. Record of Environmental Consideration 

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

Project NamelNumber: Hughes Elementary School-Custodial Lodge/PW 16913vsn2 
Applicant Name: Recovery School District 
Project Location: 3519 Trafalgar St. New Orleans, LA 70119 
Latitude: 29.98782, Longitude: -90.08057 
Project Description: Hurricane Katrina caused catastrophic damage on August 29, 2005 to Langston 

Hughes Elementary School-Custodial Lodge. 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 ofanother existing RSD school. This 
project scope of work includes only the demolition and disposal of Langston Hughes Elementary SchooJCustodial 
Lodge. 

National Environmental Policy Act <NEP A) Determination 

D Statutorily excluded from NEPA review (Review Concluded) 
D Programmatic Categorical Exclusion 
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 

o Supplemental Environmental Assessment (Reference EA or PEA in comments)
D Environmental Impact Statement 
~ Scope ofwork 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 
District has conducted a satisfactory process of public involvement and outreach in its project development and is otherwise 
eligible for consideration under Alternative Arrangements for NEPA compliance. The Recovery School District is 
responsible for archiving public involvement materials. This material will be available at close-out for authentication and 

Isuch documentation will be made available for the closeout reviewer. 

D Project is Non-Compliant (see attached documentation justifYing selection). 
Reviewer and Approvals 
FEMA Environmental Reviewer: 


Name: Adam Borden, E . st, FEMA LA-TRO 

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FEMA Environmental Liaison Officer or Delegated Approving Official: 
Name: Cynthia Teeter, Deputy Environmental Liaison Officer, FEMA LA TRO 

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Record ofEnvironmental Consideration (Version April 2007) 

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

A. National Historic Preservation Act (NHP A)

D Not type of activity with potential to affect historic structures or archaeological resources (Review Concluded) 

D Activity meets Programmatic Agreement, December 3, 2004. Appendix A: Allowance No. 
Are project conditions required? D Yes (see Section V) D No . 
r8J Programmatic Agreement not applicable for historic structures or archeological sites, must conduct standard Section 106 
Review (see comments). 
D Other Programmatic Agreement dated applies 

HISTORIC BUILDINGS AND STRUCTURES 
D No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) 
[8J Building or structure listed or 45/50 years or older in project area and activity not exempt from review. 


[8J Determination of No Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) 
Are project conditions required? r8J 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/SHPO/THPO 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 scope of work has no potential to affect archeological resources (Review Concluded)
r8J Project affects only previously disturbed ground. (Review Concluded)
D Project affects undisturbed ground or grounds associated with a historic structure 


D Project area has no potential for presence of archeological resources 
D Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence 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 D Yes (see Section V) D No (Review Concluded)
D Determination of historic properties affected 
D NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file) 
Are project conditions required D Yes (see Section V) D No (Review Concluded) 
D NR eligible resources present in project area (FEMA finding/SHPO/THPO 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/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) 

Comments: FEMA, in consultation with the State Historic Preservation Officer (SHPO), has determined that the demolition 
of Langston Hughes Custodial Lodge and removal offoundation will have no effect on historic properties. 
Correspondence/Consultation/References: -Amber Martinez, Historic Preservation Specialist 

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) 

Record of Environmental Consideration (Version April 2007) 


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: 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 detennined in letters dated 
September IS, 200S for Katrina. 

C. Coastal Barrier Resources Act 

[gI 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 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: Project is not within a CBRA zone. 
Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced 04120/09. 


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 of Clean Water Act or Section 9/10 of Rivers and Harbors Act pennit, 
including qualification under Nationwide Pennits. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 




o Project would affect waters of the U.S. by discharging to a surface water body. 


Comments: No jurisdictional waters of the U.S., including wetlands, occur in the project area. 
Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwi/) queried 
on 04/20/09. 

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) 

[gI Project is located in a coastal zone area and/or affects the coastal zone 
[gI 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 detennined 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 \800-
276-4019. 
Corres ondence/ConsultationiRe erences: Louisiana Coastal Zone rna s ueried 04/20/09. 

F. Fish and Wildlife Coordination Act 

[gI 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. 


Record ofEnvironmental Consideration (Version April 2007) 


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/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana.gov/) queried 04/20109. 

G. Clean Air Act 

[gI 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: This project involves the renovation of a public structure. The proposed project includes 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 

[gI 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. 
D Farmland Conversion Impact Rating, Form AD-I006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPP A) is precluded. No 
prime or unique farmland present. 
Correspondence/Consultation/References: National Resource Conservation Service, Web Soil Survey 
(htto:llwebsoilsurvev.nrcs.usda.gov/aoo/) referenced 04/20109. 


I. Migratory Bird Treaty Act 

D Project not located within a flyway zone (Review Concluded) 
[gI Project located within a flyway zone. 
[gI Project does not have potential to take migratory birds (Review Concluded) 
Are project conditions required? D Yes (see section V) [gI 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. 
Correspondence/Consultation/References: USFWS guidance letter dated September 27,2005. 


J. Magnuson-Stevens Fishery Conservation and Management Act 

[gI 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) 

Record of Environmental Consideration (Version April 2007) 


Comments: Project is not located in any surface waters with the potential to affect EFH species. 
Correspondence/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana.govD referenced 04/20/09. 

K. Wild and Scenic Rivers Act 

[gI 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 determined by NPS/uSFS. FEMA cannot fund the action. 
(NPS/uSFS/uSFWS/BLM consultation on file) (Review Concluded)
o Project does not adversely affect WSR. (NPS/uSFS/uSFWS/BLM consultation on file) 
Are project conditions required? 0 YES (see Section V) 0 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. 

L. Resource Conservation and Recovery Act 

Slate Hazardous Materials and Solid Waste Laws and Resource Conservation and Recovery Act 
Comments: The renovation activities associated with this project may result in various types of debris and wastes, some of 
which may be hazardous. Therefore, all debris and waste must be treated, stored, and disposed of in a proper manner and 
location. (See Section V) 

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


[gI No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) 

o Located in Floodplain or Effects on FloodplainslFlood levels 

o No 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)
D Beneficial Effect on Floodplain Occupancy/Values (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: This 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 should be are-obligation of funds or changes to the scope of work. 
Correspondence/Consultation/References: Kimberly R. Rogers, Floodplain Management Specialist 

B. E.O. 11990 -Wetlands 

[gI No Effects on Wetland(s) and/or 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: No wetlands were determined to be present by checking the USFWS National Wetlands Inventory (NWI) maps. 
Correspondence/Consultation/References: USFWS NWI map accessed on-line. 
(http://wetiandsfws.er.usgs.gov/wtlnds/launch.html) 04/2012009. 

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

Record ofEnvironmental Consideration (Version April 2007) 


D Project scope of work has no potential to adversely impact any population (Review Concluded)
D No Low income or minority population in, near or affected by the project based on information gathered from [add a 
reference] (Review Concluded) 
[8J 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) 
[8J Disproportionately high or adverse effects on low income or minority population 
Are project conditions required? [8J YES (see Section V) D NO (Review Concluded) 

Comments The percent popUlations of 70 119 are: 72.1 % Black, 23.3% White, 5.6% Hispanic. The median household 
income in 1999 was $ 21,297 and 29.2% of families are below poverty level. 

This project involves the demolition and abandonment of a public school. Costs associated with rebuilding this school will 
be applied to the reconstruction of other schools throughout Orleans Parish. This action takes into consideration the changed 
demographics as a result ofthe storm; the changed cultural environment subsequent to the age of school integration; and the 
substandard functionality of the existing buildings. This action is considered to be the best alternative 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 closeout reviewer. 

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

04120109. 

III. Other Environmental Issues 

Identify other potential environmental concerns in the comment hox not clearly falling under a law or 
executive order (see environmental concerns scoping checklist for guidance). 


IV. Extraordinary Circumstances 

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


conditions; 
D (iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
D (v) Presence of endangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
D (vi) Presence of hazardous 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 ofthe 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. 


Record of Environmental Consideration (Version April 2007) 


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 ofFEMA 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 of the Louisiana Department of Agriculture and Forestry or 
his designee(s). 
• Applicant is responsible to ensure potential hazardous materials, ifany, shall be removed, handled, transported and 
disposed 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 ofthe discovery and take all reasonable measures to avoid or minimize 
harm to the finds. The applicant shall inform their Public Assistance (PA) contacts at FEMA, who will in tum 
contact FEMA Historic Preservation (HP) staff. The applicant will not proceed with work until FEMA HP 
completes 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 of the jurisdiction where the remains are located within twenty-four hours ofthe discovery. 
The applicant shall also notifY FEMA and the Louisiana Division ofArchaeology at 225-342-8170 within seventytwo 
hours of the discovery. If this scope of work and/or the footprint/location ofthe 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. 


Record of Environmental Consideration (Version April 2007)