Reviewer Name: June R. Griffin Applicant: Recovery School District 
DisasterlEmergencylProgramIProjeet Title: DRI603LA I Hurricane Katrina !Public Assistance Program/EOR 2117 Alexander Avery Elementary 
School -Main Building 

Record of Environmental Consideration 


See 44 Code ofFederal Regulation Part 10. 

Project NameINumber: EOR 2117 Alexander Avery Elementary School Main Building / 
PW 13305 
Project Location: 5800 St. Roch Avenue, New Orleans, Louisiana, Orleans Parish 70129 
(N30.01987, W-90.03387) 

Project Description: Project activities include removing and replacing 110 LF ofcopper downspouts, 
510 LF of copper gutters, 500 SF ofasphalt shingles, 5,539 SF of fiberglass insulation, 1,000 SF of2" 
X 2" ceramic bathroom tiles, 50,000 SF ofelectrical systems for the entire main building (one floor) 
and 50,000 SF of mechanical systems for the entire main building (one floor). 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) 

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

National Environmental Policy Act (NEPA) 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) 
~ 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 (Permanent 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 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 offederal funding. 


Reviewer Name: June R. Griffin Applicant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina !Public Assistance ProgramlEOR 2117 Alexander Avery Elementary 
School-Main Building 

Reviewer and Approvals 

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

ental Reviewer. 
ental Specialist 
Signahrre;~~~~~~~~~~~~____~. Dme __~9/~8~/O~6~______~ 

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

Signahrre ~~ ,2~ . Date _~9..:....o/8",-,/O",-,6,,---___----,


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

A. National Historic Preservation Act 

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

D Applicable executed Programmatic Agreement. Otherwise, conduct standard Section 106 review. 
D Activity meets Programmatic Allowances. 
Are project conditions required? D 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)
IZI Building or structure listed or 45/50 years or older in project area and activity not exempt from review. 

IZI Determination ofNo Historic Properties Affected (FEMA fmding/SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) IZI No (Review Concluded) 
D Determination ofHistoric Properties Affected (FEMA fmding/SHPOITHPO 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 finding/SHPOITHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 

D Adverse Effect Determination (FEMA fmding/SHPOITHPO concurrence on file) 
Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 
IZI 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 ofno historic properties affected (FEMA fmding/SHPOITHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA fmding/SHPOITHPO 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 fmding/SHPO/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 fmding/ SHPOITHPO concurrence on 
file) 


Reviewer Name: June R. Griffin Applicant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina !Public Assistance ProgramlEOR 2117 Alexander Avery Elementary 
School-Main Building 

o No Adverse Effect Determination. (FEMA fmding! SHPOrrHPO concurrence on file) 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 
o Adverse Effect Determination. (FEMA finding! SHPOrrHPO 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: 09/07/2006 -The property has been determined by FEMA to be not eligible for listing in the National Register 
or located within the boundaries ofa National Register District. Concurrence with this determination was received from the 
SHPO dated 08/29/06 (see attached). In keeping with this determination, the proposed project will have no effect on 
Historic Resources. This concludes the Section 106 review for this project. V. Gomez, Historic Preservation Specialist 
Correspondence/Consultation/References: 

B. Endangered Species Act 

IZI 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) 

IComments: None 

C. Coastal Barrier Resources Act 

IZI 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 

IZI 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 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: Project is not in or adjacent to any waterways ofthe U.S. 
Correspondence/Consultation/References: 


Reviewer Name: June R. Griffin Applicant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR1603LA I Hurricane Katrina !Public Assistance ProgramlEOR 2117 Alexander Avery Elementary 
School -Main Building 

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) 

I2l Project is located in a coastal zone area and/or affects the coastal zone 

I2l 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 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. Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

I2l 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: Project is not in or adjacent to any waterways of the U.S. 
Correspondence/Consultation/References: 

G. Clean Air Act 

I2l 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: Project will not result in permanent air emissions. 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

I2l Project does not affect designated prime or unique farmland. (Review Concluded)
D Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 
D Coordination with Natural Resource Conservation Commission required. 
D Farmland Conversion Impact Rating, Form AD-I006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

D Project not located within a flyway zone. (Review Concluded) 
I2l Project located within a flyway zone. 
I2l Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) I2l 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) 


Reviewer Name: June R. Griffin Applicant: Recovery School District 
DisasterlEmergencylProgramfProject Title: DRI603LA I Hurricane Katrina !Public Assistance ProgramlEOR 2117 Alexander Avery Elementary 
School -Main Building 

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://pacificflyway.gov/DocumentslMississippi map.pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

[81 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 
Co"espondence/Consu/tation/References: 

K. Wild and Scenic Rivers Act 

[81 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 Floodplains/Flood levels and project outside Floodplain • <Review Concluded) 
[81 Located in Floodplain or Effects on FloodplainslFlood 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) 

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

environment 
[818 Step Process Complete· documentation on file 
Are project conditions required? ~YES (see section V) D NO (Review Concluded) 


Reviewer Name: lune R. Griffin Applicant: Recovel)' School District 
DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina !Public Assistance Program/EOR 2117 Alexander Avery Elementary 
School -Main Building 

Comments: 08/1112006 -The City ofNew Orleans/Orleans Parish is enrolled in the National Flood Insurance Program 
(NFIP) as of8/311970. Per Flood Insurance Rate Map (FIRM) Panel Nwnber 2252030115E dated 3/111984, project is 
located within an itA7" Zone, area of 100-yr flooding, Base Flood Elevations and Flood Hazard Factors as detennined. 
Project is repair ofbuHding, including electrical and mechanical systems. In compliance with EO 11988, a completed 8Step 
Process showing considered alternatives is attached. Per 44 CFR 9.11(0) (9), the replacement ofbuilding contents, 
materials and equipment, where possible, disaster proofing ofthe building and/or elimination ofsuch future losses by 
relocation ofthose building contents, materials and equipment to or above the Advisory Base Floodplain Elevation. Per 44 
CFR 9.12, applicant must publish a fmal Public Notice 15 days prior to the start ofconstruction activities. Final Public 
Notice is to be forwarded to the LA GOHSEP and FEMA for inclusion in the pennanent project files. K. Roof, Floodplain 
Management Specialist. Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

[8J No Effects on Wetland(s) and project located outside Wedand(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 offloodplain review 

08 Step Process Complete -docwnentation 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 

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 ApplicaDt: Recovery School District 
DisasterlEmergencylProgramIProjec:t Title: DRI603LA I Hurricane Katrina !Public Assistance ProgramlEOR 2117 Alexander Avery Elementary 
School -Main Building 

III. Other Environmental Issues 

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

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. 


II< 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 
D (i) Greater scope or size than normally experienced for a particular category ofaction 
D (U) Actions with a high level ofpublic controversy 
D (iii) Potential for degradation, even though slight, ofalready existing poor environmental 


conditions; 
D (iv) Employment ofunproven technology with potential adverse effects or actions involving unique or 
unknown environmental risks; 
D (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; 
D (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 
D (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 


protection ofthe environment. 
D (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, 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 
pennanent project files. 

Record of Environmental Consideration 7 09/08/06 


Reviewer Name: June R. Griffin Applicant: Recovery School District 
DlsuterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina /Public Assistance ProgramIEOR 2117 Alexander Avery Elementary 
School -Main Building 

2. 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 ofEmergency and Administrative 
Order" dated June 30, 2006, incorporating the provisions ofEPA'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 order. 
3. This project involves the demolition or renovation ofa 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 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 of Environmental Quality 
for abatement activities and is also responsible for ensuring proper disposal in accordance with 
the previously referenced regulations. 
4. 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, 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. 
5. 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 ofthe 
Louisiana Department ofAgriculture and Forestry or his designee(s). 


Monitoring Requirements: None