Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: Howard Hall / PW 8976 

Project Location: 2601 Gentilly Blvd., New Orleans, Louisiana, Orleans Parish 70122 (N29.59799, 
W-90.03936) 

Project Description: Project activities include removing and replacing roof, interior wood doors, 
subfloor, carpet, air condensing units, office desks, credenzas, bookshelves, chairs, tables and computer 
workstations; installing fiberglass insulation, gypsum wallboard, toilet fixtures and accessories, wash 
basin, ADA assist bars, resilient flooring, and cove base; painting walls and ceilings; repairing window 
pane and fire alarm system; and rewiring electrical receptacles. Hazard mitigation includes elevating 
the existing 5 feet by 20 feet concrete slab by 2 feet above the existing slab elevation. The new slab 
will be tied to the existing slab with dowels and epoxy. In addition, hazard mitigation will be achieved 
by compliance with current codes and standards and by good construction practices. 

Documentation Requirements 

D No Documentation Required <Review Concluded) 

D (Short version) All consultation and agreements implemented to comply with the National Historic 
Preservation Act, Endangered Species Act, and Executive Orders 11988, 11990 and 12898 are 
completed and no other laws apply. (Review Concluded) 

C8J (Long version) All applicable laws and executive orders were reviewed. Additional information for 
compliance is attached to this REC. 

National Environmental Policy Act (NEPA) Determination 

D Statutorily excluded from NEP A review. (Review Concluded)
D Programmatic Categorical Exclusion -Category <Review Concluded)
D Categorical Exclusion -Category


D No Extraordinary Circumstances exist. 

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

D Extraordinary Circumstances exist (See Section IV). 

D Extraordinary Circumstances mitigated. (See Section IV comments) 

Are project conditions required? D Yes (see section V) D No (Review Concluded)
D Environmental Assessment 
D Supplemental Environmental Assessment (Reference EA or PEA in comments) 
C8J Environmental Impact Statement 

Comments: This project meets the criteria for an Alternative Arrangement (Permanent Schools) type of project. This 
project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) laws. 

Record of Environmental Consideration 06/28/06 


Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha Dawson, Environmental Specialist 


Signature ~.(.~ . Date 06/28/2006

----~~~~~------------~ 

FEMA Regional Environmental Officer or delegated approving official. 
Name: Donald Fairley, ELO 

Signaturer£.__ ~ . Date _----'<.,;06=/2=8=/2=0=0.><.,.6_____~ 

... 

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

A. National Historic Preservation Act 

D Not type of activity with potential to affect historic properties. (Review Concluded) 

181 Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. 
181 Activity meets Programmatic Allowance # Appendix A, Section {II-EI, II-CI, II-A2, II-C2, II-BI, II-B2, II-H} 
Are project conditions required? 181 Yes (see section V) D No (Review Concluded) 

HISTORIC BUILDINGS AND STRUCTURES 
D 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 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. If not, 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 findingiSHPOrrHPO 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 
181 Project affects only previously disturbed ground. (Review Concluded) 
D Project affects undisturbed ground. 

D Project area has no potential for presence of archeological resources 
D Determination of no historic properties affected (FEMA fmdingiSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence of archeological resources 
D Determination ofno historic properties affected (FEMA fmdingiSHPO/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 fmdingiSHPOffHPO 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 SHPO/THPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Adverse Effect Determination. (FEMA fmdingl SHPO/THPO concurrence on file) 
Record of Environmental Consideration 2 06/28/06 

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

Comments: 06119/2006 -FEMA's Progranunatic 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, Progranunatic Allowances, Section {II-El, II-Cl, II-A2, 
II-C2, II-B I, II-B2, II-H}, of the document. In accordance with the PA, FEMA is not required to submit projects to the 
State Historic Preservation Officer (SHPO) for review where the work performed meets these allowances. This concludes 
the Section l06 review for this project. In keeping with the stipulations of the P A, 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 l06 and consultation with the SHPO. Non-compliance may jeopardize the receipt offederal 
funding. V.Gomez, Historic Preservation Specialist 

Correspondence/Consultation/References: 

B. Endangered Species Act 

1:81 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 


determinationlUSFWSINMFS concurrence on file) <Review Concluded) 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 


o Likely to adversely affect species or designated critical habitat 

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

IComments: None 

C. Coastal Barrier Resources Act 

1:81 Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded). 

o Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 
file) 

o Proposed action an exception under Section 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: None 
Correspondence/Consultation/References: 

D. Clean Water Act 

1:81 Project would not affect any waters of the U.S. <Review Concluded) 

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

o Project exempted as in kind replacement or other exemption. (Review Concluded) 
o Project requires Section 404/401l0r Section 9110 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: Project is not in or adjacent to any waterways of the US. 
Correspondence/Consultation/References: 

E. Coastal Zone Management Act 

o Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 
Record of Environmental Consideration 3 

06/28/06 


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). 
D State administering agency requires consistency review. 

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

Comments: FEMA has determined that this project is consistent with the Coastal Zone Management Act (CZMA) 
and the Louisiana Coastal Management Plan (LCMP). 

Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded)
D Project affects, controls or modifies a waterwaylbody ofwater. 

D Coordination with USFWS conducted 

D No Recommendations offer 

ed by USFWS. (Review Concluded) 

D Recommendations provided by USFWS. 

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

Comments: Project is not in or adjacent to any waterways of the US. 
Correspondence/Consultation/References: 

G. Clean Air Act 

181 Project will not result in permanent air emissions. (Review Concluded) 
D Project is located in an attainment area. (Review Concluded) 
D Project is located in a non-attainment area. 


D Coordination required with applicable state administering agency .. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
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. 
D Farmland Conversion Impact Rating, Form AD-I006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

D Project not located within a flyway zone. (Review Concluded) 
181 Project located within a flyway zone. 
[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: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has 
determined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other 
fish and wildlife reserves. These determinations are based on the understanding that the conditions outlined in the Louisiana 
Endangered Species Summary are met 

Record of Environmental Consideration 4 06/28/06 


Correspondence/Consultation/References: http://pacificflvway.gov/Documents/Mississippi map. pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

1:81 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: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

1:81 Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded)
D Project is along or affects WSR 
D Project adversely affects WSR as detennined by NPS/USFS. FEMA cannot fund the action. 
(NPS/uSFS/uSFWSIBLM consultation on file) (Review Concluded)

D Project does not adversely affect WSR. (NPS/uSFS/uSFWSIBLM consultation on file) 
Are project conditions required? D YES (see section V) D 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 

D No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) 

1:81 Located in Floodplain or Effects on FloodplainslFlood levels 

1:81 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 

Are project conditions required? D Yes (see section V) 1:81 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 

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

Comments: 06.28.06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) 

08.03.70. Per Flood Insurance Rate Map 225203 0095 E, dated 03.01.84, project is located in Zone B; area protected from 
the 100-yr flood by levee, dyke, or other structures subject to possible failure or overtopping during larger floods. Project is 
repair to building, which was not substantially damaged, and should have no effect on the floodplain. In compliance with 
44 CFR 9.11, to elevate, mitigate, wet or dry flood proof; mitigation measures have been considered and are attached. 
Casey Barefield, FPM. 

Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

1:81 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 
Record of Environmental Consideration 5 

06/28/06 


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 of floodplain review 

D 8 Step Process Complete -documentation on file 

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

Comments: None 
Correspondence/Consultation/References: 

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

l8:J No Low income or minority population in, near or affected by the project -(Review Concluded)

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 tbe project for extraordinary circumstances. 

*A "Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of(ii) which 
should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, 
please explain in comments. If no, 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 environmental 


conditions;
D (iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental 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 ofthe environment. 

Record of Environmental Consideration 6 06/28/06 


o (X) Potential for significant cumulative impact when the proposed action is combined with 

other past, present and reasonably foreseeable future actions, even though the impacts ofthe 
proposed action may not be significant by themselves. 

IComments: None 

v. Environmental Review Project Conditions 

General comments: 

Project Conditions: 

1. In keeping with the stipulations of the Programmatic Agreement (PA), all proposed 
repair activities should be done in-kind to match existing materials and form. Any 
change to the approved scope of work will require resubmission for re-evaluation under 
section 106 and consultation with the State Historic Preservation Officer (SHPO). Noncompliance 
may jeopardize the receipt of federal funding. 

Monitoring Requirements: None 

06/28/06

Record ofEnvironmental Consideration 7