Reviewer Name: Letha Dawson Applicant: Dillard University 
DisasterlEmergencylProgramIProjeet Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR0654 Permanent Building RepairsDent 
Hall 

Record of Environmental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Proiect NamelNumber: Pennanent Building Repairs -Dent Hall! PW 9440 

Proiect Location: 2601 Gentilly Blvd., New Orleans, Louisiana, Orleans Parish 70122 (N29.59735, 
W-90.03869) 

Project Description: Project activities include removing 47,438 square feet of flat built up roof 
including insulation; and installing 47,438 square feet ofinsulation board over deck, 47,438 square feet 
of bituminous roofing and flashings as necessary. 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) 


[8J (Long version) All applicable laws and executive orders were reviewed. Additional infonnation for 
compliance is attached to this REC. 

National Environmental Policy Act (NEPAl Determination 

o "Statutorily excluded from NEP A 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) 
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) 
[8J Environmental Impact Statement 


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


Reviewer Name: Letha Dawson Applitant: Dillard University 
DisasterlEmergentylProgramlProjett Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR06S4 Pennanent Building RepairsDent 
Hall 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha~entalSpecialist 


Signature 'CI.I.. J..1.J}Q\;J . Date _-=06::;.:.../2=8=/2=O=O=6_____~ 

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

Signature~~ . Date _-=06=/2=8""'-'/2=O:;..;:;O-=6_____~ 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

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

D Applicable executed Programmatic Agreement (12/0312004) Otherwise, conduct standard Section 106 review. 
D Activity meets Programmatic Allowance # ___ 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
[gI No historic properties that are listed or 45150 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 fmdingiSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA findingiSHPO/THPO 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 findingiSHPOffHPO concurrence on file). 
Are project conditions required? DYes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findingiSHPOffHPO 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 
[gI 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 of no historic properties affected (FEMA fmdingiSHPOITHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA findingiSHPOffHPO 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 findingiSHPOITHPO 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 findingl SHPOITHPO concurrence on file) 

Record of Environmental Consideration 2 06/28/06 


Reviewer Name: Letha Dawson Applicant: Dillard University 
DisasterlEmergencylProgramIProjeet Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR06S4 Permanent Building Repairs Dent 
Hall 

Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 

o Adverse Effect Detennination. (FEMA finding! SHPOrrHPO concurrence on file) 

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

Comments: 06/28/2006 -This structure does not meet 45-year-criterion or the level ofexceptional importance required by 
Criterion G ofthe National Register guidelines to be considered eligible for the National Register ofHistoric Places. 
Therefore, the proposed work will have no effect on historic structures. -V. Gomez, Historic Preservation Specialist 

Correspondence/Consultation/References: 

B. Endangered Species Act 

l'8I 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. 

oNo 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: None 
Correspondence/Consultation/References: 

C. Coastal Barrier Resources Act 

l'8I 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: None 
Correspondence/Consultation/References: 

D. Clean Water Act 

[8J 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 404/40 lIor Section 911 0 (Rivers and Harbors Act) pennit, including qualification 
under Nationwide Pennits. 
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) 
[8J Project is located in a coastal zone area and/or affects the coastal zone 
[8J State administering agency does not require consistency review. (Review Concluded). 


o State administering agency requires consistency review. 
Record of Environmental Consideration 3 


06/28/06 


Reviewer Name: Letha Dawson Applicant: Dillard University 
DisasterlEmergencylProgramiProject Title: DRl603LA I Hurricane Katrina I Public Assistance Program I EOR06S4 Pennanent Building RepairsDent 
Hall 

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 modify a waterwaylbody ofwater. (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) 0 NO (Review Concluded) 

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

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-I 006, 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) 

I:8:J Project located within a flyway zone. 
181 Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? D Yes (see section V) 181 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 detenninations are based on the understanding that the conditions outlined in the Louisiana 
Endangered Species Summary are met 
Correspondence/Consultation/References: http://pacifictlyway.gov/Documents/Mississippi map.pdf, 


Reviewer Name: Letha Dawson Applicallt: Dillard University 
DisasterlEmergeoc:ylProgramIProjec:t Tide: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR06S4 Permanent Building RepairsDeat 
Hall 

J. Magnuson-Stevens Fishery Conservation and Management Act 

[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 detennination/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) 
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 

[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 NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM 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: 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)
t8J Located in Floodplain or Effects on FloodplainslFlood 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). 

[8] Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 

[81 8 Step Process Complete -documentation on file 
Are project conditions required? t8J YES (see section V) D NO (Review Concluded) 

Comments: 06/28/2006 -The City of New OrleanslOrleans Parish is enrolled in the National Flood Insurance Program 
(NFIP) as of 8/311970. Per Flood Insurance Rate Map (FIRM) panel number 2252030095E dated 03/01/1984, project is 
located in Zone "B", area protected from the 100-yr flood by levee, dike or other structure subject to failure or overtopping 
during larger floods. Project is repair ofbuilding. In compliance with RO. 11988, an 8-step process has been completed 
and is attached. Per 44 CFR 9.1 1 (d)(9), for the replacement ofbuiJding contents, materials, and equipment, where possible, 
disaster proofing of the building and/or elimination of such future losses by relocation of these building contents, materials, 
and equipment to or above the advisory base floodplain. Per 44 CFR 9.12, applicant must publish a final public notice 15 
days prior to the start of construction activities. Final public notice is to be forwarded to the LA GOHSEP and FEMA for 
inclusion in the pennanent project files. K. Roof, Floodplain Management Specialist 

Correspondence/Consultation/References: 


Reviewer Name: Letha Dawson Applicant: Dillard University 
DisasterlEmergencylProgramlProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR06S4 Permanent Building RepairsDent 
Hall 

B. E.O. 11990 -Wetlands 

r8l No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded)

o 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 

o8 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 

r8l 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 
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 the 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 
D 
D 
(i) Greater scope or size than nonnally experienced for a particular category of action 
(ii) Actions with a high level of public controversy 
(iii) Potential for degradation, even though slight, ofalready existing poor environmental 
D 
conditions; 
(iv) Employment of unproven technology with potential adverse effects or actions involving 
D 
unique or unknown environmental risks; 
(v) Presence of endangered or threatened species or their critical habitat, or archaeological, 
D 
cultural, historical or other protected resources; 
(vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local 
D 
regulations or standards requiring action or attention; 
(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; 


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_ 
.. _ ... 

Reviewer Name: Letha Dawson Applicant: Dillard University 
DisasterlEmergencylProgramlProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR0654 Permanent Building RepairsDent 
Hall 

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 of the 
proposed action may not be significant by themselves. 

IComments: None 

V. Environmental Review Project Conditions 

General comments: None 

Project Conditions: 

1. Per 44 CFR 9.11(d)(9), for the replacement of building contents, materials, and equipment, 
where possible, disaster proofing of the building and/or elimination of such future losses by 
relocation of these building contents, materials, and equipment to or above the advisory base 
floodplain. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior to the 
start ofconstruction activities. Final public notice is to be forwarded to the LA GOHSEP and 
FEMA for inclusion in the permanent project files. 

Monitoring Requirements: None