Reviewer Name: Brandon M. Clark Applicant: Recovery School District 
Disaster/EmergeocylProgramiProjed Title: DRI603LA I Hurricane Katrina I Public Assistance Program / E0R318S Mildred C. Osborne 
Elementary-Auxiliary Classroom Building 

Record of Environmental Consideration 


See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: EOR3185 Mildred C. Osborne Elementary-Auxiliary Classroom Building / 
PW 14973 

Project Location: 6701 Curran Road, New Orleans, Louisiana, Orleans Parish 70126 (N30.03346, W90.01605) 


Project Description: Project scope ofwork includes restoring the facility to its pre-disaster condition 
and upgrading to current codes and standards. Project activities consist ofrepairing and replacing 
bulletin boards and chalkboards, wireless network, wood faced base cabinets, plastic laminate 
countertops, interior/exterior wood doors and hardware, fire extinguishers, rain gutters, drywall, 
drinking fountains, HVAC units and electrical components, electrical breakers and switches, and 
cleaning. 

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) 


[g] (Long version) All applicable laws and executive orders were reviewed. Additional infonnation 
for compliance is attached to this REC. 

National Environmental Policy Act (NEP A) Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 

[g] Programmatic Categorical Exclusion -Category (xv) (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).
D Extraordinary Circumstances mitigated. (See Section IV comments) 


Are project conditions required? D Yes (see section V) 0 No (Review Concluded) 
D Environmental Assessment 

o Supplemental Environmental Assessment (Reference EA or PEA in comments)
D Environmental Impact Statement 

Comments: Refer to Programmatic Categorical Exclusion (pCE)-Restoration and/or Improvement ofInternal Facility 
Systems or Components and PCE-Restoration and/or Improvement ofExtemal Systems or Components dated 09/0112005. 
See attached. 

Record ofEnvironmental Consideration 

12119/06 


Reviewer Name: Brandon M. Clark Applicant: Recovery School District 
DisasterlEmergencylProgramlProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EORJI85 Mildred C. Osborne 
Elementary-Auxiliary Classroom Building 


Reviewer and Approvals 

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

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


Signature :t>~ fY). ~l Date _--"-,,12,,,-,/l,-,,-9,-=I2~OO=6:....-----!. 

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

Signa~=;,~ ...... 1r 

Date _~1=2/~19=/=20=O=6_--! 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

[8l Not type of activity with potential to affect historic properties. (Review Concluded) 

D Applicable executed Programmatic Agreement Otherwise, 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 
[8l 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 fmdingiSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmdingiSHPOffHPO 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 fmdingiSHPOffHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findingiSHPOffHPO 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 
[8l 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 fmdingiSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA fmdingiSHPOffHPO 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 findingiSHPOffHPO 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 SHPOffHPO concurrence on 
file) 
D No Adverse Effect Determination. (FEMA fmdingl SHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination. (FEMA fmdingl 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) 

Record of Environmental Consideration 2 

12119/06 


Reviewer Name: Brandon M. Clark Appliunt: Recovery School District 
Disaster/EmergencylProgramlProject Title: DRI603LA I Hurricane Katrina I Public Assistance Progtam I E0R3185 Mildred C. Osborne 
Elementary-Auxiliary Classroom Building 

Comments: 12119/2006 -According to the project officer, this facility was built in 1969. Brandon M. Clark, Environmental 
Specialist 

Correspondence/Consultation/References: 

B. Endangered Species Act 

I:8l 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 conunents 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 
detenninationlUSFWSINMFS 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 

I:8l 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 detenninationlUSFWS 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 of the U.S. (Review Concluded)

D Project would affect waters, including wetlands, ofthe U.S. 

D Project exempted as in kind replacement or other exemption. (Review Concluded)

D Project requires Section 404/401l0r Section 9/10 (Rivers and Harbors Act) permit, including qualification 

under Nationwide Permits. 

Are ro'ect conditions re uired? D YES see section eview Concluded 

Comments: Project is unlikely to affect waters ofthe 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) 

[8J Project is located in a coastal zone area and/or affects the coastal zone 
[8J State administering agency does not require consistency review. (Review ConclUded).
D State administering agency requires consistency review. 

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

Comments: 12/19/2006 -This project is located within the Louisiana Coastal Management Zone. LA DNR has detennined 
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. Brandon M. Clark, Environmental Specialist 

Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

[8J Project does not affect, control, or modify a waterwaylbody ofwater. (Review Concluded)
D Project affects, controls or modifies a waterwaylbody ofwater. 
Record ofEnvironmental Consideration 3 


12/19/06 


Reviewer Name: Brandon M. Clark Applicant: Recovery School District 
Disaster/EmergencylProgramiProjed Title: DR1603l.A I Hurricane Katrina I Public Assistance Program I E0R3l85 Mildred C. Osborne 
Elementary-Auxiliary Classroom Building

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 unlikely to affect waters of the United States. 
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 ofdesignated prime or unique farmland. 
D Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Form AD-I 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 

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) 

o Project has potential to take migratory birds. 

o Contact made with USFWS 
Are project conditions required? D YES (see section V) 0 NO (Review Concluded) 

Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09114/2005. 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: htt.p:llpacifictlyway.govlDocuments/Mississippi map.pdf, 

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 determination/USFWSINMFS concurrence on file)


D NOAA Fisheries provided no recommendation(s) (Review Concluded). 
Are project conditions required? 0 Yes (see section V) D No (Review Concluded) 

o NOAA Fisheries provided recommendation(s) 

D Written reply to NOAA Fisheries recommendations completed. 
Are ro' ect conditions re uired? D YES see section V 0 NO eview Concluded 


Comments: None 
Correspondence/Consultation/References: 

Record ofEnvironmental Consideration 4 12119/06 


Reviewer Name: Brandon M. Clark Applicant: Recovay School District 
Di.aster/Emergenc:y/ProgramlProjeet Title: DRI603 LA I Hurricane Katrina I Public Assistance Program I E0R3185 Mildred C. Osborne 
Elementary-Auxiliary Classroom Building 

K. Wild and Scenic Rivers Act 

t8l Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded)

oProject is along or affects WSR 

o Project adversely affects WSR as detennined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded)
oProject 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 FloodplainslFlood levels and project outside Floodplain -(Review Concluded)
t8l Located in Floodplain or Effects on FloodplainslFlood levels 

oNo adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
oBeneficial Effect on Floodplain OccupancyNalues (Review Concluded), 
t8l Possible adverse effects associated with invesbnent in floodplain, occupancy or modification of floodplain 
environment 


t8l 8 Step Process Complete -documentation on file 
Are project conditions required? t8l YES (see section V) 0 NO (Review Concluded) 

Comments: 12/19/2006-The City ofNew Orleans/Orleans Parish is enrolled in the National Flood Insurance Program 

(NFIP) as of8/3/1970. Per Flood Insurance Rate Map (FIRM) panel number 2252030115 e, dated 31111984, project is 

located within a Vl6 zone, area of 100-yr coastal flooding with velocity wave action; base flood elevations and flood hazard 
factors determined. Project is repair ofbuilding, and replacement ofbuilding contents, equipment, and components for 
which applicant is required to coordinate with local floodplain administrator regarding floodplain pennit(s) prior to the start 
ofany activities. Applicant is responsible for meeting all requirements of the permit(s). All coordination pertaining to these 
permit(s), should be documented to the local floodplain administrator and copies provided to LA GOHSEP and FEMA as 
part ofthe pennanent project files .. In compliance with EO 11988, an 8-step process was completed and attached. 
Elevation infonnation, signed and sealed by a licensed surveyor, engineer or architect must be obtained and filed for 
verification ofcompliance with 44 CFR 9.11, for the placement ofcontents, materials and equipment either flood proofed or 
above the Advisory Base Flood Elevation per the ABFE maps. Per 44 CFR 9.12, applicant must publish a final public 
notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LAOHS/OEP and 
FEMA for inclusion in the pennanent project files. T.Magilke, CFM 

Correspondence/consultation/references: 

B. E.O.11990 -Wetlands 

t8l 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 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 

t8l No Low income or minority population in, near or affected by the project -(Review Concluded) 
Record ofEnvironmental Consideration 5 

12119/06 


Reviewer Name: Brandon M. Clark Applicant: Recovery School District 
DisasterlEmergeney/ProgramfProjed Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EORJI8S Mildred C. Osborne 
Elementary-Auxiliary Classroom Building 
D 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? D YES (see section V) D 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 Enviromnental Assessment (EA) with the exception of(ii) which 
should be applied in conjunction with controversy on an enviromnental issue. If the circumstance can be mitigated, 
please explain in comments. Ifno, 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, ofalready existing poor envrromnental 


conditions; 
D (iv) Employment ofunproven technology with potential adverse effects or actions involving 
unique or unknown enviromnental risks; 
D (v) Presence ofendangered 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; 
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 of the enviromnent. 
D (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: 

V. Environmental Review Project Conditions 

Project Conditions: 

1. This project must comply with all conditions of the attached Programmatic Categorical Exclusion. 
2. Project is repair of building, and replacement of building contents, equipment, and components 


for which applicant is required to coordinate with local floodplain administrator regarding 
Record ofEnviromnental Consideration 6 

12119/06 


Reviewer Name: Brandon M. Clark Applicaot: Recovery School District 
Disa.ter/Emergency/ProgramiProject Title: DR I 603 LA I Hurricane Katrina I Public Assistance Program I EORJI8S Mildred C. Osborne t 
Elementary-Auxiliary Classroom Building 

floodplain permit(s) prior to the start ofany activities. Applicant is responsible for meeting all f 

requirements ofthe permit(s). All coordination pertaining to these permit(s), should be 

I


documented to the local floodplain administrator and copies provided to LA GOHSEP and 
FEMA as part of the permanent project files .. In compliance with EO 11988, an 8-step process 
was completed and attached. Elevation information, signed and sealed by a licensed surveyor, t 
engineer or architect must be obtained and filed for verification ofcompliance with 44 CFR 9.11, 

I


for the placement of contents, materials and equipment either flood proofed or above the 
Advisory Base Flood Elevation per the ABFE maps. Per 44 CFR 9.12, applicant must publish a 
final public notice 15 days prior to the start ofconstruction activities. Final public notice is to be 

I 


forwarded to the LAOHS/OEP and FEMA for inclusion in the permanent project files. 

3. Unusable equipment, debris and material shall be disposed of in an approved manner and 

I 


location. In the event significant items (or evidence thereof) are discovered during 
implementation of the project applicant shall handle, manage, and dispose ofpetroleum products, 
hazardous materials andlor toxic waste in accordance to the requirements and to the satisfaction 
of the governing local, state and federal agencies. 

4. Removal and disposal of debris 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 vn 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. 
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 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 of the Louisiana 
Department ofAgriculture 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 of Environmental 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 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 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. 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 of 
Emergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated 
October 3,2005. 


Monitoring Requirements: None 

Record ofEnvironmental Consideration 7 12/19/06