Record of Environmental Consideration 

REVISED FOR FEMA ENVIRONMENTAL --LOUISIANA 
See 44 Code of Federal Regulation Part 10 

Project NamelNumber: Shaw Elementary School-Portablesl-3-PW 15048V4 

Applicant Name: Recovery School District 
Project Location: 2518 Arts Street Street New Orleans, Louisiana 70117 
Latitude: 29.98369 Longitude: -90.05104 

Project Description: Hurricane Katrina caused catastrophic damage on August 29,2005 to Shaw 
Elementary School. This project is one among a total of22 contributing (donor) facilities approved by FEMA 
for replacement. The Recovery School District chooses to use eligible funds for this replacement project (less 
demolition costs) towards the renovation of another existing RSD school. This project scope of work includes 
only the demolition and disposal of Shaw Elementary School. 

" "tio" iE vironmental Polic Act EPA Determination (} ~ : 
-'" 'Statut'orily excluded from NEPA review (Review Concluded) 
0'Progranimatic Categorical Exclusion 

o Cate'gorical Exclusion -Category 
O. No Extraordinary Circumstances exist. 
-. A.t&~roject conditions required? 0 Yes (see section V) 0 No &,e\ri"c\v 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)
o Environmental Impact Statement 
r8J Scope of work requires public involvement plan 


Comments: This project meets the criteria to utilize the Alternative Arrangements process within the National 
Environmental Policy Act (NEPA) approved by the Council on Environmental Quality, Department of Homeland Security, 
and FEMA on 3/23/06, Based on documentation provided by the applicant, FEMA has determined that the Recovery School 
Qfstfidiihs-cohl:iucted a satisfactory process of public involvement and outreach in its prbJeetdevelopment and is otherwise 
e'iigibl~ for contideration under Alternative Arrangements for NEPA compliance. The Recovery School District is 
responsibltl :fqr·archiving public involvement materials. This material will be available at close-out for authentication and 
such d6cUlneIitation will be made available for the closeout reviewer. 

.. II, 

o Project is Non-Compliant (see attached documentation justifying selecti0j~SI~:'\:' . d 
Reviewer and Approvals 

ental Specialist, FEMA LA-TRO j ( / 

mental Reviewer: 
Signature --t--...""...<----".I--"----h'----f----1F---i'-------Date 

tf22{OJ 

FEMA Environmental Lial 
eeter, Deputy Environmental Liaison Officer, FEMA LA TRO)· 
Officer or Delegated Approving Official: 

Name:.Cynthia 

S'ig~~e "\ f'r\ r-(.~{ 'i 16i~'~:,\';'

Date 

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'. I;;' I",! ' ~ ~ : 

Record ofEnv~ronmental Consideration (Version April 2007) 



I. Compliance Review for Environmental Laws (other than NEPA) 

A. National Historic Preservation Act (NHP A)

o Not type ofactivity with potential to affect historic structures or archaeological resources (Review Concluded) 
o Activity meets Programmatic Agreement, December 3,2004. Appendix A: Allowance No. 
Are project conditions required? 0 Yes (see Section V) No 
IZI Programmatic Agreement not applicable for historic structures or archeological sites, must conduct standard Section 106 
Review (see cot;nments). 


o Other Programmatic Agreement dated applies 


HISTORIC BUILDINGS AND STRUCTURES 
ONo historic properties that are listed or 45/50 years or older in project area. (Review Concluded)
IZI Building or structure listed or 45/50 years or older in project area and activity not exempt from review. 


IZI Determination of No Historic Properties Affected (FEMA findingiSHPOITHPO concurrence on file) 
Are project conditions required? IZI Yes (see Section V) 0 No (Review Concluded) . 
Determination of Historic Properties Affected (FEMA findingiSHPOITHIJO' c~ncurrence on fire) 


o Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. If not, explain in comments 
o No Adverse Effect Determination (FEMA findingiSHPO/THPO concurrence on file) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 
Adverse Effect Determination (FEMA findingiSHPOITHPO 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) 

ARCHEOLOGICAL RESOURCES 

oProject scop.e of work has no potential to affect archeological resources (Review Concluded)
IZI Project aff~ts only previously disturbed ground. (Review Concluded) 
oProject affects undisturbed ground or grounds associated with a historic structure 
l. . O·Pr.oject area has no potential for presence of archeological resources 


,.' i . ,p' Determination ofno historic properties affected (FEMA findingiSHPO/THPO concurrence on file) 
" I, ' (Review Concluded) .. 

o project area has potential for presence of archeological resources i i;' );; 

. ,,0 Determination ofno historic properties affected (FEMA finding4SijQPIJHPO concurrence on file) 
Are project conditions required 0 Yes (see Section V) 0 NO'@ltY(ew Concluded) 

o Determination ofhistoric properties affected 

o NR eligible resources not present (FEMA findingiSHPO/THPO concurrence on file) 
Are project conditions required Yes (see Section V) 0 No (Review Concluded) 
o NR eligible resources present in project area (FEMA findingiSHPO/THPO concurrence on file) 
o No Adverse Effect Determination (FEMA findingl SHPOITHPO concurrence on file) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 
o Adverse Effect Determination (FEMA findingiSHPO/THPO 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) 

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Commeflts: -This comment supersedes the HP comment and LIDS stipulations made by Dana Linck on 12/15/06. A 
reviewofVersjon 4 of this project was conducted in accordance FEMA's Programmatic Agreement dated December 3, 
2004. FEMA has determined that No Historic Properties are affected by the demolition 9'~ ~l,l~ modulars and pier/foundation 
removal;:tt Snaw Elementary School. SHPO concurrence with this determination was receiveo, dated 12/10/2007. The 
review o'fthe Alternate project associated with this PW will be documented in PW 18597, T~e applicant must comply with 
the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) andtJi~l~Qvertent Dis,@very Clause, 
which can be found under the Environmental Review NHPA conditions. -Amber Marti1i;l~ ~istoric Preservation Specialist 
and Jerame Cramer, Archaeologist 
Correspondence/Consultation/References: Amber Martinez, Historic Preservation Specialist and Jerame Cramer, 
Archaeologist 

B. Endangered Species Act 

Record of Environmental Consideration (Version April 2007) 

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~No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
Review Co:i1c)lided 
Listed speCies and/or designated critical habitat present in the areas affected directly 'or'iodirectly by the Federal action. 

oNo 'effect to species or designated critical habitat. (See comments for justific.~dpn) 

,i . Af~project conditions required? 0 Yes (see Section V) 0 No (Review Concluded)
D May affect, but not likely to adversely affect species or designated critical habitat (FEMA 
determinationlUSFWSINMFS concurrence on file) (Review Concluded)" L .' 
, Ar~ project conditions required? 0 Yes (see Section V) 0 No (Review"CgnCiuded) 


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: Project is located in an urban or previously developed area. Neither listed species nor their habitat occur in or 
near this site, thus FEMA finds there will be no effect to threatened or endangered species. 
Correspondence/Consultation/References: USFWS emergency consultation provisions determined in letters dated 
September IS, 200S for Katrina. 

C. Coastal Barrier Resources Act 

~Project is n~t on or connected to CBRA Unit or Otherwise Protected Area (Review c'o'ii~luded).

o Projett is blt'or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 

file) ., 0 • .' :~'.; 

o Proposed action an exception under Section 3S0S.a.6 (Review Concluded) ,:" 
o Ptoposed action not excepted under Section 3S0S.a.6, ' 
Me' project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


.! 

Comments: Project is not within a CBRA zone.::: 
Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced 04/21109. 

D. Clean Water Act 

~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 404/401 ofClean Water Act or Section 9/10 of Rivers and Harbors Act permit, 
including qualification under Nationwide Permits. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded)


D Projec~ wqu!d affect waters ofthe U.S. by discharging to a surface water body . 

. , }.' 'I, 

, . 

Comments: No'jurisdictional waters ofthe U.S., including wetlands, occur in the projectart;.i: 
Correspondence/ConsultationlReferences: USFWS National Wetlands Inventory map (http://www.fws.gov/nwi/) queried 
on 04/21/09. 

E. Coastal Zone Management Act.:t;:;-rr 

o Pr<tieet is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 

~Project is located in a coastal zone area and/or affects the coastal zone 
~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 of 
federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still 
require a coastal use pennit or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1800-
276-4019. 
Correspo"dence/Consultation/References: Louisiana Coastal Zone maps queried 04/21109 .. 

F.Fish and Wildlife Coordination Act 

[8J Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) 
R.ecord of Environmental Consideration (Version April 2007) 

1.:\,' 


Reviewer Name: Catherine Jones Project Name: Abrams Elementary School-Portable 1-3 
FEMA-1603-DR-LA Parish: Orleans 
. 't ~. 

D Project affects, controls or modifies a waterwaylbody of water. 

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: No streams or water bodies are located in or near the project area. . 
Correspondence/Consuliation/References: Louisiana Map (http://wwwlamap.doa.louisi~na.gov/) queried 04/21/09. 

G. Clean Air Act 

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

o Project is lOCated in an attainment area. (Review Concluded) 
o Project is located in a non-attainment area. , . 
D Cqordination required with applicable state administering agency. 
. Are project conditions required? D YES (see section V) D NO (Review Concluded) 


Comme~ts: This project involves the renovation of a public structure. The proposed prQjectit;lcludes activities that would 
produce a minor, temporary, and localized impact on air quality from fugitive dust particles. No long-term air quality 
impact'is anticipated. 
Correspondence/Consultation/References: EPA Region 6 Non-attainment Map. 


H. Farmland Protection Policy Act 

~Project will not affect undisturbed ground. (Review Concluded) 
D Project has a zoning classification that is other than agricultural or is in an urbanized area. (Review Concluded) 
D 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 Resources Conservation Service required. 
. • it, D Farmland Conversion Impact Rating, Form AD-I006, completed . 
.i,:' .'.' Are project conditions required? D YES (see section V) D NO (Review Concluded) 

;':~.' 

Commen'is: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No 
prime or uniqu~-farmland present. 
Correspondence/Consultation/References: National Resource Conservation Service, We,qSoil Survey 
(http://websoilsurvev.nrcs.usda.gov/app/ ) referenced 04/21109. 


~. (. 

~ '.t'" \ \ I., 

I. Migratory Bird Treaty Act 

D Project not located within a flyway zone (Review Concluded) 
~Project located within a flyway zone. 
r8J Project does not have potential to take migratory birds (Review Concluded) 
Are project conditions required? D Yes (see section V) ~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: The site is an existing disturbed area with little value to migratory birds and would not be included in the 
USFW~ migratory bird management program. . .'. 
Correspondence/Consultation/References: USFWS guidance letter dated September 27~2'6()5. 

:~.... 

\.' '. ~ \. 

J.MagnU,son-Stevens Fishery Conservation and Management Act 

~Project notlocated in or near Essential Fish Habitat (Review Concluded) 2.,

C,' 

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 Conc'luded) 
D 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? D Yes (see Section V) D No (Review Concluded) 

Record of Environmental Consideration (Version April 2007) 


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:Project is not located in any surface waters with the potential to affect EFH spedes. 
Correspondence/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana.govD referenced 04/21109. 

K. Wild and Scenic Rivers Act 

IZI Project isn~t along and does not affect Wild or Scenic River (WSR) -(Review Conduded)

D Project is along or affects WSR .. 
Project adversely affects WSR as determined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFS/USFWS/BLM 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: Project is not along and does not affect Wild or Scenic River (WSR). 
Correspondence/Consultation/References: National Wild and Scenic Rivers http://www.nps.gov/rivers/wildriverslist.html. 

't ....:

L. Resource Conservation and Recovery Act 

State Hazardous Materials and Solid Waste Laws and Resource Conservation and RecoVe!YAct 
Comm;it~s: Th~'renovation activities associated with this project may result in various@ei~bfdebris and wastes, some of 
which rna)i De' liazardous. Therefore, all debris and waste must be treated, stored, and disp(j~ed of in a proper manner and 
location. (See Section V) . 

II. C.inr6liance Review for Executive Orders 
A. E.O. 11988 -Floodplains 



IZI No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded)
D Located in Floodplain or Effects on Floodplains/Flood levels 
D No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 

Are project conditions required? D 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 

envjronment 
. '.' D 8 Step Process Complete -documentation on file 
Are project conditions required? D YES (see Section V) D NQ.(Review Concluded)

'. '_ •. '_ .. L .


\ " 

Cq",ments~ Th,is version is for the demolition of the facility. The remaining replacement funds will be de-obligated and 
applied to an alternate project involving another facility. No further floodplain review will be forthcoming for PW listed 
unless there shbuld be a re-obligation of funds or changes to the scope of work. 
CiJrrespimdenci!JConsultation/References: Kimberly Rogers, Environmental Specialist~Fldodplain 

B. E.O.11990 -Wetlands 

IZI No Effects on Wetland(s) and/or 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 offloodplain review 

D 8 Step Process Complete -documentation on file 

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

IComments: No wetlands were determined to be present by checking the USFWS Nation~!.:~:tlands Inventory (NWI) maps. I 
Record of Environmental Consideration (Version April 2007) 

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Correspondence/Consultation/References: USFWS NWl map accessed on-line. 
(htt :IIWetlandsfws.er.us s. ov/wtlnds/launch.html 04/22/2009. 

C. E.O. 12898 -Environmental Justice for Low Income and Minority Populations 

o Project scope of work has no potential to adversely impact any population (Review Concluded) 
o No Low income or minority population in, near or affected by the project based on information gathered from [add a 
reference] (Review Concluded) 


[8] 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) 

[8] Disproportionately high or adverse effects on low income or minority population 
Are project conditions required? [8] YES (see Section V) 0 NO (Review Concluded) 


Comments The percent populations of70117 are: 31.9% Black, 64% White, and 3.0% I-{i$panic. The median household 
income in 1999was $ 40,160 and 15.0% offamilies are below poverty level. .... 

This project involves the demolition and abandonment ofa public school. Costs associated with rebuilding this school will 
be applied to tlie reconstruction of other schools throughout Orleans Parish. This action takes into consideration the changed 
demographics as a result of the storm; the changed cultural environment subsequent to the age of school integration; and the 
substandatd'runctionality ofthe existing buildings. This action is considered to be the be~talternative for the welfare of the 

studentS. ,;, . ' 

One of the main goals of the RSD Master Plan was to ensure the maximization of public involvement and develop a plan 
that is embraced by the public. Numerous public meetings were held in developing the Master Plan. The meetings were 
meticulously documented and public comments were correlated for consideration in the plan. 

The Recovery School District is responsible for archiving public involvement materials. This material will be available at 
close-out for authentication and such documentation will be made available for the c1oseout.reviewer. 

Correspondence/Consultation/References: U.S. Census bureau 2000 data at http://factfinder.census.gov, referenced 

04121/09. 

III. Other Environmental Issues 

Identifyhther potential environmental concerns in the comment box not cle~rly falling under a law or 
executive order (see environmental concerns scoping checklist for guidance)., 

; ~ , , I ,,' ,';-' : 


IV. Extraordinary Circumstances 

Yes 
0 (i) Greater scope or size than normally experienced for a particular category of action 
0 (ii) Actions with a high level of public controversy , 
D (iii) Potential for degradation, even though slight, of already existing poor environmental 

conditions; 

(iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 

0 

. 
.
, , ' 

0 (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 

:Hf 

0 ',: (vi~ Presence of hazardous or toxic substances at levels which exceed Federal, state or local 
regulations or standards requiring action or attention; . 

(vii) Actions with the potential to affect special status areas adversely or other critical resources 
sl.{ch as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, 
sole or principal drinking water aquifers; 

0 

(viii) Potential for adverse effects on health or safety; and 

0 

Record of Environmental Consideration (Version April 2007) 


D (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 
protection of the environment. 

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 of the 
proposed action may not be significant by themselves. ' .• ' 

.. ,.

IComments: 

V. Environmental Review Project Conditions 

Project Conditions: 

This project must comply with all conditions of the attached Programmatic Categorical Exclusion. In 
addition, the following conditions apply as a condition of FEMA funding reimbursement; 

• In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parish of 
Orleans is 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 ofthe Louisiana Department ofAgriculture and Forestry or 
his designee(s). 

.. /. I 

• Appl'idint is responsible to ensure potential hazardous materials, ifany, shall be removed, handled, transported and 
dispos~d of in accordance with local, state and federal compliance requirements, ....... 
• 'if during the course of work, archaeological artifacts (prehistoric or historic) or human remains are discovered, the 
applicant shall stop work in the vicinity of the discovery and take all reasonable measures to avoid or minimize 
harm to the finds. The applicant shall inform their Public Assistance CPA) contaitS'llt FEMA, who will in tum 
contactFEMA Historic Preservation (HP) staff. The applicant will not proceed with 'work until FEMA HP 
! 'compi~tes consultation with the 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 of the discovery. 
The applicant shall also notify FEMA and the Louisiana Division of Archaeology at 225-342-8170 within seventytwo 
hours ofthe discovery. If this scope of work and/or the footprint/location of the new building changes, this 
project will need to be resubmitted for further Section 106 review prior to ground disturbing activities taking place. 
Failure to comply with these stipulations may jeopardize receipt of federal funding. 


• The Recovery School District is responsible for archiving public involvement materials. This material will be 
available at close-out for authentication and such documentation will be made available for the closeout reviewer. 



1':", 

Record ofEnvironmentaJ Consideration (Version April 2007)