Reviewer Name: Brandon M. Clark ApplicaDt: Recovery School District 
DisuterlEmel'leney/Program/Projeet Title: DRl603LA I Hurricane Katrina I Public Assistance Program I EOR 2240-Barbara Jordan Elementary 
School-Classroom Building G 


Record of Environmental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: EOR 2240-Barbara Jordan Elementary School-Classroom Building G I PW 

Project Location: 4348 Reynes Street, New Orleans, Louisiana, Orleans Parish 70126 (N30.01328, W


90.01137) 

Project Description: Project activities include removing and replacing components ofthe facility to 

restore it to pre-disaster condition, and upgrading the facility to current codes and standards. 

Cumulative project activities include removing and replacing wide metal roof cap, aluminum gutters, 

light flXtures, gypsum ceiling board, vinyl composition tiles, ceramic floor tiles, glass blocks, 
exterior/interior doors, cabinets and closets, sinks, chalkboards, soap dispensers, fire extinguishers, 
electrical components, gas-fired boiler, fiberglass faced insulation, condensing compressor units, water 
heater, and cleaning water circulating pumps, air handling units, and ductwork. 

Documentation Requirements 

D No Documentation Required <Review Concluded) 

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) 

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 

D Statutorily excluded from NEP A 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) 
I:8J Environmental 1m act Statement 

Comments: 8/3112006 -This project meets the criteria for an Alternative Arrangement (Pernlanent 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 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 pernlits and requirements. Non-compliance with the requirements noted above may jeopardize the receipt of federal 
funding. Brandon M. Clark, Environmental Specialist 


Reviewer Name: Brandon M. Clark Applicaat: Recovery School District 
DlsuterlEmergeacylProgramlProjeet Tide: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 2240-Barbara Jordan Elementary 
School-Classroom Building G 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Brandon M. Clark, Environmental Specialist 


Signature__13-+-L"..!::..lal:O«~~=::::""'-...L.f1t\...:......1..":""·-=~~.;.......;. Date _08/31106_----.:.


__-..!.. 

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

Signature ~--;;r 0-----P . Date __08131106_----.:. 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

D Not type ofactivity with potential to affect historic properties. (Review Concluded) 
t8I Applicable executed Programmatic Agreement_December 3, 2004_Otherwise, conduct standard Section 106 review. 
t8I Activity meets Programmatic Allowance # Section {II·EI, H-A2, H·B 1. H-A4, H-CI, I1-D2, II-H, H-B2, II-F2} 
Are project conditions required? t8I Yes (see section V) D No (Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
D 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 of No Historic Properties Affected (FEMA fmding!SHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmding!SHPOffHPO 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 finding!SHPOfTHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA finding!SHPOffHPO 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 
t8I 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 fmding!SHPOfTHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence of archeological resources 
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 
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! SHPO/THPO concurrence on 
file) 

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


Reviewer Name: Brandon M. Clark Applicant: Recovery School District 
DlsaaterlEmergeoc:ylProgramIProjed Tide: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2240-Barbara Jordan Elementary 
School-Classroom Building G 

Are project conditions required? D Yes (see section V) D No 
<Review Concluded) 

Comments: 08/3112006 -FEMA's Programmatic Agreement (pA), dated December 3, 2004, provides for expedited project 
review under Section 106 of the National Historic Preservation Act (NHPA). The scope of work as submitted in this PW has 
been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section {II-El, II-A2, II-BI, II-A4, 
II-CI, 11-02, II-H, II-B2, II-F2}, ofthe document. In accordance with the PA, FEMA is not required to determine the 
national register eligibility ofproperties or to submit projects to the State Historic Preservation Officer (SHPO) for review 
where the work performed meets these allowances. In keeping with the stipulations ofthe PA, all proposed repair activities 
should be done in-kind to match existing materials and form. Any change to the approved scope ofwork will require 
resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the 
receipt of federal fimding. This concludes the Section 106 review for this project. V. Gomez, Historic Preservation Specialist 

ICorrespondence/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)
D Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. 


D No effect to species or designated critical habitat. (See comments for justification) 

Are project conditions required? D Yes (see section V) D No (Review Concluded) 

D May affect, but not likely to adversely affect species or designated critical habitat (FEMA 

determinationlUSFWSINMFS concurrence on file) (Review Concluded) 

Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Likely to adversely affect species or designated critical habitat 
D Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? D YES (see section V) D 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). 
D Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 

file) 
D Proposed action an exception under Section 3505.a.6? (Review Concluded) 
D Proposed action not excepted under Section 3505.a.6. 


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

Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 
[8j Project would not affect any waters ofthe U.S. (Review Concluded) 
D 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 404/40 1I0r Section 9/1 0 (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 United States. 
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) 
f2] Project is located in a coastal zone area and/or affects the coastal zone 

Record of Environmental Consideration 3 OS/31106 


Reviewer Name: Brandon M. Clark Applicaot: Recovery School District 
DisasterlEmergeocylPrognmIProject Tide: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 2240-Barbara Jordan Elementary 
School-Classroom Building G 

IZI 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: 08/3112006 -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. Brandon M. Clark, Environmental Specialist 
Co"espondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

IZI Project does not affect, control, or modify a waterway/body of water. (Review Concluded)
D Project affects, controls or modifies a waterway/body ofwater. 

o Coordination with USFWS conducted 

o No Recommendations offered by USFWS. (Review Concluded) 
o 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 ofthe United States. 
Correspondence/Consultation/References: 

G. Clean Air Act 

IZI 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: Project will not result in pennanent air emissions. 
Co"espondence/Consultation/References: 

H. Farmland Protection Policy Act 

~Project does not affect designated prime or unique farmland. (Review Concluded)
D Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

D Farmland Conversion Impact Rating, Fonn 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 

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

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

o Project has potential to take migratory birds. 

D Contact made with USFWS 
Are project conditions required? 0 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://pacificflvway.gov/DocumentslMississippi map. pdf 


Reviewer Name: Brandon M. Clark Applicant: Recovery School District 
D1suterlEmergencylProgramIProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 2240-Barbara Jordan Elementary 
School-Classroom Building G 

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 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 
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 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)
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) 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: 08/26/06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) on 
8/3/70. Per Flood Insurance Rate Map (FIRM) panel number 2252030115 E, dated 3/1/84, project is located in Zone "B", 
this area protected from the annual chance (100 year) flood by levee, dike or other structures subject to possible failure or 
over topping during larger floods. This project is the repair of a building to its pre-disaster condition and replacement of 
building contents which per flood recovery guidance, dated 04/1212006, where possible, all equipment and contents should be 
elevated at least 3 ft. above the highest adjacent grade elevation. A. C. Clark, Floodplain Specialist 

Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

181 No Effects on Wetland(s) and project located outside Wetland(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 
Record of Environmental Consideration 5 08/31106 


Reviewer Name: Brandon M. Clark Applicant: Recovery Sohonl District 
DisuterlEmergency/ProlnuDlProJeet Tide: DRl603LA I Hurrioane Katrina I Publio Assistance Program I EOR 2140-Barbara Jordan Elementary 
Sohool-Classroom Building G 

Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
C01'1'espondence/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: 

DI. 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 of action 
o (ii) 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 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; 
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. 

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. 

Comments: None 
Correspondence/Consultation/References: 


Reviewer Name: Brandon M Clark ApplicaDt: Recovery School District 
DIsa.terlEmergeDeylProgram!Project Tide: DRl603LA I Hurricane Katrina I Public Assistance Program I EOR 2240-Barbala Jordan ElementaJy 
School-Classroom Building G 

v. Environmental Review Project Conditions 

Project Conditions: 

1. In keeping with the stipulations ofthe P A, all proposed repair activities should be done in-kind to 
match existing materials and form .. Any change to the approved scope ofwork will require 
resubmission for re-evaluation under Section 106 and consultation with the SHPO. Noncompliance 
may jeopardize the receipt offederal funding. This concludes the Section 106 review 
for this project. 
2. This project is the repair ofa building to its pre-disaster condition and replacement of building 
contents which per flood recovery guidance, dated 04112/2006, where possible, all equipment and 
contents should be elevated at least 3 ft. above the highest adjacent grade elevation. 
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 ofthe project applicant shall handle, manage, and dispose of petroleum products, 
hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction of 
the governing local, state and federal agencies. 
4. 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 nonhazardous 
debris collection, staging, processing and disposal sites. 
5. In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the 
Louisiana Parishes ofCalcasieu, 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 of Agriculture and Forestry or his designee(s). 
6. 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 (EPAhazardous 
waste). The applicant is responsible for ensuring that renovation or demolition 
activities are coordinated with the Louisiana Department ofEnvironmental Quality for abatement 
activities and is also responsible for ensuring proper disposal in accordance with the previously 
referenced regulations. 
7. This project involves the demolition or renovation ofa public structure. Regardless of the 
asbestos content, the applicant is responsible for ensuring that renovation or demolition activities 
are coordinated with the Louisiana Department ofEnvironmental 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.m.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. 
8. Mercury containing devices -This project potentially involves the disposal of metallic 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