildings on each site and demolition and reconstruction ofall the buildings on each site. Please describe how HAND has considered otJler alternatives, including partial rehabilitation ofthe total number of buildings on a site and phased redevelopment. Gelleral lIl/ormatioll Not Prol,;Jed • Does the request for qualifications (RFQ) require developers to have historic preservation experience? Wi[/ the redevelopment be considered under local administrative review processes such as local historic district commission review? • Has HAND explored phased redevelopment that will allow parts ofthe complex or select projects to be rehabilitated rather than complete clearance given the need for affordable housing? • How will HAND ensure that each complex is addressed as a unique resource rather than a part of a group ofcomplexes? • How will HAND approach site selection for scattered site housing? Will the City have a role in this program through its CDBG program? • HANO has indicated that it must address remediation of hazardOilS conditions at the complexes. Has the City or HUD verified the level ofcontamination? • Please advise the ACHP ofthe status of HANO's compliance with any existing Section 106 agreement documents for activities involving these public housing complexes executed before Hurricanes Katrina and Rita, including the 2002 Memorandum of Agreement concerning CJ. Peere. We look forward to working with you in your etTorts to ensure compliance with Section 106. If you have any questions., please contact me at 202-606-8533 or via email at c":lll!!hnf@.nchp.!!ov, or Blythe Semmer, the ACHP's BUD Liaison, at 201-606-8552 or via e-mail at bsemmerfltlachp.oov. Sincerely, ~a~(J~£.- Charlene Dwin Vaughn, Alep Assistant Director Federal Pemlitting, Licensing, and Assistance Section Office ofFedera! Agency Programs NATIONAL TRUST for HISTOR1C PRESERVATION"­ February 24, 2007 Ms. Judith Moran Housing Authority of New Orleans 4100 Touro Street New Orleans, LA 70122 Re: Proposed Demolition of Lafitte, C. J. Peete, B. W. Cooper, and St Bernard Housing Developments Dear Ms. Moran: This letter summarizes the comments of the National Trust for Historic Preservation regarding the public meetings convened by the Housing Authority of New Orleans (HANO) on January 30 and February 1,2007 regarding HANO's proposal to demolish four historic pubnc housing developments -Lafitte, CJ. Peete, B.W. Cooper, and St. Bernard. The National Trust was represented at the meetings by Walter Gallas, The newspaper notices for the public meetings referenced Section 106 of the National Historic Preservation Act (NHPA), 16 U.S.c. § 470f, and HANO prepared four documents entitled "Section 106 Review and Documentation," available only on HANO's web-site. However, the meetings and the documents do not conform to Section 106 requirements, and Section 106 consultation has not yet been properly initiated. Public Notice and Location ofthe Meetings Were InadequaJe. A legal notice annonncing the four meetings was placed in the Times-Picayune on January 16,2007, just two weeks before the first meeting. The location, in the Fischer Community Center, was nowhere near the four housing developments being discussed, inconvenient to any public t:ran.sit, and at a time ofday when rush hour traffic made it nearly impossible for anyone to be on time. The combined effect of these circumstances appears calculated to minimjze, not maximize, public participation. It is essential that future meetings be held at a time and place when interested members of the public can conveniently attend. In addition, since many former public housing residents do not live in the immediate New Orleans area, special efforts are necessary to reach out to these groups. Newspaper notice is not sufficient. FailllTe to Notify Consul ling Parties. Walter Gallas, Director of the National Trust's New Orleans Field Office, sent written requests to you on two occasions asking to participate as a consulting party on bebalf of the National Trust in the Section 106 consultation process for these proposed demolition and redevelopment projects. The first request was sent on December II, 2006, via email, and the second was sent on December Profeding the Irreplaceable 1785 MASSACHUSETTS AVENUE. NW • WASHINGTON. DC 20036 202.538.6000 . F .... X; 202.533 . 6038 • TTY, 202.588.6200 • WWW.NATIONALTRU5T. ORG Ms. Judith Moran February 24, 2007 Page 2 14,2006, via regular mail. Yet the Trust received no notice of the January 31 and February 1public meetings. Nor did the Trust receive any acknowledgement or folIow-up to this consulting party request. We learned of the public meetings by word-of-mouth. Failure to Make DocumentaJion Reasonably Available to the Public. No printed materials other than the evening's agenda were provided at the meeting. No complete printed copies of the draft reports on each of the developments were available either for distribution or even for viewing. The only medium by which individuals could access the reports was through the HAND web site, and the documents were posted on the web-site only a few days before the public meetings. I For many of the displaced former residents of these housing projects, who are crucial stakeholders in the review process, accessing a web­site and printing out hundreds of pages of documents is virtually impossible. Failure to Notify the Advisory Council 011 Historic Preservation. Since HUD and HANO have acknowledged that each of the four public housing developments proposed for demolition is eligible for or Ested on the National Register of Historic Places. and thus would be adversely affected by demolition, the Section 106 regulations specifically require the agency to notify the Advisory Council of the adverse effect detennination and provide documentation to the CounciL 36 C.F.R. § 800.6(a)(1). This requirement has not been satisfied. Failure to Engage in Consultation. "Consultation" is defined in the Section 106 regulations as the process of "seeking, discussing, and considering the views of other participants, and, where feasible, seeking agreement with them regarding matters arising in the section 106 process." 36 C.F.R. § 800.16(f). In contrast to this definition, the public meetings did not include "consultation." Mter a powerpoint presentation for each of the developments, members of the public attending the meetings were invited to present comments (limited to just a few minutes), and to await a response on the HANO web site. ffiJD and HANO refused to answer any questions or respond to any comments at the meeting. This was not consultatioD. The Area ofPotential Effects (APE) is Inadequate. In aU four cases, the proposed Area of Potential Effects (APE) is limited essentially to the boundaries of the historic public housing development itself. A few of the adjacent properties are also included in the proposed APE, but only with respect to potential construction irnpacts.2 The long-term secondary and cumulative effects of the redevelopment projects were not considered when developing the APE. The APE is required by the Section 106 regulations to include all areas I Even though the web-site characterizes the documents as being dated January 17,2007 (or in one case, January 22), they were not posted until several days before the public meetings. 2 The Lafitte report does not include a map of the APE (see p.24), but the text of the report (at 9-10) suggests that a very similar approach is proposed. Ms. Judith Moran February 24, 2007 Page 3 "within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties ...." 36 c.F.R. § 800. 16(d) (emphasis added). It is important to keep in mind that adverse effects under Section 106 include "reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative." /d. § 800.5(a)(1). One ofthe fundamental goals of these projects is to develop new mixed-income, mixed-use neighborhoods. The effects of these new developments would by no means be limited to the construction sites themselves. By their very nature these redevelopment projects are intended to encourage and generate economic revitalization through additional private and public investment in the surrounding communities. Those reasonably foreseeable development activities may well include the demolition of other properties, many of which are historic. The APE for each of the projects needs to be expanded to take into account these indirect, secondary, and cumulative effects.3 Specifically, we believe the APEs should be expanded to include, at the very least, the following: • CoJ. Peete: Uptown Historic District and Central City Historic District • Lafitte: Esplanade Ridge Historic District • BoW. Cooper: Central City Historic District (0.2 mile, or 1056 feet away) Failure to Identify Historic Properties. Each of the four reports states that a number of structures over 50 years old., which may be National Register-eligible, were observed adjacent to the historic public housing developments (Cooper report at 12~ Lafitte report at 10; Peete report at 15-16; St Bernard report at 10). Some of these are included within the APEs; others are noL These properties (within an expanded APE, as discussed above), need to be evaluated for their National Register eligibility in consultation with the State Historic Preservation Office (SHPO), pursuant to 36 CoER. § 800A(c). In addition, the 1930 General Laundry Building, which is located just 200 feet northwest of the Lafitte development, is one of only three surviving Art Deco! Aztec buildings in New Orleans. The fac;ade portion of the building (approximately 20 feet deep) was listed on the National Register in 1974. (Lafitte report at 9.) Given the passage of time (more than 30 years), and the current policy against listing only portions of buildings on the National Register. this property should be specifically reevaluated to determine whether the National Register boundaries should be expanded. ld. § 800.4(c)(l). The National Trust Disagrees With Implied "No Adverse Effect" Determinations. For two of the projects -Lafitte and CJ. Peete -the draft reports include within the proposed APE portions ofexisting historic districts and properties snrrounding the public housing developments. However, the reports both state that the effects of the redevelopment C.P.R. § 800. 16(d), it may make sense to develop a second APE for each project, which would relate specifically to the indirect and cumulative effects. Ms. Judith Moran February 24, 2007 Page 4 projects on the immediately adjacent historic districts will be "limited" and "clearly temporary" (Lafitte report at 10; Peete report at 15).4 It is not clear whether "limited" is considered "adverse" or not. To the extent that iimited" and "clearly temporary" may be construed to mean the substantial equivalent of"no adverse effect," the National Trust disagrees. As described in more detail above, we believe these projects will have indirect and cumulative effects that may adversely affect historic properties in the surrounding communities. In addition., all four of the reports state that '"'No impact to zoning or land use is expected from the proposed project." (B.W. Cooper report at 16; Lafitte report at 14; Peete report at 20; St Bernard report at 14.) Again, we disagree. These conclusions are all listed under "Direct Impacts," and do not even purport to take into account indirect impacts on land use. Inadequate Consideration ofAlternatives to Demolition. The Section 106 regulations require consultation to develop and evaluate alternatives or modifications to the proposed redevelopment projects that could avoid, minimize, and mitigate the adverse effects on historic properties. 36 C.ER. § 8oo.6(a). Once consultation under Section 106 is properly initiated, we expect that the subject ofalternatives that would avoid and minimize demolition will be the crucial issue for the consultation process. In order to resolve those adver:se effects, credible information will need to be developed to evaluate the conditions and rehabilitation costs for each of the public housing developments. The information contained in the web-site reports lacks credibility. For example, the reports suggest serious damage to the buildings. However. testimony at the public meetings made it clear that the buildings are structurally sound and suffered relatively minor damage, (which was exacerbated by HANO's own neglect after the hurricane). The cost estimates for rehabilitation described in the reports also lack credibility. and are contradicted by earlier estimates discussed in the newspaper. The claim in the reports that "modernization" or rehabilitation wouJd cost about 25% more than demolition and new construction lacks credibility and needs to be studied in more detail. Selection ofa De~eloper Prior to Section 106 Consultation Could Foreclose the Advisory Council's Opportunity to Comment. The Lafitte report states that a developer (providence/Enterprise) has already been selected for the Lafitte project and has very specific plans (see pp.I-2). This violates the requirement in the Section 106 regulations that consultation must be initiated early enough "so that a broad range ofalternatives may be considered during the planning process" for the project 36 C.ER. § 8oo.l(c). We are very concerned that the premature selection ofthe developer will unduly "restrict the subsequent 4 The Peete report also includes the National Register-listed Hint-Goodridge Hospital within the APE (see pp.13-14). but makes no comment or determination regarding potential effects. In addition. the Lafitte report includes the National Register-listed General Laundry Building within the APE (see p.9). but similarly makes no comment or determination regarding potential effects. Ms. Judith Moran February 24, 2007 PageS consideration of alternatives" to avoid or minimize harm to the Lafitte development, in violation of the section 106 regulations. /d. Thank you for considering the views of the National Trust. We look forward to moving into the consultation process under Section 106, and we encourage HANO and HUD to initiate Section 106 consultation soon. Sincerely, Elizabeth S. Merritt Deputy General Counsel cc: Walter Gallas, Director. New Orleans Field Office. National Trust for Historic Preservation David G. Blick, Deputy Federal Preservation Officer, U.S. Department ofHousing and Urban Development Charlene Vaughn, Advisory Council on Historic Preservation Blythe Semmer. HUD Liaison, Advisory Council on Historic Preservation Pamela A. Breaux, Louisiana State Historic Preservation Officer Robert Collins, Deputy SHPO.Louisiana Ann Herring. Louisiana Office ofCommunity Development SHIELDS MOTT LUND" moum m CO""""o" 'T "w 11C?)~~~~'₯'~ID) 3 Since the Section 106 regulations allow different APEs for different kinds of effects, 36 lUll FEB I 5 2!JQ II DEVElOPMENT February 14,2007 ____~D~E~P~~~RTM~·=ENT~____~ VIA TELECOPY AND U. S. MAIL Mr. Donald Babers Housing Authority of New Orleans 4100 Touro Street New Orleans, Louisiana 70122 Re: HUD/HANO Section 106 Process Our Ref.: 90300-01 Dear Mr. Babers: I am. writing to express my concerns and those voiced by others in the historic preservation comnmnity with HUD/HANO's attempt to comply with Section 106 of the National Historic Preservation Act ("NHPA"). Many ofthe concerns discussed below were expressed atthe public hearingS on January 30 and Februaiy 1, 2007, held at the Fischer CoI1llllIlD.ity Center on the Westbank. Additionally, the concerns listed below relate specifically to Section 106 and not to any other compliance-related matters. I would request that these comments be included in the public record for the four housing developments proposed for demolition. My predominant concern relates to HUD/HANO's perception of the consu1trt:ion process under the NHPA. Section 106 requires a federal agency to elicit public participation in the consultation process. I am concerned that HUDIHANO has failed to properly comply with this aspect of Section 106. The following is a list of problems that I see with HUDIHANO's efforts related to the consultation and public participation process: • Notice ofpublic hearings was inadequate because itwas provided only two weeks prior to the hearings when typically notice should be given thirty days in advance of the hearings, considering the nature and scope ofthe undertaking. Additionally, the notice posted in the newspaper was difficult to locate and not readily visible to the casual reader. • The public hearings were held at Fischer Community Center on the Westbank, whereas all four housing developments are located on the east bank of the river. The choice of location and times for the hearings made it difficult for anyone who wanted to attend to do so. Particularly, former residents of the four housing developments would have experienced significant difficulties in attending the hearings, not only due to the time and 6SO POYDIWi STRIE't rum 2600 • taW OIUIANS. LOUISIANA. 701JO • TnInlONE 004) S8t-#4S • FACSIMlLE !.504l S8t-#oW • WWW-SHlElDSMOTIl.UND.COM SHIELDS MOTI LUND 1-L7. Mr. Donald Babers February 14, 2007 Page 2 location of the hearings. but also because of the difficulty ofusing public transponation to get to the Westbank (e.g., two or three transfers would have been necessary). • HUDIHANO has failed to reach out to the former residents of the four housing developments that may not be living in the city dne to Hmricane Katrina and the closure of the housing developments. The former residents have a vested interest in the historic value of the properties under Section 106 process and are also indispensable to the cultural resources survey which HUDIHANO stated is currently underway_ • HUDIHANO stated at the presentation that persons who wished to make their comments on the proposed action could do so orally at the bearings or in writing and that responses from HUDIHANO would be forthcoming on February 16, 2007. Coincidentally. that is the same date that HUDIHANO stated that it would provide answers to the questions and comments made during the public comment period, leaving no opportunity for the public to make further comments on HUDIHANO's responses. • Considering that BUDIHANO does not intend to respond to the questions and comments on the Section 106 process until February 16. 2007, it is even more troubling that HUDIHANO representatives refused to respond to any questions or comments during the public hearings. • The so-called public connnent period is scheduled to last approximately two weeks, from the date of the first bearing on January 30 through February 16, zro7. The short two­week public comment period is woefolly insufficient under Section 106. • HUD/HANO provided no illumination on how itplans to continue the Section 106 process following the close of public comment period on February 16. 2007. HUDIHANO representatives only vaguely mentioned that the consulting process would continue beyond the public comment period, but did not provide any details. In addition to the failure to provide adequate notice of the hearings or elicit public participation in a meaningful way. HUDIHANO has failed to provide documentation that should be made available to the public for review and comment: • During the presentation, HUDfHANO repeatedly referred to documents that could be located on the HANO website. Many of the documents HUDIHANO stated would be available 01). "!he website are simply not there. Moreover, many people bave had difficulty locating the docmnents referenced by HUDIHANO and have experienced problems with downloading from the website. • Additionally. HUDIHANO did not make its Section 106 documentation available on its website until approximately one week before the hearings. which provided a very limited amount of time for persons interested in the process to review the documentation in advance of the hearings. SHJELDS MOTI LUND UJ. Mr. Donald Babers February 14, 2007 Page 3 • Moreover, many fonner residents of the housing developments do not have access to the Internet and, therefore, do not have an opportunity to review the documents made available on HANO's website. HUDIHANO has failed to make the subject documentation available in printed form at any location. such as public libraries or HANO's offices, that would allow persons without access to the Internet to review the documentation. • As oftoday's date, HUD/HANO has still failed to make available proposed alternatives, plans. or other documentation on the alternatives to demolition. It is impossible to analyze the potential alternatives to demolition without this documentation. • HUDIHANO has fulled to make available any information or documentationon thecultural resources survey, Historic American Buildings Survey ("HABS"), the archeological survey, or any other surveys it is conducting in its attempt to comply with Section 106. • Doring its presentatio~ HUDIHANO made repeated misrepresentations of facts related to each of the housing developments and offered.no documentary support. For example, in the presentation it was stated that the four developments were substantially damaged by Hurricane Katrina and the flood. However, as many of the persons who spoke at the bearings pointed out. the four housing developments were probably the safest places in the city and sustained minimal damage in comparison to the other housing structnres in the city. • In addition to failing to provide documentation ofthe foregoing matters for public review and comment, both RUD and HANO have uot adequately responded to my office's requests for public records under the Freedom ofInformation Act ("FOIA") and Louisiana Public Records Request Act ("LPRRA") made on December 22, 2006. • In response to my FOIA request, HUD failed to respond within twenty (20) days as required by law. After I sent a follow-up letter demanding a response, HUn finally contacted me (via voicemail) to let me know that the documents were being compiled. My follow-up phone calls have gone unanswered. As ofthe date of1his letter, is has been fifty-three (53) days since the request and still no documents have been made available for review. • Inresponse to my request under LPRRA, general counsel for BANO contactedme and told me that the request was overbroad and asked that I narrow my request. A follow-up letter narrowing the document request was sent on January 15, and I did not receive a response until last week. Only yesterday was I infonned by HANO representatives that some docmnents are now ready for review, fifty-two (52) days since the request. SHIELDS MOTI LUND LU. Mr. Donald Babers February 14, 2007 Page 4 Another major concern with HUD/HANO's attempts to comply with the Section 106 process is its actions (or inaction) related to consulting parties: • Persons and entities that were listed as potential consulting parties by the State Historic Preservation Officer ("SHPQ") on a list that was provided to HUDIHANO were not provided notice of the hearings. For instmce, Jim Logan, a New Orleans attorney with experience with Section 106, was listed as a potential consulting party but never received notice of the hearings or an invitation to be a consulting party . • Additionally, entities with an interest in the Section 106 process, such as the National Trust for Historic Preservation, requested to be a consulting party but have yet to receive a response from HUD/HANO. • HUDIHANO stated in its presentation that five Indian tribes were invited to be consulting parties. The fact that there may be no Indian tribes living anywhere in the area of the four housing developments and have been invited as consulting parties, when interested historic preservation entities have not been invited, is troubling. While the foregoing is addressed specifically to the Section 106 process and the public hearings, I would also like to address the draft Section 106 reports recently made avaiIable by HUDfHANO on its website: • A review ofthe report on all four developments would lead to the conclusion that they are essentially identical in many respects. Even though each development bas its own characteristics. the report leads one to believe that HUDIHANO has failed to consider each housing development on its own merits. Considering HUDIHANO's request to the SHPO that each of the developments be treated individually rather than as a group (under a programmatic agreement), this is especially distressing. • In Section 2.1, entitled Project Description, HUD/HANO states that the housing developments suffer from high density. overpopulated units, deteriorated buildings and infrastructure. obsolete building components. hazardous building materials, and building envelopes that are not energy efficient. Many of these claims are unfounded. For example. the housing developments do not soffer from high density, overpopulated units. In fact. these units have relatively low levels of density compared to other housing developments in comparable cities. HUDIHANO's plan fur mixed-income housing would convert thecurrentdevelopmen1s into low-density. suburb-Jikeneighborboods which would bouse many fewer residents than the current developments. Furthermore, the infrastructure is not deteriorated, bot only needs proper maintenance and some rehabilitation to be 100% ready for occupancy. Additionally. the reference to "obsolete building components" is overly broad, to say the least, because cities in other areas ofthe country are now using the same model to construct new housing developments. SHIELDS MOTI LUND L-L-' Mr. Donald Babers February 14,2007 Page 5 • Also under Section 2.1, it states that construction activities will include the demolition of existing structures and the removal ofexisting infrastructures. Additionally, HUDIHANO has already selected a developer with a plan to redevelop the Lafitte housing development; As will be discussed below, HUDIHANO's decision to move forward with its demolition plan without proper consideration of alternatives is a violation ofthe Section 106 process. There canbe no proper consultation with the public and consideration ofviable alternatives ifthe agency bas already decided on which course of action it intends to take. • Under Section 2.2, entitled Methodology, HUDIHANO states that it bas consulted with the SHPO, the Advisory Council on Historic Preservation, and the National Register of Historic Places to identify historic properties located inthe defined Area of Potential Effect ("APE"). The reports also state that HUDfHANO bas retained U.S. Risk Management to complete "all research required for the completion of the Section 106 review." At the end of that section, it states "HUD/HANO to provide additional infonnation concerning public meetings and additional consultation will be added later." Under Section 106, consultation should occur throughout the course of the decision-making process, not once the plan to demolish and rebuild bas been finalized. • Section 3.3, entitled Hurricane Katrina, delineates the damages sustained by the housing developments from Hurricane Katrina and the resulting flood. HUDIHANO outlines the various damages sustained by the buildings and makes it seemas ifthese buildings suffered significant stroctural damage as a result of the hurricane. However, as was stated at the public hearings, an architect/engineer frm;n MIT has already perfoIUled an evaluation of the stroctoral integrity ofthe developments and found that they were strnctnrally sound and suffered insignificant damage from the storm. • Also under Section 3.3, HUDIHANO cites mold growth as a problem that needs to be addressed. However, this would not be the case ifHUDIHANO had moved quickly after the hurricane to properly maintain the buildings rather than leaving them idle for a year and a half. Fnrthermore, there is photographic evidence from a New York Times photographer that shows the lack of mold in the units, which evidence is currently on display at the Ogden Museum of Southern Art. • Despite making numerous claims that the buildings are structurally deficient ofthe under Section 3.3.2, ffiJDlHANO states thatU.S. Risk Management "did notperfonn structural evaluations ofthe buildings." HUDIHANO's reliance on the position that the buildings suffered significant structnra1 damage without conducting an adequate survey of the stroctnra1 integrity of the buildings is disturbing. • Section4.3. entitled ArcheologicalResou:rces, statesthat the SHPO informed HUDIHANO of the potential for intact archeological deposits to be encountered during redevelopment.. HUDIHANO states that it has authorized Earth Search, Inc. to conduct a Phase I cu1tnra1 resources survey. However. no further details are given. SlllELDS MOTI LUND I-LP. Mr. Donald Babers February 14. 2007 Page 6 • Section 4.4. entitled Native Americanllndian Tnlles, states that. according to SHPO, five Native American Tribes were identified for possible archeological consultation on the proposed redevelopment. HUDIHANO also states that it has invited each of the tribes to be consulting parties to the Section 106 process. Again. it is worth reiterating the incongruity of inviting these Native American tribes but not local historic preservation concerns that have either been provided to HUD/HANO as potential consulting parties or who have specifically requested in writing to be a consulting party. • Under Section 5.1. entitled Demolition. HUDIHANO discusses the use ofa HABS survey, but provides no specifics on the documentation process other than stating that HUDIHANO will gather historic pictures/drawings ofthe properties and prepare written documentation such as narratives, statements of significance, etc. • Under Section 5.3, entitled Economic Impact. HUDIHANO states that it has retained ECM Consultants, Inc. to prepare three cost estimates to determine the most cost-effective option to improve the housing developments. The first cost estimate would involve improving the development to its condition before the hurricane and addressing immediate needs. The second process would involve demolishing the inside and roofs of the buildings and to improve the buildings so they meet current building codes. This process is entitled "modernization.-The third estima1e involves demolition ofthe entire deveJopment and constructing an entirely new development. • As an example, the -modernization" cost estimate for Lafitte is quoted at $154.4 million dollars. This includes the complete demolition of the interiors ofbuildings , as well as the roofs of the majority of the buildings. The third cost estimate, for demolition and new construction at Lafitte, would be $124 million dollars, approximately24.4% higherthantbecostof-modernization.· Theamountqooted for -modernization-for eachdevelopment exceeds the cost estimate for demolition and. rebuilding. • Despite these numbers, HUDIHANO has provided no other docomentation ofhow these costs were derived and has not made any of the estimates available to the public for review. It is difficult to comprehend how the demolition of the entire building and the construction ofa new building is 25%cheaper than rehabilitation, considering that previous estimates. discussed in local newspapers, put the cost of demolition and reconstruction substantially higher than rehabilitation. • Under Section 6.0. entitled Indirect Impacts, HUDIHANO addresses issues that would arise due to the demolition and. reconstruction of the four developments. including visual impact. air quality concerns, vibration concerns, construction traffic vibrations, noise pollution, and traffic problems. However. these short-term effects should not be the only indirect impacts considered. Section 106 requires the federal agency to also take into consideration the long-term indirect and direct effects of the proposed action. and it appears that HUDIHANO bas failed to meet this requirement. SHIELDS MOTT LUND LLP Mr. Donald Babers February 14, 2JXJ7 Page 7 • Section 7.0, entitled Area of Potential Effect, is three sentences. HUDIHANO states that the APE ..should encompass the geographic area within which an undertaking may directly or indirectly result in alterations of character or use of historic properties." Based on this information, HUDIHANO bas created an APE that is roughly two blocks incircumference around each development. Ai; stated by Walter Gallas of the National Trust at the public bearings last week, these APEs are woefully inadequate and are the smallest APEs we have seen. Additionally, HUDIHANO has failed to explain how it derived each APE other than drawing a rough circ1e around each development. The determination of an APE sbould be a much more intensive process that should be conducted in concert with public comment and participation. • Under Section 8.0, entitled Consulting Parties, HUDIHANO's mismanagement of the Section 106 process is plainly evident. HUDIHANO states that consultation took place withHANO. HUD, the Advisory Council, and the SHPO in meetings and conference calls in November and. December 2006. It also states "include information after consulting parties are identified." Despite HUDIHANO's representations at the public hearings, no significant efforts have been made to contact consulting parties and to respond to those who have requested to be consulting parties. Considering that the public comment period will end in a week, this is a serious problem. All of the above problems have caused many in the historic preservation community to be extremely concerned with HUDIHANO's handling of the Section 106 process. From the information presented at the public bearings and the documents that HUDIHANO has made available, itappears that HUDIHANO has seriously underestimated its responsibilities in eliciting public participation and consu1tation. As I stated at all four hearings, it appears that HUDIHANO bas perfonned the entire Section 106 process backwards. After making its determination to demolish and rebuild, HUDIHANO is now seeking public comment on those plans. The process has been abused. If HUDIHANO wishes to properly comply with Section 106, it will make availablealtematives to demolition that may be reviewed and commented on by the public and itwill also seek more public consultation with regard to the development of its plans. We hope that the foregoing outline of our concerns will help to ensure that HUDIHANO properly complies with Section 106. In addition to coII1pliance with the NHPA. many in tbe historic preservation community are also concerned that HUDIHANO has decided to do an enviromnental assessment rather than an environmental impact statement under the National Environmental Policy Act ('"NEPA"). HUDIHANO can avoid many of the problems it has encountered in the Section 106 process if it begins to include the public now in its efforts to comply with NEPA. particularly the proper evaluation of alternatives to demolition and the Environmental Justice aspect ofthe statute. SIDELDS MOTI LUND loU. Mr. Donald Babers February 14, 2007 Page 8 As was made clear at the public hearings, the preliminary hearings and public comment period should not be the end of the Section 106 process, but hopefully only the beginning. With best regards, I am, ~' Michael D. Lane MDL:elm cc: Senate Homeland Security and Governmental Affairs Committee Senate Disaster Recovery Subcommittee House Committee on Financial Services House Subcommittee on Housing and Community Opportunity Senator Mary Landrieu Senator David Vitter Congressman Bill Jefferson Mr. Alphonso Jackson, U.S. Department ofHousing and Urban Development Ms. Tina Powell. U.S. Department ofHoming and Urban Development Mr. Dirk K.empthorne, U.S. Department of the Interior Mr. Stephen L. Johnson, Enviromnent3l Protection Agency Me. James L. Connaughton, Council on Environmental Qoality Mr. John M. Fowler, Advisory Council on Historic Preservation Mayor C. Ray Nagin Ms. Judith Moran, Housing Authority ofNew Orleans Ms. Suzie Elkins, Louisiana Office of Community Development Ms. Ann Herring, Louisiana Office of Community Development Mr. Mike McDaniel, Louisiana Department ofEnvironmental Quality Mr. Milton Bailey, Louisiana Housing Finance Agency Ms. Pam. Breaux, Louisiana State Historic Preservation Office Mr. Robert Collins, Louisiana State Historic Preservation Office Mr. Peter Brink, National Trost fur Historic Preservation Ms. Betsy Merritt. National Trost for Historic Preservation Mr. Walter Gallas, National Trust for Historic Preservation Mr. Tun Logan. Logan and Soilean Mr. Jim Dogan. Louisiana I.andmarks Society Ms. Patricia Gay. Preservation Resource Center Mr. David Marcello, Tulane University Law Clinic Mr. Tom O'Malley, AFL-CIO Golf Coast Revitalization Program Mr. Saul Schapiro, Rosenberg and Schapiro Ms. Diane Yernel, National Low-Income Housing Coalition Mr. Nicolai Ouroussoff, New York Times Mr. David Marcello. Tulane Law School Clinic _I....-.-~­ "U -( "--. L, ,~ '" 833 Howard Avenue, yJ Floor New Orleans, LA 70113 Tele :(504) 566-0900 -Fax:(504) 566-0080 smart@smartincl .com www.smartincl.com Comments on the Section 106 Process Who Are We? Smart., Inc. is a for profit business corporJtion that was incorporated with the Secretary of State for the State of Louisiana on the 17th of February 1993. C. Knox LaSister III has (ed the company over the past 12 years as the sole shareholder and CEO of Smart., fnc. The primary business activity is real estate advisory services. We specialize in the development of affordable housing and the promotion of community-based solutiQns to economic development. llle mission of Smart, Inc. is to distinguish itself in the real estate industry through developing technologically enhanced housing and commercial facilities for low and moderate-income families and small business entrepreneurs. Comments: The wealth of experience of knowledge that Smart has concerning Public Housing in HA's throughout the United States affords us the ability to believe that redevelopment in those areas would be essential to the growth and redevelopment of New Orleans. Mixed-Use development would be an area for the city to explore, however we caution on having somewhere for the people of this "Great City" to return home to. The city must look at the UBig Picture" and how the decisions they make today will effect us tOll1Qrrow. Just simply returning residents to these housing authorities without plans of developing more viable solutions may not be in the best interest of the city. Another suggestion is the revitalization of the units possible looking at condomium situations, that will allow the residents to be able to invest in the property and produce pride of where they are living. There must be somewhere to return residents home as soon as possible (as a temporary housing solution), as well as a plan in place that can relocate those residents to more modem, safe and vital neighborhoods. One project in which Smart, Inc. We are currently engaged as Developer for the Alexandria Housing Authority_ Services include development of a vacancy reduction and asset management plan for a 481 unit public housing community. With the approval of the plans accomplished. Smart is now structuring project financing, assembling the development team and beginning the revitalization effort. The revitalization of the entire site includes a combination of demolition. conversion of unit sizes, and minor and major renovation. The goal is to create a neighborhood that gives each resident a sense of place and a sense ofhomeownership. This may be an avenue for the city to explore at those development sites. _L--_ I ~I lU -, "-. \J ~, What Do We Do? We provide Real Estate Management Services; Real Estate Financing Services; Neighborhood RC\'italization Services. Master Planning Services; Public Housing Operations Management; Property Maintenance and Management; and Training and Technical Assistance. Our specialties include: Public Housing Administration: Section 8 Program Administration; Mixed Use Commercial Development; and Mixed Income Residential Development For over a decade. Smart. Inc. has provided real estate services to the government. Through our engagements. we have helped acquire. design. de\'elop. finance. implement. revitalize. manage. sell and transfer residential and comJTIeTc1als projects throughout the United States and the Caribbean. Acknowledged for our work in affordable housing. community development, and public housing initiatives. we continue to deliver successful solutions for our c1ienl~. Smart. Inc. has been engaged by the U.S. Department of Housing and Urban Development to provide SEMAP Technical Assistance and training and support services to several Housing Authorities depending on level of HUD identified need. For those engagements we prO\;ded on-site SEMAP Assessments. developed Corrective Action Plans. and provided technical assistance and training services. Our training and technical assistance servlces included but not limited to: developing, tracking and monitoring systems for Correcti\'e Action Plan implememation; executive and management staff training; implementation of approved Corrective Action Plans; serving as communications liaison between HUD, the PHA. residents and property owners; quality control sampling methodology development and monitoring; evaluations of payment standard, rent reasonableness and utility allowance detenninations; and development of occupancy, tenant selection. waiting list, computation of income and rents. and rent caJculation policies and procedures; HQS inspections of units and HQS enforcement; program accounting; family self-sufficiency programs and program marketing. Our Implementation Project Team is comprised of professionals and technicians with proven "hands-on" experience. We are singularly committed to achieving excellent outcomes for each and every engagement. Our approach is time and cost sensitive. while supporting a level of services designed (0 achieve the highest level of quaJity and success. The point of contact is Lisa McClinton, email addresslmcclinton@smartincl.com. Ilollsing\l1tiIol'ity or \e\\-(Jrle:uls L , ()(-' pal'tlllell 1-() f ProclIre111 ell t l~ (~oII ITa (' tS e~~Hf~~~l€a~~0Jj~ A.JPIJP~cca ~ ~ I lOllsillg _-'II tho1'1 ty 0 f \ e l. • 4100 1()lIl'O S .\Jp,y ()rlpCllls.. S04-G­ HOUSING AUTHORITY OF NEW ORLEANS DISADVANTAGED BUSINESS ENTERPRISE PROGRAM CERTIFICATION APPLICATION FORM The undersigned does hereby swear that the statements contained In the application and all attachments. which have been provided in support of this application, are true, accurate, and complete. and indude all material informalion necessary to identify and explain the ownership and operation ot : ~~J~~~A~~+~J:~~C~"_______ (Intert Fun Name of Business) The undersigned agrees that, as part of the certification procedure. HANO may freely contact any person or organization named in the application to verify statements made in the application. Any material misrepresentations will be grounds for immediate rejection of the application for certification. termination of any contract which may be awarded, and for initiating action under Federal and State laws concerning fraudulenl statements. If after filing this application, and before work is completed on a contract covered by this program, there is any significant dlange in the information submitted, the undersigned agrees to infocm HANO of the change either directly or through the prime contractor, as applicable. cr'Name: Title: Date: Affix Corporate Seal (where a If Corporate Seal is not affixed. this document must be notarized. BOBBIE C. SMITH J!I'!l Subscribed and sworn to !-J£~ (. 7~,lh (Notary Publ~f~~p~~')t'lu(· (' / (Seal) #81019 before me this ~~ day of WItt<-tL,' Lf . 20 D1 My Commission expires: At ItJ!I< /CU 'S5'-Otv I T& /. 'fe.... Date Signed by Applicant 7:-3 Ed 'UJo 7 page 1 of 3 Business TerePhone:~'t})5t,G -09Du Faxkl-i)5<0(", -OO~0 Email Address:\k'uJOC. ~-M:1,G"J f\\Fed Tax 10: 7CJ -}c2 Lv 4qc:2 q SECTION 2: BUSINESS TYPE Indicate the products and/or se1Vices that you provide. Check all appficable boxes. iYConslrudion G/T'echnology Consulting (;}'Construction Management o Technology Supplies llrlJemolilion o Human Resources o Electrical Work [;}'Consulting o Electrical Supplies o Legal Services o Plumbing Work o Brokerage Services o Plumbing Supplies o Property Appraisals o!Property Management o Messenger Services o Office Supplies o Janitorial Services o Grass Cutting Services ~ther. Please Describe: _ . .~;L~tlrSI~~~Lt1tteMeJJa.ht>v SEcnON 3: EVlDENCE OF CERnRCATION Indicate Louisiana Unified Certification Program certifying agency. Check all that apply . .AtIach current letter of certifICation from at least one of the agencies Checked. If applying as a Resident Owned Business, Evidence of Certification is not required. o Louisiana Department ofTransportation o Regional Transit Authority o Louis Armstrong International Airport o Orleans Levee Disbict o England Airpark Authority o Cily of Shreveport SECTlON 4: MBElWBE MEMBERSHIP It is the parleY of the Housing Authority of New Or1eans that Minorily and Women Business Enterprises have the maximum opportunity to participate in the performance of contracts financed in whole or in part with federal funds. In order to monitor and report our success in this area, we ask you to voluntanly answer the folrowlng Questions. This information is for statistical purposes of ownership only, and has no effect on whether or not you wm be awarded a contract wilh HAND. Please check one of the following which best describes the person or person(s) possessing the certification(s) identified in Section 3 above: ~canAmerican 0 Hispanic o Asian o Native American 0 Woman o Other. Company Namlk 3btA&l-, :L:"2. (Please Print) page 20f 3 SECTION 5: SECTION 3JRESIDENT BUSINESS CERTIFICATION REQUIREMENTS Business concems seeking to certify as Section 3 and/or Resident Owned businesses must complete this section. 1. Qualifying individual ownership percentage: _____________ 2. Qualifying individual's address: 3. Attach a list of persons employed by your businesses. Identify each employee by name and title. and list the date of employment, home address. and beginning and ending salary. 4. Identify percentage of current subcontracts awarded to Section 3 businesses. Name of Qualifying Subcontractor Percent of dollar award of total contract Company Nam~~~dI ""INc (Please riot) page 3 of 3 To: Advisory council on Historic Preservation Copy: Housing Authority ofNew Orleans Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support of Providence and Enterprise's joint partnershjp to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding commuruty as a whole, would be an unfortunate oversight on the part oftbe Advisory Council and it shows a lack ofconcern for people and their well-being. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations of poor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. Quality of Life is an important factor in rebuilding of New Orleans. LaGtte lacked a basic quality of life, and the New New Orleans will hopefully be a city that has a higher quality of life. This is the starting point for that to occur. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modern standards for housing, while at the same time allowing residents to return right away to a portion of the uruts as a part ofa phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest of both the residents and the people of the surrounding community and New Orleans as a whole. As a citizen ofNew Orleans, I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future ofthis community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank you for taking the time to hear my voice, and for all that you do for the welfare of this city and its citizens. Signed, Kawana Ripoll 2321 St Nick St New Orleans, LA ]055 SL Charles Avenue, Suite 100 GREATER NEW ORLEANS New Orleans, Louisiana 70130 FOUNDATION (504) 598-4663 {504} 598-4.676 Fax For a vibmnt region. www.gnot.org BOARD OF TRUSTEES M. Cleland Powell III Chainnan Gregory Ben Johnson President & CEO Myron E. Moorehead, M.D. Vice Chairman Kim M.Boyle Secretary Gary N. Salamon Treasurer Frances G. Villere PastOulirman MadJyn B. Bagneris John D. Becker Maria E. Bonilla Edgar L. Chase ill Philip F. Cossich Jr. Joseph Failla IT Ludovico Feoli David Francis Richard W. Freeman JI. Philip J. Gurm Paul M Haygood Scott P. Howard Robert E. Howson Henry M. Lambert J. Thomas Lewii Lean O. Moses Andr~K. Moss Rajender K. Pannu Michael O. Read Anthony Recasner, Ph.D. Robert D. Reily GloriaRichard-Davis, M.D. William R Shane Jr. Stephen L. Sontheimer Phyllis M. Taylor Cheryl R Teamer David R Voelker Joseph E. Williams April 2, 2007 Advisory Council on Historic Preservation 1100 Pennsylvania Ave. NW. Suite 809 Washington, DC 20004. Dear Advisory Council: We are writing to indicate aur support of the proposed phased redevelopment and new Homebuilding Plan proposed by Providence and Enterprise for . Lafitte. We believe they have considered historic preservation opportunities when planning this redevelopment. As you know, redevelopment of Lafitte is a key part of the Providence1 Enterprise Homebuilding Plan. The practical, sentimental, and heritage value of the brick buildings has been raised by a number of people participating in the planning process, induding residents who have strong memories of living in a place with good friends and a strong community. Despite that, most residents have indicated that they're ready for a change and are excited by the opportunity to live in more modem units, especially singles and doubles with yards and porches, as well as larger rooms. lhey support the phased approach to redevelopment that Providence is proposing, including enabling residents to come home now by opening a number of existing units at lafitte temporarily, until the new units are ready. Providence and Enterprise have considered ways to preserve the existing buildings at Lafitte, and the best opportunity they see involves preserving the Management Building as a community facility that will become a place to celebrate and share the rich heritage of Lafitte. Preserving the apartment buildings is not consistent with the changes and improvements that residents have told Providence they want Sincerely, From: Sent: Tuesday, April 10, 2007 1 :34 PM To: 106Comments Cc: Subject: Lafitte Housing program I support the proposed phased redevelopment oft/,e Lafitte Housing Project and the new Homebuilding Plan. I particularly appreciate the way that Providence Community Housing and Enterprise Homes have considered historic preservation opportunities when planning the redevelopment ofLaftlte, I believe that this project has been delayed for far too long and must move forward quickly ifthe City ofNew Orleans is going to be able to welcome its resiilellts, particularly its poor residents home. I would appreciate your approving their application as soon as possible. From: Sent: Tuesday, April 10, 2007 12:43 PM To: 106Comments Cc: Subject: Support of Providence Rebuilding Project To Whom It May Concern: I am writing to indicate my support of the proposed phased . redevelopment and New Homebuilding Plan proposed by Providence and the Enterprise for Lafitte. I believe those involved have considered the historic preservation opportunities when planning this redevelopment. As you know, redevelopment of Lafitte is a key part of the Providence/Enterprise Homebuilding Plan. The practical, sentimantal, and heritage value of the brick buildings has been raised by a number of people participating in the planning process, including residents who have strong memories of living there. Such as myself, who did not live there, but my grandparents did and raised all six(6) of their children in the Lafitte Housing Development. Despite that, many residents have indicated that they are ready for a change and are excited by the opportunity to live in more modern units, especially single and doubles with yards and porches, and larger rooms. I support the phased approach to redevelopement that Providence is proposing, including enabling residents to come home now by opening a number of existing units at Lafitte temporarily, until the new units are ready. Providence and Enterprise have considered ways to preserve existing buildings at Lafitte, and the best opportunity they see involves preserving the Management Building as a community facility that will become a place to celebrate and share the rich heritage of Lafitte. Preserving the apartment buildings is not consistent with the changes and improvements that residents have told Providence they want. Sincerely, From: Sent: Friday, April 06, 2007 11 :56 AM To: 106Conunents Cc: SUbject: Lafitte Development I am in support of the redevelopment that is planned by Providence and Enterprise for the Lafitte Housing Development. The development is in need of upgrading and n10dern provisions for residents to have a better quality of life that they had before the hurricane displaced the residents. Redevelopment will be better for the community, not just the land space that Lafitte encompasses. Seeing families and children living in better quality housing will make New Orleans a better city. Preservation of some ofthe components of the development are welcome but they should not interfere with the need for quality housing for people. Delaying this redevelopment delays the return ofthe people who have been an important link to the heritage ofthe city. Please move forward with this plan as soon as possible for the benefit ofso many residents who call New Orleans HOME. From: Sent: Monday, April 09, 2007 11 :46 AM To: 106Comments Subject: phased redevelopment ofLaffite Dear Sirs, I would like to voice my support for the phased redevelopment of the Lafitte Housing Project as proposed by Providence Community Housing and Enterprise. I serve on the board of__, as well as __, the non-profit that runs __. The people on the board and staff at Providence, along with our partners at Enterprisehave gone to great lengths to make this re-development a great success. I can assure you that our motives are pure and we are working with the fonner residents to help their return to a better place, a better city. [fyou have any questions of me, please feel free to call . God Bless From: Sent: Monday, April 09, 2007 11:41 AM To: 106Comments Cc: Subject: Lafitte Housing Development I am in support of the proposed phased redevelopment ofthe Lafitte Housing Development as proposed by the Providence Community Housing and Enterprise Homes. We are quickly approaching the two year anniversary of Hurricane Katrina and our residents are still displaced. It is time to quickly implement a plan that will bring people home. The residents of the housing development deserve better living conditions than what they were subjected to prior to the hurricane. It was unacceptable then and is even more so now. They deserve modem housing, with up to date amenities,in a safe community to raise their children. Now is the time to maximize the opportunity for change. From: Sent: Tuesday, April 10,20077:12 AM To: 106Comments Subject: Please Support Re-development Plans! To Whom It May Concern: I am writing to express my support of Providence and Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations ofpoor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modem standards for housing, while at the same time al10wing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest ofboth the residents and the people of the surrounding community and New Orleans as a whole. As a past citizen ofNew Orleans for 22 years, I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future of this community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank. you for taking the time to hear my voice and for all you do in your efforts to better this city and its citizens. Signed, From: Sent: Thursday, April 12,20072:38 PM To: I06Comments Subject: Lafitte Redevelopment To the Advisory Council on Historic Preservation: Thank you for providing me the opportunity to share with you my thoughts on the redevelopment of the Lafitte Public Housing Community. I have followed the development of the ProvidencelEnterprise Homebuilding Plan (Plan) for several months and am quite familiar with the issues surrounding the redevelopment of the community, including concerns regarding historic preservation and phased redevelopment. I fully support both the process used to develop the Plan as well as its recommendations. Providenceand Enterprisehave gone to great lengths to truly understand the needs of both the current and former residents of the community and the residents' desire to find a way to balance the historic aspects of the existing buildings with the strong need to have more modem homes. The Plan strikes that balance with elegance. Families have made it clear that they want new homes with modem amenities that will serve families across a broad range of incomes. The Plan contemplates that the existing apartments will be demolished and replaced with new homes with all the modem amenities families expect and need while the Management Office will be restored and used as a community center. Restoring the ManagementBuildingfor this use supports the community's desire to retain an important component ofthe neighborhood's architectural heritage while providing a unique place for the community to congregate. I also support the phased redevelopment plan which will allow some residents to return to the neighborhood now and live temporarily in the old Lafitte units until the new homes are ready. Again, Providenceand Enterpriseshould be commended for listening to the community and using their creativity to develop a plan that balances CUlTent and future needs in a commonsense manner. Please feel free to contact me ifyou have any additional questions or comments. From: Sent: Thursday, April 12, 200710:33 AM To: 106Comments Subject: Lafitte Housing To: The Advisory Council on Historic Preservation As a member of a few non-profit community boards, I have been apprised of the plans for the redevelopment of Lafitte. I endorse whole-hea11edly the ProvidencelEnterprise Homebuilding Plan, which incorporates the preservation of the Management Building, along with a phased redevelopment of the apartment buildings. This approach will provide much-needed improvement & modernization, and, as a result, a better quality of life for all the residents. Most sincerely, From: Sent: Wednesday, April 11,20075:09 PM To: 106Comments Cc: Subject: Lafitte housing I am writing as a member of the board of to support the redevelopment approach adopted by Provident/Enterprise Homebuilding Plan. As a past chairman of the , I am well aware of the importance of historic preservation to New Orleans. I believe that the plan to preserve the management building will provide an example of the type of construction used when the site was originally developed. The irony of the situation is that the type and quality of the original construction makes it difficult to modify the buildings for adaptive reuse. It would be extremely costly to modify what I understand are poured in place concrete walls to fit the lifestyles of to day's families. From: Sent: Tuesday, April 10,2007 10:00 PM To: 106Comments Subject: 106 Comments April 10, 2005 To Whom it May Concern: ram writing in full support of the phased redevelopment of the Lafitte Housing Project in New Orleans. I also suppOli the home building plan as developed by the Providence Community Housing and Enterprise Homes. We need safer housing to be provided and a plan to project the historic preservation ofNew Orleans. The housing initiative of Providence and Enterprise does just that. It is important of the phased in plan to allow people to return quickly as well as to redevelop other possibilities for housing for New Orleans. It has taken too long for the plans ofNew Orleans for housing to take place 24 months is too long. I am concern of the high rent that is being assesed to our citizens ofNew Orleans. We need decent housing for the poor and one that is affordable. In my point of view the poor of the city have as much ofa right to return as do those who are wealthly. Please act now!! From: Sent: Tuesday, April 10,20073:06 PM To: 106Comments Subject: 106 Comments While many have raised questions about the historic and sentimental value of the brick buildings at Lafitte, the displaced residents deserve and desire something better. Why not preserve a portion of Lafitte, perhaps the historic Management Building, but give the residents updated, livable housing. A phased development allows those who wish to come home a place to live in the short term, while better quality housing is constructed. Preserve a piece ofLafitte as a tribute to the history of the development and the people who lived there. But constructing a new and healthy community gives those who return an improved quality of life for themselves and their children. -----Original Message----­From: Sent: Tuesday, April 10, 2007 11:27 AM To: l06Comments Subject: Letter to ACHP Dear Policymakers at ACHP and HANO, I was informed of a grassroots effort to halt the demolition of the Lafitte Housing development due to the Historic value of the development. I believe the preservation of people is more important than the preservation of bricks. Please see my attached letter. Thank you for your time. From: Sent: To: 1 Cc: Subject: Lafitte Program Time is essence. and Middle Class. It is our Middle that ways back home~ residents. means are it appears Namely, it's Poor explored to the City ofNew is doing little to bring our residents Providence Community and Enterprise Homes have a proposal on Not only will be brought back home, the proposal also preserve the historic preservation and ofthe I unequivocally support the proposed redevelopment Project new Homebuilding as proposed by Providence. We all experienced what a "delay in can mean. Subsequently a "City Under , a large percentage our citizens displaced, and others returning. approval the application submitted by Community Housing and Home is urgently requested. From: Sent: Monday, April 09, 2007 11: 11 AM To: I06Comments Subject: Redevelopment of Lafitte Housing Project in Treme To: Advisory council on Historic Preservation Copy: Housing Authority ofNew Orleans Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support ofProvidence and Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations of poor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modern standards for housing, while at the same time allowing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest of both the residents and the people of the surrounding community and New Orleans as a whole. As a citizen ofNew Orleans,I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future of this community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank you for taking the time to hear my voice and for all you do in your efforts to better this city and its citizens. From: Sent: Friday, April 06, 200710:16 AM To: 106Comments Subject: Lafitte Public Housing Neighborhood To: Advisory council on Historic Preservation Copy: Housing Authority ofNew Orleans Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support of Providenceand Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations ofpoor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modern standards for housing, while at the same time allowing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest of both the residents and the people of the surrounding community and New Orleans as a whole. As a citizen ofNew O,.leans, I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future ofthis community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank you for taking the time to hear my voice and for all you do in your efforts to better this city and its citizens. Signed, -----Original Message----­ From: Sent: Monday, April 09, 2007 4:55 PM To: 106Comments Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support of the Providence/Enterprise Homebuilding Plan, and to urge your approval of this plan. While I understand the need for historic preservation, I believe that the safety and well-being of those who will inhabit these buildings must take precedence over the desire to preserve the buildings' original blueprints. The flaws of these original designs have become painfully apparent over the years; the cramped conditions and poorly considered layouts have proven to be a perfect landscape for drug dealers and criminals, while making it more difficult for police to fight crime effectively. Providence and Enterprise have carefully weighed the architectural, historical, and human components of this equation and have come up with the only plan that makes sense. Their plan to rebuild a mixed income neighborhood, meeting modern housing standards while respecting the local architecture, will give former Lafitte residents the chance of a better life while also allowing them to reclaim their old home. As a New Orleanian who is personally rebuilding and who is deeply concerned about the future of our city, I hope that you will consider my opinion and those of my peers. We understand the importance of this city's history, and we know that now is the time to make history by making the right decisions. I appreciate your taking the time to read this, and I thank you for all of your efforts on behalf of the people and the city of New Orleans. Sincerely, From: Sent: Monday, April 09, 2007 4:57 PM To: 106Comments Cc: Subject: FW: Redevelopment of the Lafitte Housing Project I am writing in support ofthe proposed phased redevelopment ofthe Lafitte Housing Project and the new Homebuilding Plan. I particularly appreciate the way the ProvideltceCommultity Housing and Enterprise Homes have considered historic preservation opportunities when planning the redevelopment ofLafitte. I believe that this project has been delayedfor far too long and must move forward quickly iftire City ofNew Orleansis going to be able to welcome its residents, particularly its poor residents home. I would appreciate your approving their application as soon as possible. The practical, sentimental, and heritage value ofthe brick buildings has been raised by a number ofpeople participating in tire planning process, including residents who have strong memories in a place with good friends and a strong community. Despite that, many residents Irave indicated tlrat they are ready for a change and are excited by the opportunity to live in more modern unit especially singles and doubles with yards andporches, as well as larger rooms. Preservil,g the apartment building is not consistent with the changes and improvement that residents have told Providence they want; therefore redeveloping the Lafitte Housing Project with the new Homebuilding plans that have been presented would bring afresh inviting appearance bring this area into the 21st century. Your urgent attention to expediting this project would be a GOD send to the community and a GREAT rejuvenatiltg step to rebuilding our great City ofNew Orleans. Sincerely Yours, From: Sent: Monday, April 09, 2007 11 :06 AM To: 106Comments SUbject: Lafitte Development This e-mail is to advise you that I strongly support the phased redevelopment and the new Homebuilding Plan for Lafitte. Preserving the apartment buildings as is does not provide for improvements that residents themselves want. Providence and Enterprise are committed to preserving the Management Building as a community facility which would preserve and celebrate the heritage of Latitte which is of tremendous importance. Enabling some residents to come home now will, I believe, offer hope and be a sign of good faith to all those who want to return to an improved community. Thank you for this opportunity to share my thoughts. May God Bless, From: Sent: Monday, April 09, 20074:43 PM To: 106Comments Cc: Subject: Redevelopmant of the Lafitte Housing Project I am writing in support ofthe proposed pltased redevelopment ofthe Lafitte Housing Project and the new Homebuilding Plan. I particularly appreciate tlte way the ProvidenceCommullity Housing and Enterprise Homes have considered historic preservation opportunities when planning the redevelopment ofLafitte. I believe that this project Itas been delayedfor far too 10llg and must nwveforward quickly ifthe City ofNew Orleansis going to be able to welcome its residents, particularly its poor residents home. I would appreciate your approving their application as soon as possible. The practical, sentimental, and heritage value ofthe brick buildings has been raised by a number ofpeople participating in the planning process, including residents wlto have strong memories ill a place with goodfriends and a strong community. Despite that, many residents have indicated that they are ready for a change and are excited by the opportunity to live in more modern unit especially singles and doubles with yards andporches, as well as larger rooms. Preserving the apartment buildillg is not consistent with tI,e changes and improvement tltat residents have told Providence they want; therefore redeveloping tlte Lafll1e Housing Project with the new Homebuilding plans that Itave been presented would bring afresh inviting appearance bring this area into the 21st century. Your urgent attention to expediting this project would be a GOD send to the community and a GREAT rejuvenating step to rebuilding our great City ofNew Orleans. Sincerely Yours, From: Sent: Monday, April 09, 2007 2: 15 PM To: 106Comments Subject: LAFITTE HOUSING PROGRAM April 9, 2007 Housing Authority ofNew Orleans: Remembering my life as a child and the life of my family on in the Lafitte Housing Development, I am writing to express my support of the proposed fe-development and new Homebuilding Plan. I particularly appreciate the way that Providence Community Housing and Enterprise Homes have considered historic preservation opportunities when planning the re­development. As you know the re-development ofLafitte is a key part of the ProvidencelEnterprise Homebuilding Plan. The practical, sentimental, and heritage value of the brick buildings has been raised by a number of people paIiicipating in the planning process, especially residence who have strong memories as does myself, of living in a place with good friends and a strong community. Despite that, many residents have indicated that they are ready for a change and are excited by the opportunity to live in more modem units, expecially singles and doubles. The dwellings will have yard space and porches with larger rooms. My friends support the phased approach to redevelopment that Providence is proposing, including enabling residents to come home now by opeing a number of existing units of Lafitte as a temporary measure, until the new units are ready. From: Sent: Monday, April 09,2007 12:33 PM To: 106Comments Subject: Redevelopment of Lafitte I am a business man and life long New Orleansresident. I am raising my family of five children here and have committed to stay after the storm. ram also involved in various conununity activities including serving as ______ As such, I am writing in support ofthe Providenceand Enterprise Homebuilding Plan for the Lafitte housing community. I believe the plan has taken into careful consideration the expressed desires of the residents who want to return, the historical nature of the buildings, and the cost implications of the various redevelopment options. The cun-ent plan balances those issues well. Preserving the administration building as a community center allows for some maintenance of ties to the legacy of Lafitte. Building newer, single and double family units provides for living spaces that better meet the needs of residents for daily living in the long tenn. I believe it is time to make some decisions and move forward with the redevelopment. As with any plan, not everyone will be completely satisfied. There has to be some compromise. But, the city of New Orleansneeds to show greater progress toward recovery. We need to make more homes available for returning residents. There should be an abundance ofjobs with the road and bridge work over the river and lake, the condominium and high rise construction coming to the city, and the desperate need for people to support the tourism industry. Now, we need quality places for people/workers to live. Providenceand Enterpriseare experienced in providing this important cog in the recovery ofthe city. Let's give them the green light. They are professionals. Let's trust their recommendations and move past planning stage and move on to the building stage. Thank you for considering my comments. From: Sent: Monday, April 09,2007 10:12 AM To: 106Comments SUbject: Redevelopment plans for Lafitte Housing Project in Treme To: Advisory council on Historic Preservation Copy: Housing Authority ofNew Orleans Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support ofProvidence and Enterprise's joint partnership to redevelop the site ofthe Lafitte Public Housing Neighborhood, and to urge your approval ofthese plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations of poor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modern standards for housing, while at the same time allowing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best to respect the historic architectural character the neighborhood while at the same time the best interest of both and people the sUITounding community and New Orleans as a whole. I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in future ofthis community and whose focus seems to be directed at saving the stmctures themselves, which have limited historical value and have in become symbols of a failed social experiment warehouse the poor and isolate them from the surrounding community. Thank you taking the time to hear my voice and for all you do your 0++-......-+" to better New Orleans and its Signed, From: Sent: Thursday, April 05,20074:22 PM To: 106Comments Subject: To Whom It May Concern: I am writing to express my support ofProvidence and Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood. I urge you to approve these plans. Focusing on preserving the buildings themselves, rather than the well-being of the residents and the surrounding community as a whole, would be an unfortunate oversight on the part of the advisory council. It would be a mistake simply to return these residents to the problematic environment that existed in these developments before Katrina: large concentrations ofpoor residents in deteriorating, cramped conditions, which served to foster crime of all types and often resulted in a pervasive feeling of hopelessness for the residents. Plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modem standards for housing, while at the same time allow residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood, while at the same time serving the best interests of both the residents and the people f the surrounding community and the city as a whole. As a citizen ofNew Orleans, I urge you to consider my opinion when pondering your decision. I also hope that you will not be influenced by outside activists who have no personal stake in the future of this community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols ofa failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank you for taking the ttime to hear my voice and for all that you do in your for the welfare of this city and its citizens. Sincerely yours, -----Original Message----­From: Sent: Friday, April 06, 2007 10:51 AM To: 106Comments Subject: Support for Providence and Enterprise plans for redevelopment of Lafitte To Whom it may concern: am located in Tulane/Gravier neighborhood of New Orleans. I am writing to ask your support for the planned redevelopment of the Lafitte as proposed by Providence/Enterprise Homebuilding plan. Our neighborhood was serious damaged by the flood that followed Hurricane Katrina . We need a good plan to bring our people back as soon as possible. I believe the Providence/Enterprise plan best meets that need. They plan to work with displaced residents in a phased plan that allows some residents to return as soon as possible, but also bring about need changes that we have been working for in our neighborhood over the last six years. Thank you. From: Sent: Thursday, April 05,2007 3:44 PM To: 106Comments Subject: Redevelopment plans for Lafitte Housing Project in Treme To: Advisory council on Historic Preservation Copy: Housing Authority ofNew Orleans Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concem: I am writing to express my support ofProvidence and Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these deVelopments before Katrina: large concentrations ofpoor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modem standards for housing, while at the same time allowing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest of both the residents and the people of the surrounding community and New Orleans as a whole. As a citizen ofNew Orleans, I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future of this community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank you for taking the time to hear my voice and for all you do in your efforts to better this city and its citizens. Signed, -----Original Message----­From: Sent: Thursday, April 05, 2007 3:01 PM To: 106Comments Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support of Providence and Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations of poor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modern standards for housing, while at the same time allowing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest of both the residents and the people of the surrounding community and New Orleans as a whole. As a citizen of New Orleans, I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future of this community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the surrounding community. Thank you for taking the time to hear my voice and for all you do in your efforts to better this city and its citizens. Signed, From: Sent: Thursday, April 05,20073:24 PM To: 106Comrnents Subject: Redevelopment plans for Lafitte Housing Project in Treme To Whom It May Concern: I am writing to express my support of Providence and Enterprise's joint partnership to redevelop the site of the Lafitte Public Housing Neighborhood, and to urge your approval of these plans. I believe that focusing on preserving the buildings themselves, rather than the well-being of the residents themselves and the surrounding community as a whole, would be an unfortunate oversight on the part of the Advisory Council. I believe that it would be a mistake to simply return these residents to the same problematic environment that existed in these developments before Katrina: large concentrations ofpoor residents in deteriorating, cramped conditions, which served to foster crime & drugs and often resulted in a pervasive feeling of hopelessness for the residents. I believe that the plans to revive this neighborhood by rebuilding homes for a mixed income neighborhood, including both renters and home owners and meeting modem standards for housing, while at the same time allowing residents to return right away to a portion of the units as a part of a phased redevelopment, is the best way to respect the historic architectural character of the neighborhood while at the same time serving the best interest of both the residents and the people of the surrounding community and New Orleans as a whole. As a citizen ofNew Orleans, I urge you to consider my opinion when deliberating your decision. I would also hope that you will not be influenced by outside activists who have no personal stake in the future of this community and whose focus seems to be directed at saving the structures themselves, which have limited historical value and have in fact become symbols of a failed social experiment to warehouse the poor and isolate them from the sun'ounding community. Thank you for taking the time to hear my voice and for all you do in your efforts to better this city and its citizens. Signed, From: Sent: Thw-sday, April 05, 2007 11 :29 AM To: 106Comments Cc: Subject: Lafitte Housing Redevelopment Dear Louisiana Advisory Council on Historic Preservation: It has come to my attention that concerns have been raised regarding the current development plan proposed by Providence Community Housing and he Enterprise Foundation. In this post-Katrina environment, we have the opportunity to provide public housing that we can be proud of and that will benefit the lives of many. I know that Providence has considered several ways to preserve the existing buildings at Lafitte. All things considered, it is the people that live in the development and not the physical structures that should remain. The proposed development plan, with its phased approach, will provide the residents with exceptional housing and a preferred living enviromnent. Please consider my support for the redevelopment plan, as submitted by Providence, when making your final detennination. Sincerely, -----Original Message----­From: Sent: Sunday, April 01, 20072:05 PM To: 106Comments Cc: Subject: Lafitte To the Advisory Council on Historic Preservation: Having worked for over 20 years with two of the PreservationResourceCenter's programs, Operation Comeback and Rebuild Together, I truly appreciate that neighborhoods become more attractive when older buildings are restored. Having also lived in New Orleansfor the last 70 years, it has become very evident that public housing has ceased to be an asset to our city and unfit environments in which to raise our children. The opportunity to listen to the residents of this communities, which Providence and Enterprise have done, at last gives those families a voice in creating a safe, viable community. All of us want to bring back this city better that before Katrina. We need your help. It is my understanding that the residents want change -modem, affordable housing that accommodates their larger families. Please respect the residents input as they have often been the victim rather than the beneficiaries of change. There is also the recommendation for phased development which would allow resident to return to existing units while the rest of the site is being redeveloped. I strongly support that proposal as well as the way that Providenceand Enterprisehave considered historic preservation opportunities when planning the redevelopment of Lafitte. The creation of affordable housing post Katrina is extremely challenging .... your decision to support the Lafitte residents, Providence and Enterprisewill make an enonnous difference in the Lafitte neighborhood. Sincerely, -----Original Message----­From: Sent: Monday, April 02, 20072:37 PM To: 106Comments Subject: Comments to ACHP Dear Advisory Council on Historic Preservation: As someone that has lived in the Historic Treme neighborhood for 50 years, I have an intimate knowledge and appreciation for preserving history. While I have never lived in the Lafitte Housing Developments, I did have relatives and many, many school mates and friends that did live there during my upbringing. I have raised the issue of preserving history to my fellow Providence Board members on a number of occasions. We have considered and discussed ways to preserve buildings while at the same time meeting the urgent need of the Lafitte residents to return home. Many of the residents have concluded that it is time for a better way of living and they support the plans they themselves participated in drafting. I feel that the phased redevelopment and the new building plans submitted by ProvidencefEnterprise Homebuilding will, with all due respect, honor the Historic site on which the Lafitte currently sits. The new plans, with it's boundaries intact, will always be known --to those of us that grew up in the area --as the Lafitte. The new plans provides not only an opportunity to bring home those that were living in the Lafitte just prior to Katrina, but also a very real possibility to bring back to the site those that grew up in Lafitte, but had moved out. The more modern units will provide more of a private family style of living that you find in more suburban areas coupled with the historic touches that you expect in the Treme area. I look forward to working with all interested parties as we bring back New Orleans. -----Original Message----­trom: Sent: Monday, April 02, 2007 8:28 AM To: 106Co~nents Subject: I support the proposed phased redevelopment of the Lafitte Housing Project and new Homebuilding Plan. I particularly appreciate the way that Providence Co~unity Hosing and Enterprise Homes have considered historic preservation opportunities when planning the redevelopment of Lafitte, I believe that this project has been delayed for far too long and must move forward quickly if the City of New Orleans is going to be able to welcome its residents, particularly its poor residents home. I would appreciate your approving their application as soon as possible. -----Original Message----­From: Sent: Saturday, February 03, 2007 1:10 PM To: 106Comments Subject: professional opinion Having worked in the construction/renovation field for over 20 years, I feel inclined to support the views of other professionals; namely, that the demolition of such solidly built and historically­relevant sites such as Lafitte Housing Project would be crime against the people of New Orleans. The waste of time and energy spent to reduce these grand structures to rubble would be better spent to renovate. Though the contractors who are suggesting that demoliton is most cost-efficient, I know for a fact that this is a falsehood, and would further suggest that these same contractors are either making these statements with hopes of sharing in some monetary windfall, or they simply don't know ther business. It is true that the cost of "renovations" could be astronomical, but as with any that would depend on the extent of the renovation. The city does not need to turn these former projects into luxury condos. In all actuallity, very little renovation will be needed, seeing that most of these units recieved zero damage from the hurricanes. The immediate need for affordable housing would also be served in a more prompt and timely fashion if one were to use the existing buildngs. And as a gentleman so aptly put it at the meeting on Feb 1st, " if we are hit with a Category 5 hurricane tomorrow, the Lafitte projects would be some of the few structures in New Orleans that would still be standing". In closing, I do not suggest that the Projects return to their former use. I would suggest a mixed-income model would work in the existing structures, just as it has worked in some of the older projects in NYC, whereby the tenants are a mixture of low-income families paying one rate, the dis-abled and elderly paying another, the middle­income paying yet another. sincerely, a concerned citizen From: Sent: Wednesday, February 07, 2007 1:05 PM To: 106Comments Subject: THE LAFmE HOUSING DEVELOPMENT... MY NAME IS , AND I LIVED @ , AND MY LIFE IS AFFECTED TREMENDOUSLY BECAUSE I AM NOT ALLOWED TO COME BACK TO MY HOME.... .ITS AS IF MY LIFE IS IN LIMBO, ......BEFORE KATRINA, I WORKED (2) JOBS AND I FELT VERY BLESSED TO BE A PART OF T HE LAFITTE COMMUNITY......I STRUGGLED TO LIVE IN NEW ORLEANS, I PAID HIGH RENT TO SLUM-LORDS, WHOSE ONLY CONCERN WAS THAT "U BETTA HAVE THAT RENT", EVEN IF THE WATER WAS BACK'N UP IN MY FACEBOWL WHEN THE NEIGHBORS FLUSHED THEIR TOILET!!!!THERE WERE TIMES WI-IEN I HAD TO CHOOSE WHETHER OR NOT TO BUY FOOD OVER PAYING THE LIGHT BILL, I'M A SINGLE PARENT AND I WAS LIVING IN A HOTEL WITH MY CI-llLD AT TIlE TIME I WAS NOTIFIED OF MY ELGIBILITY FOR THE LAFITTE, AT LAST, MY PRAYERS WERE ANSWERED......! WAS GETT'N SOME HELP ....... (AFTER 8 YEARS OF STRUGGLES AND EVICTIONS) I FINALLY GOT A UNIT ... .IT WAS SO NICE!!!!!MUCH BETTA THAN THE PLACES I WAS STRUGGLING TO PAY 500­650MTHLY ...... WHEN THERE WAS A PROBLEM OF ANY KIND INTERNALLY IN MY UNIT,:MRS. FOXWORTH AND HER STAFF WERE ON IT....THEY HAD SMILES ON THEIR FACES, ALWAYS SAIDGOODMORN'N ... FOR THE 1ST TIME IN 8 YEARS I FELT LIKE I WAS IN THE RIGHT PLACE, AND I COULD CATCH UP ON THE THINGS THAT POVERTY FORCED ME AND MY CHILD TO LIVE WITHOUT ... WE HAD NO HEALTH INSURANCE BECAUSE I COULDN'T AFFORD IT, MY CAR WAS IMPOUNDED BECAUSE I COULDN'T AFFORD CAR INSURANCE, BUT LIVING IN THE LAFITTE, TI-IE BUSES AND THE STREETCAR WAS A V AlLABLE , I WORKED IN THE RIVERWALK (SECURITYIDISPATCHER)AND I WOULD SOMETIMES EVEN WALK CANAL STREET (GET EXERCISE)AND WHEN THE TOURIST WOULD SEEM LOST, I'D GLADLY ASSIST WITH DIRECTIONS .... LIFE WAS BEAUTIFUL FOR MY FAMILY PRE­KATRINA, AND I COULD FEEL THE SUN ON MY FACE, IT WOULD BE SUCH A INJUSTICE FOR THE RESIDENTS OF THE LAFITTE, THIS PLACE IS SOLID AS A ROCK........I STAYED IN MY CONDO DURING THE WHOLE STORM, IT DIDN'T MOVE......THE ROOF t-TEVER LEAKED A BIT, THE WINDOWS DIDN'T EVEN BLOW OUT.......WHAT A MIGHTY GOD WE SERVE!!!!AS A MATTER OF FACT MY AIRCONDITIONS ARE STILL IN THE WINDOWS ... J KNOW POLITICS MAY HAVE ITS SAY IN A LOT OF AREAS, BUT OUR CITY IS MISSING REVENUE BECAUSE WE HAVE NO WHERE TO LIVE IF WE WANTED TO COME BACK.....NOT ALL PEOPLE THAT LIVED IN THE PROJECTS OF OUR CITY WERE BAD, I'VE MET THE MOST BEAUTIFUL PEOPLE, THE MOST PRAYlNG PEOPLE RIGHT THERE....... SO TO WHOMEVER READS THIS INSERT, PLEASE CONTINUE TO CALL ON THE MIGHTY NAME OF JESUS, SO THAT WE MAY ONE DAY COME HOME, AND MAY THE LAFITTE BE THAT PLACE!!!!! I'D LIKE TO SA Y THAT MRS. FOXWORTH WAS DOING A MAGNIFICIENT JOB ...... SHE HAD BEGAN TO AlLOW THE YOUNG CHILDREN THAT CAME TO OUR COMMUNITY CENTER(SOJOURNER TRUTH) TO WORK IN THE PIZZA PARLOR AND THE ICECREAM SHOP. THEY DELIVERED TO THE RESIDENTS OF THE LAFITIE, BECAUSE THE OTHER LOCAL PIZZA PLACES WOULDN'T DELIVER TO THE PROJECTS(AND THEY WERE ACTUALLY BETTER THAN THOSE OTHER GUYS)WE GOT A CHANCE TO MEET OTHER RESIDENTS AT THE MONTHLY MEETINGS ALSO. MRS. FOXWORTH HAD BEGAN TO BEAUTIFY THE GROUNDS TOO...OUR DUMPSTERS WERE BRIGHTLY PAINTED, WE HAD BEAUTIFUL FLOWERBEDS AROUND THE GROUNDS AND I WAS PROUD TO LIVE THERE....... AND I WILL BE PROUD TO COME HOME..... From: Sent: Thursday, April 05, 2007 4:18 PM To: 106Comments Subject: I support the equitable redevelopment of public housing To Whom It May Concern: As a resident born and raised in New Orleans, I believe it is important that our city redevelop higher quality public housing in mixed-income, mixed-use communities that replace evelY publicly supported unit that is demolished. I believe just as strongly that we must involve those who were residents of public housing before the hurricane meaningfully in the planning of those communities. Redevelopment can and should be done in phases that allow residents who want to move back now to do so while portions of the housing are replaced. Our community is in gridlock, and precious political, social, and fmancial resources are being squandered on this conflict. The best and only way through this is for all involved to commit to openness, transparency, and legitimate concern for and support ofthe well-being ofthose who were displaced. By slowly building trust with each other we will expand the number and quality of choices before us. Here's to building a better future together for all the people ofNew Orleans. -----Original Message----­ From: Sent: Friday, February 23, 2007 8:36 PM To: 106Comments Subject: public housing My comment is short and sweet. Redevelop the housing projects!!! They are an eyesore, breed crime, reduce surrounding property value, and feed the mentality of entitlement that is horribly prevalent in the city of New Orleans.The projects were meant to be transitional housing for people who are having a tough time and need temporary help. Instead they have turned into a way of life for generation after generation of many New Orleans families. You can see the sense of entitlement when the former tenants claim no one has the right to keep them from THEIR properties. Well they are not theirs. The properties belong to the tax payers of the United States and they want something better for their money ... . -----Original Message----­From: Sent: Friday, February 23,2007 11 :07 AM To: 106Comments Subject: HOD 106 Review of Public Housing in New Orleans Greetings: I wish to convey my input on the matter ofpublic housing in the City ofNew Orleans and the efforts to re-develop the public housing complexes we cun'ently have. . We have seen different plans to re-develop some of these areas and have been impressed with most. Many are accusing the proponents of re-development oftrying to remove public housing and render many homeless. This is a despicable accusation and should have no place in this process. We understand and agree that there is to be public housing. However we cannot in good conscience advocate the return ofour many families who rely on public housing to the horribly failed system that has been public housing for so long and we not only can do better for our public housing citizens, we have a duty to do so. I completely agree with Ms. Emelda Paul who stated so brilliantly at your hearing yesterday "I want to see residents coming back to something decent". Why do we continue to tell our fellow citizens who live in public housing that what is there now is the best they can hope for. This oUght to be not only unacceptable to you and I, but to mankind. These facilities were in terrible dis-repair prior to the flood and now have worsened greatly as a result. Those who advocate returning our citizens to such conditions are doing a grave disservice to our residents who reside in public housing. The people in these housing developments are good people and are more often the victims of crime rather than the perpetrators of it. I would like to draw attention to the East Lake development in Atlanta GA. From my reading this took a very depressed area ofhigh crime and low literacy and completely turned it around. And it WAS inclusive ofresidents in public housing. With this successful example ofhow to re-develop an area ofpublic housing without rendering good people homeless, why not allow re-development to begin so that our citizens in public housing can have homes that give them a sense of dignity and which they can be proud of. Thank you From: Sent: Friday, February 02, 2007 6:49 PM To: 106Comments Subject: Public housing We are still unable to return to our home in Mid-city because of damage sustained in from storm! The idea that perfectly liveable space is being pulled down seems insane/wasteful. Another reason we cannot come back .. is not only that both our workplaces were destroyed (we are teachers), but, that AFFORDABLE HOUSING in the city at this time, is almost nonexistant!! We understand that many structures need to be removed, but wasting our tax-payers money and keeping thousands of citizens from returning immediately to their home...is just wrong, and we ask all of those involved in this decision to sit back and RETHINK!! Thank-you for your time. From: Sent: Tuesday, February 20, 2007 8:00 PM To: 106Comments Subject: Re-opening the housing projects ram a middle-class, divorced mother of one and am totally opposed to having these people return. r was on a field-trip last week and evelY parent on the bus agreed this was a TERRIBLE idea. These individuals don't want to better themselves they want to return to low income housing projects. They don't take care of the developments, no matter how much money or how many times they are repaired. The aren't interested in returning to the city to improve themselves or the city. The projects are and have been for years infested with drugs and crime. I like others listened to them on the news speaking as ifthey are owed something. Home owners like myself are struggling to get our homes and lives back together that's where money should go. We have as a result of the hurricane lost several historical buildings. There is no need to preserve the projects. You saw the news, you've had meetings with this unappreciative individuals. The projects were designed to be a short-term living area for unemployed and under employed residents. We have four and five generations living in one or more units and every development. At what point do these individuals take responsibility for themselves and their lives? Is it New Orleans' or Louisianans' fault that they continue to have babies on top ofbabies. They aren't interested in a helping hand they want hand­outs. From: Sent: Wednesday, February 21, 2007 4:01 PM To: 106Comments Subject: Redevelopment Project I think HANO should think all of these projects through thoroughly. The residents who chooses to return should be screened thoroughly as well. Make sure that the staff check with the previous landlord as to the condition in which the property was left when the tenant moved out. The tenant should have a job. The units should be of quality material and standards unlike the previous ones. Inferior material was used to renovate the properties and the profit ended up in the pockets of the contractor and or politicians. I know the condition of which the units were in when I left there as an Assistant Manager. Please make sure that you hire the best people to manage these units who will be fair and enforce the lease. Unlike the previous administration. The rules applied to some and not all!!! I do look forward to coming back to New Orleans just to see what has developed with these units. Here in Texas the tenants are responsible for aI/ of their own utilities. I think that should be the same in New Orleans for the new units. Make them responsible citizens and not be government and tax payers dependent. You have a hard and rough road to travel and I will be praying that this is a SUCCESS for all involved. Seek the help from other Agencies in other states and see what's working for them and make this a New Dawning for Public Housing Residents. -----Original Message----­From: Sent: Thursday, February 22, 2007 2:15 PM To: 106Comments Subject: CJ Peete, BW Cooper, St. Bernard and Lafitte public housing sites Please don't tear down viable historic buildings. Instead, re-open these buildings to help relieve the city's housing crisis. Change the basic contract by which public housing is made available in order to avoid the problems of the past. Thank you, From: Sent: Thursday, February 22, 2007 2:24 PM To: 106Comments Subject: 0 Peete, BW Cooper, St. Bernard and Lafitte Re: comments on the potential effects of the redevelopment of the CJ Peete, BW Cooper, St. Bernard and Lafitte public housing sites on historic properties in the project area. As a lifelong New Orleanian, I cannot express how strongly I feel that all high density housing projects should be demolished. Demolition ofthe projects and the rebuilding ofmixed-income housing can only have a positive effect on the surrounding neighborhoods, which have experienced a steady decline as a result of their proximity to the housing projects, which are breeding grounds for crime, poverty, drug addiction and despair. Although I realize that the fonner residents of the housing projects feel that they are somehow entitled to live in housing that is affordable to them because it is subsidized by others, in post Katrina New Orleans, we no loner have the luxury of supporting thousands ofun-employed and under-employed citizens. Nor should the fonner public housing residents be given any preference, when former market-rate renters cannot afford a place to live and property owners cannot return to live in the properties that they own. Any historical significance these projects may have is FAR outweighed by the negative impact they have on our City. In addition. the funds needed to renovate the housing projects could be put to better use by renovating existing single and multi=family houses in the same neighborhoods. There are so many houses that were abandoned before Katrina, whose owners do not have the funds or the will to maintain the property and there are many more now. Why not buy these historic properties and renovate them to provide low income housing, in addition to building new housing? From: Sent: Thursday, February 22, 2007 2:57 PM To: l06Corrunents Subject: Proposed demolition ofthe four public housing projects Dear HANO Board: I oppose the propose demolitions of the four public housing projects. Your board has stated that it would cost more to bring them up to code, than to demolish and rebuild them, but your own inspectors have found that these buildings actually survived the flooding in very good shape. With a minimal amount of cleaning and repair, these aparbnents can be readied for their tenants, who have been literally locked out of their homes for the last year and a half. These tenants are willing to clean these apartments, repair the damage, and take care of them. Your management staff has never taken good care of these apartments, and has let them deteriorate, through demolition by neglect. Three years ago, some of us from C3/Hands Off Iberville went onto the lberville Housing Project grounds, and found burned out lights, high wire fences, and other obstacles, which impeded tenants' use of the grounds. Many of these problems could have been easily repaired, making that project more livable for its tenants. The four housing projects slated for demolition probably have many of the same neglected facilities. The tenants aren't to blame for this four-decades worth of neglect. This neglect is your agency's responsibility, and your staff should find the money, and make the needed repairs, so that these displaced families can return home. Your agency and HUD have talked of public housing tenants exercising "personal responsibility". Tenants who volunteer their time and effort to clean up their apartments and insist on cleaning up their public housing complexes are exercising "personal responsibility." What could be more indicative of showing upersonal responsibility" than stepping forth, and taking responsibility for a public housing complex, especially when those supposedly in charge have refused to do so, and have offered up all kinds of excuses, such as how much more it would cost to clean and repair minimally damaged apartments, than to blow about $500 million more on tearing down these very well-built apartments, and replacing them with less-distinguished "town homes" along the lines of the River Garden apartment complex? Your agency has never offered up any verifiable proof of a link between these public housing projects and drug use and violent crime, except for proximity between these three elements, or some vague concepts of "concentrations of poverty" or "density". Your agency hasn't shown reporters, public policy groups, public interest lawyers or public housing advocates any studies that would justify your decision to tear down these four public housing complexes. Most of these public housing tenants would like their homes and apartment complexes to be safe, well-lit, well-kept (as in the apartments and hallways painted, the rodents killed, the plumbing working. toilets and sinks that don't back up, and water stains removed.), and have the grounds and gardens restored. Many of them remember being promised on-site community centers, and places for their children to play. Those have either never been built, or they were set up, and have never been properly maintained. Instead of spending close to $700 million to tear down these very sturdy, well­designed public housing complexes, and replace them with inferior housing, you should use that money to fund the cleanup of these four housing projects, have them reopened, and ensure that their residents can return. Many of these tenants work in low-wage tourism and hospitality industry jobs, and must have a place to live, before they can return to their jobs, and help rebuild our economy. Their children, who spent the last 18 months either in school in other cities, or adrift in our city, upon returning home, need "roots", a place to call home, where they can return. Sincerely, From: Sent: Thursday, February 22, 2007 4:22 PM To: 106Comments Subject: projects My comments on bringing back the projects: I think it would be a terrible mistake to resurrect the CJ Peete. BW Cooper. St. Bernard and Lafitte public housing sites.Those places were areas of concentrated poverty and criminal activity that rotted whole communities where the projects were built. The projects were supposed to give its inhabitants a chance to improve themselves. It backfired. The projects caused perfectly good neighborhoods to turn to blighted neighborhoods once the housing project inhabitants turned the projects, and then the surrounding neighborhoods. into turfs for drug sales and a do nothing attitude that did not lead to self improvement. Those projects were dens for generations of people who were not contributing to the tax base of the city and worst of all, had no incentive to work to improve their environment. I'm sure there were a few hard working people living in the projects but I'll bet they were working as hard as they could to get out of the project environment which does not encourage education, hard work, a sense of community pride and legitimate business activity. Those projects are what people in other parts of the country look at and say, "why can't those dumb people in New Orleans help themselves?" It doesn't make any sense to resurrect an already ridiculously broken system of concentrated poverty and criminal activity. I realize we need housing but reopening the projects will quiet a few people complaining about a housing shortage but the bigger problems will remain-the crime and poverty will return and more and more hard working people will find it easy to make the choice to flee a city that can't learn from it's own.mistakes. I'll take a housing shortage over housing projects full of the same people doing the same thing they were doing pre-Katrina any day. Anyone who wants this city to come back better than it was before should feel the same way. -----Original Message----­ From: Sent: Friday, February 23, 2007 11:05 AM To: 106Conunents Subject: Re-Open Public Housing! I have been a resident of NOLA since 1992. I have worked on Jackson Square since 1993. I have been living in my apartment at 623 St. Peter St in the FQ for over 10 years. I very strongly feel that the plan to tear down public housing MUST be abandoned! It is far less expensive to repair the damage and open them up. There is a a real housing crisis here in NOLA. There is also a crisis for businesses looking for help in low paying jobs. Re-opening public housing will help on both counts. From: Sent: Friday, February 23, 2007 11:07 AM To: 106Comments Subject: HUD 106 Review of Public Housing in New Orleans Greetings: I wish to convey my input on the matter ofpublic housing in the City ofNew Orleans and the efforts to re-develop the public housing complexes we currently have. We have seen different plans to re-develop some of these areas and have been impressed with most. Many are accusing the proponents of re-development of trying to remove public housing and render many homeless. TIlls is a despicable accusation and should have no place in this process. We understand and agree that there is to be public housing. However we cannot in good conscience advocate the return of our many families who rely on public housing to the horribly failed system that has been public housing for so long and we not only can do better for our public housing citizens, we have a duty to do so. I completely agree with Ms. Emelda Paul who stated so brilliantly at your hearing yesterday III want to see residents coming back to something decent". Why do we continue to tell our fellow citizens who live in public housing that what is there now is the best they can hope for. This ought to be not only unacceptable to you and I, but to mankind. These facilities were in terrible dis-repair prior to the flood and now have worsened greatly as a result. Those who advocate returning our citizens to such conditions are doing a grave disservice to our residents who reside in public housing. The people in these housing developments are good people and are more often the victims ofcrime rather than the perpetrators of it. I would like to draw attention to the East Lake development in Atlanta GA. From my reading this took a very depressed area ofhigh crime and low literacy and completely turned it around. And it WAS inclusive ofresidents in public housing. With this successful example of how to re-develop an area of public housing without rendering good people homeless, why not allow re-development to begin so that our citizens in public housing can have homes that give them a sense ofdignity and which they can be proud of. Thank you From: Sent: Friday, February 23, 2007 12:25 PM To: 106Comments Subject: Project Development Since over a year ofcommunity input/planning has occurred through neighborhood meetings, the Lambert and UNOP processes, we should follow those recommendations. Also, studies show that mixed income housing is the best model for a low to no income population. It's best for the residents and the community as a whole. Throughout the world, cities and the experts have come to realize housing that concentrates poverty does it's population a disservice. Mixed income housing provides economic and social opportunites unavailable in concentrated Federal housing developments. Please do not use the old model~ but disperse low income housing throughout our City, including IbervilIe. It was reported this week that there are 1,500 low income units available right now with no candidates. PLEASE DO NOT CONCENTRATE OUR POVERTY. SECJ'ION 106 REVIEW AND DOCUMENTATION LAFllTE HOUSING DEVELOPMENT, NEW ORLEANS, LOUISIANA HOUSING AUTIiORITY OF NEW ORLEANS JANUARY 2007 APPENDIXF COPIES OF TRANSCRIPTS FROM PUBLIC MEETINGS 15060165 Laline Section 106 Report.doc U. S. RISK MANAGEMENT, L.L.C. HOUSING AUTHORITY OF NEW ORLEANS STATE OF LOUISIANA PUBLIC MEETING RE: LAFITTE HOUSING DEVELOPMENT * * * * * * * * * * * * * * • * * * * SECTION 106 CONSULTATION MEETING HELD AT FISCHER COMMUNITY CENTER, 1400 SEMMES, NEW ORLEANS, LOUISIANA 70114, ON THURSDAY, FEBRUARY 1,2007. REPORTED BY: Darcee Michele Cacibauda Certified Court Reporter MR. BABERS: We're going to go ahead and get started. Good evening and welcome to the Section 106 consultation meeting on Lafitte. Under the requirements of National Environmental Protection Agency, we are required to consider any adverse affects on property listed or eligible to be listed on the National Register of Historic Places that may be the result from a federal undertaking. The this meeting is being held in conjunction with the State of Louisiana and the City of New Orleans. The purpose of this meeting is to do just that. We are asking for your comments, not only because it is a requirement, but more importantly, because we value your input and desire community input in a" of our endeavors. We ask that you limit your comments to this issue and want to point out that responses will be published on the HANO web site within 15 day of the meeting. I would like to introduce at this time, Mr. Jeffrey Riddel, who is our HANO executive director. Jeff, good to see you. And also, we have Mike Lorando, who may be able to make it, from the State Historic Preservation Office. Also, we have Tracy Dodd with U.S. Risk Management. And we also have Attorney Rosalind Jones Larkins who will be moderating. Again, thank you for coming, and we do value and appreciate your input, and we are wanting to hear what you have to say. So at this time, I'm going to ask Attorney Larkins to come forward. 1 3 MS. LARKINS: 2 Good evening. Before we get started, just to 3 the preliminaries, speaker who signed up for comments will 4 be called. You have a three-minute period of time to deliver your 5 comment. However, we are offering an opportunity to acknowledge 6 those persons who would like to yield your time to another 7 representative. We would like that to be acknowledged this time. 8 There is one person that would like to yield their time to a 9 representative. Due to the time-limit of the meeting, we're going to 10 keep the comments roster available for another thirty minutes to 6:15 11 to allow those with delays, for whatever reason, an 12 opportunity come in and sign up. Now, we'll proceed with the 13 meeting. If there's no questions, we'll proceed with the meeting. 14 We'll start with a fifteen minute presentation -­ 15 Yes, sir? 16 MR. LOGAN: 17 Since it seem you only hav~ a few people here, 18 can folks make their comments, and then if there's a lag time the 19 will other people who were initial speakers be able to get up and 20 say a few more comments, have a second three-minute period? 21 MS. LARKINS: 22 Well, we actually are using a roster. And going to continue according to that. However, I will yield the meeting 24 to Mr. Babers once all the person who have signed the roster, and Mr. Babers will go from there. MR. LOGAN: So Mr. Babers will be the one to answer that? MS. LARKINS: Correct, because we actually have another meeting that's scheduled after this meeting, so we can move in a timely order, okay? Thank you. Yes? MS. PAUL: Yes. Will you ask people to identify themselves so we will know who is speaking? MS. LARKINS: Yes. We're going to call the names off. MS. PAUL: What was his name? MS. LARKINS: You're name, sir? MR. LOGAN: My name is Jim Logan. MS. LARKINS: Jim Logan. I'm here pretty much here by myself right now. MS. LARKINS: Okay. I was just asking you because she wanted you identified. UNIDENTIFIED SPEAKER: Do you know what the meeting is about? MS. LARKINS: 1 Actually. The 15-minute presentation Ms. 5 2 3 4 Dodd is going to give, will you an overview of the meeting. UNIDENTIFI ofthe 5 Well, I might have something to 6 MS. LARKINS: 7 Well, you can and ~hor",..Ho.. you decide that 8 you don't want to comment, then I call your you can go 9 ahead and 10 UNIDENTIFI 11 12 Okay. All right. MS. LARKINS: 13 The comment actually, will still outside 14 and available. But after the presentation, though, you will able to 15 sign up. 16 Okay. Anyone else? 17 (No 18 MS. LARKINS: 19 Okay. We'll started, Ms. Dodd. MS. DODD: Good evening. Can everybody me in the back? is Dodd. I'm States Risk Management. We are a consulting firm that works with 24 Authority of New Orleans tasked with completing the 106 documentation process. In this for Lafitte Housing Development, but also tasked with completed various other compliance related issues to the Lafitte Housing Development project itself. What we are tal~ing about here tonight is the 106 documentation developmental review process, which basically concerns the compliance with state historic preservation office requirements. And essentially what we are doing is working within HANO'S vision to transform existing, aging, deteriorated, and obsolete housing into new mixed-income community. Basically, the hope of HANO is that this will create viable neighborhoods that integrate HANO families and housing into the community and serve as a catalyst for recovery post-Katrina in the city as well as reducing density and concentration in the developments and also helping to maintain the integrity and the visual connectivity of the developments itself so that they mirror the type of neighborhood and communities that are in and around the current developments. Let me tell you a little bit about the 106 overview. Essentially, it is delineated and described by the National Historic Preservation Act of 1966, and it is required for any federal undertaking, any undertaking that uses federal money that may have an adverse effect on a property listed or eligible to be listed on the National Historic Register of Places. Although Lafitte is not listed on the National Historic Register, it is eligible to be listed on the National Historic Register. So, for that reason, we are here discussing the 106 process. And essentially, what it does is, it looks at adverse effects that may include direct and indirect impacts, both temporary and permanent to the surrounding community. And what we do is we focus on something called the area of potential effect, or I'll shorten it APE for the purposes of this. Essentially, what it is, is the area of particular effect --And right behind me, you will see a drawing that have here of an area photograph with the Lafitte Housing Development and what we call the area of potential effect and the National Historic Register listed property, which is the laundry facility for the Lafitte. And then neighboring, you've got the Esplanade Bridge Historic District, and then you can see the boundary of the streets. Essentially, this is what we have, to date, determined to be the area of potential effect. This is in draft form. You can see this document and download it on the Housing Authority of New Orleans' web site as well as with the documentation that supports how we came up with the area of potential effect. But essentially what it is, it's a geographical area. And what does is look at the direct or indirect effects in and around the community that may result in alterations of the character or use of historic properties. And again, as I said earlier, it deals with direct impacts. Here, we're looking at demolition, re-development, economic impact, land-use changes, but it also deals with indirect impacts associated with completing the project or the undertaking, such as visual impacts, air quality, vibration concerns, noise traffic. And these can be both on a temporary as well as a permanent basis. And they're all part of how we evaluate the area of potential effect. Essentially, as I said earlier, you've got the general laundry building right here, which was National Historic Register listed in 1994. You've got the Esplanade Bridge Historic District, which was listed in 1980 that is partially included in the area of potential effect. Lafitte Housing Development is, again, eligible but not listed. In here, you've got structures in the adjacent neighborhoods that are over 50 years old, and they're also not included in the Esplanade Historic Bridge District. In addition to that, you've got archaeological resource issues associate with the project. What HAND is doing is they are undertaking what is called a Phase I archaeological survey, which basically will allow, rather, document the type of things that are seen as a result of the progress of the construction and demolition activity. And it's all being done under the guidance of the State Historic Preservation Office. And in order to address other potential historic properties, the State Historic Preservation Office has provided a list of five Native American tribes that may have interest in being consulting parties and may be interested in archaeological consultations as part of the process. Essentially, here, again, is the drawing, APE behind me. Please keep in mind that this is a draft. And the reason that this is a draft is that this is the beginning of a very long process as far as public involvement and public participation and state review and state evaluation. And the reason it's draft is because we area awaiting consulting party comments. We are awaiting consulting party to review the documentation and tell us their thoughts. Comments will be received tonight. We'll tell you how you can also put written comments into place. And then, those comments will be addressed and this will undergo state review. So again, that's why you see "draft" on everything. And you'll see the same on the documents that can be downloaded from the HAND web site. Essentially, going back to the criteria for the area of potential effect, talking about direct impacts. Here, the demolition, what we're hoping to do is extensive documentation with regard to Historic American Buildings Survey. And there will be photographs that will be collected and documented prior to demolition. With regard to re-development, we're talking about a mixed community, mixed-income community with rental units and with home ownership and essentially trying to re-establish the neighborhood network within the Development itself by reconnecting the roads that outline the Development and bringing them back in to get more of a sense of community and neighborhood. And all of this is being done with guidance from the Louisiana Speaks Planning Initiative Book. Let me tell you a little bit about that. Essentially, it's the guidance document, the Louisiana Speaks Pattern Book. And what does is, it drives this process or it serves to guide this process. And we're hoping for, based upon the pattern book, is to create a redevelopment that will occur at a lower density than is currently there now. The Louisiana Speaks Pattern Book will service, again, as I said, the planning guide for the entire process. And within it, you will see, and we'll revert to the type of architectural styles that are more common to the neighborhood. And those will be taken forward into the design and construction, architectural construction process. Essentially, again, we're looking and reestablishing the public street grids, bringing the community back into the neighborhood. And we're talking about all the proposed construction designed being done in accordance with approval from the State Historic Preservation Office and from ACPH. And, basically, that will ensure that redevelopment in this area conforms to those things that you see in the Louisiana Speaks Patterns Book and maintains the visual integrity of the neighborhoods and positive visual impact to the surrounding community. To give you an idea of past projects and the type of things that we've been seeing, this is the new Fischer. This is what you see currently surrounding this community building. This is what old Fischer, Fischer high-rise looked like. You see a stark difference. This is new Desire, and this is new River Garden, which was the old St. Thomas Housing Development. And these are the types of designs that we are talking about for architectural designs. Now, with regard to other direct impacts, we are looking at economics and were also looking at land-use issues. With regard to economics, immediate repairs to Laffite, we're looking at $24 million. That's not bringing everything up to code and making this housing livable for the general public. Modernization, current codes cost approximately $154, $155 million, but that doesn't address substrate or structural soils issues or the structural issues themselves that, obviously, have some significant deterioration as a result of Katrina. Demolition and new construction is slated to cost about $124 million. And if you looks, there's almost a 25 percent difference between rehabilitating these structures and redeveloping. Land-use. One of the other direct impacts that we are looking at is, basically, HANO maintaining a long-term lease on this site so that they have continual involvement in the property in the future. Now, with regard to what we were asking of groups and the general public is to function as consulting parties in this 106 process. And, essentially, what we are doing is we're asking for organizations and individuals who are concerned with potential affects on the historic properties to get involved in the process and to request to be a consulting party. HANO and HUD consider all written requests to participate as consulting parties, and invitations to consulting parties have already been extended to local and state agencies, Native American tribes, neighborhood organizations, historical groups and activists, other prominent individuals that have already requested to be in involved under the guidance of SHPO. And these are groups that we have received by list in name and address form from the State Historic Preservation Office. So this is where HANO has started. And, essentially, the role of the consulting party is that we're going to be seeking your comments and getting you involved in the process of seeking further discussions and also receiving your views on the 106 process itself. Essentially, part of that involves commenting during the public comment period. If some of 12 you saw the initial first advertising in the Times-Picayune approximately two weeks ago, that was the start of the public comment period. Public comment period extends for another two weeks. And, essentially, what we are hoping is the consulting parties I will comment, they'll review the documents and the findings that are posted on the web site, on HANO's web site, and they'll also get involved in comment on the memorandum of agreement. Let me explain what the MOA exactly is. Comments that you can hear and comments that you put on the web site, are going to part of the permanent record. All comments that are I received, will be posted and will be addressed on the HANO web site. There is also newly a HANO mailbox specifically to receive comments for the 106 documentation process for requesting to be a consulting party. You will also find this on the web site. You can submit comments and number ways in addition to that mailbox. Submitting them in a written form. You can submit them during this public meeting. Stand up and they'll be read into the record, record it, or you submit them, as I said earlier, in writing to HANO, either through the web site or directly to Judith Moran as stated in the public notice with the address printed on it. But, essentially, all comments must be submitted by 16. Now, as I talked to you about earlier, we're looking at entering into a memorandum of agreement, which we commonly call it MOA. And basically, what it is, it's a binding agreement that records the terms and conditions between the state and the Housing Authority of New Orleans to resolve any of the impacts and the effects of the undertaking of those impacts on historic properties as part of this project. Essentially, what happens is when an MOA is filed, it included certain types of documentation. And, basically, that includes the evaluation on how we determined was an adverse effect and how those effects are going to be minimized or avoided. And it also contains the summary of use and the comments that were received during the public comment period. And essentially, what it's used for is the agency, State Historic Preservation Office, uses it as a means to monitor and record the activities associated with the project and to check on it during implementation. And it also has provisions of termination of the proposed activity. And that is the final role of the consulting party. So essentially, as I said, and to summarize, what we're hoping for is that people in groups here will be part of the consulting party process, will come up tot he microphone, they'll give verbal comments, they'll go to HANO's web site, pull down the documents, request to be consulting parties, or submit written comments directly to Judith Moran at the Housing Authority of New Orleans. Thank you. MS. LARKINS: For those persons who were not in the meeting before we started, the comment sheet will remain open for signatures to make comments until 6:15. It's now six o'clock. Also if someone has entered since the meeting, the floor has been open to receive acknowledgments of persons who may want to yield their three minutes to a representative speaker. If we have someone that's present that would like to yield their three minutes for comments to a representative, we can acknowledge that person now. (No response) MS. LARKINS: So we'll proceed with the comments. Mr. James Dugan. MR. DUGAN: Good evening. I'm James Dugan from the Louisiana Landmark Society. I feel just like a jazz musician buzzing my theme. But I want to state again, for the record, for each individual, that Louisiana Landmark Society has significant reservations and objections to the plan as proposed as I said last time, the evening before last. Your fundamental concepts that these buildings are obsolete, etcetera and so on, the buildings seem to be worn out by neglect. I don't believe that most people would consider that, the way they're putting it, the housing is aging, obsolete and beyond repair. More on point, these new buildings are inferior construction. They arise out of a new tradition in the public housing relative to what was done in an experiment based with the rest of the country. These are not, as you showed in you example, the old Fischer project. These are not, with the exception of the old Fischer, which is now gone, those sorts of projects. They are low-density, garden style apartments. These are not the miles and miles of public housing you have in Manhattan, New York. These are garden-style apartments. These are the models that all of these mixed income, scared to say, developments that you are proposing in Peete under 106, were modeled after. This is the experiment that succeeded. And to say because of years of denying and the neglect, that somehow attributing all this to FEMA, particular the housing project, most of which did not flood, seems disingenuous and it seems to anyone who's in Louisiana Landmark Society that the vital architectural model that is harmonious to the surroundings does not try to mimic them in a historical sort of way. They are, not to be overly critical, but what is across the street is not New Orleans. It is not. It's a simulation. It's the Disneyland version. And to lose a valuable vital 100-year construction and put an imitation that is really, really a 20-year construction, and ignore the lessons learned by the experiment that New Orleans succeeded in many, many ways, where many of the public housing authorities failed across the country is disingenuous and would be very tragic. Thank you. MS. LARKINS: Jaime Loughner, Mayday NOLA. MS. LOUGHNER: I'm Jamie Bork Loughner, and I'm a member of Mayday NOLA, and I come here to register my strongest objections to what you're planning. Pretty much, the gentleman in front of me registered many of the same objections I have, which is the buildings and very solid, very strong. They withstood Katrina beautifully. I just was in one for 17 days, and I can say that it was in great condition. It's appalling that you would utilize a storm to take people out of their communities, to keep people out of their communities because the plan is to reduce public housing by 90 percent. It's outrageous that the public is standing for it, and I encourage everyone to object as strongly as I have. I will continue to do everything in my power to oppose this. And I stand before you appalled and mortified that my government is in cahoots with developers to pretty much spread the misery of the displaced people who are suffering, to continue to allow these people to be in places in Atlanta that they don't want to be, in places in Texas that they don't want to be. These people deserve to come home. They have a right to come home, and your plans are going to stop them from coming home. And so I hope, I pray that we are going to be able to stop your plans. MS. LARKINS: Jake Arena. MR. ARENA: Good evening. My name is Jay Arena with United Front for Affordable Housing. First, I want to clarify the comments by Ms. Dodd with the U.S. Risk Management. I am not a consulting party to this crime. I am a dissenter to the crime that Housing Authority of New Orleans, the Housing and Urban Development, Bush administration, and the opportunistic consultants that are collaborating in the destruction of the Lafitte community. I was at Lafitte Development in September of 2005, just after people were allowed to return to the city. I was with a number of people for United Front for Affordable Housing and the residents of Lafitte. Lafitte had not been flooded. People were trying to move back in, but the authorities refused to turn on the utilities. This is viable housing, not obsolete housing, housing that we desperately need in this city. Furthermore, Professor Fernandez from the Massachusetts Institute Technology has also --and these are independent, objective examinations of these buildings --has shown that they are viable. People can move in with just a little bit of cleanup. Furthermore, other consultants have also looked at this and confirmed that. What that said, we have to look at what is the real reason that they want to destroy that. This is not about concern about the residents. It's not about rebuilding better housing. It's about seizing valuable real estate in the city that developers had wanted for years. And Hurricane Katrina provided an opportunity for that. That is the real agenda. It's about the agenda, the powerful in this city and this country of changing the class and racial demographics of this city, putting through, what we call, racial and class cleansing. And in my short time, let me just point out a few of the other distortions put out by Ms. Dodd and her fancy PowerPoint presentation. She talks about that it's cheaper to knock these buildings down and put up their clapboard replacement. We've also had studies done that it would be cheaper, it would be more economical to rehab the well built Lafitte Development, which is modeled after the Pontalba Apartments in the French Quarter, than to send your bulldozers after that. And we have to also emphasize who is collaborating in this crime. We're talking about parties, consulting party. Well, one is the archdiocese of New Orleans. So that has to be emphasized that there iron, so-called, providence community housing is also collaborated with the destruction of affordable housing, which is part of the agenda of racial class cleansing. Furthermore, our consultant showed the, incredibly showed that the so-called River Garden, the community still called St. Thomas, as a model for Lafitte. I can't believe they're still pushing this. St. Thomas was 1510 public housing apartments, rent­controlled which, people paid 30 percent of their income for rent and utilities. That has been replaced by under 200 units. And those haven't even been --That's what's promised. A huge, huge reduction in affordable housing and very few, only a handful, of the former St. Thomas residents have ever been able to see their new community, their redeveloped community. And that is what you're promising for the new Lafitte? This is what you're telling us? Well, let me end with this. Whatever you say, the community is going to continue to fight. We have courageous people like Jamie from Mayday NOLA who has stood with the community and willing to defend those viable apartments. And that's what will be done at Lafitte regardless of how many strike forces or SWAT teams of other forms of repression that you are ready to unleash on the people of this community. MS. LARKINS: Ms. Elizabeth Cook. MS. COOK: I'm with the C-3/Hands off Iberville. And again, to be redundant, I'm discussing the illegitimacy of this process. This hearing should not be happening because the only legitimate process is to reopen the communities and let the people come home, since that wasn't done in advanced to this stage where, yet, another illegitimate hearing has taken place. And, again, your PowerPoint presentation, there's a fancy show of facades, but in hiding the facades, I was talking to a resident who lives in Hendee Homes. There's a number of repairs that are already needed in her home. She just moved in there a few months ago. We know that the housing that is going to replace the developments is going to be inferior to the quality of the buildings that are already there. Regarding Lafitte, I worked closely with a resident who recently got in a car accident, Patricia Thomas. She moved seven times since Katrina. So HANO's claim that they are helping residents to get resettled is false. People are suffering. They're having to move time and time again. Patricia Thomas was literally a part of the St. Peter Claver Church, a part of the church to form the congregation about the plans of the Providence Community Housing has to redevelop Lafitte. Patricia Thomas knew that many residents of Lafitte attended St. Peter Claver. Father Jacques, the pastor of St. Peter Claver is on the board of director's of Providence. Patricia Thompson knew that this was extremely unfair that so many people lived in Lafitte contributed time, money to the congregation of St. Peter Claver and in return, Father Jacques was on the Board of Directors of an organization that plans to demolish, to take part in the demolition of the development and redevelopment. Patricia Thomas knew the truth of what is going on. Again, the only legitimate process is not this hearing. It is to reopen public housing and let the people come home. MS. LARKINS: Mr. Greg Christie. Lafitte resident, Mr. Greg Christie. (No response) MS. LARKINS: Mr. Mike Howells. As Mr. Howells comes, I'd just like to note that it's 6:15. For those of you who have not signed up for cornments, you have a few seconds to go sign the comment book. MR. HOWELLS: Okay. I just want to mention that Mr. Christie would speak today, but he is feeling very ill about the stress of not being able to return home has added to his physical problems. But he's made it very clear time and again that he, like, most of other residents in Lafitte, wants to come back. He's a friend of mine, so I wanted to at least make sure his word get out that D. J. Christie wants to return home. And as for my own words, one thing that might have came out a little different from other people, and I mean United Front for Affordable Housing, is that I stayed here. I never left the whole while. And I live on the corner of Barracks and Rampart. And as the thousands of people started going down Rampart Street, marching off to the Superdome, they had to march right by my house. And I saw many of those people go there. I assumed that there were some people who were from the Lafitte Housing complex who were on their way to the Superdome after the flooding. It's just etched in my mind how terrifying it was for those people that have to live, leave their homes. And I know how terrifying it is not to be able to come back because we were threatened with arrest for staying in homes on the east bank after the storm. But one thing I'd also like to mention here is you're dealing with the ambiance, also a contribution of Lafitte. I know that some other folks are going to be dealing with that, the preservationists, That the buildings in Lafitte, which held up, as we all know, very well in the storm; just scrub them down a little bit and they'll be fine, were modeled after the Pontalba apartments. Okay? We have people who come from around the world and go to the Pontalba, go to Jackson Square, and admire the Pontalba apartments. I know that because I work there. I'm a reader. And that is one of the great attractions of the French Quarter, the Pontalba Apartments. Now, here we have buildings modeled after the same style of historical architecture that is literally at the heart and soul of New Orleans, that are in good shape. The first floor may need be worked up a little bit, but we know they're in good shape. The first floor may need worked out a little bit. But we know they're in good shape, and you're talking about tearing them down. There's a crime against humanity enforced for not letting people return. And I favor reopening all 896 units now, repa.ir and reopen because it's my understanding, my support. But also, it's, well, this is a blow against the history, culture of New Orleans. And we know that Lafitte is eligible for the National Historic Register. The preservationists have made this over and over again. And it is a violation of the law to knock down these buildings. On top of it, there's the incredible human need for the housing in the first place. So how can in any way, shape or form, this action be justified as enhancing New Orleans? It isn't enhancing New Orleans visually. It isn't adding to the ambience. It's ruining it. You want to put these cookie-cutter houses up instead, but they'll blown down in the next hurricane. And instead of people being able to go to the second and third fourth and save themselves in Lafitte, they'll drown in their homes, the little cookie-cutter homes in the Treme area. And that's, what we're talking about is murder before it even happens. And so this is another responsibility. So obviously, I'm arguing my strategy is to repair and reopen. You say that if we repair and reopen it's substandard. Every house in this city is substandard. I'm sure that Lafitte will at least be in better shape if it's scrubbed up a little bit than 95 percent of the other homes in the city, and it certainly would be safer. And I think everyone, of course, who was living there, has a right to come back. And for the people who if there's some extra units open up, we've got a waiting list of 6,000 families that need to get into public housing, they can fill those units. But I think it's a crime that's being planned here. And I think, if you have any conscience, you will vote against knocking these developments down, and you vote for repair and reopening. We'll worry about the finer points two or three years from now when it comes to matching this or that standard. But right now, we need to get these places open. They're as safe as any place in the city. Thank you. MS. LARKINS: Mr. Robert Tannen. MR. TANNEN: Good evening. I'm here representing the Downtown Neighborhood Improvement Association otherwise commonly known as DNIA. And within that organization, we have a housing committee that is been meeting on a regular basis for some period of time before Katrina. I wish to be named as a consulting party through this committee, and also to be named in opposition to the proposed action of demolition. We believe that the proposed actions and the process being used currently, as well as previously by HUD and HAND to determine the proposed action, is in violation of the National Historic Preservation Act of 1966 and the National Environmental Policy Act of 1969. We will be providing more detailed information about the basis of this opposition, but I would like to say tonight that HUD and HAND is treating these properties in language and studies, including the study that's been presented here tonight, as unsuitable for habitation, but is not treating these properties as historic, which is the intent of 1966 Act. That is we're hearing about the unsuitability and the poor condition and dilapidation, but not the issue of the historic merit to these properties, which have been recommended for inclusion on the National Register of Historical Places. Then the Environmental Policy Act which would kick in after this process, which ends, I believe, on the 17th, or thereabouts, will require equal consideration of alternatives to demolition. We have heard nothing about the alternatives to demolition from HUD and HAND and from the consultants. And, yet, we've been told that that information will be available at some web site. But all the effort thus far has been to justify the demolition program as oppose to presenting publicly the alternatives, which should be given equal consideration. Thank you. MS. LARKINS: Jim Logan. MR. LOGAN: Good evening. My comments, I think, in many ways, will echo what Ms. Cook just said that the meeting shouldn't be taking place tonight. But I think I've got what their reasons. And just since we're making a record of this, I think it's important that everybody understand that there was no proper, timely notice to anybody about meetings that are being held tonight, and the one's that I understand were held on Tuesday night. There have been many requests made to, I believe, HUD and HAND to be a consulting party, and yet, those folks were never contacted, and specifically, advised about this meeting. There have been many other meetings held for the residents of the housing projects, and you have sign-in sheets for those meetings. And several speakers at those meetings specifically got up and talked about preservation matters. And to my knowledge, none of those people were specifically advised of this meeting, just like that, knowledge that they had an interest in the issues we're trying to talk about tonight. You have neighborhood organizations that live in or near those projects that are within the historic districts. And again, to my knowledge, none of those, very easy to contact, organizations and individuals were not contacted about the series of meetings. There was, I understand, a list provided to HANO and/or HUD by the SHPO's office that specifically had the names of some folks to contact. And I was one of the people that was on that list, and I have never been contacted formally to participate in any of these meetings. Folks in .the community have been monitoring a federal lawsuits that's going on now concerning the displacement of the residents, and trying to find out, by watching that, when there might be a discussion on the federal preservation issues, etcetera. And my understanding was that as recent as December '06, HUD and HANO returned to court in that other litigation that we don't know anything going on in that demolition. There hadn't been any plans, etcetera. So I find it very interesting we are having this meeting again without the people being able to find out anything who are monitoring the lawsuit. Secondly, similarly, there were pending the Freedom of Information Act requests made to of all the agencies, specifically including HUD and HANO for information about what might be going on with the NEPO reviews of the 106 process. Again, to my knowledge, there has been no response made in a timely manner by HUD and HANO that were offering any documents in response to those requests. This whole issue of what's going to take place with the housing projects in New Orleans has been a matter of incredible intense scrutiny, certainly locally. The Times-Picayune almost daily has an article that touches on this in one way or the other. And I know it's also been picked up by the New York Times, the Washington Post, and probably a lot of other publications that I'm just not aware. And again, despite all of that interest out there in the community, I haven't seen that there's been any public notice getting in any of the local media talking about, "We're going to have a meeting on the 106, on NEPO. We went everybody to come and share and contribute their views with us." Now, we do know that there, apparently, was some kind of a notice put in the Times-Picayune several weeks ago. But again, I don't think this qualifies as any kind of meaningful advertising of public notice concerning these meetings. HANO has advertised or put notice out for public meetings or others will typically take out, I think it's an eighth of a page sized ad in the Picayune that says, "Dear residents, we're having a meeting. We're going to talk about the new development. Please come." Clearly, you know, it's a nice ad. It's easy to see. When I'm sitting there reading the paper as I have my morning coffee, I run acr.oss --FEMA is also going through consideration of a lot of demolitions in town. And they run the same kind of, you know, easy to see, quarter to eighth of a size newspaper ads. We didn't have anything like that. I understand that's, there was this small print type ad in the back page of the classified section. don't think that cuts it in this particular instance. I have concerns about the location you've picked for the meeting, as the previous speaker said. It's not in connection or even close to any of the projects that would be impacted. I think there's been some difficulties with the time frame being scheduled. It's tough for folks to crossover, literally, in the middle of rush-hour traffic. I know I had a problem getting over for this evening's meeting, and I understand even some of you, some of the panelists had a tough time getting over. The issue of documents that you made available to people to review, I think that you're putting things online. And I don't know if the residents, many of the people who have an interest in this process, have access to get things online. So again, I want some documents being made locally available at the community centers, at libraries, which is a common way to put information out there when you really want people to have access to it. I've also noticed that the documents that have been posted on the HANO site have apparently been changing. When I first got word of these meetings, I think it was late Wednesday evening last week, I did look at the HANO web site. And then, Friday afternoon I was back online and what I had seen the night before was different than what was posted on the web site late Friday afternoon. So, you know, which documents are the public supposed to look at? When is the complete set going to be made available? And there is -­I don't know if it's a typographical error or not, but on your web site, it said these documents that are currently being shown were posted on January 17. That's absolutely false. They didn't go up until last Friday late in the afternoon. That's needs to be clarified. I have further cornments. I would ask for additional time. I think, overall, there's a been a shockingly gross failure to comply with the advising council regulations on historic preservation matters and your obligation, HAND's obligation to affirmatively seek out and engage in a timely preservation community in th is effort. I do have some additional comments. And if you have more time, I'd like the opportunity to present them to you. Thank you. MS. LARKINS: Mr. Michael Lane. MR. LANE: My name is Michael Lane, and I'm a concerned citizen, and I have some comments and then I have five or six questions that I would like to be answered by HANO with the posting on the web site or however you intend to do that. As stated in the presentation, the National Historic Preservation Act requires the federal agency to take into consideration the adverse effects upon properties that are eligible or listed on the National Registry for Historic Places. The purpose of the National Historic Preservation Act is to require the federal agencies to take into consideration alternatives prior to expending any federal funds or making any firm decisions on what it's going to do. Because the Historic Preservation Act requires the federal agency to really take into account the effects that the proposed action will have on historic properties. Everything that I have seen so far, whether from reviewing documents to the meetings here tonight and on Tuesday night and talking with everybody else, that HANO had already made the decision to demolish. And only now are going through the Section 106 process seeking public input and participation and comments and reviews after the decision. Now, the Section 106 process, it appears to me, has been done backwards. The purpose of the National Preservation Act and Section 106 is to force the federal agencies to take into consideration alternatives prior to making a final decision because, what's the purpose of having public input and public participation in it's comment period as you have now, if you've already made your decision when you know what you're going to do? In connection with that, the first question I have is: Have HANO/HUD made a firm decision to demolish or are they still open to listen to viable alternatives to demolition to preserve these historic properties? Now, in connection with these alternatives, we have had some numbers thrown around, and I heard some rumors that maybe alternative plans have been on the web site. And I can't confirm whether that's true or not. But the second question I have is: Have HANO/HUD put together any proposals, applications, or plans for alternatives other than demolition, and have you located funding sources for the other alternatives? And if so, where can we see that documentation, and where can the public take a look at that and have a review on that instead of just the demolition plans? As for the public comment period, in the previous meetings, it was said that the comment period would end on February 16th. And I think it's scurried around in here tonight because you changed up the presentation. Last week, you said the comment period was going to be from the hearing time not until the 16th, which is two weeks. Now, you're saying that public comment period started back when the ads for the newspaper were run. And I think that the variation that you were trying to extent the period when we first heard public hearings on that. For example, I was informed of a meeting with HANO representatives with the Office of Community Development to talk about the presentation this week. I was invited and asked me to attend and HANO attorneys objected to my presence at that meeting, although I was invited by the person who was holding that meeting. So the public participation process has not occurred anytime before Tuesday of this week. And I want to ask: Do you really believe a two-week consultation period is sufficient enough time to elicit public participation comment and review? And I would also like to state that the fact that you're not posting answer to the questions until February 16 when the period is closed doesn't allow a period of time of comment from the public and it's disingenuous. I have two more brief questions. I'll just put them very briefly. What other area of intended means to elicit public participation, besides this hearings and besides the advertisement in the papers, and what efforts have been made to get public participation from those who were displaced by Hurricane Katrina, the former residences of these developments who will have a lot to say, and will probably be people you need to talk to to have a cultural resources survey done right away. And now that some of them are not here, I'd like to know what efforts you've made to contact those people to do those things? And finally, we've heard a lot about consulting parties, and there's been a lot of things said, I've heard a lot about people not getting responses to their requests to be a consulting party, and things of that nature. I'd like to know, at this point, who has been invited to be a consulting party and have you invited all those persons listed on SHPO's list potential consulting parties to be consulting parties? Thank you. MS. LARKINS: Mr. Eugene Ben. I recognize Mr. Eugene Ben has -­ MR. BEN: Yeah, I'll hand my interview to Mr. Fraise. MS. LARKINS: Okay. Just wanted to acknowledge it. Russell Fraise, Mr. Russell Fraise. MR. FRAISE: My name is Russell Fraise, and my family has lived in the Lafitte Development since the 40's. I've been to numerous meetings with Mr. Babers, Mr. Jackson, everyone concerning the Lafitte. I have no knowledge of the other three demolition projects, but when my family came back in middle or late 2006, there was no damage. We understand the 106 review. When I first got back in January of this year, I wrote to Baton Rouge to the person who's in charge of historic preservation. And I got a letter back to me saying that it had to be Housing Authority and HUD to request that 106 review. I went online today to try to get that review, and there a hhpp www --I went online and nothing came up. At the bottom of the screen, it says 60 pages, but nothing came up on the computer. I've seen some of the proposals for the Lafitte, and I think some of them are really good. And some of the consultants --The process itself, from the united plan, goes to the city council, to city planning commission, then to the full council, then to the mayor, then to the governor. They are people seriously in need of housing that have to come home. And Housing Authority and HUD are single-handedly denying these people the right to come home. My family, Mr. Babers, you should know, are strayed out throughout the United States. I'm the only one here. They keep calling me about when they can come home, and I can't say anything. I can't say a thing. I know that some things have to be redone. I understand that. But Claiborne and Orleans, where I grew up, is a few blocks from the French Quarter. The French Quarter was not flooded. The front part of Lafitte was not flooded. I've turned in pictures. I've turned in video of the height of the steps and the actual water line below the steps. For Housing to 1 come along and say everything in Lafitte is not livable, it's a flat out lie, 2 flat out lie. 3 MS. LOUGH 4 Liar. Absolutely, you're lying. MR. 6 Anyway, what I was asking with the 106 7 review that's mandated, how long will it be before a decision that's 8 public will be made about redeveloping the housing development, if 9 that can be answered. Thank you. MS. LARKINS: 11 Mr. Walter Gallas. 12 MR. GALLAS: 13 My name is Walter Gallas. the 14 National for Historic here in New We've in here on ground since October 16 and we opened a field here as part of our commitment, 17 this national organization's commitment to assist in recovery of 18 New 19 The National Trust is an organization that dates back to 1 Our are in Washington, And The Trust is intimately involved with the creation of the National Historic Preservation Act in 1966, which grew out of national concerns across 23 the country with, in response the National Highway the 24 redevelopment programs, Toner", programs that were destroying the cultural resources of our Dick Moe, the President of National Trust has called Katrina to be one of the, probably the greatest cultural disaster, threatens the richest cultural, among the richest cultural resources in our country, and that's why we are here. And we look at these proposals for these developments and see threatened loss, further resources and historic resources and especially at a time when there's such a critical shortage, as other people have already recognized, of housing in New Orleans. As others have said before, it's very clear here from a national, international level of what we are doing here in New Orleans. We, too, have real concerns about this process. The Section 106 process is supposed to be a give and take, a true consultation where the stakeholders, the people who have a stake and interest in whatever the undertaking is, are invited to the table. They don't just sign sheets outside to state consulting party. We don't just stand up to microphones and wait two weeks for a response to their questions. It's not just taking comments. It's true consultation. That's not what this appears to be. I only learned about this meaning because someone we have really noticed it was put in the paper on January 16. That's two weeks before the meeting. I had requested on two occasions in December on behalf of the National Trust to be a consulting party and received no notice about this meeting. One substantive for comment directly on the presentation, and I said this at the other, in regards to the other two proposals that were made on Tuesday, this area of potential effect, it's a real tricky kind of concept there that you have to pay attention to. 1 You can look it and say, okay, you've drawn a around the 2 project, whatever the project and say, this is the only impact 3 going to look out, thinking it's only about impact of construction. APE, 4 as it said in PowerPoint itself, as the presenter , are direct and indirect, permanent and temporary effects. much greater 6 all around the hborhood and all around this part of city 7 at this development, the creation of this type of development, 8 removing one and replacing on it's behalf on other housing around 9 on the other types of residences that might go in there other than speculative demolition that go on, as people state, okay, 11 here's impact. So APE is way too narrowly defined. 12 Ridge, people of Ridge 13 and neighborhoods, they need to included as well in this 14 discussion. Everybody around needs to invited. I, too, have a question about who has the 16 letters making an invitation to become a consulting party? It's very 17 important National Trust wants to go on Record as saying 18 interested in ensuring that this nrn.... c<><:' is a full and inclusive 19 process that allows all those by these plans at the table. Thank you. MS. LARKINS: 22 Ms. Patricia 23 BY MS. GAY: I'm Patricia Gay, Director of the Preservation Resource Center, a city-wide nonprofit organization that works for the preservation of the historic neighborhood architecture of the city. We're founded in 1974, not too long after the National Preservation Act in 1966. The Section 106 that was established at the time was designed for just this sort of purpose, to give citizens a chance to comment on the historicity on the historic resources of the nation and to get professional people, as well, a chance to evaluate it. My organization is opposed to the demolition of these historic buildings. We applaud your intent to create a mixed use, mixed-income environment for the residents, but we say that, in working to improve the quality of life, the people who live here and in the surrounding area, there are many things that could've been done and weren't done in previous years; better maintenance, more security, perhaps cutting through some streets for better circulation and transportation, some landscaping. These buildings are of value. If a storm directly, if we get a direct hit from a category 5 storm, I feel that of all buildings in the city, these would survive. After a storm where we lose a lot, as we have in the city, don't start demolishing buildings. You use that has survived. You use what has survived. So we would like to participate in restoring these buildings to reuse by residents and to make them better than ever. We think, following the storm, we do have an opportunity to make some things better than they ever were before. And we urge you to reconsider your apparent plans to demolish these buildings. We do not think that alternatives have been sufficiently considered and are very, very distressed to losing, to think that losing an important resource, housing resource and a resource to our city and our neighborhoods. Thank you. MS. LARKINS: Ms. Laura Tuggle. MS. TUGGLE: Hi. My name is Laura Tuggle. I work with the New Orleans Legal Assistance. And as I've been working there almost 14 years now, I almost have historicity, or whatever that word that the prior speaker used. As I'm not a historic preservationist, I'm a people person. I'm not quite as concerned about the buildings as the people that had once lived in the buildings. But I do share many of the concerns about actual properties. And it goes without saying that the housing shortage that we have now, that people need a place to be. But I can tell you that, from having worked with low income folks for a lot of years now, all of my clients that resided in public housing were dying to get into the Lafitte. Every single person that wanted a transfer to another site, wanted a transfer to the Lafitte or the Iberville because the Lafitte and the Iberville were the cream of the crop, and they still are the cream of the crop. I mean, today, on my way back from a meeting not too far from the building, HANO's building on Touro, as I was coming down the interstate, you know, you see these great beautiful roofs, and I mean, they look good. And these are the buildings that we're being told are viable and not, you know, potentially obsolete. And when Congress made a report, when HUD made a report to Congress about their damage assessment for the public housing stock last year, they used the $24 million number, which we saw in the PowerPoint presentation as the damage assessment. And now, when you compare the $24 million number, because I think it was around 124 million to rehab, it doesn't make sense to tell us it's more cost efficient, you know, all of a sudden you want to modernize things. But, yet, my clients who are dying to get into those place because they're viewed as so much better, now we need $155 million to modernize those places? I mean, I understand that there's a lot of concern. And, obviously, they do need some work, but people need some places to be. And when this whole new development process is over and done with, probably by the time, maybe even many of us die, I hope that we're left with a city that's not just a new New Orleans with a n-e-w, but we need it to be one that we knew, with a k-n-e-w, and I hope that's we wind up with. MS. LARKINS: I would like note for the Record Mr. William Bennet, is not participating. Next, we have Ms. Gloria Irving. MS. IRVING: Good night, everybody. My name is Gloria Irving, alias "Mama Glo." A lot of people know me in here. And I'm talking to support Lafitte, not only Lafitte, all the projects. I come to support as much as I can. It's not much I can say, but I can tell you how I feel. feel like you're talking about tearing down all of the projects. I just came back from Houston, Texas where all the people, Lafitte, Iberville, St. Bernard, all these people is dying to come home, but they cannot home. And I'm speaking mostly for the senior citizens. It's a lot of people needing to come home. People been calling me and calling me. And I say, I don't know what they're going to do. But guess what, I'm still going to be a fighter. I'm a fight it till it ends. And I ain't going let them tell me, live there no more. I don't have too much to say because I hurts and I know many of us are hurting. Every time I get on the mic to say something, I'm go to crying. I go to crying because I know we feel it. People in the projects feel it, even the people in the private sectors. They could clean out their house. What's wrong with us cleaning out our home? That's our home. I was born and raised in New Orleans. I'm 70 years old. I'll be 71 this year coming up. And I ain't just started fighting. I've been fighting for them to help people. And they sits, like they're sitting at table, they look at you. You know, they don't have no feeling. I really believe they don't have no feelings for us. I say what I have to say. I'm sorry. And just like I said, they going to put me in jail, the old lady like me. I doubt that they can because ain't nothing else they could do with me. But I just ask and I pray that your God, you all forget about God. You all forget about God. I done saw many coming, and I saw many go. And I'm going to see many come and go again, because God going to let me see this because they misusing us. They think we don't know no better. But as the people is being going and going, and I done learned many things. I know a lot of things. So all I'm asking you all, let us go to our house. We could get there and clean them up. Now, you're talking about putting people in jail. Going to their own house. Well, I'm going to be ready to go to jail because I'm going to my house. Ya'il can get ready to lock me up anytime ya'il be ready because I'm going to 1460 Milton. And I'm going to bring lots more with us because we all going to go to jail. (Applause from the crowd.) So I'm telling you now, we're not going to hide. And many of ya'il know me, ya'il know I'm going to say what I've got to say. And that's it. And I pray for all of ya'il because you need prayers. MS. LARKINS: Ms. Alesa Lewis. MS. LEWIS: Good evening. I'm Alesa Lewis. I resided at 619 North Claiborne Avenue, in the Lafitte Housing Project. Nothing is wrong with my apartment, not one thing is wrong with my apartment. And Mr. Donald, I had asked you once, I asked you twice, I don't know why all this talking about tearing those apartments down when nothing is wrong with those apartments at all because I go to mine every day. Everyday I go to mine. There's nothing that don't need to be cleaned but the walls. But ya'il won't let me clean that. I ask you all, don't tear it down. Let us back in. Ain't nothing wrong with it. MS. LARKINS: Pia Mascaro. MS. MASCARO: My name is Pia Mascaro, and I'm a journalist and writer. I have a few things to say, something that we've been talking about, comment at briefly. I would like to know why you decided to have these meetings here knowing that most of the residents to the housing have no transportation. So it's difficult for them to be here tonight. Furthermore, we are away from any close for a ride. The second thing is you haven't showed me HANO's what repair will costs. You're talking about sample, but actually vaguely and vaguely public. The third thing I'm wondering about, material that would used for the new housing. I think you mentioned new Fischer, I think it's the new Fischer, I tooked to look at the residency there. Some people are already complaining as to leak, leaks in their apartment. And this leads to my second question which is: Why is HANO try to keep destroying sturdy, strong buildings for a building that probably are not of as good quality. Mostly people in that building are city people. Add to that, to that cornment, I was here in New Orleans three days after the storm, and I had a chance to spend a few days with the rescue team on a boat. We went to the Lafitte Development. There was very little water to the north side of Lafitte. And most of the people that we rescued there actually were people who gathered from all the neighborhoods to survive the storm in the Lafitte Development. So again, the question is: Why takes such a risk to destroy the only sturdy building that you have in this city which is a city of hurricanes? My last question regards the process actually. I'm not really sure, but I think you are going to close the comments on February 16. But at the same time, we can post an answer on February 16. So to ask the question: Are you really going to answer, since you promised the same thing at the November 29th meeting, but there were never answers posted for that meeting. And secondly, if answers come until at the same time, how can there be real representation process? MS. LARKINS: t That concludes the comment section of this meaning. MR. BABERS: In light of the fact that we started a few minutes late, I'm going to allow an additional ten-minute time. If we don't have anyone that has not spoken full. MS. LARKINS: Would you go forward with extending the meeting? MR. BABERS: Extent the meeting an additional ten minutes. MS. LARKINS: And that's for further comments? MR. BABERS: For further comments. MS. PAUL: My name is Emelda Paul. I'm the President of the Lafitte Housing Development. I was one of those that came before you all, Mr. Baber, came to you a couple of months ago, maybe longer, because the residents kept calling wanting to know why couldn't they get back into their apartments. There was no water damage or anything. I can only speak for my apartment. The water came up to the second stairs in my hallway. My neighbor that lived under me --By the way, I have grown in Lafitte. The water came in her house. The whole front was --She's on the ground floor. That was flooded. My grandson who lived about five doors away from me ~ was the same for me. I don't believe that about two or three months after we left, all of that couldn't have been cleaned up. But the next thing I notice, we had iron doors. That was telling us something. That was telling us something. I don't think it was right at all. Those plans was way before Katrina. But my thing is now, how long is it going to take for this recovering the new building? They talk about the bricks and the mortar. We're talking about lives. There are people that want to go back in there. We've got to make sure it's clean and sanitary. If there's going to be progress, I want to make sure that all the residents that want to come home, that they come home. That they have a place to stay. And that, when you say "affordable housing," we're talking about where our people can pay that rent. And I'm not talking about sky-high rent. So you keep this in mind. We done lost too many of our people, especially the elders, from the stress and sickness. I lost a sister, and it's hurting thing to see what our president is doing to us. Thank you. MS. LARKINS: Is there anyone else that would like to have an additional three minutes? Would you like to speak? MR. LOGAN: Yes, ma'am, I would. MS. LARKINS: Three minutes. MR. LOGAN: I appreciate the opportunity to talk to ya'ii. A lot of what I wanted to say has been covered already by the people. I really haven't had much of a chance at all to look at these documents that have been posted. Again, I'm not clear on which documents I'm supposed to be looking at. But in reviewing the ones that are on the web site now, a few things did catch my eye, but these are probably the questions, which I guess you're not going to answer tonight, but: Why the individual Section 106 reviews being done for these projects rather than (IA) which I understand is what the SHPO's office had recommended back in June of 2006. It seems to me that that's a much more efficient way to handle these reviews. It just doesn't make a whole lot of sense. I think everybody's going to have a lot more work than they're receiving now. My question tonight is: Who's in charge? I think the process is extremely problematic. I think the involvement of one kind or another of HUD/HANO the meetings in the City of New Orleans. I think you need to clearly establish lines for both communication and legal responsibility and purposes. I think you're setting yourself up for further problems down the road. You're beginning right now. I think we all need to have an explanation of the funding sources for these projects. Several of the people in this room, including myself, are involved in parts of the St. Thomas redevelopment. And I think there had been an expectation that the other redevelopments will take place using Code 6 funds, as I understand that's not the case. But again, we received the gravitational on that. What is status of these plans? What are the documents that are available? Who do we go to to get them other than what's out there on the web site? Who's been involved in getting us to this particular contact? I mean, we're all to a thing with this on to setup and a HANO requesting consulting party status, advising people of this meeting, etcetera. To my knowledge, none of that's included in packet that's on the web site. Until you identify these other people that are involved, you know, up to today, I think a lot of these folks are going to get involved in this point forward. Same questions about how the APE was determined. Who drew the line where the input was had? Who made the decision with what information was looked at? Consideration of alternatives. It appears that demolition was the foregoing conclusion. During consideration of negative impacts, effects into adjoining neighborhoods, speculative demolition identification; none of this seems to be addressed as part of the fold, and part of the 106. And finally, what are the next steps? I mean, Ms. Dodd, in her opening presentation, explained that this is the beginning of a very long process. Well, you've got a lot of people he who have a great deal of interest in this. So, I think, in fairness to them, some additional information about, when they leave this evening, what happens next, not just the two-week comment period, but what do HUD and HANO have planned out for the coming months, how is that process going to play out? It is critical that you be transparent in providing information as well as possible about this process unfolding. Thank you. MS. LARKINS: We have Ms. Lilly Parker. MS. WOODFORK-PARKER: Good evening. My name is Lilly Woodfork Parker. I'm a resident of public housing. I also oppose the demolition. I've been going to all the UNOP meetings. And if they can agree that we need housing, you know, that we should've had. The plan that they have, really, you wouldn't even believe that the people, plan is people plan because I've been to all of them. I've been to all the meetings. I 'can't see --I mean, it's like a foregone conclusion that we hand out but it's already been, you know, it's already been decided when we came here. And it doesn't seem like, right now that anyone is thinking about that. But I really don't think that the site should be torn down. We never said we didn't think that they shouldn't be modernized or fixed up. We did said we did not wholesale conviction. And right now, that's what seems to be going on. But as I've said, I've attended mostly all of the UNOP meetings, and they've come to the forgoing conclusion that we do need housing and that these building shouldn't be demolished, especially at a time right now. Thank you. MR. BABERS: This concludes the meeting for Lafitte. We will take a break, and the meeting for the St. Bernard Public Housing will start at 7:30. Thank you . CERTIFICATE I, Darcee Michele Cacibauda, Certified Court Reporter, in and for the State of Louisiana, do hereby certify that the foregoing transcript is true and correct, as reported by me and reduced to typewriting under my person supervision. Darcee Michele Cacibauda Certified Court Reporter Louisiana License #99084 Lafitte 1 MEMORANDUM OF AGREEMENT 2 AMONG 3 U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, 4 LOUISIANA STATE mSTORIC PRESERVATION OFFICER, AND ADVISORY COUNCIL ON HISTORIC PRESERVATION 6 REGARDING THE REDEVELOPMENT OF THE LAFITTE 7 PUBLIC HOUSING COMPLEX, LOCATED IN NEW ORLEANS, LOUISIANA 8 9 WHEREAS, the U.S. Department of Housing and Urban Development (HUD) will provide federal funds to the Housi ng Authority of New Orleans (HANO) as partial funding for the redevelopment 11 of the Lafitte Public Housing Complex (the Undertaking). that inc1udes Public Housing Capital 12 Funds and Community Development Block Grant funds from the Louisiana Office of Community 13 Development's Road Home Program (from the Fiscal Year 2006 Department of Defense 14 Appropriations Acts, Pub. L. No. 109-148 (2005) and Pub. L. No. 109-234 (2006»; and 16 WHEREAS, HANO and its developer will apply for and use sources of non-federal financing to 17 carry out the Undertaking, including but not limited to Low Income Housing Tax Credits (LIHTC) 18 from the Louisiana Housing Finance Agency, per the Gulf Opportunity Zone Act of 2005 (Pub. L. 19 No. 109-135); and 21 WHEREAS, HUD is the "agency official" for the purposes of Section 106 compliance, as defined 22 at 36 CFR 800.2(a), and in accordance with regulations found at 24 CFR Part 50, "Protection and 23 Enhancement of Environmental Quality;" and 24 WHEREAS, HANO will enter into a Master Development Agreement with a qualified developer to 26 execute the Undertaking; the developer, Providence Enterprise Orleans LLC, has been chosen by 27 HANO and will have a long tenn role and responsibilities in the implementation of this agreement; 28 and 29 WHEREAS, the Undertaking is described as a multi-phased redevelopment of Lafitte as follows: 31 A. The Lafitte Housing development, constructed in 1941, is surrounded by three National 32 Register Historic Districts-Esplanade Ridge, Mid-City and Parkview. The Esplanade Ridge 33 National Register district contains two local historic districts-Treme and Esplanade Ridge. The 34 development is bounded by Lafitte Street, Orleans A venue, N. Claiborne A venue, and N. Rochablave Street. The 27.2 acre site includes 896 public housing units which are deteriorating 36 and damaged by Hurricane Katrina. 37 B. The APE of the Lafitte Development was established around the proposed area per 24 CFR Part 38 50 and 36 CFR Part 800. It extends to seven hundred-fifty (750) feet around the proposed project 39 site. Where the boundary is interrupted by 1-10, a major roadway, the APE boundary is set at that roadway. The APE also encompasses a portion of North Claiborne A venue, Lafitte Street, and 41 North Rochablave Street. 42 1 Lafille 1 C. Lafitte will be redeveloped with 1,500 affordable and market rate units on the Lafitte housing 2 site and in the neighborhood. These units are planned to include 276 public housing units, 624 3 affordable rental units, and 600 homeownership units. 4 D. The goal of on-site development activities is to replace existing Lafitte public housing residences with 556 units of affordable rental housing and home ownership units meeting 6 contemporary standards of quality and safety. The on-site units will include 100 public housing 7 units designated for seniors, 176 public housing units for families and 100 tax credit only units. 8 This phase will also include the construction of 40 homeownership units on the site for low-income 9 families and 140 homeownership units on the site for moderate income families. This first phase of the redevelopment of Lafitte will also include 192 units to be developed in the neighborhood and 11 supported with Section 8 project-based assistance and 64 homeownership units for moderate 12 income families that will also be located off-site in the Lafitteffreme neighborhood. 13 E. The goal of off-site development activities is to provide 688 new affordable rental and for-sale 14 housing units of contemporary standards of quality and safety. WHEREAS, HUD has determined that the Undertaking is subject to review under Section 106 of 16 the National Historic Preservation Act (16 U.S.c. 470), and its implementing regulation, 36 CFR 17 800; and 18 19 WHEREAS, the signatories agree to accept the loss of the vast majority of the buildings at the Lafitte complex contingent upon the rehabilitation of the historic administration building and the 21 rehabilitation of a limited representative sample of residential buildings in proximity to the 22 administration building; and 23 24 WHEREAS, HUD has formally recognized the following organizations as "additional consulting parties" per 36 CFR 800.2(c)(5): City of New Orleans (and the Historic Districts Landmarks 26 Commission), National Trust for Historic Preservation, Louisiana Landmarks Society, Preservation 27 Resource Center of New Orleans, and Lafitte Resident Council; and 28 29 WHEREAS, the residents have been invited to participate in Section 106 consultation and have expressed their preliminary views by correspondence, resolutions, or other means; and 31 32 WHEREAS, HUD has invited federally recognized Indian tribes to consult on this Undertaking, 33 and they have indicated their interest will be limited to ground disturbing activities that have the 34 potential to affect archaeological resources identified in consultation with SHPO; and 36 WHEREAS, HUD has determined, in consultation with SHPO, that the Undertaking may cause 37 adverse effects to historic properties and that this agreement is the appropriate vehicle to mitigate 38 potential adverse effects; and 39 WHEREAS, HUD, in consultation with the SHPO, has delineated the area of potential effects 41 (APE), which is presented in narrative and graphical form in Appendix A, subject to appropriate 42 modifications necessitated by the implementation of off-site housing; and 43 2 Lafitte WHEREAS, HANO and the developer have informed the consulting parties that off-site 2 development of rental housing related to this Undellaking is expected to occur in areas beyond the 3 APE; and 4 WHEREAS, HOD has invited HANO, as the recipient of federal funds, to sign this agreement as 6 an "invited signatory" per 36 CFR 800.6(c)(2) since it has responsibilities under this agreement; 7 and 8 9 WHEREAS, the developer has been confirmed but has not been contracted at the time of the signing of this agreement; HANO will legally bind the developer in the Master Development 11 Agreement to fuJIy comply with the provisions of this agreement; and 12 13 WHEREAS, only the "signatories" and "invited signatories" have rights to seek amendments or 14 termination of this agreement; and 16 WHEREAS, HUD has invited the National Trust for Historic Preservation, Louisiana Landmarks 17 Society, Preservation Resource Center of New Orleans, and the Lafitte Resident Council to sign 18 this agreement as "concurring parties," per 36 CFR 800.6(c)(3); and 19 WHEREAS, HUD has identified, through consultation with the SHPO, ACHP, consulting parties, 21 and the public, that the APE contains properties eligible for or listed in the National Register of 22 Historic Places: Lafitte Public Housing Complex (eligible under Criterion A for historical 23 association), Mid-City Historic District, Parkview Historic District, and Esplanade Ridge Historic 24 District; and 26 WHEREAS, HUD has determined, in consultation with the SHPO, ACHP, additional consulting 27 parties, and the public, that reasonable and good faith efforts to carry out appropriate 28 identification/evaluation of historic properties regarding the on-site redevelopment have been 29 completed; and 31 WHEREAS, HUD will allow HANO and the developer to coordinate the proposed off-site program 32 in a phased approach with the terms of this agreement (as noted below) and as the regulations allow 33 at 36 CFR 800.4(b)(2) and 800.5(a)(3); and 34 WHEREAS, HUD has determined, in consultation with the SHPO, ACHP, additional consulting 36 pallies, and the public, that the redevelopment may pose adverse effects to historic properties in the 37 APE for the following reasons: demolition of existing on-and off-site structures; ground 38 disturbance; new construction; possible stabilization and rehabilitation of certain on-and off-site 39 structures; temporary traffic congestion and construction noise; and 41 WHEREAS. the roles and responsibilities of each of the consulting parties is clarified in the tenns 42 of this Agreement since there is a need for ongoing post-Agreement reviews; and, 43 44 WHEREAS, this agreement will be appended as a requirement to the Master Development Agreement entered into between HANO and the developer of the property. 46 3 Lafitte NOW, THEREFORE, mID, SHPO, and ACHP agree that the proposed Undertaking will be implemented in accordance with the following stipulations in order to take into account the effects of the proposed undertaking on historic properties. STIPULATIONS HUD, in consultation with HANO and the selected developer, shall ensure that the measures in this agreement are carried out. I. ROLES AND RESPONSIBILITIES A. HUD's Office of Public and Indian Housing: As the Section 106 agency official, it is legally responsible for the Undertaking and for oversight of HANO to ensure compliance with this agreement. B. HANO: As the recipient of federal funds, it is responsible for completion of the project, including oversight of the developer. Although HANO is under HUD recei vership, HANO remains a separate and distinct legal entity. C. The developer: Upon execution of the Master Development Agreement, it shall be responsible for development of the master plan, all construction activities, and acquisition of financing. D. SHPO: When HUD and HANO request that SHPO review a finding or detennination regarding identification and evaluation of historic properties affected, SHPO shall respond within 30 days. Based on the phased submittals of HUD and HANO's identification and evaluation of historic properties, the SHPO will be responsible for consulting with and providing technical assistance to HANO and the developer consistent with the terms of this agreement. Due to both the large scale of this undertaking and HUD and HANO's desire to expedite the Section 106 consultation with SHPO, mID and HANO will consult with SHPO on means to facilitate such consultation e.g., helping SHPO identify funding sources. E. ACHP: The ACHP will provide oversight, advise on disputes, and detennine whether the terms of this agreement are being met. F. Consulting parties: The consulting parties are responsible for commenting and advising HUD and HANO on the determinations to be made in the implementation of this agreement. Consulting parties include the Resident Council. G. The public: It has a right to participate in the development of the master plan and to provide comment as appropriate. 4 wfitte II. ELEMENTS UNIQUE TO THE LAFITTE HOUSING DEVELOPMENT 2 A. HANO and the Developer will preserve and reuse the administration building along with a 3 limited representati ve sample of residential buildings selected by HANO and the Developer, and 4 concurred in by the ACHP and SHPO, as part of the Master Plan. When selecting residential buildings, the Developer may include an analysis of why three-story structures may not be feasible. 6 B. HANO and the Developer will ensure that the design of Lafitte's new on-site housing includes 7 linkages to the adjacent National Register listed and eligible historic districts--Esplanade Ridge, 8 Mid-City, and Parkview, and takes into account indirect and cumulative effects resulting from new 9 construction. C. HANO and the Developer will develop a construction protection plan for the contributing 11 buildings along the borders of the historic districts closest to the Lafitte development, especially the 12 Esplanade Ridge and Mid-City Historic Districts, to avoid and minimize adverse effects .. 13 D. HANO and Developer will consult with the SHPO and Resident Council regarding the 14 development of a retention and protection plan for select landscape elements that contribute to the historic character of the Lafitte complex. The developer shall retain those landscape elements that 16 can be used in the redevelopment without compromising the proposed on-site new construction. 17 E. HANO and the Developer will address the rehabilitation and use of the Sojuourner Truth 18 Community Center as part of the Master Plan development. 19 F. The creation of new street grid patterns has been developed with residents and corrununity stakeholders during initial phases of the Master Plan development. As per Stipulation ill, there 21 will be additional opportunities to involve neighborhood associations within the three adjacent 22 historic districts to ensure that the siting of various architectural styles and the location of off-site 23 parking is compatible with the architectural character of adjacent historic distlicts. 24 G. HANO and the Developer will coordinate the implementation of rehabilitation, demolition, and new construction activities outlined in the Master Plan to ensure that time is allowed for 26 consultation with residents regarding the collection of historical information and documentation 27 needed to properly interpret the history and significance of the Lafitte complex. 28 29 III. MASTER PLAN DEVELOPMENT 31 A. As part of the development of the master plan, the developer will integrate the following 32 historic preservation principles into the program: 33 34 1. Thorough analysis of rehabilitation of certain existing buildings, including the administration building and a limited representative sample of residential buildings in 36 proximity to the administration building, to meet the programmatic needs for non­ 37 residential uses. 38 5 Lafitte 2. Retention of landscaping which defines the housing sites, where possible. B. HUD, HANO and the developer will involve the consulting parties, residents, and the public in the development of the master plan. HUD and HANO will take into account the input of the parties and document their analysis of the input. C. Upon approval of the Master Plan and the selection of prototype designs for new construction, HANO and the developer will develop a plan to insure construction traffic will be routed to minimize impact to schools, churches and other sensitive receptors and will rely on use of roads adequately sized to handle the increased traffic loads and counts. D. In the event that HANO and the Developer detennine to explore retention of additional units that would not necessitate reprocessing the tax credit application, they will notify and consult with consulting parties as part of the Master Plan process. IV. DOCUMENTATION A. HABS: In consultation with SHPO, HANO will select a representative number of buildings to be documented per a Level II Historic American Buildings Survey (HABS). In accordance with Appendix B, HANO will submit Level II HABS documentation on the Lafitte property to the HABS Division of the National Park Service (NPS) for review and acceptance. Within 150 days of execution of this agreement, the NPS-accepted HABS documentation for selected properties will be submitted in final form as follows: original photograph negatives, archival photographs, architectural drawings, and written data will be provided to the HABS Collection of the Library of Congress; two sets of archival photographs, architectural drawings, and written documents will be provided to the SHPO (for deposit with SHPO records and the Louisiana State Archives). B. Exhibit: HANO and the developer will consult with Lafitte residents, SHPO, ACHP, additional consulting parties, and the public to develop and complete an oral history project and historic as well as archaeological exhibit for display on site incorporating oral and narrative histories, documents, illustrations, or other artifacts. The scope of work for this effort will be developed in consultation with SHPO. Consideration will be given to contracting with a local college/university to execute these projects. Distribution of the final written and graphical products will also be a subject of this consultation in which all the parties will be invited to participate. This exhibit will be completed by December 31,2010. V. PROFESSIONAL QUALIFICATIONS HANO and the developer will hire or retain a design professional with previous experience working with historic preservation and historic architecture to provide technical assistance, as needed, during the preliminary design development phase, and in response to comments HANO or the developer receives from the consulting parties regarding the design for new construction and the scope of work for rehabilitation activities outlined in the Master Plan for the complex. 6 Lafitte VI. ON·SITE DESIGN DEVELOPMENT A. The site plan for new development on the cleared site will be consistent with the Master Plan developed under Stipulation III. 1. The Master Plan will incorporate existing landscape elements that do not compromise an efficient layout and reuse of the site. 2. HANO and the developer will provide to all consulting parties a written summary describing how new construction will be phased, and what activities will be included within each phase. 3. HANO and the developer will provide plans illustrating/depicting the design prototypes to be used for the new construction on site and specify where each design will be located throughout the site plan. 4. The plans for the rehabilitation of the administration building and a limited representative sample of residential buildings to be selected as part of the Master Plan development will be carried out concurrent with new on-site development. B. Consistent with the Master Plan, HANO and the developer will design new construction and develop rehabilitation plans that are responsive to the Secretary of the Interior's Standards, the Louisiana Speaks: Pattem Book. and appropriate local design guidelines for new construction. The developer will provide to the SHPO for review and comment design elevations and proposed siting of all prototype residential structures to be used within the site. C. Demolition and Salvage: 1. Upon securing a representative number of buildings for recordation of the complex as determined in consultation with SHPO in accordance with Stipulation IV, HANO and the Developer may proceed with the demolition of all units with the exception of the buildings designated for recordation, administration building and a limited representative sample of residential buildings as described in the Master Plan. 2. HANO and the developer will secure the buildings that are to be retained on-site during demolition and new construction and ensure that unanticipated damage by contractors will be avoided. 3. Prior to demolition, HANO and the developer will consult with SHPO on the feasibility of instituting a timely and cost-effective salvage plan to identify, retrieve, and move historic building materials (e.g., windows, doors, bricks, etc.) for reuse in other local rehabilitation projects. D. The design review process for all on-site development, including new construction and rehabilitation, will provide for the review of schematic plans, preliminary plans, and final drawings by the consulting parties and the public: 1. HANO and the developer will convene a public meeting, post appropriate documents on the web, and make them available at local venues, so that consulting parties, Resident Council, evacuees, and the general public have the opportunity to provide comments and recommendations. 7 Lafitte 2. HANO and the developer will make the documents available for a minimum of 30 2 days for comment, after which HANO and the developer will summarize comments 3 received and advise the parties to this agreement of changes that HANO and the 4 developer have made. 3. HANO and the developer shall submit final plans to the SHPO based on the 6 foregoing process for review and comment pri,or to the initiation of construction. 7 8 9 VII. OFF-SITE AFFORDABLE HOUSING DEVELOPMENT 11 A. Goals for off-site affordable housing development: 12 13 1. The developer will seek to mitigate adverse effects on adjacent neighborhoods in the 14 vicinity of the Lafitte complex, by focusing off-site acquisition efforts on vacant sites and blighted properties located within these neighborhoods and on structurally sound 16 properties suitable for rehabilitation. 17 2. The developer wi II seek to mitigate adverse effects on historic districts in the vicinity of 18 the Lafitte complex, including Esplanade Ridge, Parkview and Mid-City, by focusing 19 off-site acquisition efforts on vacant sites and blighted properties located within these historic districts. 21 3. SHPO will assist HANO and the developer with seeking state and federal tax credits for 22 the rehabilitation of historic buildings if appropriate. The developer will explore with 23 SHPO opportunities to maximize the use of these incentives by clustering in-fill new 24 construction and rehabilitation projects. 26 B. HANO and the developer will ensure that the identification and evaluation of parcels acquired 27 for off-site housing will be completed in phases prior to determining which alternative (e.g. 28 rehabilitation, in-fiJI, demolition, conveyance) will be used to provide affordable housing on the 29 site. 31 C. HUD will ensure that HANO and the developer will not acquire properties from property 32 owners who, with intent to avoid the requirements of Section 106, have intentionally significantly 33 adversely affected a historic property. 34 D. In order to expedite the review of the off-site program, HANO and the developer will develop 36 written protocols on activities listed below with the SHPO to standardize reviews, to be shared with 37 consulting parties. These protocols will address: 38 39 1. Stabilization of structures awaiting rehabilitation. 2. Identification of property types, activities, or geographical areas exempt from review. 41 3. Analysis of alternative treatments. 42 4. Identification of demolition and site clearance procedures. 43 5. Development, if appropriate, of a salvage plan based on Stipulation VI.C.3, prior to 44 demolition. 6. Coordination of related site improvements in historic districts, e.g., parking. 46 7. Coordination of historic reviews. 8 Lafitte 1 E. Rehabilitation of historic buildings for off-site housing will adhere to the Secretary of the 2 Interior's Standards for Rehabilitation to the maximum extent feasible. If HANO and the 3 developer detennine that it is not feasible to adhere to the Standards, they will submit alternative 4 treatments to the SHPO for review and comment. If the SHPO concurs with designs that do not meet the Standards, HANO, the developer, and SHPO will execute a letter agreement that will be 6 filed with HUD and the ACHP prior to project implementation. Such agreements will explain why 7 the Standards could not be met. 8 9 VIII. ARCHAEOLOGY 11 12 A. All archaeological surveys and monitoring conducted pursuant to this Agreement, as well as 13 any treatment plans for archaeological resources developed pursuant to this Agreement, will be 14 carried out by or under the oversight of a person meeting the professional qualifications for Archeology under "The Secretary of the Interior's Professional Qualification Standards" (48 Fed. 16 Reg. 44,716 (Sept. 29, 1983)). Reviews will be documented by the professional making the 17 review. 18 B. For on-site work, HANO and the developer will consult with SHPO to develop a research 19 design for a Phase I archaeological survey in the immediate area of proposed ground disturbance. Based on the results of the survey, HANO and the developer will take aJl necessary steps to achieve 21 Section 106 compliance. 22 23 C. For off-site work, HANO and the developer will provide SHPO with a map and addresses of 24 properties for the development of off-site housing. The SHPO and the developer will create a written protocol for selecting a representative sample of the off-site properties. The development 26 of the selected properties will be monitored by an archaeologist to determine if archaeological sites 27 are present. If a site is discovered, work will cease until the SHPO, HANO and the developer agree 28 on a plan for determining the National Register eligibility of the site, and determining what, if any, 29 further archaeological testing is appropriate .. 31 D. In the event that archaeological investigations, on-or off-site, uncover archaeological sites that 32 are eligible for listing on the NRHP or have religious and cultural significance to Indian tribes, 33 HUDIHANO/developer will consult with SHPO and conduct any necessary additional 34 investigations to achieve Section 106 compliance with regards to those archaeological sites, including the development of an archaeological mitigation plan, as appropriate. Such consultation 36 with SHPO may also involve one or more tribes, as appropriate. 37 38 E. BUD shall ensure that all draft and final archaeological reports reSUlting from actions pursuant 39 to this agreement will be prepared in accordance with the SHPO's Section 106 Investigations and Report Standards. All draft reports will be completed and provided to the SHPO within 90 days of 41 the completion of the archaeological investigations for review and comment. The SHPO will be 42 afforded 30 days to review and comment on all submissions. Upon comment from BUD and 43 SHPO, a final report will be produced. The on-site archaeological investigations and off-site 44 investigations will not be incorporated into a single final report. 9 Lafitte F. HUD shall ensure that HANO will curate all archaeological materials collected and all 2 associated documentation in accordance with applicable state regulations. Artifacts and associated 3 records shall be curated with the Louisiana Division of Archaeology to ensure retention and care of 4 the collections and to provide access to these materials for future research. 6 7 IX. DURATION 8 9 A. This agreement shall be considered in effect as of the date of the last signature by the "signatories" and/or "invited signatoties." HUD will file a signed copy with the ACHP. 11 12 B. It is anticipated that this project will take place in multiple phases. As long as any phase of this 13 project is still underway, the agreement shall remain in effect. 14 16 X. POST-REVIEW & UNANTICIPATED DISCOVERIES 17 18 HANO and the developer will comply with the Louisiana Unmarked Human Burials Act in the 19 event that human remains are discovered. HANO and the developer shaH notify HOD, SHPO, ACHP, and the tribes (if appropriate) within 48 hours if it appears that the Undertaking may affect 21 a previously unidentified property that may be eligible for inclusion in the National Register or 22 affect a known historic property in an unanticipated manner. HANO and the developer will stop 23 construction in the vicinity of the discovery and take all reasonable measures to avoid or minimize 24 harm to the property until HUD concludes consultation. If the newly discovered property has not previously been included in or detennined eligible for the National Register, HANO and the 26 developer may assume that the property is eligible for purposes of this agreement or may request 27 that HUD assess the National Register eligibility of the property. HANO and the developer shall 28 include information regarding their proposed actions to resolve any adverse effects resulting from 29 the discovery in their notice and shall provide a notice of the discovery to the additional consulting parties if requested by the SHPO. The ACHP will not participate in the review of HANO and the 31 developer's proposed actions unless ACHP's participation is requested by HUD, SHPO, or ttibes 32 (if they are participating). If the SHPO or tribes (if they are participating) do not object to HANO 33 and the developer's recommendations within 48 hours, HUD will require HANO and the developer 34 to modify the scope of work, as necessary, to implement the recommendations. HOD will take into account any timely objection by the SHPO and tribes (if they are participating) and authorize 36 HANO and the developer to carry out appropriate actions. This process to resolve any adverse 37 effects arising from a post-review discovery has been developed pursuant to 36 CFR §800.13(a)(2) 38 and all actions in conformance with this process will satisfy HUD's responsibilities under Section 39 106 and 36 CFR Part 800. HANO and the developer shall provide HUD, SHPO, tribes (if they are participating), and any other party that participated in the review of this discovery, with a report of 41 the actions taken pursuant to this stipulation within 90 days after their completion. 42 43 44 10 Lafitte XI. MONITORING AND REPORTING 2 3 Beginning 6 months after the execution of this agreement and every 6 months thereafter, until it 4 expires or is terminated, HANO and the developer shall provide all consulting parties to this agreement with a summary report detailing work undeltaken and work planned for the upcoming 6 6 months pursuant to its terms. A meeting shall be held annually with HUD, HANO, the developer, 7 and the consulting parties in conjunction with the six-month report provided in January of each 8 year, starting in 2008. The report shall also include any proposed scheduling changes, significant 9 problems encountered dealing with historic properties, and significant disputes and objections recei ved concerning efforts to carry out the terms of this agreement. The report may include 11 recommendations regarding amendments that would assist in the implementation of this agreement. 12 Failure to provide such summary report may be considered noncompliance with the terms of the 13 agreement pursuant to Stipulation XIV. Reports will also be filed at HANO and will be available 14 for public review upon request. 16 17 XII. DISPUfE RESOLUTION 18 19 A. Should any of the signatories object to the manner in which the terms of this agreement are implemented or, within the specified time frames, to any plans prepared for the Undertaking that 21 are subject to review pursuant to the agreement, HUD will consult further with the objecting party 22 to resolve their concerns. If HUD determines that such objection cannot be resolved, HUD will 23 forward all documentation relevant to the dispute to the ACHP including its proposed response to 24 the objection. Within 30 calendar days after receipt of all pertinent documentation, the ACHP will either: 26 27 1. Advise HUD that it concurs with their proposed response, whereupon HUD will respond to 28 the objection accordingly; or 29 2. Provide HUD with recommendations, which it will take into account in reaching a final 31 decision regarding the dispute; or 32 33 3. Notify HUD that it will comment pursuant to 36 CFR 800.7(c), and proceed to comment on 34 the subject in dispute. Any ACHP comment provided in response to such a request will be taken into account by HUD in accordance with 36 CFR 800.7(c)(4) with reference only to 36 the subject of the dispute, and HUD's responsibility to carry out all actions under this 37 agreement that are not the subject of the dispute will remain unchallenged. 38 39 B. If the ACHP fails to provide recommendations or to comment within 30 days, HUD may authorize HANO and the developer to implement that portion of the Undertaking subject to dispute 41 under this Stipulation in accordance with any documentation as submitted and as amended by 42 HUD. 43 44 C. Any recommendation or comments provided by the ACHP will be understood to pertain only to the subject of the dispute, and the responsibility of HOD to carry out all actions under this 46 agreement that are not the subject of the dispute will remain unchanged. 11 Lafitte D. Any consulting party may also seek resolution of a dispute concerning this agreement by 2 notifying HUD or SHPO, and the ACHP as appropriate. 3 4 XIII. PUBLIC INVOLVEl\tIENT 6 7 A. Public Notification: HANO and the developer will ensure that the public -especially displaced 8 public housing residents -are apprised regularly on the progress of the project and receive 9 notifications of meetings through a variety of media, including newspaper advertising, internet postings, and direct mail. 11 12 B. Public Objections: Any member of the public objecting to the execution of any tenns or plans 13 resulting from this agreement may seek resolution by notifying SHPO or HUD, and the ACHP as 14 appropriate. 16 17 XIV. Al\tIENDl\tIENTS & NONCOMPLIANCE 18 19 A. If any of the signatories or invited signatories to this agreement detennines that its tenns cannot be camed out or are not being camed out, or that any amendment to its terms must be made, that 21 party shall immediately consult with the other signatories to develop an amendment to this 22 agreement pursuant to 36 CPR 800.6(c)(7) and 800.6(c)(8). 23 24 B. Notwithstanding any provisions in this agreement, stoppage of work in furtherance of the undertaking shall be necessary during the following situations only: (1) pursuant to Stipulation X 26 concerning post-review unanticipated discoveries; or (2) after a Tennination pursuant to Stipulation 27 XV. 28 29 XV. TERMINATION 31 32 A signatory or invited signatory may terminate this agreement only (1) after the signatories engage 33 in a consultation set out in Stipulation XIV lasting no less than 30 days; and (2) after one of the 34 three following circumstances occur: (a) one of the signatories detennines that compliance with the agreement is impossible as a result of unforeseen or unforeseeable circumstances; or (b) one of the 36 signatories detennines that one of the other signatories is not complying with the tenns of the 37 agreement; or (c) one of the signatories determines that an unforeseen and significant modification 38 of the undertaking altering the effects on historic properties in a negative fashion has occurred, the 39 signatories cannot agree on how to resolve consequential and potential adverse effects, and one of the signatories decides to terminate consultation pursuant to 36 CFR 800.7(a). Within 30 days 41 following termination, HUD shall notify the signatories and consulting parties if it will initiate 42 consultation to execute a subsequent agreement with the signatories under 36 CPR 800.6(c)(1) or 43 request the comments of the ACHP under 36 CPR 800.7(a) and proceed accordingly. 44 12 lAfitte EXECUTION OF THIS MEMORANDUM OF AGREEMENT and implementation of its terms by 2 HUD evidences that it has taken into account the effects of this Undertaking on historic properties 3 and afforded the ACHP an opportunity to comment. 4 SIGNATORIES: 6 7 U.S. D PARTMENT OF HOUSING AND URBAN DEVELOPMENT 8 9 0 --"7"'---\-7-1------------- Date: _t:r.l-,_1..__._O'f 11 OI't-allfle.-:r:--t: abrera, Assistant Secretary, Public and Indian Housing 12 14 13 ADVd:L~~PRES::AT;;3~? 16 17 John M. Fowler, Executive Director 18 19 LOUISIANA DIVISION OF HISTORIC PRESERVATION, DEPARTMENT OF CULTURE, RECREATION & TOURISM 26 27 INVITED SIGNATORY: 28 29 HOUSING AUTHORITY OF NEW ORLEANS ~ C~1~i~C~'b.ti,eReceiVer Date: 34 ~V£Ap{1/I~~P-. 13 Lafitte CONCURRING PARTIES: Date: Date: Date: Date: 14 Lafitte 1 APPENDIX A: AREA OF POTENTIAL EFFECTS 2 15 Lafirte APPENDIX B: HABS STIPULATIONS 2 3 Level II HABS documentation will be completed on a representative sample of buildings selected 4 by HANO in consultation with SHPO. 6 Photography and photographic development will be executed in compliance with HABS standards. 7 The following standards will also apply: 8 9 • Each photograph will clearly note the building documented according to its HANO-designated building number. 11 12 • Each of the four elevations of the buildings selected will be photographically documented; 13 in cases where the rear fa~ade is obscured by foliage, an adclitional photograph of the rear 14 fa~ade of a building of the same type will be included. When possible, other objects (such as automobiles) will be excluded from photographs. 16 17 • Variant roof styles of each building type will be documented in photographs. 18 19 • All exterior details for each building will be documented, including (but not necessarily limited to) widows, doors, vents, chimneys, canopies, iron work, plaques, cornerstones, etc. 21 22 • A sample apartment interior will be documented. Variations in interior details, such as 23 fireplaces, mantels, staircases, etc., will be documented inclividually. 24 • The documentation will include streetscape and other site photographs in order to provide a 26 contextual understanding of the site. This includes site details such as original fencing and 27 laundry lines/poles. 28 29 In addition to the photographic documentation of the existing builclings, the following are also required: 31 32 • A site plan noting HANO-designated building numbers, building types, and roof styles. 33 This information may be keyed on a single plan sheet, provided that the information i~ 34 clearly presented. 36 • A complete history of the Lafitte Public Housing Complex, including historic photographs. 37 A timeline of the modernization of the development would be a useful addition, if available. 38 39 • A complete indexed set of existing historic drawings. 41 • A history of the development of the area prior to the housi ng development' s construction, 42 which will provide a context for understanding the neighborhood and the impact of the 43 construction of the Lafitte Redevelopment. 44 16 APPENDIXF NOISE ASSESSMENT Noise Assessment Survey Department of Housing and Urban Development Noise Assessment Guidelines (24 CFR 51) Overview The Lafitte Housing Development is bounded by Lafitte Street, Orleans Avenue, North Claiborne Avenue, and North Rocheblave Street. The Housing Authority of New Orleans plans to demolish all 896 units, followed by subsequent construction of approximately 556 new units, including some project based Section 8 units, and the disposition of the property. Noise Analysis The noise analysis will evaluate the site's exposure to three major sources of noise: aircraft, roadways and railways. After the three factors are combined, the noise environment at the site will come under one of the following three categories: Acceptable -DNL not exceeding 65 decibels Normally Unacceptable -DNL above the 65 but not exceeding 75 decibels Unacceptable -DNL above 75 decibels Noise levels that are Normally Unacceptable or greater will require the implementation of attenuation measures such as shielding affected buildings with barriers, the installation of noise insulating materials, or reconfiguring buildings away from the noise source. USRM has used the most current information available, including traffic counts, noise contour maps, and other data collected in conjunction with this assessment. The NAG specifies that there are three main sources of noise to any urban environment. Each is addressed below: 1. Aircraft -All military and civil airports within 15 miles of the site must be considered. There are three airports within 15 miles of the subject property. The aggregate DNL value for all three airports is 55 decibels. • New Orleans Lakefront Airport (New Orleans, Lollisiana) -This airport handles almost exclusively private traffic. It is located approximately five miles from the subject property. Its DNL value is lower than any measured by Figure 3. However, through the regression analysis, the linear equation used by HUD determined a DNL value of 55. • Louis Armstrong International Airport (Kenner, Louisiana) -This airport is located approximately 10 miles from the subject property. The derived equation was used to find a DNL value of 55 for New Orleans' main commercial airport. • Naval Air Station, Joint Reserve Base at Alvin Callender Field (Belle Chasse, Lollisiana) -This military airfield lies approximately five miles from the subject property. Again, the noise from the airport is not measurable by Figure 3. Since contour maps were not available for review, and the distance is comparable to the Louis Armstrong Airport, a DNL value of 55 was utilized. 2. Roadways -All roads that are within 1,000 feet of the site were considered. For each roadway, data was collected from governmental agencies, employees in the field, and other existing sources. Assumptions include a nighttime traffic flow of 15 percent in accordance with NAG, and distribution of traffic flows according to the Louisiana Department of Transportation and Development (LDOTD) "Classification Counts." The average traffic speeds for automobiles, medium and heavy trucks on this major roadway are 35 mph; therefore, the average traffic speed adjustment factor of 0.40 in Table 4 was applied to automobiles and a factor of 0.81 in Table 7 was applied to heavy trucks on Worksheet C. A nighttime fraction of 0.15 with an adjustment factor of 1.00 was applied to both the automobile and heavy truck worksheet, which yielded no change in the overall adjustment. The aggregate combined DNL for all roadways is 63.45 decibels. 3. Railways -All railroads within 3,000 feet of the site were considered. One railroad, the Illinois Central Railroad, is located over 5,000 feet away from the subject property. Since there are no railroads within the specified parameter, no worksheet is attached. A DNL value of <55 decibels will be used for the railroad. Conclusions An evaluation of the three main contributors to noise to the Lafitte Housing Development has been found to have an Acceptable Level of noise at 64.55 DNL. Terms Definition and explanation of commonly used terms and acronyms • dB -Decibel, unit used to measure sound • DNL -Outdoor day-night average sound level in decibels; this value is a function of noise generated and distance from an NAL to that noise • NAL -Noise Assessment Location, representative locations around a site where noise is expected • NEF -Noise Exposure Forecast • Nighttime -Between the hours of 10pm and 7am References U.S. Department of Housing and Urban Development, Office of Policy Development and Research. Noise Assessment Guidelines. http://\V\Vw.hLl(ltTov/officcs/cpd/cncr~ycl1\'ir()l1/ em·j l'Ollnle Ilthes( III rccs/ ).,'11idcboob/Ilrlise/ c11ap tc 1'5.I'd f. Worksheet A, Site Evaluation (page 26 of Noise Assessment Guidelines) Necessary Infonnation Site Location The subject property is located at 2101 Lafitte Street, Orleans Parish, Louisiana Program PHA Redevelopment Project Name Lafitte Housing Development Locality 2101 Lafitte St, New Orleans, Louisiana 70112 File Number Sponsor's Name Providence Community Housing, Charlotte Bourgeois Sponsor's Phone (504) 821-7222 Street Address Claiborne Building, Suite 7-270 1201 North 3nl Street Baton Rouge, Louisiana 70802 Acceptability Category DNL Predicted for 1. Roadway Noise Acceptable 63.45 Present 2. Aircraft Noise Acceptable 55 Present 3. Railway Noise Acceptable <55 Present Final Site Evaluation 64.55 Date:_---.J.)....ul....y.....2""'5......2...,0""'0'-'-7______ Worksheet B, Aircraft Noise (from page 27 of Noise Assessment Guidelines) Necessary Information Airports (within 15 miles) Naval Air Airport Lake front Louis Armstrong International Station NoYes Yes 1. Are DNL, NEF, or CNR Contours Available? No No 2. Any supersonic aircraft operations? No 3. Estimating ap[1roximate contours from Figure 3 7 71 a. number of nighttime jet operations n/a 212 241b. number of daytime jet operations n/a 282 951c. effective number of operations (lOa+b) n/a d. distance A for 65 dB 70 dB 75 dB e. distance 13 for 65 dB 70 dB 75 dB 4. Estimating DNL from Table 2 a. distance (in miles) from 65 dB contour to flight plan (Dl) .07 .03 b. distance from NAL to flight rlan (D2*) 3.88 9.73 c. D2 divided by Dl 55.43 324.33 <55d. DNL** <55 5. Orerations projected for what year 2007 2007 6. Total DNL for aU airports 55 Date:_--.J.].."ulO/-y.....,2""S....2""O"""Ow..7______ 'Note: These measurements were made relative to the NAL for the specific purpose of this noise assessment survey. "Note: Table 2 lloes not give a DNL level for values where 02 llivillell by 01 is a value greater than 3.16, an equation derived to find the ONL values. Worksheet C, Roadway Noise (from page 28 of Noise Assessment Guidelines) Necessary Information Major Roads (within 1,000 feet) I-lOE & US90I3 1. Distance in feet from the NAL to the edge of the road a. nearest Jane b. farthest lane c. average (e ffective distance) 63.83 182.21 123 2. Distance to stop sign nla 3. Road gradient in percent 0% 4. Average s~e~c1 in mph a. automobiles b. heavy trucks -up_hill c. he:!'.'}1 trucks -downhill 35 35 35 5. 24 hour average number of automobiles and medium 16,730* trucks in both directions (ADl) a. automobiles 15,894 b. meclium trucks 418 c. effective ADT (a+(10b)) 20,074 6. 24 houraverage number of heavy trucks a. uphill n/a b. downhill nla c. total 418 7. Fraction of nighttime traffic (lOpm to 7am) 0.15 8. Traffic projected for what year? Present Adjustments for Automobile Traffic 9 Stop and go Table 3 10 Average speed Table 4 11 Nighttime Table 5 12 Auto ADT (line 5c) 13 Adjusted Auto ADT 14 DNL Workchart 1 15 Barrier Attenuation 16 Partial DNL 1-10 & US90B nla DAD 1.00 20,074 8,030 61.5 nla 61 .5 Adjustments for Heavy Truck Traffic 17 18 19 , 20 21 22 23 24 25 26 27 Gradient Average Truck Stop Nighttime Adjusted DNL Barrier Partial Table 6 Speed ADT/2 and go Table 5 Truck Workchart Anenuation DNL Table 7 Table B ADT 2 I-lOE & US90I3 nla 0.81 209 nla 1.00 169 59 0 59 Total Automobile and Heavy Truck 63.45 DNL k1r~ Signature: _______________ Date:_--.J.]""'u)'-/-y......2""'S.....,.2=0"-"0'-'-7______ *Note: This traffic data for 1-1 OE to US90B was coUected by the Louisiana Department ofTransportation anti Development. In view of the U.S. Census l3ureau, Orleans Parish had an estimated population of 484,674 in 2000 and 223,388 in 2006, a 54% retluction. j\ 30% rduction in population was used to adjust the original ADT of 23,901.) Source Citation: U.S. Census Bureau, Population Division. COlin!] total poplllation and estimated <'ontponeJ1ts ofpoplllation change: April 1 , 2000 to JIIIY 1, 2006. From a compilation by the GNO Community Data Center. < http://www.gnocdc.org> Workchart 1 Autos (55 mph) 67 lJIt ~---------------------------------­ Workchart2 Heavy Trucks (55 mph) 100,000 d 1"­ 80,000 ~--1-'r H !" , IT I ~ '''' 7;//;)f:)ri:~r7.'J.1v.;6~1I ::;;(-11 I,Y~1J7 liF: .j'I ~;! I:r.t::: 100 '/ '/ i! I~'. r'i7' -r--rl.ft II' r, ~ rw, T -­DNl 75 70 65 I'·i +-H-fl :-rH t I ' I' r I··I i.::J::r.:: ,;t , ;. . r~ r~ I ~ ..",--, H rrrv ._', ttll II -1-l" II '--I -F" 'J-'"11-3.l-i:L.J; o E 4000 1:1:s (5 > Q C ~1.I, .... I i ~~I;!1I ,~/iVr ~₯:1;:t,:j,;';j :lr"J Y"':~H'f' ilL! '1:I;::tr-=£V-:; t~ r 'n~: II. ,t.;, V.-I , Li '-;J , fC; , if ,.-\I, II I' ~ I:::: 2000 sooo 10 20 40 60 100/~!> 200 400 bOO 1000 EffectIve Distance