Reviewer Name: Letha Dawson AppilcaDt: Dillard University 
DlsasterlEmergeDcylProgramIProject Tide: DRI603LA f Hurricane Katrina f Public Assistance Program f EOR06SS Pennanent Building Repairs • 
Lawless Memorial Chapel 

Record of Environmental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Project NamelNumber: Pennanent Building Repairs·Lawless Memorial Chapel / PW 9424 

Project Location: 2601 Gentilly Blvd, New Orleans, Louisiana, Plaquemines Parish, 70122 
(N29.59665, W·90.04006) 

Project Description: Project activities include replacing the entire 12,607 square feet ofclay tile roof 
and 3,058 square feet of vinyl composite tile, repairing 1,064 square feet of interior plaster fInishes, 
painting 1,064 square feet ofinterior plaster wall, caulking 100 linear feet ofexterior brick wall cracks, 
and cleaning/removing spray-paint from 800 square feet ofexterior brick. Hazard mitigation will be 
achieved by compliance with current codes and standards. 

Documentation Reg uirements 

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) 


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

National Environmental Policy Act (NEPAl Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category <Review Concluded) 
o Categorical Exclusion -Category


o No Extraordinary Circumstances exist. 

Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 
D 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 
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 ofproject. This 
project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) Laws. 


Reviewer Name: Letha Dawson Applicant: Dillard University 
DisasterlEmel'lencylPrograllllProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR06SS Permanent Building RepairsLawless 
Memorial Chapel 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha Dawson, Environmental Specialist 


Signature LMtaJl.9~ . Date _--"'-07:..:../2=-4.:..:.,:/2::.;:0"-=0.,:.6_____--:. 

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

Signature~~J--_--',~c::::::' . Date _~07~/2=_4.:..:../2=.:0~0=6_____--:. 

I. Compliance Review for Environmental Laws <other than NEPAl 

A. National Historic Preservation Act 

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

t8I Applicable executed Programmatic Agreement (12/03/2004) Otherwise. conduct standard Section 106 review. 
t8I Activity meets Programmatic Allowance # Appendix A, Section II.A.-I, ILA.-2, II.D -I, and ltD -6 
Are project conditions required? t8I Yes (see section V) D No <Review Concluded) 

mSTORIC 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 45150 years or older in project area and activity not exempt from review. 

D Determination ofNo Historic Properties Affected (FEMA fmdinglSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination ofHistoric Properties Affected (FEMA fmdinglSHPOffHPO 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 fmdinglSHPOffHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA fmdinglSHPOffHPO 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 
t8I 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 fmdinglSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination of no historic properties affected (FEMA fmdinglSHPOffHPO 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 findinglSHPO/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 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)

o Adverse Effect Determination. (FEMA fmdingl SHPOffHPO concurrence on file) 


Reviewer Name: Letha Dawson Applicant: Dillard University 
Dill.terlEmergencylProgramIProject Title: DR I 603lA I Hurricane Katrina I Public Assistance Program I EOR06SS Permanent Building Repairs • 
Lawless Memorial Chapel 

D Resolution ofAdverse Effect completed. (MOA on file) 

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

(Review ConeJudedl 

Comments: 07122/06 -FEMA's Programmatic Agreement (PA), dated December 3, 2004, provides for expedited project 
review under Section 106 ofthe National Historic Preservation Act (NHPS). The scope ofwork as submitted in this PW 
has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section II.A.-I, II.A.-2, n.D 1, 
and II.D -6 ofthe 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. 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 of Federal funding. This concludes the Section 106 review for this project. 
Elrhei S. Thibodeaux, Historic Preservation Specialist 

07122/06 -All plaster repair work shall be done in accordance with the recommendations laid out in the US Department of 
the Interior's Preservation Brief 21: Repairing Historic Flat Plaster Walls and Ceilings 
(http://www.cr.nps.govlhps/tpslbriefslbriet2l.htm) and Preservation Brief28: Painting Historic Interiors 
(http://www.cr.nps.govlhps/tpslbriefslbriet28.htm) by qualified personnel with experience working on historic buildings. 
Every effort shall be made to minimize the loss of additional historic fabric through the use of the gentlest means ofrepair 
possible and through adequate protection ofundamaged areas. Failure to comply with these stipulations may jeopardize 
receipt ofFEMA funding. Elrhei Thibodeaux, Historic Preservation Specialist 

07/22106 -All masonry cleaning shall be done in accordance with the recommendations laid out in the US Department of 
the Interior's Preservation Brief 0 1 : Assessing Cleaning and Water-Repellent Treatments for Historic Masonry Buildings 
(http://www.cr.nps.govlhps/tpslbriefslbrietnl.htm) by qualified personnel with experience working on historic buildings. 
Every effort shall be made to minimize masonry damage through the use of the gentlest means ofcleaning possible and 
through adequate protection of undamaged areas. Failure to comply with this stipulation may jeopardize receipt ofFEMA 
funding. Elrhei Thibodeaux, Historic Preservation Specialist 

07122/06 -All clay tile repair work shall be done in accordance with the recommendations laid out in the US Department of 
the Interior's Preservation Brief #30: The Preservation and Repair of Historic Clay Tile Roofs 
(http://www.cr.nps.govlhps/tpslbriefslbrieOO.htm) and Preservation Brief #4: Roofmg for Historic Buildings 
(http://www.cr.nps.govlhps/tpslbriefslbrief4.htm) by qualified personnel with experience working on historic buildings. 
Every effort shall be made to minimize the loss of additional historic fabric through the use of the gentlest means of repair 
possible and through adequate protection of undamaged areas. Failure to comply with these stipulations may jeopardize 
receipt ofFEMA funding. Elrhei Thibodeaux, Historic Preservation Specialist 

Correspondence/Consultation/References: 

B. Endangered Species Act 
t8J 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) 

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 

determinationlUSFWSINMFS 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/C onsultationiReferences: 



Reviewer Name: Letha Dawson AppllcaDt: Dillard University 
DlwterlEmergeDcylProgramIProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR06SS Pennanent Building Repairs • 
Lawless Memorial Chapel 

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.61 (Review Concluded) 
oProposed action not excepted under Section 3505.a.6. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Cqncluded) 


Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 
181 Project would not affect any waters of the 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) 
oProject requires Section 404/40 Ilor Section 911 0 (Rivers and Harbors Act) pennit, including qualification 
under Nationwide Pennits. 
Are project conditions required? 0 YES (see section V) D NO (Review Concluded) 


Comments: Project is not in or adjacent to any waterways ofthe US. 
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) 

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 detennined 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 modity a waterwaylbody of water. (Review Concluded) 
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: 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 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) 

Record of Environmental Consideration 4 


Reviewer Name: Letha Dawson Applicant: Dillard University 
DlsuterlEmergencylProgramJProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR06SS Permanent Building Repairs· 
Lawless Memorial I 

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 of designated 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. 


I8l Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) I8l 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 09/1412005. 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: http://pacificflyway.gov/DocumentslMississippi map.pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 
I8l 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) 

o NOAA Fisheries provided recommendation(s) 

D Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? 0 YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 
l2J 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 determined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 

o 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: 


Revitwer Name: Letha Dawson Applicant: Dillard University 
DisuterlEmergencylProgramIProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR06SS Pmnanent Building Repairs Lawless 
Memorial Chapel 

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) 
181 Located in Floodplain or Effects on FloodplainsIFlood levels 

181 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Ate project conditions required? 181 Yes (see section V) 0 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 
Ate project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: 07/2112006-The City of New Orleans/Orleans Parish is enrolled in the National Flood Insurance Program 
(NFIP) as of8/311 970. Per Flood Insurance Rate Map (FIRM) panel number 2252030095E dated 311/1984, project is 
located in zone "B", area protected from the IOO-yr flood by levee, dike or other structure subject to failure or overtopping 
during larger floods. Project is repair ofbuUding to pre-disaster footprint, which is not likely to affect the floodplain. Per 
flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents should be elevated at least 3 ft. 
above the highest adjacent grade elevation. K. Roof, Floodplain Management Specialist. 

Correspondence/consultation/references: 

B. E.O. 11990 -Wetlands 

181 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 

o Located in Wetland or effects Wedand(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 
Ate 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 

181 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 
Ate project conditions required? 0 YES (see section V) 0 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: 


IUVlewer !'i.me: Lema uawson Applic.Dt: Dillard University 
DlsuterlEmergencylProgr.mlProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR0655 Permanent Building Repairs • 
Lawless Memorial Chapel 

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 Environmental Assessment (EA) with the exception of(H) 
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 

o (i) Greater scope or size than normally experienced for a particular category ofaction 
o (ii) Actions with a high level ofpublic controversy 
o (iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; 
o (iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
o (v) Presence ofendangered 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 ofthe 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: None 

V. Environmental Review Project Conditions 

General comments: None 

Project Conditions: 

1. Per flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents 
should be elevated at least 3 ft. above the highest adjacent grade elevation. 
2. In keeping with the stipulations of the 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 SHPO. Noncompliance 
may jeopardize the receipt of Federal funding. 
3. All plaster repair work shall be done in accordance with the recommendations laid out in the 
US Department of the Interior's Preservation Brief 21: Repairing Historic Flat Plaster Walls 
and Ceilings (http://www.cr.nps.gov/hps/tpslhriefslhrief21.htm) and Preservation Brief 28: 
Painting Historic Interiors (http://www.cr.nps.gov/hps/tpslhriefslhrief28.htm) by qualified 
personnel with experience working on historic buildings. Every effort shall be made to 


07/24/06


......." .." ••UWIC: u:tna uawson Applicant: Dillard University 
DlsasterlEmergencylPrOlramIProJect Tide: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR06SS Permanent Building Repairs • 
Lawless Memorial Chapel 

minimize the loss ofadditional historic fabric through the use ofthe gentlest means ofrepair 
possible and through adequate protection of undamaged areas. Failure to comply with these 
stipulations may jeopardize receipt ofFEMA funding. 

4. All masonry cleaning shall be done in accordance with the recommendations laid out in the US 
Department ofthe Interior's Preservation Brief 01: Assessing Cleaning and Water-Repellent 
Treatments for Historic Masonry Buildings (http://www.cr.nps.govlhpsltpslbriefslbriefOl.htm) 
by qualified personnel with experience working on historic buildings. Every effort shall be 
made to minimize masonry damage through the use of the gentlest means ofcleaning possible 
and through adequate protection ofundamaged areas. Failure to comply with this stipulation 
may jeopardize receipt ofFEMA funding. 
5. All clay tile repair work shall be done in accordance with the recommendations laid out in the 
US Department of the Interior's Preservation Brief#30: The Preservation and Repair of 
Historic Clay Tile Roofs (http://www.cr.nps.govlhpsltpslbriefslbrief30.htm) and Preservation 
Brief#4: Roofing for Historic Buildings (http://www.cr.nps.govlhpsltpslbriefslbrief4.htm) by 
qualified personnel with experience working on historic buildings. Every effort shall be made 
to minimize the loss ofadditional historic fabric through the use ofthe gentlest means ofrepair 
possible and through adequate protection ofundamaged areas. Failure to comply with these 
stipulations may jeopardize receipt of FEMA funding. 


Monitoring Requirements: None