Record of Environmental Consideration 


See 44 Code of Federal Regulation Part 10. 

Proiect NamelNumber: EOR 2139 Bradley Elementary School-Building B / PW 13331 

Project Location: 2401 Humanity Street, New Orleans, Louisiana, Orleans Parish 70122 
(N29.99228, W"90.05436 

Project Description: Project activities include replacing 228 LF of vinyl base, 792 SF of 5/8" drywall 
& studs, 1,101 SF of5/8" drywall ceiling, (11) 48" (1) suspended fluorescent tube light, 1,032 SF of 
12" VT flooring, 50 LF of24" D insulated air duct, and (1) 42 circuit, 1 phase outdoor, panel board. 
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 (NEP A) 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 Supplemen~al Environmental Assessment (Reference EA or PEA in comments) 
~ 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 of environmental 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 and Approvals 

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

C\d~~~~~a:::..~~-----!.. Date _-=8/.:::::..30=/=06~___----!. 
ional Environmen fficer or delegated approving officiaL 
Name: Howard R. Bush, ELO 


. Date _~8"-,,/3,,-,,O::....:/O=6____---,


Signature ~0:? 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

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

D Determination ofNo Historic Properties Affected (FEMA fmding!SHPO/THPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic 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 fmding!SHPOITHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA finding!SHPO/THPO concurrence on file) 
D Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 
rgj 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 finding! SHPOITHPO concurrence on 
file) 

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

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

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

Comments: Building B was constructed in 1964. 
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 

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 


determinationlUSFWS/NMFS 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 Forma) 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 
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 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 
181 Project would not affect any waters of the 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 404/401!0r Section 9110 (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 of the U.S. 
Correspondence/Consultation/References: 

E. Coastal Zone Management Act 

o Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 

181 Project is located in a coastal zone area and/or affects the coastal zone 
I:8J State administering agency does not require consistency review. (Review Concluded>. 

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

Record of Environmental Consideration 3 08/30/06 

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

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modifY a waterwaylbody of water. (Review Concluded) 

o Project affects, controls or modifies a waterwaylbody of water. 

o Coordination with USFWS conducted 

o No Recommendations offered by USFWS. (Review Concluded) 
o Recommendations provided by USFWS. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


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

G. Clean Air Act 

181 Project will not result in pennanent air emissions. (Review Concluded) 

o Project is located in an attainment area. (Review Concluded) 
o Project is located in a non-attainment area. 


o Coordination required with applicable state administering agency.. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: Project will not result in pennanent air emissions. 
CorrespondenCe/Consultation/References: 

H. Farmland Protection Policy Act 

181 Project does not affect designated prime or unique farmland. (Review Concluded) 

o Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Fonn AD-1 006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

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

rgJ Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) rgJ 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: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has 
detennined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other 
fish and wildlife reserves. These detenninations are based on the understanding that the conditions outlined in the Louisiana 
Endangered Species Summary are met. 
Correspondence/Consultation/References: http://pacificflyway.govlDocuments/Mississippi map.pdf, 


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 detenninationlUSFWSINMFS 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 

181 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 detennined 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)
181 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)

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

environment 

181 8 Step Process Complete -documentation on file 

Are project conditions required? 181 YES (see section V) D NO (Review Concluded) 

Comments: 08/09/2006 -The City ofNew Orleans 1Orleans Parish enrolled in the National Flood Insurance Program 
(NFIP) as of08/0311970. Facility is located within an "A2" Zone, area of 1OO-yr flooding, Base Flood Elevations and Flood 
Hazard Factors as detennined per Flood Insurance Rate Map (FIRM) Panel Number 2252030095 E, dated 03/0111984. 
Project is repair ofbuilding and replacement ofequipment 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 fmal public notice is to be published 15 days prior to the start ofany 
construction activities. Documentation ofcompleted public notice is to be forwarded to FEMA and LA GOHSEP for 
inclusion in the pennanent project files. A. C. Clark, Floodplain Specialist. Correspondence/Consultation/References: 


B. E.O.11990 -Wetlands 

~No Effects on Wetland(s) and project located outside WetJand(s) -(Review Concluded) 

o Located in Wetland or effects WetJand(s)

o Beneficial Effect on Wetland -(Review Concluded) 
o Possible adverse effect associated with constructing in or near wetland 
o Review completed as part of floodplain review 
o 8 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 






Comments: None 
Correspondence/Consultation/References: 

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

~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 
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? 0 YES (see section V) 0 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 (ii) which 
should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, 
please explain in comments. If no, 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 ofpublic controversy 
D (iii) Potential for degradation, even though slight, of already existing poor environmental 


conditions; 
D (iv) Employment of unproven technology with potential adverse effects or actions involving unique or unknown 
environmental risks; 
D (v) Presence of endangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
D (vi) Presence ofhazardous 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; 


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: 

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 
permanent project files. 
2. 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. 
3. In accordance with the Formosan Termite Initiative Act, (LA. R.8. 3:3391.1 thru 3391.13) the 
Louisiana Parishes ofCalcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, 
8t. Bernard, 8t. Charles, 8t. 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 ofthe 
Louisiana Department of Agriculture and Forestry or his designee(s). 


Monitoring Requirements: None