Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
Disaster/EmergencylProgram/Projed Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EORIOII Osborne Elementary School 
Modular Classroom 

Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: EORI0l1 Osborne Elementary School I PW 10495 

Project Location: 6701 Curran Blvd, New Orleans Louisiana Orleans Parish 70126 (N30.03343 W90.01511) 


Project Description: Project activities include replacing modular classroom space (3,072 SF). Hazard 
mitigation will be achieved by compliance with codes and standards. 

Documentation Requirements 

D No Documentation Required (Review Concluded) 

D (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) 

rgJ (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 

D Statutorily excluded from NEP A review. (Review Concluded) 
D Programmatic Categorical Exclusion -Category (Review Concluded) 
D Categorical Exclusion -Category


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

Are project conditions required? D Yes (see section V) No (Review Concluded) 
D Environmental Assessment 
D Supplemental Environmental Assessment (Reference EA or PEA in comments) 
rgJ Environmental Impact Statement 

Comments: This project meets the criteria for an alternative arrangement (Permanent Schools) type of project. This project 
has conditions and re uires miti ation under the other EHP laws. 


Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
Disaster/EmergencylProgramlProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR I 0 II Osborne Elementary School 
Modular Classroom 

Reviewer and Approvals 

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

FEMA Environmental Reyiewer. 

Name: Catherine Jones, En . onmental Spec' 
Signature_~---,,_-+--+-+-->..c-______--=-' Date _--=8/:....;,:0=3:...:/2=0=06""--_____=_ 


FEMA Regional Enviro ental Officer or delegated approving officiaL 
Name: Howard R. Bush, ELO 

Signature~~,e= . Date _--=8/---"'0=3/=2=00=6"--___---'


I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

r8J Not type of activity with potential to affect historic properties. (Review Concluded) 
D Applicable executed Programmatic Agreement __Otherwise, conduct standard Section 106 review. 
QActivity meets Programmatic Allowance # ______ 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 

HISTORIC BUILDINGS AND STRUCTURES 
r8J No historic properties that are listed or 45150 years or older in project area. (Review Concluded) 
D Building or structure listed or 45150 years or older in project area and activity not exempt from review. 

D Determination ofNo Historic Properties Affected (FEMA fmdinglSHPO/THPO concurrence on file) 
Are project conditions required? Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmdinglSHPO/THPO concurrence on file) 
D Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. Jfnot, explain in comments 
D No Adverse Effect Determination (FEMA findinglSHPO/THPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA fmdinglSHPO/THPO concurrence on file) 
D Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 
r8J Project affects only previously disturbed ground. (Review Concluded) 
D Project affects undisturbed ground. 

D Project area has no potential for presence of archeological resources 
D Determination ofno historic properties affected (FEMA findinglSHPO/THPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 
D Determination ofhistoric properties affected 
D NR eligible resources not present (FEMA findinglSHPO/THPO concurrence on file). 

Are project conditions required DYes (see section V) D No (Review Concluded) 
D NR eligible resources present in project area. (FEMA fmdingl SHPO/THPO concurrence on 
file) 

D No Adverse Effect Determination. (FEMA findingl SHPO/THPO concurrence on file) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Conduded) 
D Adverse Effect Determination. (FEMA fmdingl SHPO/THPO concurrence on fife) 


Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramlProject Title: DRl603LA I Hurricane Katrina I Public Assistance Program I EOR I 0 11 Osborne Elementary School 
Modular Classroom 

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

Comments: 08/02/2006 -Modular buildings were placed in the mid-60. Catherine Jones, Environmental Specialist. 
812/2006 -Historic review complete: the structures do not meet the SO-year-criterion, nor do they possess the level of 
exceptional importance required by criteria consideration ofthe National Register Guidelines to be considered eligible for 
the National Register ofHistoric Places. Therefore, the proposed work will have no effect on historic properties. Scope of 
work indicates minor ground disturbing activities associated with the demolition and replacement of the modular structures 
within their pre-disaster locations. Upon consultation of SHPO data, there are known archaeological sites within .S miles of 
the project area; however ground disturbance will be minor due to building being elevated on strip foundation piers. 
Demolition must follow the lower impact demolition stipulations & additional protocols which are attached. The 
stipulations and protocols should be explicit in the demolition contract. Failure to comply with these stipulations & 
additional protocols will jeopardize receipt offederal funding. Ifduring the course ofwork, archaeological artifacts 
(prehistoric or historic) or human remains are discovered, the applicant shall stop work in the vicinity ofthe 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's Historic Preservation Staff. The applicant will not proceed with work 
until FEMA's Historic Preservation Staffhas completed consultation with the Louisiana State Historic Preservation Officer 
(SHPO). In addition, ifunmarked 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 ofthe 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 22S-342-8170) within seventy-two 
hours ofthe discovery. Ifthis scope of work and/or location ofthe new buildings change, this project will need to be 
resubmitted for further Section 106 review prior to ground disturbing activities taking place outside of the pre-disaster 
footprint ofthe building. Katherine Zeringue, Historic Preservation Specialist! Archaeologist 

Correspondence/Consultation/References: 

B. Endangered Species Act 

~No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
(Review Concluded) 
D 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? Yes (see section V) D No (Review Concluded)


o 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) NO (Review Concluded) 

IComments: None 

C. Coastal Barrier Resources Act 

~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 3S0S.a.6? (Review Concluded)
D Proposed action not excepted under Section 3S0S.a.6. 


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

Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 


Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
DisasterlEmergeocylProgramlProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EORIOII Osborne Elementary School 
Modular Classroom 

~Project would not affect any waters ofthe U.S. (Review Concluded) 

o Project would affect waters, including wetlands, ofthe U.S. 

o Project exempted as in kind replacement or other exemption. (Review Concluded) 
o Project requires Section 404/401lor Section 9/10 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


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

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) 

~Project is located in a coastal zone area and/or affects the coastal zone 
~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 Concluded 

Comments: FEMA has determined 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 

~Project does not affect, control, or modifY a waterwaylbody of water. (Review Concluded)

o Project affects controls or modifies a waterwaylbody of water. 

o Coordination with USFWS conducted 

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


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

G. Clean Air Act 

~Project will not result in permanent air emissions. (Review Concluded) 

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? YES (see section V) 0 NO (Review Concluded) 

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

H. Farmland Protection Policy Act 

~Project does not affect designated prime or unique farmland. (Review Concluded)

o Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Form AD-l 006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 


Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
Disaster/EmergencylProgramlProjeet Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR I 0 II Osborne Elementary School 
Modular Classroom 

I. Migratory Bird Treaty Act 

D Project not located within a flyway zone. (Review Concluded) 
~Project located within a flyway zone. 
~Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) ~No (Review Concluded)
D Project has potential to take migratory birds. 
D Contact made with USFWS 
Are project conditions required? D YES (see section V) D NO (Review Concluded 

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: htto:lloacificflvwav.e:ov/Documents/Mississiooi mao.odf. 

J. Magnuson-Stevens Fishery Conservation and Management Act 

~Project not located in or near Essential Fish Habitat. (Review Concluded)
D Project located in or near Essential Fish Habitat. 
D Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Are project conditions required? D Yes (see section V) D No (Review Concluded)
D Project adversely affects Essential Fish Habitat (FEMA deteOllinationlUSFWSINMFS concurrence on file) 

D NOAA Fisheries provided no recommendation(s) (Review Concluded). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
NOAA Fisheries provided recommendation(s) 

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

Comments: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

~Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded)
D Project is along or affects WSR 
D Project adversely affects WSR as detennined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 
D Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) 
Are project conditions required? D YES (see section V) D 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 

D No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded)
\8J Located in Floodplain or Effects on FloodplainslFlood levels 
D No adverse effect on floodplain and not adversely affected by the floodplain. (Review Conduded), 
Are project conditions required? 0 Yes (see section V) D No (Review Concluded)
D Beneficial Effect on Floodplain OccupancyNalues (Review Conduded). 


Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
DisasterlEmergencyfProgramfProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR I01 I Osborne Elementary School 
Modular Classroom 

o Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 

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

Comments: 07/28/2006-The City ofNew Orleansl Orleans parish is enrolled in the National Flood Insurance Program 
(NFIP) as of08-03-70. As per Flood Insurance Rate Map (FIRM) panel number 2252030 lISE dated 03-01-84. Project is 
located within a V16 zone, area of IOO-yr coastal flooding with velocity (wave action), base flood elevations and flood 
hazard factors determined. The project is the replacement ofbuilding, equipment and components, as per 44 CFR 9.11 
mitigation or minimization standards must be applied. Where possible, building contents, materials, and equipment 
(mechanical or electrical) must be elevated to or above advisory base flood elevations. In compliance with EO 11988, an 8step 
process was completed and is attached. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior to 
the start ofconstruction activities. Final public notice is to be forwarded to the LAGOHS/OEP and FEMA for inclusion in 
the permanent project files. A Cramer FPM Specialist 

Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

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






Comments: None 
Correspondence/Consultation/References: 

c. E.O. 12898 -Environmental Justice For Low Income and Minority PopUlations 

~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 Concluded) 


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 Exeeutive Orders, and in 
consideration of other environmental factors, review the projed fOI" extraordinary cil"eumstanees. 
Record of Environmental Consideration 6 

08/03/06 


Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 
Disaster/EmergeDcylProgramlProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 10 II Osborne Elementary School 
Modular Classroom 

D 

D 

D 

D 

D 

D 
D 


D 

D 

• 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. If the circumstance can be mitigated, 
please explain in comments. If no, leave blank. 

(i) Greater scope or size than normally experienced for a particular category of action 
(ii) Actions with a high level of public controversy 


(iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; 

(iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
(v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
(vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local 
regulations or standards requiring action or attention; 


(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; 

(viii) Potential for adverse effects on health or safety; and 

(ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 
protection ofthe environment. 
(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 ofthe 
proposed action may not be significant by themselves. 

IComments: None 

v. Environmental Review Project Conditions 

Project Conditions: 

1. Per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, 
building contents, materials, and equipment (mechanical or electrical) must be elevated to 
or above advisory base flood elevations. In compliance with EO 11988, an 8-step process 
was completed and is attached. Per 44 CFR 9.12, applicant must publish a final public 
notice 15 days prior to the start of construction activities. Final public notice is to be 
forwarded to the LAGOHS/OEP and FEMA for inclusion in the permanent project files. 
2. Demolition must follow the lower impact demolition stipulations & additional protocols 
which are attached. The stipulations and protocols should be explicit in the demolition 
contract. Failure to comply with these stipulations & additional protocols will jeopardize 
receipt of federal funding. If during the course of work, 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 (P A) contacts at FEMA, who will in tum 
contact FEMA's Historic Preservation Staff. The applicant will not proceed with work until 
FEMA Historic Preservation staff has completed consultation with the Louisiana State 
Historic Preservation Officer (SHPO). In addition, if unmarked graves are present, 



Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board 

DisasterlEmergencylProgramlProjed Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR I 0 II Osborne Elementary School 

Modular Classroom 

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 of Archeology at 225-342-8170) within seventy-two hours ofthe discovery. Ifthis 
scope of work and/or location of the new buildings change, this project will need to be 
resubmitted for further section 106 review prior to ground disturbing activities taking place 
outside ofthe pre-disaster footprint ofthe building. 

Monitoring Requirements: None