Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProject Title: DRI603LA! Hurricane Katrina lPublic Assistance ProgramlEOR 15921.M. Augustine Middle 
Building A 

Record of Environmental Consideration 


See 44 Code ofFederal Regulation Part 10. 

Project Name/Number: EOR 1592 I.M. Augustine Middle School-Building A / PW 12434 

Project Location: 425 S. Broad Street, New Orleans, Louisiana, Orleans Parish 70119 
(N29.96233, W-90.09045) 

Project Description: Project activities include replacing 39,345 SF ofplumbing system (ground 
floor), 39,345 SF of mechanical HV AC units (first floor only), and 39,345 SF ofelectrical system 
(ground floor, including lights). Replace (2) 3070 flush double exterior wood doors (auditorium), (2) 
3070 flush double interior wood doors (auditorium), 124 LF of 6" wood base (auditorium stage), and 
334 SY ofstage drapes (auditorium stage). Hazard Mitigation will be achieved by compliance with 
codes and standards and good construction practices. 

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) 

C8J (Long version) All applicable laws and executive orders were reviewed. Additional information for 
compliance is attached to this REC. 

National Environmental Policy Act (NEPAl Determination 

D Statutorily excluded from NEPA 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) D No (Review Concluded) 
D Environmental Assessment 
D Supplemental Environmental Assessment (Reference EA or PEA in comments) 
C8J Environmental Impact Statement 

Comments: Although this project would have qualified as a CATEX (XV) under 44 CFR Part 10.8 (D) (2), this project 

meets the defmition ofCritical Infrastructure (Pennanent Schools) under the Alternative Arrangements for NEPA 

Compliance. This project has conditions and requires mitigation under the other Environmental and Historic Preservation 

(EHP) Laws, which are listed under the NEPA Level ofEnvironmental Review in the Project Worksheet. Any changes to 

this approved Scope ofWork will require submission to, and evaluation and approval by, the state and FEMA prior to 

initiation ofany work, for compliance with the National Environmental Policy Act. The applicant is required to obtain and 

comply with all local, state and federal pennits and requirements. Non-compliance with the requirements noted above may 
jeopardize the receipt offederal funding. 


Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
DisasterlEmergency!Program!Project Title: DR1603LA / Hurricane Katrina !Public Assistance Program/EOR 1592 I.M. Augustine MiddleBuilding 
A 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 

Name: June R. 
Signature:_~:lt:::1&~-:..AL...,~~~~..-!.~_----!' Date _~9/=2=6/,-",O=6____---=-

FEMAReg' cer or delegated approving official. 
Name: Ho d R. Bush, ELO 

Signature ~r:I3 . Date _---"9:.:..:/2~6:::../0~6~___--'


~ 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

D Not type of activity with potential to affect historic properties. (Review Concluded) 

[8j Applicable executed Programmatic Agreement. Otherwise, conduct standard Section 106 review. 
D Activity meets Programmatic Allowance, Appendix A, Section II (BI, B2, A2, AI, CI, H, D2, I-D, & C2). 
Are project conditions required? [8j Yes (see Section V) D No (Review Concluded) 

HISTORIC BUILDINGS AND STRUCTURES 
D No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) 
D Building or structure listed or 45/50 years or older in project area and activity not exempt from review. 

D Detennination ofNo Historic Properties Affected (FEMA findingiSHPOfTHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Detennination of Historic Properties Affected (FEMA findingiSHPOfTHPO concurrence on file) 
D Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. Ifnot, explain in comments 
D No Adverse Effect Detennination (FEMA fmdingiSHPOfTHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Detennination (FEMA findingiSHPOITHPO 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 
[8j 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 Detennination ofno historic properties affected (FEMA fmdingiSHPO/THPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence of archeological resources 
D Detennination of no historic properties affected (FEMA fmdingiSHPO/THPO concurrence on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 
D Detennination of historic properties affected 
D NR eligible resources not present (FEMA findingiSHPO/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 findingl SHPO/THPO concurrence on 
file) 

D No Adverse Effect Detennination. (FEMA fmdingl SHPO/THPO concurrence on file) 
Record of Environmental Consideration 2 09/26/06 


Reviewer Name: June R. Griffin Applieant: Orleans Parish School Board 
DisasterlEmergeney/ProgramiProject Title: DRI603LA I Hurricane Katrina /Public Assistance Program/EOR 1592 I.M. Augustine MiddleBuilding 
A 

Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 

o Adverse Effect Determination. (FEMA finding! SHPOITHPO concurrence on file) 

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

Comments: 09125/2006-Cleaning of historic building materials, systems and finishes must be executed in accord with the 
guidance contained in the U.S. Department of the Interior, NPS, Preservation Brief No. 6, dangers of abrasive cleaning to 
historic buildings, (see http://www.cr.nps.govlhpsltpslbriefslbrief06.htm). Requirements include identification ofmaterials 
to be cleaned, protection of materials not to be cleaned, identification ofgentlest means of cleaning possible and testing of 
cleaning means and methods. Work is to be executed by qualified workers, with documented successful experience working 
with historic building materials. Abrasive methods of cleaning are prohibited including: power washing, pressure washing 
and blasting, unless under the supervision of a qualified Building Conservator or Historical Architect. Washing with 
potable water, non-ionic detergent, scrubbing with natural bristle brushes and rinsing with potable water is acceptable for 
most historic building materials. Other methods may be acceptable when specified by a qualified Historical Architect (36 
CFR Part 61). Failure to comply with these stipulations may jeopardize receipt ofFEMA funding. -V. Gomez, Historic 
Preservation Specialist. 
9/25/2006 -FEMA's Programmatic Agreement (PA), dated December 3, 2004, provides for expedited project review under 
Section 106 of the National Historic Preservation Act (NHPA). The scope ofwork as submitted in this PW has been 
reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section {II-BI, II-B2, II-A2, II-AI, 1ICl, 
II-H, II-D2, I-D, II-C2}, of the document. In accordance with the PA, FEMA is not required to submit projects to the 
State Historic Preservation Officer (SHPO) for review where the work performed meets these allowances. This concludes 
the Section 106 review for this project in keeping with the stipulations ofthe PA all proposed repair activities should be 
done in-kind to match existing materials and form. Any change to the approved Scope of Work will require resubmission 
for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt of federal 
funding. V. Gomez, Historic Preservation Specialist 
Correspondence/Consultation/References: 

B. Endangered Species Act 

[8J No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review 
Concluded)

o Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. 

o No effect to species or designated critical habitat (See comments for justification) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
oMay affect, but not likely to adversely affect species or designated critical habitat (FEMA 


determinationlUSFWSINMFS concurrence on file) (Review Concluded) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 


oLikely to adversely affect species or designated critical habitat 

o Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

IComments: None 

C. Coastal Barrier Resources Act 

[8J Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded). 

o Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 
file) 

o Proposed action an exception under Section 3505.a.6? (Review Concluded) 
oProposed action not excepted under Section 3505.a.6. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 


Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProjeet Title: DR 1603LA I Hurricane Katrina /Public Assistance ProgramlEOR 1592 I.M. Augustine Middle Building 
A 

D. Clean Water Act 

[8J 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 404/40 lIor Section 9/10 (Rivers and Harbors Act) pennit, including qualification 
under Nationwide Pennits. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: Project is not in or adjacent to any waterways ofthe U.S. 
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) 

[8J Project is located in a coastal zone area andlor affects the coastal zone 
[8J State administering agency does not require consistency review. <Review Concluded). 

oState administering agency requires consistency review. 
Are project conditions required? 0 YES (see section V) 0 NO <Review Concluded) 

Comments: This project is located within the Louisiana Coastal Management Zone. La DNR has detennined that 
receipt offederal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the Coastal 
Zone may still require a Coastal Use Pennit or other authorization from DNR. Projects may be coordinated by 
contacting LA DNR at 1-800-276-4019. Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

[8J Project does not affect, control, or modify a waterwaylbody ofwater. (Review Concluded) 

o Project affects, controls or modifies a waterwaylbody ofwater. 

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 ofthe U.S. 
Correspondence/Consultation/References: 

G. Clean Air Act 

[8J Project will not result in pennanent 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? 0 YES (see section V) 0 NO (Review Concluded) 

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

H. Farmland Protection Policy Act 

[8J 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, Fonn AD-1006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
DisasterlEmergency/Program/Project Title: DR1603LA I Hurricane Katrina /Public Assistance ProgramlEOR 1592 I.M. Augustine Middle 
Building A 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

o Project not located within a flyway zone. (Review Concluded)
t8l Project located within a flyway zone. 

t8l Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) t8l No (Review Concluded)

oProject has potential to take migratory birds 

o Contact made with USFWS 
Are project conditions required? 0 YES (see section V) 0 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: http://pacificflyw~ov/Documents/Mississippi map.pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

t8l 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 determinationlUSFWSINMFS 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 

t8l Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) 

o Project is along or affects WSR 

oProject adversely affects WSR as determined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 
oProject 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: 


Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina lPublic Assistance ProgramlEOR 1592 I.M. Augustine MiddleBuilding 
A 

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)
t8J Located in Floodplain or Effects on FloodplainslFlood levels 

o No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded)
t8J Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain 
environment 


t8J 8 Step Process Complete -documentation on file 
Are project conditions required? t8J YES (see section V) 0 NO (Review Concluded) 

Comments: 09119/2006. The City of New Orleans/Orleans Parish enrolled in the National Flood Insurance 
Program (NFIP) as of 8/3170. As determined per Flood Insurance Rate Map (FIRM) Panel Number 
2252030160E, dated 03-01-84. Facility is located within an "A4" Zone, area of 100-yr flooding, Base Flood 
Elevations and Flood Hazard Factors. The Project is repair ofa building and replacement of 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 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. A. Cramer FPM Specialist. Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

t8J 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) 






Comments: None 
Correspondence/Consultation/References: 

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

t8J 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: 


Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
DisasterlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina !Public Assistance ProgramlEOR 1592 I.M. Augustine MiddleBuilding 
A 

III. Other Environmental Issues 

Identify otber 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 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. Ifno, leave blank. 

Yes 

o (0 Greater scope or size than normally experienced for a particular category of action 
o (ii) Actions with a high level of public 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 ofendangered 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 
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: 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. 

Record ofEnvironmental Consideration 7 


Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board 
Disaster/EmergencylProgramlProject Title: DR1603LA I Hurricane Katrina !Public Assistance ProgramlEOR 1592 I.M. Augustine MiddleBuilding 
A 

2. Removal and disposal of debris containing household hazardous waste and certain categories of 
liquid wastes must be performed in accordance with all applicable federal and state laws, 
regulations, executive orders and guidelines. Lac Title 33 Part VII requires that specified items, 
including lead acid batteries, used oil filters, used motor oil, scrap tires, CFC's (refrigerants), 
radioactive waste or regulated infectious wastes must be segregated from and excluded from 
non-hazardous debris collection, staging, processing and disposal sites. 
3. In accordance with the Formosan Termite Initiative Act, (LA. R.8. 3:3391.1 thru 3391.13) the 
Louisiana Parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, 


81. Bernard, 81. Charles, 8t. John the Baptist, 8t. Tammany, Tangipahoa and Washington are 
under quarantine. The movement ofwood or cellulose material, temporary housing or 
architectural components (e.g. beams, doors and other wood salvaged from a structure) may not 
leave the quarantined parishes without written authorization from the commissioner ofthe 
Louisiana Department ofAgriculture and Forestry or his designee(s). 

Monitoring Requirements: None