Reviewer Name: Nicole Poret Projett NamefEnv Database No: City Hall Roof Radio Antenna System 
FEMA-1603/1607-DR-LA Parish: Orleans 


Record of Environmental Consideration 

REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 
See 44 Code of Federal Regulation Part 10 

Project NamelNumber: City Hall Roof Radio Antenna SystemIPW 158341 FIPS 071-55000-00 

Project Location: 1300 Perdido St., New Orleans, Orleans Parish, Louisiana 70112, Latitude: 
29.9526, Longitude: -90.07669 

Proiect Description: High winds from Hurricane Katrina caused catastrophic damage to the antenna 
system at the Emergency Operations System at New Orleans City HalL The system is comprised of five 
forty foot radio towers with 31 antennae ofvarious lengths attached to them and 24 free standing 
antennae. Three ofthe five forty foot towers were destroyed and various antennae on all the towers were 
destroyed. Twenty-one ofthe twenty-four free standing antennae were destroyed. The Hazard Mitigation 
Proposal is for the fabrication and installation ofheavy duty tower mounts. 

Documentation Requirements 

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) 

C8J (Long version) All applicable laws and executive orders were reviewed. Additional information for 
compliance is attached to this REC and/or included in project files, as applicable. 

National Environmental Policy Act (NEPAl Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category (Reference PCE in comments) (Review Concluded) 
o Categorical Exclusion - Category
o No Extraordinary Circumstances exist. 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded)
o Extraordinary Circumstances exist (See Section IV). 


o Extraordinary Circumstances mitigated. (See Section IV comments) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 


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


Comments: This project meets the definition of critical infrastructure (government and court administration buildings) under i 
the Alternative Arran ements for NEP A com liance. 

Reviewer and Approvals 

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

FEMA Environmental Reviewer: 
Name: Nicole Poret 



Reviewer Name: Nicole Poret Project NamelEnv Database No: City Hall Roof Radio Antenna System 
FEMA·160J/1607·DR·LA Parish: Orleans 


FEMA Regional Environmental Officer or Delegated Approving Official: 

NSl.amgnaeture:B~~

~-:::-:-:."c-Ic::::;;=----~~~p_~~.~~___Date 2r'lu --01


I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act (NHP A) 

D Not type of activity with potential to affect historic properties. 
[8J Activity meets Programmatic Agreement, December 3, 2004. Appendix A: Allowance No. II B I 
Are project conditions required? D Yes (see Section V) t'8:I No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

HISTORIC BUILDINGS AND STRUCTURES 
I:8l 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 ofNo Historic Properties Affected (FEMA finding!SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No <Review Concluded) 
D Determination of Historic Properties Affected (FEMA finding!SHPOITHPO 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!SHPOrrHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA finding!SHPO/THPO concurrence on file) 
D Resolution of Adverse Effect completed. (MOA on file) 
Are project conditions required D Yes (see Section V) D No <Review Concluded) 

ARCHEOLOGICAL RESOURCES 
D 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 finding!SHPOITHPO concurrence or 
consultation on file). <Review Concluded) 
D Project area has potential for presence of archeological resources 
D Determination of no historic properties affected (FEMA finding!SHPO/THPO concurrence on file) 
Are project conditions required DYes (see Section V) D No <Review Concluded) 
D Determination ofhistoric properties affected 
D NR eligible resources not present (FEMA finding!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 finding! SHPOITHPO concurrence on file) 

D No Adverse Effect Determination. (FEMA finding! SHPO/THPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No <Review Concluded) 
D Adverse Effect Determination. (FEMA finding! SHPOITHPO concurrence on file) 

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

Comments: FEMA's Programmatic Agreement (PA), dated December 3, 2004, provides for expedited project review under 
Section 106 ofthe 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}, {B· 1 }, 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 offederal funding. This concludes the Section 106 review for this project. 

Correspondence/Consultation/References: NHPA effect determinations made by Derek A. Galose, FEMA Historic 
Preservation Specialist. 

2


Reviewer Name: Nicole Poret Project NamelEnv Database No: City Hall Roof Radio Antenna System 
FEMA·1603/1607·DR·LA Parish: Orleans 

B. Endangered Species Act 

181 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
(Review Concluded) 

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

o No effect to species or designated critical habitat (See comments for justification) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 
o May affect, but not likely to adversely affect species or designated critical habitat (FEMA 


detenninationlUSFWSINMFS concurrence on file) (Review Concluded) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 


o Likely to adversely affect species or designated critical habitat 

o Fonnal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 

Comments: 
Correspondence/Consultation/References: Endangered Species Summary for USFWS Consultation, letter to Don Fairley 
dated September 15,2005 

C. Coastal Barrier Resources Act 

181 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 detenninationlUSFWS consultation on file) 

o Proposed action an exception under Section 3505.a.6 (Review Concluded) 
o Proposed action not excepted under Section 3505.a.6. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: 
Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced March 26, 2007. 


D. Clean Water Act 

[:gI Project would not affect any waters ofthe U.S. <Review Concluded) 

o 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 404/401/0r Section 9/10 (Rivers and Harbors Act) penn it, including qualification under 
Nationwide Penn its. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: 
Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil)queried on 
March 26, 2007. 


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) 

181 Project is located in a coastal zone area and/or affects the coastal zone 
181 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) 

Corres ondence/Consultation/Re erences: Louisiana Coastal Zone rna s ueried on March 26, 2007 

F. Fish and Wildlife Coordination Act 

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

o Project affects, controls or modifies a waterwaylbody ofwater. 

o Coordination with USFWS conducted 

o No Recommendations offered by USFWS. (Review Concluded)
o Recommendations provided by USFWS. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Record of Environmental Consideration (Version 3/14/06) 


Reviewer Name: Nicole Poret Project Name!Env Database No: City Hall Roof Radio Antenna System 
FEMA-1603/1607-DR-LA Parish: Orleans 

Comments: 
Correspondence/ConsultationlReferences: Damage description and scope of work from Project Worksheet # 15834 


G. Clean Air Act 

[8J 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: 
Correspondence/Consultation/References: EPA Region 6 Non·attainment Map, Damage description and scope ofwork from 
Project Worksheet # 15834 

H. Farmland Protection Policy Act 

[8J Project does not affect designated prime or unique fannland. (Review Concluded)
D Project causes unnecessary or irreversible conversion ofdesignated prime or unique fannland. 
D Coordination with Natural Resource Conservation Commission required. 
D Fannland Conversion Impact Rating, Fonn AD-I006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 


I. Migratory Bird Treaty Act 

D Project not located within a flyway zone. (Review Concluded) 
[8J Project located within a flyway zone. 
[8J Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) [8J 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 USFWS 
migratory bird management program. Height of antennas will remain the same as pre·stonn conditions and should have no 
adverse effect on migratory birds. 
Correspondence/Consultation/References: http://library.fws.govlPubslMississippi]lywaymap.pdf, Damage description and 
scope of work from Project Worksheet # 15834 

J. Magnuson-Stevens Fishery Conservation and Management Act 

[8J Project not located in or near Essential Fish Habitat. (Review Concluded) 
D Project located in or near Essential Fish Habitat. 
D Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Are project conditions required? D Yes (see Section V) D No (Review Concluded)
D Project adversely affects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS concurrence on file) 
D NOAA Fisheries provided no recommendation(s) (Review Concluded), 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D NOAA Fisheries provided recommendation(s) 
D Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments: Project is not located in or near any surface waters with the potential to affect EFH species. 
Correspondence/ConsultationlReferences: Damage description and scope ofwork from Project Worksheet # 15834 

4


Reviewer Name: Nicole Poret Project Name/Euv Database No: City Hall Roof Radio Antenna System 
FEMA·1603/1607·DR-LA Parish: Orleans 
K. Wild and Scenic Rivers Act 

IZl 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 NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) <Review Concluded)
o Project does not adversely affect WSR (NPSIUSFSIUSFWSIBLM consultation on file) 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: 
Correspondence/Consultation/Rejerences: National Wild and Scenic Rivers http://www.nps.gov/rivers/wildriverslist.html. 


L. Other Relevant Laws and Environmental Regulations 

Resource Conservation and Recovery Act 
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 (such as asbestos and lead based paint) and/or toxic waste in accordance to the 
requirements and to the satisfaction ofthe governing local, state and federal agencies. 

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


o No Effect on FloodplainslFlood levels and project outside Floodplain· (Review Concluded) 
IZl Located in Floodplain or Effects on FloodplainslFlood levels 

[81 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 0 Yes (see Section V) [81 No (Review Concluded) 

o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). 
o Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 


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

Comments: The city of New Orleans/Orleans Parish is enrolled in the National Flood Insurance Program (NFIP) as of 
08/0311970. Facility is located within an "A I" zone, area of 1OO-yr flooding, base flood elevations and flood hazard factors as 
detennined per Flood Insurance Rate Map (FIRM) panel number 225203 0 160E, dated 03/0111984. Project is for repair of 
rooftop radio antenna systems (damaged by wind) which is not likely to affect any floodplain. 
Correspondence/ConsultationiRejerences: FEMA Flood Insurance Rate Map, Community Panel No. 2252030160E, dated 
08/0311970. Kara Knott, CFM 

B. E.O. 11990 -Wetlands 

[81 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 
o 8 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 






Comments: 
Correspondence/ConsultationiRejerences: USFWS NWI map accessed on-line March 26, 2007. 


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

[81 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) 


5


Reviewer Name: Nicole Pore! Project Name/Env Database No: City Hall Roof Radio Antenna System 
FEMA-1603/1607-DR-LA Parish: Orleans 

Comments: The percent populations of10112 are: 15.0 %, African American 19.0 % White and 4.3 % Asian. The median 
household income in 1999 was $1,448 and 15.1 % of families are below poverty level. 
CorrespondenceiConsultationiRejerences: U.S. Census bureau 2000 data at http://factfinder.census.gov, referenced March 
26,2001. 

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). 

NEPA Compliance for Alternative Arrangements: 
In order to comply with the NEPA process, and because ofthe potential for this project to have an adverse impact on the 
environment, including the social and economic environments, prior to initiating the project, the applicant must prepare a 
public involvement plan and conduct a public involvement process. FEMA's Environmental and Historic Preservation (EHP) 
staff can provide guidance to determine how much and what type of public involvement is appropriate for a given project. If 
needed, the public outreach group can assist you in designing and implementing a public involvement program. Copies ofany 
articles, public notices, meeting minutes, and public comments should be provided to FEMA to become part ofthe project 
record. 

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. 

Yes 

o (i) Greater scope or size than normally experienced for a particular category of action 
o (ii) Actions with a high level of public controversy 
o (iii) Potential for degradation, even though slight, ofalready existing poor environmental 
conditions; 
o (iv) Employment ofunproven 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; 
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 of the 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: 

V. Environmental Review Project Conditions 

Project Conditions: 

I) 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 of 
petroleum products, hazardous materials (such as asbestos and lead based paint) and/or toxic waste in accordance to the 

6

Record of Environmental Consideration (Version 3/14/06) 


I 


r 

t 

I ~ 

I 


Reviewer Name: Nicole Pore! Project NamelEnv Database No: City Hall Roof Radio Antenna System 
FEMA-1603/1607-DR-LA Parish: Orleans 
accordance to the requirements and to the satisfaction of the governing local, state and federal agencies. 

2) In order to comply with the NEPA process, and because of the potential for this project to have an adverse impact on the 
environment, including the social and economic environments, prior to initiating the project, the applicant must prepare a 
public involvement plan and conduct a public involvement process. FEMA's Environmental and Historic Preservation (EHP) 
staff can provide guidance to detennine how much and what type ofpublic involvement is appropriate for a given project. If 
needed, the public outreach group can assist you in designing and implementing a public involvement program. Copies ofany 
articles, public notices, meeting minutes, and public comments should be provided to FEMA to become part ofthe project 
record. 

7