APPENDIX A. FIGURES Figure 1 is a vicinity map of south east Louisiana. Orleans Parish, metropolitan New Orleans, and project location is noted. Map includes highways and parish boundaries from ESRI Basemap and topogrpahic features from National Geographic TOPO. Figure 2 is a project location map showing the project boundary with local schools, the HANO Multi-family Govenment Housing, and earlier Phase of HANO Fischer Redevelopment designated overlayed on 2008 aerial photography from Digital Globe and provided by the Regional Planning Commission for Jefferson, Orleans, Plaquemines, St. Bernard and St. Tammany Parishes. Figure 3 is a schematic drawing of a typical cottage foundation with pier locations denoted. A typical pier cross-section shows pier height and width and attachment to house frame designs. Figure 4 shows 65 dBa and 75dBa contours for construction noise. Stage one construction area is marked within the project boundry. Aerial photography is provided by Digital Globe and provided by the Regional Planning Commission for Jefferson, Orleans, Plaquemines, St. Bernard and St. Tammany Parishes.. Figure 5 shows the Interstate and highway transportation routes, the Amtrak Station and cities within the vicinity of the project area. ESRI Streetmap World is used as a basemap. Figure 6 shows the Algiers Loop Regional Transit Authority Line, the Algiers Owl Loop Regional Transit Authority Line and the General Meyer Regional Transit Authority Line routes on the westbank near the project area. This data is overlayed on ESRI Streetmap World basemap APPENDIX B. CORRESPONDENCE Correspondence # 1 Date: July 10, 2009 To: Ms. Wynecta Fisher – CZM Administrator, City of New Orleans Subject: Project Review for the Environmental Assessment for Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Figure 1: Project Location Map Correspondence # 2 Date: May 12, 2009 To: Ms. Denise Rousseau Ford – GSRC RE: Fisher (Algiers) Group Site, Orleans Parish, Louisiana Alternative, Housing Pilot Program Group Housing Project The area is considered an urban area and is “built-up”, thus there will be no impact to prime farmland and it appears the project will not impact any NRCS work in the immediate area. Also, this project will not impact any farmland protection efforts in the area. Further, we do not believe there will be an adverse effect on the surrounding environment provided appropriate erosion control measures are taken during construction. From: E.J. “Ed” Giering III, P.E. – NRCS Correspondence # 3 Date: April 9, 2009 To: Ms. Denise Rousseau Ford – GSRC RE: Solicitation of Views request dated March 10, 2009, on behalf of Louisiana Recovery Authority, concerning the construction of the Fischer (Algiers) group site at New Orleans, Louisiana, in Orleans Parish We have reviewed your request for potential Department of the Army regulatory requirements and impacts on any Department of the Army projects. We do not anticipate any adverse impacts to any Corps of Engineers projects. From: Karen L. Oberlies – Department of the Army, New Orleans District, Corps of Engineers Correspondence # 4 Date: April 6, 2009 To: Denise Rousseau Ford – GSRC Subject: DEQ SOV:090316/0530 Fischer (Algiers) Group Site There were no objections based on the limited information submitted to us. However, the following comments have been included. Should you encounter a problem during the implementation of this project, please make the appropriate notification to this Department. From: Diane Hewitt – LDEQ / Community and Industry Relations Correspondence # 5 Date: March 10, 2009 (Received March 12, 2009) To: Josh Marceaux – USFWS RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project Will have no effect on those resources From: Denise Rousseau Ford – GSRC Correspondence # 6 Date: March 16, 2009 To: Denise Rousseau Ford – GSRC The proposed project lies within the designated coastal management zone. After careful review of our database, no other impacts to rare, threatened, or endangered species or critical habitats are anticipated for the proposed projects. From: Gary Lester – Natural Heritage Program Correspondence # 7 Date: March 16, 2009 To: Denise Rousseau Ford – GSRC Subject: Project Review: Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project NMFS has reviewed the letter and agrees that the project boundary is located in area of previously disturbed land that is not classified as essential fish habitat or supportive of marine fishery resources. As such, we have no comments to provide on the letter for this project review. From: Kimberly Clements – NOAA Fisheries Correspondence # 8 Date: March 10, 2009 To: Richard Hartman – National Oceanic and Atmospheric Administration RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 9 Date: March 10, 2009 To: Tammy Mick – U.S. Environmental Protection Agency RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 10 Date: March 10, 2009 To: Amy Powell – USACE RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 11 Date: March 10, 2009 To: Ed Giering – USDA, Natural Resource Conservation Services RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 12 Date: March 10, 2009 To: Kyle Balkum – Louisiana Department of Wildlife and Fisheries RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 13 Date: March 10, 2009 To: Diane Hewitt – Louisiana Department of Environmental Quality RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 14 Date: March 10, 2009 To: Paul May – Floodplain Manager, Orleans Parish RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Correspondence # 15 Date: March 10, 2009 To: Josh Marceaux - USFWS RE: Request for Project Review – Fischer (Algiers) Group Site, Orleans Parish, Louisiana Alternative Housing Pilot Program Group Housing Project From: Denise Rousseau Ford – GSRC Figure 1: Project Location Map APPENDIX C. CONCEPTUAL SITE PLAN AND AHPP COTTAGE DESIGNS Page #1: Conceptual Site Plan dated July 2009 shows the irregular shaped, 20 acre proposed Fischer site in Algiers, Lousiana with each of the 124 lots indicating the applicable cottage design. To the north the property is bounded by Shepard Street to the south by General DeGaulle Drive, to the east by Wagner Street and to the west by Thayer Avenue. Page #2: AHPP Cottage Design provided by Cypress Realty Partners with cover sheet illustrating a rendering of cottages in a neighborhood setting. Page #3: Front rendering and side rendering of the 874 square feet unit with the applicable floorplan indicating 2 bedrooms and 1 bath. Page #4: In-situ cottage rendering for the 910 square feet unit stating that it is 3 bedrooms and 1 bath with an option that allows the unit to be expanded to the 1,525 square feet cottage unit. Page #5: Front rendering and side rendering of the 910 square feet unit with the applicable floorplan indicating 3 bedrooms and 1 bath with an option that allows the unit to be expanded to the 1,525 square feet cottage unit. Page #6: In-situ cottage rendering for the 936 square feet unit with an option that allows the unit to be expanded to the 1,200 square feet cottage unit. Page #7: Front rendering and side rendering of the 936 square feet unit with the applicable floorplan indicating 2 bedrooms and 2 baths with an option that allows the unit to be expanded to the 1,525 square feet cottage unit. Page #8: In-situ cottage rendering for the 1,080 square feet unit stating that it is 3 bedrooms and 2 baths. Page #9: Front rendering and side rendering of the 1,080 square feet unit with the applicable floorplan indicating 3 bedrooms and 2 baths. Page #10: In-situ cottage rendering for the 1,112 square feet unit stating that it is 3 bedrooms and 2 baths. Page #11: Front rendering and side rendering of the 1,112 square feet unit with the applicable floorplan indicating 3 bedrooms and 2 baths. Page #12: Blank sheet stating that No In-situ cottage rendering for the 1,480 square feet unit, 3 bedrooms 2 baths unit is Available. Page #13: Front rendering and side rendering of the 1,480 square feet unit with the applicable floorplan indicating 3 bedrooms and 2 baths. Page 14: Logo of the Cypress Realty Partners. APPENDIX D. AIR QUALITY CALCULATIONS Page #1: CALCULATION SHEET-COMBUSTIBLE EMISSIONS Assumptions for Combustible Emissions Type of Construction Equipment Num. of Units HP Rated Hrs/day Days/yr Total hp-hrs Water Truck 1 300 8 240 576000 Diesel Road Compactors 1 100 8 90 72000 Diesel Dump Truck 2 300 8 90 432000 Diesel Excavator 1 300 8 15 36000 Diesel Hole Trenchers 1 175 8 15 21000 Diesel Bore/Drill Rigs 1 300 8 15 36000 Diesel Cement & Mortar Mixers 1 300 8 240 576000 Diesel Cranes 1 175 8 240 336000 Diesel Graders 1 300 8 90 216000 Diesel Tractors/Loaders/Backhoes 2 100 8 90 144000 Diesel Bull Dozers 1 300 8 90 216000 Diesel Front End Loaders 1 300 8 90 216000 Diesel Fork Lifts 2 100 8 90 144000 Diesel Generator Set 6 40 8 240 460800 Emission Factors Type of Construction Equipment VOC g/hp-hr CO g/hp-hr NOx g/hp-hr PM-10 g/hp-hr PM-2.5 g/hp-hr SO2 g/hp-hr CO2 g/hp-hr Water Truck 0.440 2.070 5.490 0.410 0.400 0.740 536.000 Diesel Road Compactors 0.370 1.480 4.900 0.340 0.330 0.740 536.200 Diesel Dump Truck 0.440 2.070 5.490 0.410 0.400 0.740 536.000 Diesel Excavator 0.340 1.300 4.600 0.320 0.310 0.740 536.300 Diesel Trenchers 0.510 2.440 5.810 0.460 0.440 0.740 535.800 Diesel Bore/Drill Rigs 0.600 2.290 7.150 0.500 0.490 0.730 529.700 Diesel Cement & Mortar Mixers 0.610 2.320 7.280 0.480 0.470 0.730 529.700 Diesel Cranes 0.440 1.300 5.720 0.340 0.330 0.730 530.200 Diesel Graders 0.350 1.360 4.730 0.330 0.320 0.740 536.300 Diesel Tractors/Loaders/Backhoes 1.850 8.210 7.220 1.370 1.330 0.950 691.100 Diesel Bull Dozers 0.360 1.380 4.760 0.330 0.320 0.740 536.300 Diesel Front End Loaders 0.380 1.550 5.000 0.350 0.340 0.740 536.200 Diesel Fork Lifts 1.980 7.760 8.560 1.390 1.350 0.950 690.800 Diesel Generator Set 1.210 3.760 5.970 0.730 0.710 0.810 587.300 Page#2: CALCULATION SHEET-COMBUSTIBLE EMISSIONS Emission factors (EF) were generated from the NONROAD2005 model for the 2006 calendar year. The VOC EFs includes exhaust and evaporative emissions. The VOC evaporative components included in the NONROAD2005 model are diurnal, hotsoak, running loss, tank permeation, hose permeation, displacement, and spillage. The construction equipment age distribution in the NONROAD2005 model is based on the population in U.S. for the 2006 calendar year. Type of Construction Equipment VOC tons/yr CO tons/yr NOx tons/yr PM-10 tons/yr PM-2.5 tons/yr SO2 tons/yr CO2 tons/yr Water Truck 0.279 1.314 3.485 0.260 0.254 0.470 340.227 Diesel Road Paver 0.029 0.117 0.389 0.027 0.026 0.059 42.544 Diesel Dump Truck 0.209 0.985 2.614 0.195 0.190 0.352 255.170 Diesel Excavator 0.013 0.052 0.182 0.013 0.012 0.029 21.276 Diesel Hole Cleaners\Trenchers 0.012 0.056 0.134 0.011 0.010 0.017 12.399 Diesel Bore/Drill Rigs 0.024 0.091 0.284 0.020 0.019 0.029 21.014 Diesel Cement & Mortar Mixers 0.387 1.473 4.621 0.305 0.298 0.463 336.228 Diesel Cranes 0.163 0.481 2.118 0.126 0.122 0.270 196.318 Diesel Graders 0.083 0.324 1.126 0.079 0.076 0.176 127.657 Diesel Tractors/Loaders/Backhoes 0.294 1.303 1.146 0.217 0.211 0.151 109.669 Diesel Bull Dozers 0.086 0.328 1.133 0.079 0.076 0.176 127.657 Diesel Front End Loaders 0.090 0.369 1.190 0.083 0.081 0.176 127.633 Diesel Aerial Lifts 0.314 1.231 1.358 0.221 0.214 0.151 109.622 Diesel Generator Set 0.614 1.909 3.032 0.371 0.361 0.411 298.232 Total Emissions 2.599 10.034 22.811 2.005 1.952 2.931 2125.647 Conversion factors Grams to tons = 0.000001102 Page#3: CALCULATION SHEET-TRANSPORTATION COMBUSTIBLE EMISSIONS Construction Worker Personal Vehicle Commuting to Construction Site - Passenger and Light Duty Trucks Emission Factors Assumptions Results by Pollutant Pollutants Passenger Cars g/mile Pick-up Trucks, SUVs g/mile Mile/day Day/yr Number of cars Number of trucks Total Emissions Cars tns/yr Total Emissions Trucks tns/yr Total tns/yr VOCs 1.36 1.61 60 240 20 20 0.43 0.51 0.94 CO 12.4 15.7 60 240 20 20 3.94 4.98 8.92 NOx 0.95 1.22 60 240 20 20 0.30 0.39 0.69 PM-10 0.0052 0.0065 60 240 20 20 0.00 0.00 0.00 PM 2.5 0.0049 0.006 60 240 20 20 0.00 0.00 0.00 Heavy Duty Trucks Delivery Supply Trucks to Construction Site Emission Factors Assumptions Results by Pollutant Pollutants 10,000-19,500 lb Delivery Truck 33,000-60,000 lb semi trailer rig Mile/day Day/yr Number of trucks Number of trucks Total Emissions Cars tns/yr Total Emissions Trucks tns/yr Total tns/yr VOCs 0.29 0.55 60 240 2 2 0.01 0.02 0.03 CO 1.32 3.21 60 240 2 2 0.04 0.10 0.14 NOx 4.97 12.6 60 240 2 2 0.16 0.40 0.56 PM-10 0.12 0.33 60 240 2 2 0.00 0.01 0.01 PM 2.5 0.13 0.36 60 240 2 2 0.00 0.01 0.02 Emission Factors Assumptions Results by Pollutant Pollutants Passenger Cars g/mile Pick-up Trucks, SUVs g/mile Mile/day Day/yr Number of Cars Number of trucks Total Emissions cars tns/yr Total Emissions Trucks tns/yr Total tns/yr VOCs 1.36 1.61 30 240 - - - 0.00 - CO 12.4 15.7 30 240 - - - 0.00 - NOx 0.95 1.22 30 240 - - - 0.00 - PM-10 0.0052 0.0065 30 240 - - - 0.00 - PM 2.5 0.0049 0.006 30 240 - - - 0.00 - Truck Emission Factor Source: USEPA 2005 Emission Facts: Average annual emissions and fuel consumption for gasoline-fueled passenger cars and light trucks. EPA 420-F-05-022 August 2005. Emission rates were generated using MOBILE.6 highway vehicle emission factor model. Page#4: CALCULATION SHEET-FUGITIVE DUST Construction Fugitive Dust Emission Factors Emission Factor Units Source General Construction Activities 0.19 ton PM10/acre-month MRI 1996; EPA 2001; EPA 2006 New Road Construction 0.42 ton PM10/acre-month MRI 1996; EPA 2001; EPA 2006 PM2.5 Emissions PM2.5 Multiplier 0.10 (10% of PM10 emissions assumed to be PM2.5) EPA 2001; EPA 2006 Control Efficiency 0.50 (assume 50% control efficiency for PM10 and PM2.5 emissions) EPA 2001; EPA 2006 Project Assumptions Construction Area (0.19 ton PM10/acre-month) Conversion Factors Duration of Construction Project 12 months 0.000022957 acres per feet Length 0 miles 5280 feet per mile Length (converted) 0 feet Width 0 feet Area 20.00 acres Staging Areas Duration of Construction Project - months Length - miles Length (converted) - feet Width - feet Area 0.00 acres Project Emissions (tons/year) PM10 uncontrolled PM10 controlled PM2.5 uncontrolled PM2.5 controlled Construction Area (0.19 ton PM10/acre-month) 45.60 22.80 4.56 2.28 Staging Areas 0.00 0.00 0.00 0.00 Total 45.60 22.80 4.56 2.28 Page#5: CONSTRUCTION FUGITIVE DUST EMISSION FACTORS General Construction Activities Emission Factor 0.19 ton PM10/acre-month Source: MRI 1996; EPA 2001; EPA 2006 The area-based emission factor for construction activities is based on a study completed by the Midwest Research Institute (MRI) Improvement of Specific Emission Factors (BACM Project No. 1), March 29, 1996. The MRI study evaluated seven construction projects in Nevada and California (Las Vegas, Coachella Valley, South Coast Air Basin, and the San Joaquin Valley). The study determined an average emission factor of 0.11 ton PM10/acre-month for sites without large-scale cut/fill operations. A worst-case emission factor of 0.42 ton PM10/acre-month was calculated for sites with active large-scale earth moving operations. The monthly emission factors are based on 168 work-hours per month (MRI 1996). A subsequent MRI Report in 1999, Estimating Particulate Matter Emissions From Construction Operations, calculated the 0.19 ton PM10/acre-month emission factor by applying 25% of the large-scale earthmoving emission factor (0.42 ton PM10/acre-month) and 75% of the average emission factor (0.11 ton PM10/acre-month). The 0.19 ton PM10/acre-month emission factor is referenced by the EPA for non-residential construction activities in recent procedures documents for the National Emission Inventory (EPA 2001; EPA 2006). The 0.19 ton PM10/acre-month emission factor represents a refinement of EPA's original AP-42 area-based total suspended particle (TSP) emission factor in Section 13.2.3 Heavy Construction Operations. In addition to the EPA, this methodology is also supported by the South Coast Air Quality Management District and the Western Regional Air Partnership (WRAP) which is funded by the EPA and is administered jointly by the Western Governor's Association and the National Tribal Environmental Council. The emission factor is assumed to encompass a variety of non-residential construction activities including building construction (commercial, industrial, institutional, governmental), public works, and travel on unpaved roads. The EPA National Emission Inventory documentation assumes that the emission factors are uncontrolled and recommends a control efficiency of 50% for PM10 and PM2.5 in PM nonattainment areas. New Road Construction Emission Factor 0.42 ton PM10/acre-month Source: MRI 1996; EPA 2001; EPA 2006 The emission factor for new road construction is based on the worst-case conditions emission factor from the MRI 1996 study described above (0.42 tons PM10/acre-month). It is assumed that road construction involves extensive earthmoving and heavy construction vehicle travel resulting in emissions that are higher than other general construction projects. The 0.42 ton PM10/acre-month emission factor for road construction is referenced in recent procedures documents for the EPA National Emission Inventory (EPA 2001; EPA 2006). PM2.5 Multiplier 0.10 PM2.5 emissions are estimated by applying a particle size multiplier of 0.10 to PM10 emissions. This methodology is consistent with the procedures documents for the National Emission Inventory (EPA 2006). Control Efficiency for PM10 and PM2.5 0.50 The EPA National Emission Inventory documentation recommends a control efficiency of 50% for PM10 and PM2.5 in PM nonattainment areas. Wetting controls will be applied during project construction (EPA 2006). References: EPA 2001. Procedures Document for National Emissions Inventory, Criteria Air Pollutants, 1985-1999. EPA-454/R-01-006. Office of Air Quality Planning and Standards, United States Environmental Protection Agency. March 2001. EPA 2006. Documentation for the Final 2002 Nonpoint Sector (Feb 06 version) National Emission Inventory for Criteria and Hazardous Air Pollutants. Prepared for: Emissions Inventory and Analysis Group (C339-02) Air Quality Assessment Division Office of Air Quality Planning and Standards, United States Environmental Protection Agency. July 2006. MRI 1996. Improvement of Specific Emission Factors (BACM Project No. 1). Midwest Research Institute (MRI). Prepared for the California South Coast Air Quality Management District, March 29, 1996. Page#6: CALCULATION SHEET-SUMMARY OF EMISSIONS Proposed Action Construction Emissions for Criteria Pollutants (tons per year) Emission source VOC CO NOx PM-10 PM-2.5 SO2 Combustible Emissions 2.60 10.03 22.81 2.01 1.95 2.93 Construction Site-fugitive PM-10 NA NA NA 22.80 2.28 NA Construction Workers Commuter & Trucking 0.97 9.06 1.25 0.02 0.02 NA Total emissions 3.57 19.10 24.06 24.82 4.25 2.93 De minimis threshold NA NA NA NA NA NA APPENDIX E. FLOODPLAIN EIGHT STEP PLANNING PROCESS AND PUBLIC NOTICE FEMA AHPP Fischer (Algiers) Group Housing Site Eight-Step Planning Process for Floodplains and Wetlands Step 1: Determine whether the Proposed Action is located in a wetland and/or the 100-year floodplain, or whether it has the potential to affect or be affected by a floodplain or wetland. Project Analysis: According to the preliminary DFIRMs (digital flood insurance rate map) dated January 13, 2008, the Fischer Site is in the 100-year floodplain in Zone AE at a advisory base flood elevation (ABFE) of 3 feet above mean sea level (amsl). Based on a review of the National Wetlands Inventory (NWI) and a site visit, wetlands will not be impacted by the proposed AHPP housing project. The proposed site is in a developed urban setting which has been used for the Housing Authority of New Orleans (HANO) housing for many years prior to its demolition and is not in an area identified as a wetland. Step 2: Notify public at earliest possible time of the intent to carry out an action in a floodplain or wetland, and involve the affected and interested public in the decision-making process. Project Analysis: A final public notice was previously issued by FEMA notifying the public regarding floodplain impacts from various proposed housing actions within the 100-year floodplains in Orleans and St. Bernard parishes. In addition, FEMA and the Louisiana Recovery Authority (LRA) will notify the public of the availability of the draft Environmental Assessment (EA) which evaluates all natural resource impacts from the proposed project, including floodplains. The public notice will be provided in a newspaper of general circulation on March 16, 2009 when the EA is made available for public review. Step 3: Identify and evaluate practicable alternatives to locating the Proposed Action in a floodplain or wetland. Project Analysis: The Applicant considered the following alternatives in selecting the proposed action: No Action Alternative: Under the No Action Alternative, no AHPP housing would be provided for families displaced from their homes. Rental resources are very limited in the affected area, and people displaced by Hurricanes Katrina and Rita would remain in housing provided by family members or friends, in hotels, in temporary "dormitories" such as homeless shelters or churches, or in facilities damaged by the storm and determined structurally unsafe or unsanitary. Although no new construction would occur in the 100-year floodplain, permanent housing for Louisiana residents would remain inadequate. Proposed Action Alternative: Under the Proposed Action Alternative FEMA would construct approximately 105 permanent single-family AHPP units (Louisiana Cottages) within the proposed project site. The approximately 20-acre plot has previously been utilized by the HANO, as multi-family government housing from the 1960s, which has since been demolished and is located in the New Orleans Westbank neighborhood of Algiers, Orleans Parish, Louisiana and is bound by Semmes Street to the north, General De Gaulle Drive to the south, the Mississippi River to the east, and Thayer Avenue on the west. The Louisiana Cottages would be built on piers to bring them up to the required ABFE of 3 feet amsl, as necessary. Driveways would be constructed to facilitate access and parking for the AHPP cottages. The houses would tie into existing water and sewer infrastructure currently located near each lot site, and utilities would then be installed to each individual cottage. Step 4: Identify the full range of potential direct or indirect impacts associated with the occupancy or modification of floodplains and wetlands, and the potential direct and indirect support of floodplain and wetland development that could result from the Proposed Action. Project Analysis: Direct impacts to the floodplain include converting approximately 20 acres of 100-year floodplain to areas outside the floodplain. The loss of floodplain area in the vicinity of the project would generally be considered a direct, permanent impact; however, in this case it would be a minor adverse effect for the following reasons: 1) the site was previously elevated by HANO after demolition of the former HANO multi-family housing when the area was filled, contoured, and graded which left the site at or near the 3 feet ABFE; 2) should the final elevation not be above the 3 foot ABFE, elevation of the proposed AHPP units to the ABFE would be attained through the addition of fill material, the construction the AHPP units on piers, or through a combination of both; 3) the proposed conversion of the project area to non-floodplain is not likely to result in an evident increase in flood velocities or elevations upstream or downstream. Although the project does not encourage additional development within the floodplain, the project will result in providing civic support to populations living in the floodplain which would be an indirect impact. No direct or indirect impacts to wetlands are anticipated for the proposed project. Step 5: Minimize the potential adverse impacts from work within floodplains and wetlands (identified under Step 4) and restore and preserve the natural and beneficial values served by wetlands. Project Analysis: To minimize impacts to the floodplain, the proposed AHPP cottages would be constructed on the proposed site which has already been filled and graded so that the AHPP group site development would be located outside the 100-year floodplain. The proposed AHPP units would be elevated above the ABFE with a finished floor elevation above 3 feet amsl. Step 6: Re-evaluate the Proposed Action to determine: 1) if it is still practicable in light of its exposure to flood hazards; 2) the extent to which it will aggravate the hazards to others; 3) its potential to disrupt floodplain and wetland values. Project Analysis: The Proposed Action remains practicable, as it increases permanent affordable housing in Louisiana, would only minimally (if at all) increase nearby flood elevations, and preserves abundant nearby floodplains retaining their natural values. Step 7: If the agency decides to take an action in a floodplain or wetland, prepare and provide the public with a finding and explanation of any final decision that the floodplain or wetland is the only practicable alternative. The explanation should include any relevant factors considered in the decision-making process. Project Analysis: Executive (EO) 11988 (Floodplain Management) requires Federal agencies to avoid direct or indirect support of development within the 100-year floodplain whenever there is a practicable alternative. FEMA applies the decision process described in 44 CFR Part 9, referred to as the Eight-Step Planning Process, to ensure that its actions are consistent with EO 11988. A final public notice for Orleans Parish was published in November 2007 informing the public of FEMA’s decision to proceed with the AHPP projects. Step 8: Review the implementation and post-implementation phases of the Proposed Action to ensure that the requirements of the EOs are fully implemented. Oversight responsibility shall be integrated into existing processes. Project Analysis: This step is integrated into the NEPA process and FEMA project management and oversight functions.