Reviewer Name: Brandon M. Clark Applicaat: Orleans Parish School Board 
DisallterlEmergeacylProgramiProject Title: DR I603LA f Hurricane Katrina f Public Assistance Program f EOR0945 Gaudet Elementary School 

Record of Environmental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: EOR0945 Gaudet Elementary School / PW 10306 

Project Location: 12000 Hayne Blvd., New Orleans, Louisiana, Orleans Parish 70128 (N30.05826, 
W-89.96761) 

Project Description: Project activities include repairing the school to pre-disaster condition and 
upgrading to current codes and standards. Cumulative project repairs include installing a diesel 
generator and all hardware for temporary and permanent power change, flushing plumbing, recharging 
and testing electrical components, removing and replacing a chain link fence, carpet, asbestos floor 
tiles, drywall, and acoustic ceiling tiles, cleaning and remediating mold contaminated surfaces and 
contents, and cleaning one swimming pool. 

Documentation Requirements 

o No Documentation Required <Review Concluded) 
o (Short version) All consultation and agreements implemented to comply with the National Historic 
Preservation Act, Endangered Species Act, and Executive Orders 11988, 11990 and 12898 are 
completed and no other laws apply. <Review Concluded) 


[gj (Long version) All applicable laws and executive orders were reviewed. Additional information for 
compliance is attached to this REC. 

National Environmental Policy Act (NEPA) Determination 

o Statutorily excluded from NEP A review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category (Review Concluded) 
o Categorical Exclusion -Category 
o No Extraordinary Circumstances exist. 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 
o Extraordinary Circumstances exist (See Section IV). 


o Extraordinary Circumstances mitigated. (See Section IV comments) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 


o Environmental Assessment 
o Supplemental Environmental Assessment (Reference EA or PEA in comments) 
[gj Environmental Impact Statement 


Comments: 7/21/2006 -This project meets the criteria for an Alternative Arrangement (permanent Schools) type ofproject. 
This project has conditions and requires mitigation under the other EHP laws. 


Reviewer Name: Brandon M. elarlc Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProjet:t Tide: DR1603LA I HUlTicane Katrina I Public Assistance Program I EOR0945 Gaudet Elernenta/y School 

Reviewer and Approvals 

o Project is Non-Compliant (See attached docwnentation justifying selection). 

FEMA Environmental Reviewer. 
Name: Brandon M. Clark, Environmental Specialist 


Signature ~C.la..r.\c.... . Date_--!.!7/=2=1I=20=O=6'--___~ 

FEMA Regional Environmental Offic~r or delegated approving official. 
Name: Donald R. Fairley, ELO 

g7,.?

Signature t 
~ . Date_--!.7~/2:!..!.1~/2:.:::;O.!::..:06~___~ 

I. Compliance Review for Environmental Laws (other than NEPA) 

A. National Historic Preservation Act 

o Not type of activity with potential to affect historic properties. <Review Concluded) 
IZl Applicable executed Programmatic Agreement 12/3/2004 Otherwise, conduct standard Section 106 review. 


IZl Activity meets Programmatic Allowance # Appendix A, Section I. A and D and E 
Are project conditions required? IZl Yes (see section V) 0 No <Review Concluded) 


HISTORIC BUILDINGS AND STRUCTURES 
IZl No historic properties that are listed or 45150 years or older in project area. <Review Concluded) 

o Building or structure listed or 45150 years or older in project area and activity not exempt from review. 

o Detennination ofNo Historic Properties Affected (FEMA findingiSHPOrrHPO concurrence on file) 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 
o Detennination of Historic Properties Affected (FEMA fmdingiSHPOITHPO concurrence on file) 


o Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. If not, explain in comments 
D No Adverse Effect Detennination (FEMA fmdingiSHPOrrHPO concurrence on file). 
Are project conditions required? D Yes (see section V) 0 No <Review Concluded) 
D Adverse Effect Detennination (FEMA fmdingiSHPOrrHPO concurrence on file) 

D Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required 0 Yes (see section V) 0 No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 
IZl Project affects only previously disturbed ground. (Review Concluded) 

o Project affects undisturbed ground. 

o Project area has no potential for presence of archeological resources 
o Detennination ofno historic properties affected (FEMA fmdingiSHPOITHPO concurrence or 
consultation on file). (Review Concluded) 


o Project area has potential for presence of archeological resources 


o Detennination ofno historic properties affected (FEMA fmdingiSHPOrrHPO concurrence on file) 

Are project conditions required 0 Yes (see section V) D No (Review Concluded) 
D Detennination of historic properties affected 

o NR eligible resources not present (FEMA fmdingiSHPOITHPO concurrence on file). 

Are project conditions required DYes (see section V) 0 No (Review Concluded) 
D NR eligible resources present in project area. (FEMA findingl SHPOrrHPO concurrence on 
file) 

o No Adverse Effect Detennination. (FEMA findingl SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) 0 No <Review Concluded) 
o Adverse Effect Detennination. (FEMA findingl SHPorrHPO concurrence on file) 


o Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required? 0 Yes (see section V) 0 No 


Reviewer Name: Brandon M. Clark Applicant: Orl~s Parish School Board 
DisasterlEmergencylProgramIProject Title: DRl603LA I Hurricane Katrina I Public Assistance Program I EOR0945 Gaudet Elementary School 

(Review Concluded) 

Comments: All buildings were constructed after the 1960's. 7/20/2006 -The structure does not meet the 50-year-criterion, 
nor does it possess the level ofexceptional importance required by Criteria Consideration G ofthe National Register 
Guidelines to be considered eligible for the National Register of Historic Places. Therefore, the proposed work will have no 
effect on historic properties. Scope of work indicates ground disturbing activities associated with repair to the electrical 
systems, parking area, and fencing. Upon consultation of SHPO data, there are no known archaeological sites within .25 
miles ofthe project area. Therefore scope ofwork meets Programmatic Agreement (12/3/2004) Allowances, Appendix A, 
Section I, A and D and E. If during the course ofwork, archaeological artifacts (prehistoric or historic) or human remains 
are discovered, the applicant shall stop work in the vicinity of the discovery and take all reasonable measures to avoid or 
minimize harm to the fmds. The applicant shall inform their Public Assistance (PA) contacts at FEMA, who will in turn 
contact FEMA historic preservation staff. The applicant will not proceed with work until FEMA historic preservation staff 
have completed consultation with the Louisiana State Historic Preservation Officer (SHPO). In addition, if unmarked graves 
are present, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is required. 
The applicant shall notify the law enforcement agency of the jurisdiction where the remains are located within twenty-four 
hours ofthe discovery. The applicant shall also notify FEMA and the Louisiana Unmarked Burial Sites Board (call the 
Louisiana Division ofArcheology at 225-342-8170) within seventy-two hours of the discovery. Failure to comply with these 
stipUlations may jeopardize receipt ofFEMA funding. -Katherine Zeringue, Historic Preservation Specialist/Archaeologist 

Correspondence/Consultation/References: 

B. Endangered Species Act 

I2?l No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
eview Concluded 
Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. 
D No effect to species or designated critical habitat (See comments for justification) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D May affect, but not likely to adversely affect species or designated critical habitat (FEMA 
determinationlUSFWSINMFS concurrence on file) (Review Concluded) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Likely to adversely affect species or designated critical habitat 
D Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

C. Coastal Barrier Resources Act 
I2?l Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded>. 
D Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 

file) 
D Proposed action an exception under Section 3505.a.6? (Review Concluded) 
D Proposed action not excepted under Section 3505.a.6. 


Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 

['8J Project would not affect any waters ofthe U.S. (Review Concluded) 

D Project would affect waters, including wetlands, of the U.s. 

D Project exempted as in kind replacement or other exemption. (Review Concluded) 

D Project requires Section 404/40 l/or Section 911 0 (Rivers and Harbors Act) permit, including qualification 

under Nationwide Permits. 

Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: Project is not in or adjacent to any waterways ofthe US. 
Correspondence/Consultation/References: 


Reviewer Nlme: Brandon M. Clark. Appliclnt: Orleans Parish School Board 
DiSisterfEmergeDcylProgrlmIProjett Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR094S Gaudet Elementary School 

E. Coastal Zone Management Act 

o Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 

181 Project is located in a coastal zone area and/or affects the coastal zone 
181 State administering agency does not require consistency review. (Review Concluded). 

o State administering agency requires consistency review. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Coneluded) 


Comments: FEMA has detennined that this project is consistent with the Coastal Zone Management Act and the Louisiana 
Coastal Management Plan (LCMP). 

Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modify a waterwaylbody of water. (Review Coneluded) 

o Project affects, controls or modifies a waterwaylbody of water. 

o Coordination with USFWS conducted 

o No Recommendations offered by USFWS. (Review Coneluded) 
o Recommendations provided by USFWS. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Coneluded) 


Comments: Project is not in or adjacent to any waterways ofthe US. 
Correspondence/Consultation/References: 

G. Clean Air Act 

181 Project will not result in pennanent air emissions. (Review Coneluded) 

o Project is located in an attainment area. (Review Concluded) 
o Project is located in a non-attainment area. 


o Coordination required with applicable state administering agency.. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Coneluded) 

Comments: Project will not result in pennanent air emissions. 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

181 Project does not affect designated prime or unique farmland. (Review Coneluded) 

o Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required.

o Farmland Conversion Impact Rating, Fonn AD-I006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Coneluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

o Project not located within a flyway zone. (Review Concluded) 
181 Project located within a flyway zone. 

[81 Project does not have potential to take migratory birds. {Review Coneludedl 
Are project conditions required? 0 Yes (see section V) [81 No (Review Concluded) 

o Project has potential to take migratory birds. 

o Contact made with USFWS 
Are project conditions required? 0 YES (see section V) 0 NO (Review Coneluded) 

Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has 
detennined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other 
fish and wildlife reserves. These detenninations are based on the understanding that the conditions outlined in the Louisiana 
Endangered Species Summary are met. 
CorrespondenCe/Consultation/References: http://pacificflyway.govlDocuments/Mississippi map.pdf 


Reviewer Name: Brandon M. Clark Appllcaut: Orleans Parish School Board 
DisasterlEmergeucylProgram1Project Tide: DR 1603LA / HUlTicane Katrina / Public Assistance Program / EOR094S Gaudet Elementary School 

J. Magnuson-Stevens Fishery Conservation and Management Act 

[8j Project not located in or near Essential Fish Habitat. (Review Concluded) 

o Project located in or near Essential Fish Habitat. 

o Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Project adversely affects Essential Fish Habitat (FEMA determination/USFWSINMFS concurrence on file)
oNOAA Fisheries provided no recommendation(s) (Review Concluded). 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o NOAA Fisheries provided recommendation(s) 






o Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

[8j Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) 

o Project is along or affects WSR 

o Project adversely affects WSR as determined by NPSIUSFS. FEMA cannot (und the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 
o Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 

L. Other Relevant Laws and Environmental Regulations 

II. Compliance Review for Executive Orders 

A. E.O. 11988 -Floodplains 

o No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) 
[8j Located in Floodplain or Effects on FloodplainslFlood levels 

[8j No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 0 Yes (see section V) [8j No (Review Concluded) 

o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). 
o Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain 
environment 


o 8 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: 07118/06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program 08/03nO. 
Per Flood Insurance Rate Map (FIRM) 225203 0 I 05 E, dated 03/01/1984, project is located in Zone 'AO'; areas of 100-yr 
shallow flooding where depths are between one and three feet; average depths of inundation are shown but no flood hazard 
factors are determined. Project is repair ofdamages caused by wind/rain/debris only to pre-disaster footprint and should not 
affect the floodplain. Casey Barefield, FPM. 

Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

[8j No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 

o Located in Wetland or effects Wetland(s) 

o Beneficial Effect on Wetland -(Review Concluded) 
o Possible adverse effect associated with constructing in or near wetland 
o Review completed as part of floodplain review 
o 8 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 






Record of Environmental Consideration 5 


Reviewer Name: Brandon M. Clark Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProjett Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR0945 Gaudet Elementary School 

Comments: None 
Correspondence/Consultation/References: 

C. E.O.12898 -Environmental Justice For Low Income and Minority Populations 
[81 No Low income or minority population in, near or affected by the project -(Review Concluded) 

o Low income or minority population in or near project area 

o No disproportionately high and adverse impact on low income or minority population-(Review Concluded) 
o Disproportionately high or adverse effects on low income or minority population 
Are project conditions required? 0 YES (see section V) 0 NO (Review Coneluded) 


Comments: None 
Correspondence/Consultation/References: 

III. Other Environmental Issues 

Identify other potential environmental concerns in the comment box not clearly falling under a law or 
executive order (see environmental concerns scoping checklist for guidance). 

Comments: None 
Correspondence/Consultation/References: 

IV. Extraordinary Circumstances 

Based on the review of compliance with other environmental laws and Executive Orders, and in 
consideration of other environmental factors, review the project for extraordinary circumstances. 

*A "Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of(ii) which 
should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, 
please explain in comments. Ifno, leave blank. 

Yes 

o (i) Greater scope or size than normally experienced for a particular category of action 
o (ii) Actions with a high level ofpublic controversy 
o (iii) Potential for degradation, even though slight, ofalready existing poor environmental 
conditions; 
o (iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
o (v) Presence of endangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
o (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local 
regulations or standards requiring action or attention; 
o (vii) Actions with the potential to affect special status areas adversely or other critical resources 
such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, 
sole or principal drinking water aquifers; 


o (viii) Potential for adverse effects on health or safety; and 
o (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 
protection ofthe environment. 
o (x) Potential for significant cumulative impact when the proposed action is combined with 


other past, present and reasonably foreseeable future actions, even though the impacts of the 
proposed action may not be significant by themselves. 

Comments: None 
Correspondence/Consultation/References: 


Reviewer Name: Brandon M. Clark Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR094S Gaudet Elementary School 

V. Environmental Review Project Conditions 

Project Conditions: 

I. If during the course ofwork, archaeological artifacts (prehistoric or historic) or human remains are 
discovered, the applicant shall stop work in the vicinity of the discovery and take all reasonable 
measures to avoid or minimize harm to the finds. The applicant shall inform their Public Assistance 
(PA) contacts at FEMA, who will in tum contact FEMA historic preservation staff. The applicant will 
not proceed with work until FEMA historic preservation staff have completed consultation with the 
Louisiana State Historic Preservation Officer (SHPO). In addition, if unmarked graves are present, 
compliance with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is 
required. The applicant shall notify the law enforcement agency of the jurisdiction where the remains 
are located within twenty-four hours of the discovery. The applicant shall also notify FEMA and the 
Louisiana Unmarked Burial Sites Board (call the Louisiana Division of Archeology at 225-342-8170) 
within seventy-two hours of the discovery. Failure to comply with these stipulations may jeopardize 
receipt of FEMA funding. 

Monitoring Requirements: None