Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School-Site 
& Grounds 

Record of Environmental Consideration 


See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: Bradley Elementary School -Site & Grounds I PW 13436 

Project Location: 2401 Humanity St., New Orleans, Louisiana, Orleans Parish, 70122 (N 29.99228, 
W -90.05436) 

Project Description: Project activities include removing and replacing concrete driveway slab and 
concrete sidewalk slab, pressure washing and cleaning residue film on chain link fence and playground 
equipment. 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) 


rg] (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 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) 
rg] Environmental Impact Statement 


Conunents: 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 NEP A Level of Environmental 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 
DislSterlEmergenc:ylProgramIProject Title: DR I603 LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School· Site 
'" Grounds 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha Dawson~ Environmental Specialist 


Signature__

~_~~....::.....;1.-~~:"'::"':::;';:;""...;...:o,oL...!._..::Io....:.' Date _---"-0=8/.=3=112==00::...:6'--____----'


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

Signature ~rJ3~ . Date _-=08=/3",-"1=12=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 and D. 
Are project conditions required? [gI Yes (see section V) D No <Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
D 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 Detennination ofNo Historic Properties Affected (FEMA findinglSHPO/THPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Detennination 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. If not, explain in comments 
D No Adverse Effect Detennination (FEMA fmdinglSHPOITHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Adverse Effect Detennination (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 
[gI 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 Detennination of no historic properties affected (FEMA findinglSHPOITHPO concurrence or 
consultation on file). <Review Concluded) 
D Project area has potential for presence of archeological resources 
D Detennination of no historic properties affected (FEMA findinglSHPO/THPO concurrence on file) 
Are project conditions required Dyes (see section V) D No (Review Concluded) 
D Detennination of historic properties affected 
D NR eligible resources not present (FEMA findinglSHPO/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 findingl SHPOITHPO concurrence on 
file) 

D No Adverse Effect Detennination. (FEMA findingl SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Adverse Effect Detennination. (FEMA findingl SHPOITHPO concurrence on file) 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramlProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School -Site 
& Grounds 

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

Comments: 8/28/06· Scope ofwork indicates ground disturbing activities associated with replacing concrete walkway and 
driveway. Upon consultation of data 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 ofwork as submitted meets the criteria outlined in the Programmatic Agreement dated December 3, 
2004, Appendix A, Section I A and D. In accordance with this document, FEMA is not required to submit projects to the 
SHPO for review where the work perfonned meets these allowances. Ifduring the course ofwork, 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 fmds. The applicant shall infonn their Public Assistance 
(PA) contacts at FEMA, who will in turn 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, 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 notity the law enforcement agency ofthe jurisdiction 
where the remains are located within twenty-four hours ofthe discovery. The applicant shall also notity 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 

[gI 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 Fonnal 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 

[gI 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 

[gI 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 404/401l0r 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) 


Record ofEnvironmental Consideration 3 08/31/06 


Reviewer Name: Letha Dawson ApplicaDt: Recovery School district 
DisasterlEmergeDcylProgramiProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School· Site 

& Grounds 

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) 

123 Project is located in a coastal zone area and/or affects the coastal zone 
123 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 
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 

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

o Project affects, controls or modifies a waterwaylbody ofwater. 

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: None 
Correspondence/Consultation/References: 

G. Clean Air Act 

123 Project will not result in permanent air emissions. (Review Concluded)

o Project is located in an attainment area. (Review Concluded) 
oProject 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: None 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

123 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, Form AD-l 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) 
123 Project located within a flyway zone. 

123 Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) t8J No (Review Concluded) 

08/31106


Reviewer Name: Letha Dawson Applieant: Recovery School district 
Di.asterlEmergeDcylProgramIProjcct Title: DRI603LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School-Site 
& Grounds 

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.gov/Documents/Mississippi map.pdf, 

J. Magnuson-Stevens Fisbery 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 NPS/uSFS. FEMA cannot fund the action. 
(NPS/uSFS/uSFWSIBLM consultation on file) <Review Concluded) 
D Project does not adversely affect WSR. (NPS/uSFS/uSFWSIBLM 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 FloodplainsIFlood levels 

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

Are project conditions required? D Yes (see section V) IZl 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: 08111/06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) 
on 08/03/1970. Per Flood Insurance Rate Map (FIRM) 225203 0095 E, dated 03/0111984, project is located in zone 'A-2'; 


Reviewer Name: Letha Dawson Applic:ant: Reoovery School district 
DlusterlEmergenc:ylProgramIProjec:t Title: DR! 603 LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School· Site 
& Grounds 
area of IOO-yr flooding, base flood elevations and flood hazard factors detennined. Project is repair of grounds facilities to 
pre-disaster footprint and should have no effect on floodplain. Casey Barefield, FPM. 

Correspondence/consultation/references: 

B. E.O.11990 -Wetlands 

I8J No Effects on Wetland(s) and project located outside WetJand(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 
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 

I8J 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(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 

o (i) Greater scope or size than nonnally experienced for a particular category of action 
o (H) Actions with a high level ofpublic 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 ofendangered or threatened species or their critical habitat, or archaeological, 


cultural, historical or other protected resources; 
Record of Environmental Consideration 6 

08/31106 


Reviewer Name: Letha Dawson Applicant: Rewvery School district 
DisasterlEmergencylProgr.mlProjed Tide: DR 1603LA I Hurricane Katrina I Public Assistance Program E0R2202 Bradley Elementary School· Site 
& 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. If during the course ofwork, 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 (P A) contacts at FEMA, who will in turn 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, 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 ofArcheology at 225-342-8170) 
within seventy-two hours ofthe discovery. Failure to comply with these stipulations may 
jeopardize receipt of FEMA funding. 
2. Unusable equipment, debris and material shall be disposed ofin 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. 


Monitoring Requirements: None