Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergeacylProgramlProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I E0R2131 Fannie C Williams Middle 
School-Library Building-Permanent Repairs. 

Record of Environntental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: Fannie C Williams Middle School-Library Building-Pennanent Repairs / 
PW 13114 

Project Location: 11755 Dwyer Road, New Orleans, Louisiana, Orleans Parish, 70128 (N30.02969, 
W-89.94919) 

Project Description: Project activities include replacing aluminum flashing; cleaning and high 
pressure washing exterior brick walls and concrete floors; surface preparation and painting CMU walls; 
cleaning and painting metal door frames, metal book shelves and aluminum window frames; removing 
and replacing fiberglass insulation, gypsum wallboard, suspended ceilings, vinyl composition tiles, 
cove base, commercial doors, wood doors, door hardware, wire glass, casework, cabinets, sinks, 
chalkboards, bulletin boards, water cooler, switchboards, main circuit breaker, and blinds; and painting 
gypsum wallboards and doors. Some mitigation will be achieved by compliance with current codes 
and standards and by good construction practices. 

Documentation Reguirements 

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) 

I:8J (Long version) All applicable laws and executive orders were reviewed. Additional infonnation 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) 
I:8J Environmental Impact Statement 

Comments: This project meets the criteria for an Alternative Arrangement (Permanent Schools) type ofproject. 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 
of work will require submission to, and evaluation and approval by, the state and FEMA prior to initiation ofany work, for 

08/29/06Record of Environmental Consideration 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DlnsterlEmergencylProgramlProjed Title: DR I 603 LA I Hurricane Katrina I Public Assistance Program I EORll31 Fannie C Williams Middle 
School.Library Building-Permanent Repairs. 

compliance with the National Environmental Policy Act. The applicant is required to obtain and comply with all local, state 
and federal permits and requirements. Non-compliance with the requirements noted above may jeopardize the receipt of 
federal funding. 

Reviewer and Approvals 

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

Name: Letha 
Signature-"-~=-_-=...;.......;_"""",,,.........=-=--___.....:.. Date _-..::<.O=8/..=2=9/..=2.;::;..OO:..;:6"--____----=. 


FEMA Regional Environmental Officer or delegated approving official. 
Name: Howard R. Bush, ELO 

Signature ~~--T .Date _-..::<.O=8/..=2=9/..=2.;::;..OO:..;:6"--___~----=


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

A. National Historic Preservation Act 

t8I Not type ofactivity with potential to affect historic properties. (Review Concluded) 

D Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. 
D Activity meets Programmatic Allowance # ___ 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 

HISTORIC BUILDINGS AND STRUCTURES 
t8I 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 findingiSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA findingiSHPOffHPO concurrence on file) 
D Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. If not, explain in comments 
D No Adverse Effect Determination (FEMA fmdingiSHPOffHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA fmdingiSHPOffHPO 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 
t8I Project affects only previously disturbed ground. (Review Concluded) 
D Project affects undisturbed ground. 

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


Reviewer Name: Letha Dawson Applicant: Recovery School district 

DislsterlEmergeneylProgramIProjeet Title: DR I603 LA I Hurricane Katrina I Public Assistance Program I EORll31 Fannie C Williams Middle 
School-Library Building-Pennanent Repairs. 

o NR eligible resources present in project area. (FEMA finding! SHPOffHPO concurrence on 
file) 

oNo Adverse Effect Determination. (FEMA finding! SHPOffHPO concurrence on file) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Adverse Effect Determination. (FEMA finding! SHPOffHPO 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: The structure does not meet the SO-year-criterion, nor does it possess the level ofexceptional importance 
required by Criteria Consideration G ofthe National Register guidelines to be considered eligible for the National Register 
of Historic Places. Therefore, the proposed work will have no effect on historic properties. 

Correspondence/Consultation/References: 

B. Endangered Species Act 

181 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 


determinationfUSFWSINMFS 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: None 
Correspondence/Consultation/References: 

C. Coastal Barrier Resources Act 

181 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 determinationfUSFWS consultation on 
file) 

o Proposed action an exception under Section 3S0S.a.6? (Review Concluded)
o Proposed action not excepted under Section 3S0S.a.6. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 

181 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 404/40Ilor 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: None 
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) 
t8J Project is located in a coastal zone area and/or affects the coastal zone 

t8J State administering agency does not require consistency review. (Review Concluded). 
Record of Environmental Consideration 3 08129/06 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEme'1lencylProgram!Project Title: DR 1603l.A I Hurricane Katrina I Public Assistance Program I EORlI3! Fannie C Williams Middle 
School-Library Building-Permanent Repairs.

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 DNR has determined that 
receipt of federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the Coastal 
Zone may stilJ 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: 

F. Fish and Wildlife Coordination Act 

t8J Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) 
D Project affects, controls or modifies a waterwaylbody 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: None 
Correspondence/Consultation/References: 

G. Clean Air Act 

t8J 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: None 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

t8J 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-I006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

D Project not located within a flyway zone. (Review Concluded) 
t8J Project located within a flyway zone. 
t8J Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) I:8J 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 09114/2005. Specifically, FEMA has 
determined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other 
fish and wildlife reserves. These determinations are based on the understanding that the conditions outlined in the Louisiana 
Endangered Species Summary are met. 
Correspondence/Consultation/References: http://pacifictlyway.gov/Documents/Mississippi map.pdf, 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DlsasterlEmergency/frogramIProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EORll31 Fannie C Williams Middle 
School-Library Building-Permanent Repairs. 

J. Magnuson-Stevens Fishery Conservation and Management Act 

181 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 determinationlUSFWSINMFS 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: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

IZI 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: 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)
IZI 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), 

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

environment 

IZI 8 Step Process Complete -documentation on file 

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

Comments: 08/08/2006 -The City of New Orleans 1Orleans Parish enrolled in the National Flood Insurance Program 
(NFIP) as of 08/03/1970. Facility is located within an "A4" zone, area of 100-yr flooding, base flood elevations and flood 
hazard factors as determined per Flood Insurance Rate Map (FIRM) panel number 2252030115 E, dated 03/0111984. 
Project is repair of building and replacement of equipment and components. In compliance with EO 11988, an 8-step 
process was completed and is attached. As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where 
possible, building contents, materials, components and equipment (mechanical or electrical) must be elevated to or above 
Advisory Base Flood Elevations. Per 44 CFR 9.12, a final public notice is to be published 15 days prior to the start of any 
construction activities. Documentation of completed public notice is to be forwarded to FEMA and LA GOHSEP for 
inclusion in the permanent project files. A. C. Clark, Floodplain Specialist 
Correspondence! consultation/references: 8-Step Process 

B. E.O. 11990 -Wetlands 

IZI No Effects on WetJand(s) and project located outside Wetland(s) -(Review Concluded) 
Record of Environmental Consideration 5 

08/29/06 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramIProject Title: DR I603LA f Hurricane Katrina f Public Assistance Program I E0R2131 Fannie C Williams Middle 
School-Library Building-Permanent Repairs.

o Located in Wetland or effects Wetland(s) 

o Beneficial Effect on Wetland -(Review Concluded) 
oPossible 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 

[8j 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 

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

Comments: None 
Correspondence/Consultation/References: 

IV. Extraordinary Circumstances 

Based on tbe review of compliance witb otber environmental laws and Executive Orders, and in 
consideration of otber 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. If the circumstance can 
be mitigated, please explain in comments. lfno, leave blank. 
Yes 
D (i) Greater scope or size than normally experienced for a particular category of action 
D (ii) Actions with a high level ofpubJic controversy o (iii) Potential for degradation, even though slight, ofalready existing poor environmental 
conditions; 
D (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; 
D (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; 
D (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. 
Record ofEnvironmental Consideration 6 

08/29106 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
Di.a.terlEmergencylProgramlProject Title: DR I603 LA I Hurricane Katrina I Public Assistance Program I E0R2131 Fannie C Williams Middle 
School-Library Building-Permanent Repairs. 

o (x) Potential for significant cumulative impact when the proposed action is combined with 

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

IComments: None 

v. Environmental Review Project Conditions 

General comments: None 

Project Conditions: 

1. As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, 
building contents, materials, components and equipment (mechanical or electrical) must be 
elevated to or above Advisory Base Flood Elevations. Per 44 CFR 9.12, a final public notice is 
to be published 15 days prior to the start of any construction activities. Documentation of 
completed public notice is to be forwarded to FEMA and LA GOHSEP for inclusion in the 
permanent project files. 
2. 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. 
3. 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 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. Applicants managing debris staging, 
processing, burning or disposal sites (other than previously permitted landfills) that have been 
permitted by Louisiana Department of Environmental Quality must also complete an 
Emergency Debris Management Site Certification (Self Certification) regarding compliance 
with all applicable substantive laws and executive orders. 
4. 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 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). 
5. 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 "Sixth Amended Declaration ofEmergency and 
Administrative Order" dated June 30, 2006 or latest amended declaration, incorporating the 


Record of Environmental Consideration 7 08/29/06 


Rmrwn Name: Letha Dawson Applieant: Recovery School district 
DisasterlEmtrgeneylProgramIProjed Title: DRl603LA / Hurricane Katrina / Public Assistance Program / E0R2131 Fannie C Williams Middle 
School·Library Building·Permanent Repairs. 

provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 

the Louisiana Administrative Code (LAC) 33JII.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 order. 

6. 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 renovation or demolition 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. 
7. This project potentially involves the disposal ofmetallic mercury containing electronic devices. 
The applicant is responsible for ensuring that these devices are recovered, recycled, reused or 
sequestered in accordance with the Louisiana Department of Environmental Quality (LDEQ) 
"Declaration ofEmergency; Mercury-Containing Devices and Electronic Equipment as 
Universal Waste" letter dated October 3, 2005. 


Monitoring Requirements: None