Reviewer Name: Adam Borden, Env. Specialist Project NamtlEnv. Database No: CroSllman Scbool-Modular a.SIIrooms (I) 
FEMA-I603/1607-DR-LA PW#IlS41 
P.risb: Orleans 

Record of Environmental Consideration 


REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -Z006 
See 44 Code ofFederal Regulation Part 10 

Project NameINumber: Crossman School-Modular Classrooms (1) 1PW#12541 
FIPS#071-UFTI3-00 

Project Location: 4407 S Carrollton Ave., New Orleans LA 70119 
Latitude: 29.97156, Longitude: -90.10408 

Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior 
and interior damage to Crossman School-Modular Classrooms (1) of the Orleans Parish School Board. This pw reimburses 
the eligible applicant for replacement ofthe building within the existing footprint. The new building will be replaced 
according to codes and standards upgrades. All work will be performed in a previously disturbed area with no indication of 
nearby waterways or other bodies of water. 

Documentation Requirements 

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) 

~ (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is 
attached to this REC and/or included in project files, as applicable. 

National Environmental Policy Act (NEPAl Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category (Reference PCE in comments) <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) 
~ Environmental Impact Statement 


Comments: This project meets the criteria for the alternative arrangement, permanent school, type of project. This project 
has conditions and re uires miti ation under the other EHP laws. 

Reviewer and Approvals 

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


Specialist 


Signature _£.~-==:"-.J.~:!!!!!:::.~~~::::::__Date 


Revitwer Name: Adam Bordea, Eav. Specialist Project NamtlEav. Oatabase No: Crossmaa School-Modular Classrooms (I) 
FEMA-IAJ/I607-DR-LA PWfll2541 
Parish: Orleans 

FEMA Regional Eovironmeotal Officer or Delegated Approviog Official: 
Name: Howard R. Bush, Environmental Liason Officer 

Signature _~....&-___-==-~...:.___=-zL?~____Date _..;:;.K_-....,;Co{....,;.=0..;:::10:......-_--'


I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act (NHPA) 
181 Not type ofactivity with potential to affect historic properties. 
D Activity meets Programmatic Agreement, December 3, 2004. Appendix A: 


Are project conditions required? D Yes (see Section V) D No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

HISTORIC BUILDINGS AND STRUCTURES 
181 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 fmdinglSHPOIIHPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No <Review Concluded) 
D Determination of Historic Properties Affected (FEMA finding/SHPOffHPO 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 Determination (FEMA findinglSHPOrrHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) D No <Review Concluded) 
D Adverse Effect Determination (FEMA findinglSHPOrrHPO 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) 

ARCHEOLOGICAL RESOURCES 
181 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 of no historic properties affected (FEMA fmdinglSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA findinglSHPOffHPO 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 findinglSHPOffHPO 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 SHPOffHPO concurrence on 
file) 

D No Adverse Effect Determination. (FEMA fmdingl SHPOffHPO concurrence on file) 
Are project conditions required? DYes (see Section V) D No (Review Concluded) 
D Adverse Effect Determination. (FEMA fmdingl SHPOIIHPO concurrence on file) 

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

Comments: Historic review complete: the structures do not meet the 50-year-criterion, nor do they possess the level of 
exceptional importance required by criteria consideration G of the 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 minor ground disturbing activities associated with the demolition and replacement ofthe modular structures 
within their original locations. Upon consultation of SHPO data, there are no known archaeological sites within .5 miles of 

Record ofEnvironmental Consideration (Version 08/04/06) 


the project area. 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 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 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 225-342-8170) within 
seventy-two hours ofthe discovery. Ifthis scope of work and/or the 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 ofthe predisaster 
footprint ofthe building. 
Co"espondence/Consultation/References: NHPA effect determinations made by Katherine Zeringue, FEMA Historic 
Preservation Specialist/Archaeologist 

Revitwer NI ..t: Adl.. Bordta, Eav. Sptc:llUst Projtd NI..tlEav. DltablR No: Crosl..la Sellool-Modular alurOOll.S (I) 
FEMA-I603II607-DR-LA PW#11S41 
Plrbll: OrInDa 

B. Endangered Species Act 
[8l 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) 
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? 0 Yes (see Section V) 0 No (Review Concluded) 


o Likely 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) 

Comments: Project is located in an urban or previously developed area. Neither listed species nor their habitat occur in or 
near this site, thus FEMA fmds there will be no effect to threatened or endangered species. 
Co"espondence/Consultation/References: USFWS emergency consultation provisions determined in letters dated 
September 15,2005 for Katrina. 

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


Comments: Project is not within a CBRA zone. 
Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced 08/04/06. 


D. Clean Water Act 
!8J Project would not affect any waters of the U.S. (Review Concluded) 


o Project would affect waters, including wetlands, of the U.S. 

o Project exempted as in kind replacement or other exemption. (Review Concluded) 
o Project requires Section 404/401/0r 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) 


IComments: No jurisdictional waters of the U.S., including wetlands, occur in or near the project area. 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Crossman Scbool-Modular Classrooms (I) 
FEMA-I603/1607-DR-LA PW#Il541 
Parlsb: Orleans 

Co"espondencelConsultationIRe/erences: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil) queried 
on 08/04/06. 

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)
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>. 
D State administering agency requires consistency review. 
Are project conditions required? D YES (see Section V) D NO <Review Concluded) 

Comments: This project is located within the Louisiana Coastal Management Zone. LA Department of Natural Resources 
(DNR) has determined that receipt of federal assistance 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 1-800-276-4019. 
Co"espondencelConsultationIReferences: LDNR Louisiana Coastal Zone map 2002. 

F. Fish and Wildlife Coordination Act 
181 Project does not affect, control, or modify a waterway/body of water. <Review Concluded)
D Project affects controls or modifies a waterway/body of water. 


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: No streams or water bodies are located in or near the project area. 
Co"espondencelConsultalionIRe/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD queried 08/04/06. 

G. Clean Air Act 
D Project will not result in permanent air emissions. (Review Concluded) 
181 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: This project involves the demolition or renovation of a public structure. Regardless ofthe asbestos content, the 
applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department 
of Environmental Quality (LDEQ) in accordance with the LDEQ "Sixth Amended Declaration of Emergency and 
Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March I, 2006, incorporating the provisions 
of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code 
(LAC) 33.m.5151 and Chapter 27. Should Asbestos Containing Materials (ACMs) be present at the project site, the 
applicant is also responsible for ensuring proper disposal in accordance with the previously referenced administrative 
orders. 
CorrespondencelConsultationIRe/erences: EPA Region 6 Non-attainment Map. 

H. Farmland Protection Policy Act 
181 Project does not affect designated prime or unique farmland. <Review Concluded)
D Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 


D Coordination with Natural Resource Conservation Commission required. 
D Farmland Conversion Impact Rating, Form AD-I 006, completed. 
Are project conditions required? D YES (see section V) D NO <Review Concluded) 

Comments: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No 
prime or unique farmland present. 
CorrespondencelConsultationIRe/erences: National Resource Conservation Service, Web Soil Survey 

I(http://websoilsurveY.nrcs.usda.gov/app/ )referenced 08/04/06. 


Reviewer Nlme: Adlm Borden, Env. Spedilist Project NlmelEnv. Oltlblse No: ero.mlD Sebool-Modular Clissrooms (I) 
FEMA-1603f1607·0R-LA PW#11541 
Plrish: Orlelns 

I. Migratory Bird Treaty Act 

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

181 Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) ~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 Concluded) 

Comments: The site is an existing disturbed area with little value to migratory birds and would not be included in the 
USFWS migratory bird management program. 
Com!spondence/ConsultlltlonlRejerences: USFWS guidance letter dated September 15, 2005 for Katrina 

J. Magnuson-Stevens Fishery Conservation and Management Act 

~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) 
o NOAA 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: Project is not located in or near any surface waters with the potential to affect EFH species. 
Correspondence/ConsultlltionIRejerences: Louisiana Map (htt;p:/Iwwwlamap.doa.louisiana.govD referenced 08104/06. 

K. Wild and Scenic Rivers Act 

~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 NPS/uSFS. FEMA cannot fund the action. 
(NPS/uSFS/uSFWSIBLM consultation on file) (Review Concluded) 
o Project does not adversely affect WSR. (NPS/uSFS/uSFWSIBLM consultation on file) 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/ConsultlltionlRe/erences: National Wild and Scenic Rivers htt;p:llwww.nps.gov/rivers/wildriverslist.html. 
referenced 08104/06 . 


L. Other Relevant Laws and Environmental Re ulations 


State Hazardous Materials and Solid Waste Laws 
Comments: -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana 
parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the 
Baptist, 8t. Tammany, Tangipahoa and Washington are under quarantine. The movement of wood 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 of the Louisiana Department of Agriculture 
and forestry or his designee(s). 

-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. Failure to comply with applicable legal requirements in debris 
collection andlor disposal operations will jeopardize federal funding. The clean-up or restoration/repair ofsites damaged as 
a result ofsuch operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a 
determination of ineligibility is made. 

Reviewer Name: Adam Borden, Env. Speclali.t Project NamelEav. Database No: Croumaa Scbool-Modular aallrooms (1) 
FEMA·l603Il607·DR·LA PW"12541 
Parl.b: Orleans 

-Lead-Based Paint -this project involves the demolition ofa public structure that may contain surfaces coated with LeadBased 
Paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating 
LBP shall comply with applicable provisions of 29 CFR parts 1910 and 1926 (OSHA -worker safety), and 40 CFR 260 
through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with 
the Louisiana Department ofEnvironmental Quality for abatement activities and is also responsible for ensuring proper 
dis sal in accordance with the reviousl referenced re ations. 

II. Compliance Review for Executive Orders 
A. E.O.11988 -Floodplains 
D No Effect on FloodplainsIFlood levels and project outside Floodplain -<Review Concluded) 
[81 Located in Floodplain or Effects on FloodplainsIFlood levels 


D No adverse effect on floodplain and not adversely affected by the floodplain. <Review Concluded), 

Are project conditions required? D Yes (see Section V) D No <Review Concluded)

D Beneficial Effect on Floodplain OccupancyNalues <Review Concluded).

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

environment 
[81 8 Step Process Complete -documentation on file 
Are project conditions required? [81 YES (see Section V) D NO <Review Concluded) 

Comments: The site is located in Zone A4. 

htt,p:llstore.msc.fema.gov/webapplwcslstoreslservletlFemaWelcomeView?storeld= 1 000 1 &catalogld= I 000 I &langId=-l , 
The city ofNew Orleans/Orleans Parish is enrolled in the National Flood Insurance Program (NFIP) as of 8/311970. Per 
Flood Insurance Rate Map (FIRM) panel number 2252030095E dated 3/111984, project is located within an "A4" zone, 
area of 100-yr flooding, base flood elevations and flood hazard factors as determined. Project is replacement ofmodular 
classroom building. In compliance with EO 11988, a completed 8-step process showing considered alternatives is attached. 
Applicant is required to coordinate with local floodplain administrator regarding floodplain permit(s) prior to the start of 
any activities. Applicant is responsible for meeting all requirements ofthe permit(s). All coordination pertaining to these 
permit(s), should be documented to the local floodplain administrator and copies provided to LA GOHSEP and FEMA as 
part ofthe permanent project files. Per 44 CFR 9.11 (d)(9), the replacement ofbuilding contents, materials and equipment 
should be, where possible, wet or dry-proofed, elevated, or relocated to or above the Advisory Base Flood Elevation 
(ABFE) per the ABFE maps. Per 44 CFR 9.12, applicant must publish a fmal public notice 15 days prior to the start of 
construction activities. Final public notice is to be forwarded to the LA GOHSEP and FEMA for inclusion in the permanent 
project files. K. Roof, Floodplain Management Specialist. 

Correspondence/ConsultationIRe!erences: FEMA Flood Insurance Rate Map, Community Panel No. # 2252030095E 
dated 311/1984 

B. E.O.11990 -Wetlands 
[81 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 
D Located in Wetland or effects Wetland(s)


D Beneficial Effect on Wetland -<Review Concluded)

D Possible adverse effect associated with constructing in or near wetland 
D Review completed as part offloodplain review 
D 8 Step Process Complete -documentation on file 


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

Comments: No wetlands were observed during site visit or determined to be present by checking the USFWS National 
Wetlands Inventory (NWI) maps. 
Correspondence/ConsultatlonIRe!erences: USFWS NWI map accessed on~line 
(htt,p:llwetlandstws.er.usgs.gov/wtlndsllaunch.html) 08/04/06. 



Reviewer Name: Adam Borden, Env. Specialist Project NamtJEnv. Database No: Crossman Scbool-Modular Classrooms (I) 
FEMA-I603/1607-DR-LA PW#I2541 
Parisb: Orleans 

C. E.O. 12898 -Environmental Justice for Low Income and Minority Populations 

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

181 Low income or minority population in or near project area 
181 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: The percent populations of70119 are: 72.1% Black, 23.3% White, and 5.6% Hispanic. The median household 
income in 1999 was $ 21,297 and 29.2% of families are below poverty level. 
CorrespondenceiConsultatlonIRe/erences: U.S. Census bureau 2000 data at http://factfinder.census.gov, referenced 
08/04/06. 


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). 

State Hazardous Materials and Solid Waste Laws 
Comments: -In accordance with the Fonnosan Tennite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana 
parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the 
Baptist, St. 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 of the Louisiana Department ofAgriculture 
and forestry or his designee(s). 

-Removal and disposal of debris containing household hazardous waste and certain categories of liquid wastes must be 
perfonned 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, efc's 
(refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous 
debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris 
collection and/or disposal operations will jeopardize federal funding. The clean-up or restoration/repair of sites damaged as 
a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a 
detennination of ineligibility is made. 

-Lead-Based Paint -this project involves the demolition of a public structure that may contain surfaces coated with LeadBased 
Paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating 
LBP shall comply with applicable provisions of29 CFR parts 1910 and 1926 (OSHA -worker safety), and 40 CFR 260 
through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with 
the Louisiana Department ofEnvironmental Quality for abatement activities and is also responsible for ensuring proper 
disposal in accordance with the previously referenced regulations. 

CorresoondenceiConsultationIReference: 

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

Yes 
D (i) Greater scope or size than nonnally experienced for a particular category of action 
Record of Environmental Consideration (Version 08/04/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamtlEnv. Database No: Crossman Stbool-Modular aassrooms (I) 
FEMA-I603/1607-DR-LA PW#ll541 
Parish: Orleans 

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 ofunproven 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 ofthe 
proposed action may not be significant by themselves. 


IComments: None 

V. Environmental Review Project Conditions 

Project Conditions: 

The following conditions apply as a condition of FEMA funding reimbursement: 

• This project involves the demolition or renovation ofa public structure. Regardless of the asbestos content, the 
applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana 
Department of Environmental Quality (LDEQ) in accordance with the LDEQ "Fifth Amended Declaration of 
Emergency and Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March I, 2006, 
incorporating the provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 
the Louisiana Administrative Code (LAC) 33.III.5151 and Chapter 27. Should Asbestos Containing Materials 
(ACMs) be present at the project site, the applicant is also responsible for ensuring proper disposal in accordance 
with the previously referenced administrative orders. 
• In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes of 
Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, st. Charles, St. John the 
Baptist, St. 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 of Agriculture and forestry or his designee(s). 
• Removal and disposal ofdebris 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. Failure to comply with 
applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The 
clean-up or restoration/repair of sites damaged as a result of such operations are ineligible for federal funding. 
Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. 
• Lead-Based Paint -this project involves the demolition of a public structure that may contain surfaces coated with 
Lead-Based Paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise 
concentrating LBP shall comply with applicable provisions of 29 CFR parts 1910 and 1926 (OSHA -worker 
safety), and 40 CFR 260 through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that 
project activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities 
and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. 
• 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 & 



Reviewer Nlme: Adlm Borden, Env. Spedllist Project NlmelEnv. Dltlblse No: Crossmla Scbool-Modullr Clusrooms (I) 
FEMA-I603/1607-DR-LA PWIII2S41 
Plrisb: Oriel as 

additional protocols will jeopardize receipt of federal funding. 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 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 
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. Ifthis scope of 
work and/or the footprintllocation ofthe new building changes, 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. 

• Applicant is required to coordinate with local floodplain administrator regarding floodplain permit(s) prior to the 
start of any activities. Applicant is responsible for meeting all requirements of the permit(s). All coordination 
pertaining to these permit(s), should be documented to the local floodplain administrator and copies provided to 
LA GOHSEP and FEMA as part of the permanent project files. Per 44 CFR 9.11 (d)(9), the replacement of 
building contents, materials and equipment should be, where possible, wet or dry-proofed, elevated, or relocated to 
or above the Advisory Base Flood Elevation (ABFE) per the ABFE maps. 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 LA GOHSEP and FEMA for inclusion in the permanent project files. K. Roof, Floodplain 
Management Specialist.