Record of Environmental Consideration 


See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: st. Joseph Street Call Center Phone System / PW 14019 

Project Location: 625 St. Joseph Street, New Orleans, Louisiana Orleans Parish 70165 
(N29.9441, W-90.07118) 

Project Description: Project activities include removing and replacing workstations, switch boards, 
and the complete phone system which includes the call distribution system and 30 Meridian phones. 
The complete phone system was located in the basement. Hazard mitigation will be accomplished 
through a proposal to relocate the phone system to the third floor ofthe St. Joseph Street building. 

Documentation Reg uirements 

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) 
[8J (Long version) All applicable laws and executive orders were reviewed. 
compliance is attached to this REC. 
Additional information for 

National Environmental Policy Act (NEP A) Determination 

~~~~~~~-'~[J Statutorily excluded fromi"fEPA review. (Reyiew Concludedr) ~~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) 
[8J Environmental Impact Statement 

Comment: Although this project would have qualified as a CATEX (xv and xvi) under 44 CFR part 10.8 (dX2), this project 
meets the defmition ofcritical infrastructure (Utilities and Wastewater Treatment Plants) under the Alternative 
Arrangements for NEPA compliance. This project has conditions and requires mitigation under the other 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 

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

FEMA Environmental Reviewer. 
Name: Perry J. Boudreaux, Environmental Specialist 


Signature ~LĄ: . Date_~9/-=2=O/-=2=OO~6,----___-----=. 

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

Signature ~~?.......-;z . Date_------"9..:....:/2=O:..:....:I2=O:....::;O-=-6____~ 


I. Compliance Review for Environmental Laws (other than NEP A) 

A. National Historic Preservation Act 

181 Not type ofactivity with potential to affect historic properties. <Review Concluded) 

D Applicable executed Programmatic Agreement December 3, 2004 
D Activity meets Programmatic Allowance Sections 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
181 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 Detennination ofNo Historic Properties Affected (FEMA fmdingiSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Detennination of Historic Properties Affected (FEMA fmdingiSHPOffHPO concurrence on file) 
D Property a National Historic Landmark and National Park Service was provided early notification 

durin the consultation rocess. If not, ~j>~la=in"':-:=in'-'c':::.:0c'::mm===e:-cn=ts==c=_-----. 
No Adverse Effect Detennination (FEMA findingiSHPO/THPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 


D Adverse Effect Detennination (FEMA fmdingiSHPOITHPO 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 
181 Project affects only previously disturbed ground. <Review Concluded) 
D Project affects undisturbed ground. 

D Project area has no potential for presence ofarcheological resources 
D Detennination of no historic properties affected (FEMA fmdingiSHPOITHPO concurrence or 
consultation on file). <Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Detennination of no historic properties affected (FEMA findingiSHPOITHPO concurrence on file) 
Are project conditions required D Yes (see section V) D No <Review Concluded) 
D Detennination of historic properties affected 
D NR eligible resources not present (FEMA fmdingiSHPOITHPO 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 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 findillgl SHPOITHPO concurrence on file) 

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

Comments: 09.20.2006 The project activities as described in the scope of work will have no effect on Historic Resources as 
they involve the replacement of building contents only. No Historic Preservation review is required. This concludes the 
Section 106 review for this project. Perry J. Boudreaux, Environmental Specialist. 

ICorrespondence/Consultation/References: 

B. Endangered Species Act 

I8J 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. 

oNo 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 

I8J 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 3S0S.a.6? (Review Concluded)
o Proposed action not excepted under Section 3S0S.a.6. 
Are project conditions required? 0 YES (see section V) 0 NO <Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 

I8J 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: Project is not in or adjacent to any waterways of the US. 
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) 

I8J Project is located in a coastal zone area and/or affects the coastal zone 
I8J 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 Department of Natural 
Resources 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. 

Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modify a waterway/body of water. (Review Concluded) 
D Project affects, controls or modifies a waterway/body 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: Project is not in or adjacent to any waterways of the US. 
Correspondence/Consultation/References: 

G. Clean Air Act 
181 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 
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. 

o Farmland Conversion Impact Rating, Form AD-..-llI+OIfIOIh6-;,c~o"'n"'1pn1llf'!etfte~df---.--------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) 
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 
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/Documents/Mississippi map.pdf, 

09/20/06


J. Magnuson-Stevens Fishery Conservation and Management Act 

181 Project not located in or near Essential Fish Habitat. <Review Concluded) 

o Project located in or near Essential Fish Habitat. 

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 detenninationlUSFWSINMFS 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 NPS/USFS. FEMA cannot fund the action. 
(NPS/uSFS/uSFWSIBLM consultation on file) <Review Concluded) 
o Project does not adversely affect WSR. (NPS/uSFS/uSFWSIBLM 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 

____ -ClNo Effect on FloodplainsfFlood 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 offloodplain 
environment 


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

Comments 09/18/06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) 
on 08-03-70. Per Flood Insurance Rate Map (FIRM) panel number 2252030160e dated 03-01-84, project is located in 
Zone "B", area protected from 100-yr flood by levee, dike, or other structure subject to failure or overtopping during larger 
floods. Project is replacement of contents, which per flood recovery guidance, dated 04/12/2006, should, where possible 
relocated or elevated to an elevation of at least 3 feet above ground level. A. Cramer FPM Specialist. 

Correspondence/Consultation/References: 

I 


I 


I 


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 
o Review completed as part of floodplain review 







o8 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 
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 

oNo disproportionately high and adverse impact on low income or minority population-(Review Coneiuded) 
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 otber 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 tbe review of compliance with otber environmental laws and Executive Orders, and in 
consideration of otber 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, 
"--~..___.m·--·please explam m comments. If-no~M]eave---6Iarik. ~--~-----


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 ofendangered 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 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 flood recovery guidance, dated 04/12/2006, contents and equipment should, where possible 
be relocated or elevated to an elevation ofat least 3 feet above ground level. 
2. Unusable equipment, debris and material shall be disposed of in an approved manner and 
location. In the event significant items (or evidence thereot) 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. Mercury containing devices -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 of Environmental Quality (LDEQ) "Declaration ofEmergency; 
Mercury-containing Devices and Electronic Equipment as Universal Waste" letter dated 
October 3, 2005. 


Monitoring Requirements: None 

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