Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: EOR1081 Prince of Peace Lutheran School/ PW 11049 

Project Location: 9301 Chef Menteur Highway, New Orleans, Orleans Parish, Louisiana 70127 
(N30.01647, W89.97915) 

Project Description: The project is the repair to the Prince of Peace Lutheran School in order to return 
it to pre-disaster condition. In addition this project includes a Hazard Mitigation Proposal to install 
drywall in two sections with a caulked gap (covered by chair rail moulding) sufficient to eliminate 
wicking, replace drywall vapor barrier and fiberglass insulation with a drainage fabric and sprayed 
urethane insulation to eliminate mold growth (within 3500 SF of wall cavity), replace VCT flooring 
with a polyurethane floor system to provide wet flood proofing for 3,182 SF of gym floor, replace VCT 
flooring with a polyurethane floor system to provide wet flood proofing for 1,650 SF of kindergarten 
classroom floors, replace VCT flooring with an epoxy/colored quartz composition floor system to 
provide wet flood proofing of 8,000 SF of floor, replace VCT flooring with an epoxy/colored quartz 
composition floor system to provide wet flood proofing of2,300 SF of floor, elevate two fused 
disconnects one foot above ABFE to provide dry flood proofing of electrical gear, elevate four air 
conditioning units by adding 102 SF ofbrick to the wall to support a concrete platform 3 feet above 
grade. 

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) 

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

National Environmental Policy Act (NEP A) Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 

D Programmatic Categorical Exclusion -Category xv and xvi (Reference PCE in comments) 
(Review Concluded) 

o Categorical Exclusion -CategoryD 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) D No (Review Concluded) 
D Environmental Assessment 

o Supplemental Environmental Assessment (Reference EA or PEA in comments) 

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[gJ Environmental Impact Statement 

IComments: This project meets the criteria for an Alternate Arrangement Permanent Schools type ofproject. 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Nicole Poret 

Signature \.?~T~ . Date _7...<.-.:..1_,~--,--r/_CO(p_-.-. 

FEMA Regional Environmental Officer or delegated approving official. 
Name: William Fagan 

Signature ~ 


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

A. National Historic Preservation Act 

o Not type ofactivity with potential to affect historic properties. (Review Concluded) 
~Applicable executed Programmatic Agreement December 3, 2004 Otherwise, conduct standard Section 106 review. 


~Activity meets Programmatic Allowance 
Are project conditions required? 0 Yes (see section V) ~No (Review Concluded) 


HISTORIC BUILDINGS AND STRUCTURES 

o No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) 
~Building or structure listed or 45150 years or older in project area and activity not exempt from review. 

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

o Determination ofHistoric Properties Affected (FEMA findingiSHPOrrHPO 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 
o No Adverse Effect Determination (FEMA fmdingiSHPOrrHPO concurrence on file). 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Adverse Effect Determination (FEMA findinglSHPOrrHPO concurrence on file)


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

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

o Project affects undisturbed ground. 

o Project area has no potential for presence ofarcheological resources 
o Determination ofno historic properties affected (FEMA findingiSHPOrrHPO concurrence or 
consultation on file). (Review Concluded) 


o Project area has potential for presence of archeological resources 
o Determination ofno historic properties affected (FEMA findingiSHPOrrHPO concurrence on file) 
Are project conditions required 0 Yes (see section V) D No (Review Concluded) 
o Determination of historic properties affected 






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D NR eligible resources not present (FEMA fmding!SHPOITHPO concurrence on file). 

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

D No Adverse Effect Detennination. (FEMA finding! SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Detennination. (FEMA finding! SHPOITHPO concurrence on file) 

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

Comments: This scope of work has been reviewed and meets the criteria in Appendix A, Programmatic Allowances, Items 
(I)(E), (II) (A) (I, 2, & 4), (II) (B) (I), (II) (C) (I), (II) (D) (I), (II) (E) (I), (II) (H) and (IX) (A) ofFEMA's Programmatic 
Agreement (PA) dated December 3, 2004. In accordance with the PA, FEMA is not required to detennine the national 
register eligibility ofproperties where work perfonned meets the Appendix A criteria. All ground disturbing activities being 
perfonned in previously disturbed or archaeologically surveyed areas do not require Section 106 review. In keeping with the 
stipulations ofthe PA, all proposed repair activities should be done in-kind to match existing materials and fonn this 
concludes the Section 106 review for this project. 
Correspondence/Consultation/References: Chelsea Klein, Historic Preservation Specialist 

B. Endangered Species Act 

t8I 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? 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 Fonnal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: 
Correspondence/Consultation/References: Endangered Species summary for USFWS service consultation, letter to Don 
Fairley from USFWS dated Septemberl 5,2005 

C. Coastal Barrier Resources Act 

t8I 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 detenninationlUSFWS 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: 
Correspondence/Consultation/References: FIRM Map 2255203011 5E, dated 03/01/1984 


D. Clean Water Act 

t8I Project would not affect any waters ofthe U.S. (Review Concluded) 
D Project would affect waters, including wetlands, ofthe U.S. 

Record of Environmental Consideration (07/1112006) 3 07111/06 

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

D Project requires Section 404/401l0r Section 9/10 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
Are project conditions required? D YES (see section V) t'8l NO <Review Concluded) 

Comments: 
Correspondence/Consultation/References: Damage description and scope ofwork from the Project Worksheet. 


E. Coastal Zone Management Act 

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

t'8l Project is located in a coastal zone area andlor affects the coastal zone 
D State administering agency does not require consistency review. (Review Concluded). 
t'8l State administering agency requires consistency review. 

Are project conditions required? t'8l YES (see section V) D NO (Review Concluded) 

Comments: This project is located within the Louisiana Coastal Management Zone. LA Department ofNatural 
Resources has determined that receipt of federal funding is consistent with the Louisiana coastal resource program. 
Projects within the coastal zone may still require a Coastal Use Permit or other authorization from DNR. Projects 
may be coordinated by contacting LA DNR at 1-800-267-4019. 

Correspondence/Consultation/References: Firm Panel Number 22051C0225E, dated 03123195. 

F. Fish and Wildlife Coordination Act 

t'8l Project does not affect, control, or modifY a waterwaylbody of water. (Review Concluded)
D Project affects, controls or modifies a waterwaylbody ofwater. 

D Coordination with USFWS conducted 
D No Recommendations offered by USFWS. (Review Concluded)
D Recommendations provided by USFWS. 


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

Comments: 
Correspondence/Consultation/References: Damage description and scope ofwork from the Project Worksheet. 


G. Clean Air Act 

t'8l Project will not result in permanent air emissions. (Review Concluded) 
D Project is located in an attainment area. (Review Concluded) 
D Project is located in a non-attainment area. 


D Coordination required with applicable state administering agency. 

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

Comments: 
Correspondence/Consultation/References: Damage description and scope ofwork from the Project Worksheet. 


H. Farmland Protection Policy Act 

t'8l Project does not affect designated prime or unique farmland. <Review Concluded)
D Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 
D Coordination with Natural Resource Conservation Commission required. 
D Farmland Conversion Impact Rating, Form AD-I006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 


Comments: Project is located in the city ofNew Orleans. 
Correspondence/Consultation/References: http://wwwlamap.doa.louisiana.gov/ 

I. Migratory Bird Treaty Act 

D Project not located within a flyway zone. (Review Concluded) 
[8J Project located within a flyway zone. 
[8J Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) [8J No (Review Concluded)
D Project has potential to take migratory birds. 
D Contact made with USFWS 
Are project conditions required? IIItYES (see section V) fit'NO (Review Concluded) 

Comments: 
Correspondence/Consultation/References: http://library.fws.govlPubs/Mississippi Flywaymap.pdf 


J. Magnuson-Stevens Fishery Conservation and Management Act 

[8J 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 determination/USFWSINMFS 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) 
D 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: 
Correspondence/Consultation/References: http://www.nmfs.noaa.govlhabitatihabitatprotection/efhl 


K. Wild and Scenic Rivers Act 

[8J 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 determined 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: 
Correspondence/Consultation/References: Damage description and scope of work from Project Worksheet; 
http://wwwlamap.doa.louisiana.gov/ 


L. Other Relevant Laws and Environmental Re ulations 


Identify relevant law or regulations, resolution and any consultation/references 


II. Compliance Review for Executive Orders 

A. E.O. 11988 -Floodplains 

o No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded)
IZl Located in Floodplain or Effects on Floodplains/Flood levels 
IZl No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 

Are project conditions required? D Yes (see section V) [8] No (Review Concluded) 
D Beneficial Effect on Floodplain OccupancyNalues (Review Concluded), 


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

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

Comments: The city of New Orleans and Orleans parish enrolled in the National Flood Insurance Program (NFIP) 
08/03/1970. Per Flood Insurance Rate Map (FIRM) 225203 0115E, dated 03/0111984, project is located in zone "A4", area 
of IOO-year flood; base flood elevations and flood hazard factors determined. Project is for building repairs including 
mechanical, electrical, and plumbing components. Hazard mitigation proposals attached. Applicant shall follow all 
applicable local, state and federal laws, regulations and requirements. In compliance with E.O. 11988, an 8-step process has 
been completed and has been sent to data entry for attachment. Alternatives have been considered and are listed in step 3, 
alternative 3. Per 44 CFR 9.1 I (d)(9), for the replacement of building contents, materials, and equipment, where possible, 
the building shall be disaster proofed and/or such future losses shall be eliminated by relocation ofthese building contents, 
materials, and equipment outside or above the advisory base floodplain. Per 44 CFR 9.12, applicant must publish a fmal 
public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOSHEP 
and FEMA for inclusion in the permanent project files. 

Correspondence/Consultation/References: Dana Mehlman, Environmental Specialist 

B. E.O. 11990 -Wetlands 

IZl No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded)

D Located in Wetland or effects Wedand(s) 

D Beneficial Effect on Wetland -(Review Concluded) 

D Possible adverse effect associated with constructing in or near wetland 

D Review completed as part offloodp lain review 

D 8 Step Process Complete -documentation on file 

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

Comments: 
Correspondence/Consultation/References: http://wwwlamap.doa.louisiana.gov/, damage description and scope ofwork 


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

IZl No Low income or minority population in, near or affected by the project -(Review Concluded) 

D Low income or minority population in or near project area 
D No disproportionately high and adverse impact on low income or minority population-(Review Concluded) 
D Disproportionately high or adverse effects on low income or minority population 

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

Comments: 28.1% Caucasian, 67.3% African American, 3.1% Hispanic, 27.9% Individuals below poverty level. 
CorrespondenCe/Consultation/References: http://factfinder.census.govlhome/saff/main.html 


III. Other Environmental Issues 

Identify otber potential environmental concerns in tbe comment box not clearly falling under a law or 
executive order (see environmental concerns scoping cbecklist for guidance). 

Resource Conservation and Recovery Act (RCRA) 

Comments: Unusable equipment, debris and material shall be disposed of in an approved manner and location. In the event 
significant items (or evidence thereof) are discovered during implementation ofthe project applicant shall handle, manage, 
and dispose ofpetroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the 
satisfaction ofthe governing local, state and federal agencies. 
Correspondence/Consultation/References: Damage description and scope of work from the Project Worksheet. 


IV. Extraordinary Circumstances 

Based on tbe review of compliance witb otber environmental laws and Executive Orders, and in 
consideration ofotber environmental factors, review tbe 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. If no, leave blank. 

Yes 

o (i) Greater scope or size than normally experienced for a particular category ofaction 
o (ii) Actions with a high level of public controversy 
o (iii) Potential for degradation, even though slight, of already 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 ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
o (vi) Presence of hazardous 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 of the 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 ofthe 
proposed action may not be significant by themselves. 

IComments: 

V. Environmental Review Project Conditions 

General comments: 
Project Conditions: 

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I) In compliance with E.O. 11988, an 8-step process has been completed and has been sent to data entry for attachment. 
Alternatives have been considered and are listed in step 3, alternative 3. Per 44 CFR 9.1 1 (d)(9), for the replacement of 
building contents, materials, and equipment, where possible, the building shall be disaster proofed and/or such future losses 
shall be eliminated by relocation of these building contents, materials, and equipment outside or above the advisory base 
floodplain. 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 LA GOSHEP and FEMA for inclusion in the permanent project files. 

2) This project is located within the Louisiana Coastal Management Zone. LA Department of Natural Resources has 
determined that receipt offederal funding is consistent with the Louisiana coastal resource program. Projects within the 
coastal zone may still require a Coastal Use Permit or other authorization from DNR. Projects may be coordinated by 
contacting LA DNR at 1-800-267-4019. 

3) Unusable equipment, debris and material shall be disposed of in an approved manner and location. In the event 
significant items (or evidence thereof) are discovered during implementation of the project applicant shall handle, manage, 
and dispose of petroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the 
satisfaction of the governing local, state and federal agencies.