Reviewer Name: Letha Dawson ApplieaDt: Recovery School District 
DisuterlEmergencylProgramIProjeet Title: DRI603LA I Hurricane Katrina I Public Assislance Program I EOR 2207 Edward Livingston Middle 
School -Storage Building 

Record of Environmental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: Edward Livingston Middle School-Storage Building / PW 13376 

Project Location: 7301 Dwyer Road, New Orleans, Louisiana, Orleans Parish, 70126 (N30.02198, 
W-90.00289) 

Project Description: Project activities include removing and replacing built-up bitumen roof with 
aggregate/flashing, drywall, incandescent light fixture, halogen exterior light fixture, hollow metal 
door, aluminum windows, and wooden work bench. 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 (Sbort 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) 


C8j (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 

o Statutorily excluded from NEPA review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category <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) 
C8j 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 
ofwork will require submission to, and evaluation and approval by, the state and FEMA prior to initiation ofany 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 
Di.a.terlEmergeDcylProgramIProjed Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2207 Edward Livingston Middle 
School-Storage Building 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha Dawson, Environmental Specialist 


Signature,__.....Ii.......c..;:~:::...J..l-=...;~~=~-= Date _--=-08=1=24..:.:.1=20.::..;O:..:6~____---=


___...:.. 

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

Signature ~~L-;;;l------;7""'L7' . Date _--,,-,08:::.:../2=-4:.:..:/2=O=O=.6_____

, 
, 
-!, 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 
181 Not type of activity with potential to affect historic properties. (Review Concluded) 
D Applicable executed Programmatic Agreement (12/03/2004) OthelWise, 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 
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 findinglSHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmdinglSHPOITHPO 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 fmdinglSHPOITHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findinglSHPOITHPO 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 ofno historic properties affected (FEMA fmdinglSHPOITHPO 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 fmdinglSHPOITHPO concurrence on file) 
Are project conditions required D Yes (see section V) DNo (Review Concluded) 
D Determination of historic properties affected 
D NR eligible resources not present (FEMA fmdinglSHPOITHPO 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 SHPOITHPO concurrence on 
file) 
D No Adverse Effect Determination. (FEMA fmdingl SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) DNo (Review Concluded) o Adverse Effect Determination. (FEMA fmdingl SHPOITHPO concurrence on file) 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
Di.a.terlEmergencylProgramIProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR 2207 Edward Livingston Middle 
School -Storage Building 

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

Comments: According to the Project Officer, the school facility was constructed in 1983 and the storage building was built 
after 1960. 

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 


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 
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 404/401l0r 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: 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) 

181 Project is located in a coastal zone area and/or affects the coastal zone 
t8l 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) 

Comments: This project is located within the Louisiana Coastal Management Zone. LA DNR has determined that 
receipt offederal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the Coastal 

Record of Environmental Consideration 3 


Reviewer Nlme: Letha Dawson AppliClnt: Recovery School District 
DisuterlEmergencylProgramIProJect Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2207 Edward Livingston Middle 

School -Storage Building 
Zone may still require a Coastal Use Pennit or other authorization from DNR. Projects may be coordinated by 
contacting LA DNRat 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 
Co"espondence/ConsuitationiReferences: 

G. Clean Air Act 

181 Project will not result in pennanent 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 
Co"espondence/ConsuitationiRejerences: 

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, Fonn AD-I 006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Co"espondence/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) 
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 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. 

Record of Environmental Consideration 4 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramJProject Title: DR1603LA! Hurricane Katrina! Public Assistance Program! EOR 2207 Edward Livingston Middle 
School -Storage Building

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 detennination/USFWS/NMFS 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: 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) 


o Project is along or affects WSR 

o Project adversely affects WSR as detennined by NPSIUSFS. FEMA cannot rund tbe action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 
o Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) 
Are project conditions required? 0 YES (see section V) 0 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 

o No Effect on FloodplainsIFlood levels and project outside Floodplain -(Review Concluded) 
181 Located in Floodplain or Effects on FloodplainslFlood levels 

181 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 181 Yes (see section V) 0 No (Review Concluded) 

o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). 
o Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 


o 8 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: 0811 0/2006-The City ofNew OrleanS/Orleans Parish is enrolled in the National Flood Insurance Program 
(NFIP), as of08/03/1970. Per Flood Insurance Rate Map (FIRM) panel number 2252030 liSE dated 03/0111984, project is 
located within an "A4t1 zone, area of IOO-yr flooding, base flood elevations and flood hazard factors as detennined. Project 
is repair of building, including replacement of lighting fIXtures. Per 44 CFR 9.11 (0)(9), the replacement of building 
contents, materials and equipment, where appropriate, disaster proofing of the building and/or elimination of such future 
losses by relocation of those building contents, materials and equipment to or above the advisory base elevation. K. Roof, 
Floodplain Management Specialist. 

Correspondencelconsultation/references: 

B. E.O. 11990 -Wetlands 
181 No Effects on Wetland(s) and project located outside Wetland(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 
/ 0 Review completed as part of floodplain review 

o 8 Step Process Complete -documentation on file 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
Disa.terlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina I Public: Assistance Program I EOR 2207 Edward Livingston Middle 
School· Storage Building 

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 

181 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: 

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. Ifno, leave blank. 
Yes 
o (i) Greater scope or size than normally experienced for a particular category ofaction o (ii) Actions with a high level of public controversy o (iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; o (iv) Employment of unproven 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 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 of the 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 


Rcvicwcr Namc: Letha Dawson Applicant: Recovery School District 
DisasttrlEmcrgcncylProgramll'rojed Tide: DR1603L.A I Hurricane Katrina I Public Assistance Program I EOR 2207 Edward Livingston Middle 
School· Storage Building 

v. Environmental Review Project Conditions 

General comments: None 

Project Conditions: 

1. Per 44 CFR 9.11 (D)(9), the replacement of building contents, materials and equipment, where 
appropriate, disaster proofmg ofthe building and/or elimination ofsuch future losses by 
relocation ofthose building contents, materials and equipment to or above the advisory base 
elevation. 
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. 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, S1. 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). 
4. 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 June 30, 2006 or latest amended declaration, incorporating the 
provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 
the Louisiana Administrative Code (LAC) 33.111.5151 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. 
5. 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. 
6. 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 ofEnvironmental Quality (LDEQ) 
"Declaration ofEmergency; Mercury-Containing Devices and Electronic Equipment as 
Universal Waste" letter dated October 3, 2005. 


Monitoring Requirements: None 

08/24/06