Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencyJProgramlProject Title: DR I603 LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School -Grounds 

Record of Environmental Consideration 


See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: Fannie C Williams Middle School -Grounds I PW 13271 

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

Project Description: Project activities include removing, disposing and replacing light poles, anchor 
bases, floodlights and chain link fencing. Some mitigation will be achieved by compliance with 
current codes and standards and by good construction practices. 

Documentation Requirements 

o No Documentation Required (Review Concluded) 
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) 


I:8J (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 

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


o No Extraordinary Circumstances exist. 

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

o 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) 
I:8J Environmental Impact Statement 

Comments: This project meets the criteria for an Alternative Arrangement (Permanent Schools) type of project. 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 of any work, for 
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 Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramlProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School-Grounds 

Reviewer and Approvals 

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

FEMA Envirorunental Reviewer. 
Name: Letha Dawson, Envirorunental Specialist 


Signature ~~ . Date _-=08=/3=0:::.,:/2=0=0=6_____.....;. 

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

Signature ~:z:s- . Date _-=08=/3=0:::.,:/2=0=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) 

[gI Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. 
[gI Activity meets Programmatic Allowance # Appendix A, Section I A, E and I. 
Are project conditions required? [8J Yes (see section V) D No (Review Concluded) 

HISTORIC BUILDINGS AND STRUCTURES 
[gI 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 findingiSHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination ofHistoric Properties Affected (FEMA frndingiSHPOffHPO 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 frndingiSHPOffHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA frndingiSHPOffHPO 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 
[8J 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 frndingiSHPOffHPO 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 findingiSHPOffHPO 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 finding!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 frnding! SHPO/THPO concurrence on 
file) 

D No Adverse Effect Determination. (FEMA findingl SHPO/THPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
Adverse Effect Determination. (FEMA frnding! SHPOITHPO concurrence on file) 

Record of Environmental Consideration 2 


Reviewer Nlme: Letha Dawson Appliunt: Recovery School district 
DislstnlEmergencylProgrlmIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School -Grounds 

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

Comments: 8129/06 -Scope of work indicates ground disturbing activities associated with replacing fences and concrete 

bases for light poles. Upon consultation ofdata provided by the State Historic Preservation Officer (SHPO), there are no 
known archaeological sites within .25 miles ofthe project area and all work will occur within a previously disturbed area. 
Therefore, the scope of work as submitted meets the criteria outlined in the Progranunatic Agreement dated December 3, 
2004, Appendix A, Section I A, E and I. In accordance with this document, FEMA is not required to submit projects to the 
SHPO for review where the work performed meets these allowances. If during the course of work, 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, ifunmarked graves are present, compliance with the Louisiana Unmarked Human Burial Sites 
Preservation Act (R.S. 8:671 ET SEQ.) is required. The applicant shall notify the law enforcement agency ofthe jurisdiction 
where the remains are located within twenty-four hours 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 ofthe discovery. Failure to comply with these stipulations may jeopardize receipt ofFEMA funding. -Dana Linck, 
Historic Preservation Specialist/Archaeologist. 

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) 
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: None 
Correspondence/Consultation/References: 

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: None 
Correspondence/Consultation/References: 

D. Clean Water Act 
[8j Project would not affect any waters ofthe 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 404/401l0r Section 9110 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Penn its. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 



Reviewer Nlme: letha Dawson Appliclnt: Recovery School district 
DislsterlEmergencylProgrlmlProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School· Grounds 

Comments: None 
Correspondence/Consultation/References: 

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) DNO (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 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: 

F. Fish and Wildlife Coordination Act 
181 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: None 
Correspondence/Consultation/References: 

G. Clean Air Act 
181 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 
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-1006, 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) 
181 Project located within a flyway zone. 


181 Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) 181 No (Review Concluded) 

Record of Environmental Consideration 4 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisastulEmergencylProgramJProjed Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School-Grounds 

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 
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://paciflcflyway .gov/Documents/M ississippi map. pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

18I 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? D Yes (see section V) D No (Review Concluded) 
o 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? 0 YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

18I 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) 
I:8J Located in Floodplain or Effects on FloodplainslFlood levels 

18I No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 

Are project conditions required? I:8J 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 of floodplain 

environment 

D 8 Step Process Complete -documentation on file 

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

Comments: 08/07/06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) 
08/0311970. Per Flood Insurance Rate Map 225203 0 lISE, dated 03/01/1984, project is located in zone A4, area of 100yr 
flood; base flood elevations and flood hazard factors determined. Project is repair and replacement of contents. As per 44 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramIProjed Title: DR I 603 LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School· Grounds 

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.---
Rezwan Karim, CFM 

Correspondence/consultation/references: 

B. E.O.11990 -Wetlands 
181 No Effects on Wetland(s) and project located outside WetJand(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 of floodplain review 
D 8 Step Process Complete -documentation on file 


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

Comments: None 
Correspondence/Consultation/References: 

C. E.O.12898 -Environmental Justice For Low Income and Minority Populations 
181 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: None 
Correspondence/Consultation/References: 

III. Other Environmental Issues 

Identify other potential environmental concerns in the comment box not clearly falling under a law or 
executive order (see environmental concerns scoping checklist for guidance). 

Comments: None 
Correspondence/Consultation/References: 

IV. Extraordinary Circumstances 

Based on the review of compliance with other environmental laws and 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 (H) 
which should be applied in conjunction with controversy on an environmental issue. If the circumstance can 
be mitigated, please explain in comments. Ifno, leave blank. 
Yes 
D o o 
o 
o 
(i) Greater scope or size than normally experienced for a particular category of action 
(ii) Actions with a high level of public controversy 
(iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; 
(iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
(v) Presence of endangered or threatened species or their critical habitat, or archaeological, 

cultural, historical or other protected resources; 
Record ofEnvironmental Consideration 6 

08/30106 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramlProjed Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School -Grounds 

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 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 

General comments: None 

Project Conditions: 

1. 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. 
2. If during the course of work, archaeological artifacts (prehistoric or historic) or human remains 
are discovered, the applicant shall stop work in the vicinity of the discovery and take all 
reasonable measures to avoid or minimize harm to the finds. The applicant shall inform their 
Public Assistance (PA) contacts at FEMA, who will in tum contact FEMA Historic 
Preservation staff. The applicant will not proceed with work until FEMA Historic Preservation 
staffhave 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 of Archeology at 225-342-8170) 
within seventy-two hours ofthe discovery. Failure to comply with these stipulations may 
jeopardize receipt of FEMA funding. 
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 ofpetroleum 
products, hazardous materials and/or toxic waste in accordance to the requirements and to the 
satisfaction ofthe governing local, state and federal agencies. 
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 ofthe 
Louisiana Department of Agriculture and Forestry or his Designee(s). 


Record of Environmental Consideration 7 


Reviewer Namt: Letha Dawson Applicant: Recovery School district 
DisasterJEmergencylProgramlProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR 2141 Fannie C Williams Middle 
School -Grounds 

5. 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 of Emergency; Mercury-Containing Devices and Electronic Equipment as 
Universal Waste" letter dated October 3,2005. 

Monitoring Requirements: None