Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: SWB of NO -Administration Building / PW 9747 

Project Location: 6501 Florida Avenue, City of New Orleans, Louisiana, Orleans Parish 70117 
(N29.99753, W-89.99740) 

Project Description: Project activities include rebuilding the New Orleans Sewerage and Water 4,000 
square feet Administration Building. Hazard mitigation will be accomplished by applying current 
codes and standards to the new construction. 

Documentation Requirements 

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) 


[gI (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 

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) 
[gI Environmental Impact Statement 


Comments: 6.24.2006. This project meets the criteria for an Alternative Arrangement (Utilities and Wastewater Treatment 
Plants) type of project. This project has conditions and requires mitigation under the other EHP laws. 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Record of Environmental Consideration 06129/06 



Name: Perry J. Boudreaux, Envirorunental Specialist 

Signature ~~ . Date_~6/-=2=9/-=2.,:..;OO~6,---___----=


FEMA Regional Envirorunental Officer or delegated approving official. 
Name: Don Fairley, ELO 

Signature ~~~ • Date_----::6"""/2=9.:.,:/2::..=O-"-06:.-___--" 

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) 
~Applicable executed Programmatic Agreement December 3,2004 Otherwise, conduct standard Section 106 review. 
~Activity meets Programmatic Allowance # Appendix A Section I (A) 
Are project conditions required? ~Yes (see section V) D No (Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
~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 fmdinglSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic 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. If not, explain in comments 
D No Adverse Effect Determination (FEMA fmdinglSHPO/THPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findinglSHPO/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 
~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 findinglSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination of no historic properties affected (FEMA fmdinglSHPQ/THPO concurrence on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 
D Determination ofhistoric properties affected 
D NR eligible resources not present (FEMA fmdinglSHPOffHPO 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 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) 

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

Record ofEnvironmental Consideration 2 


Comments: 6/27/2006 -Historic review complete: As demolition ofthis structure was covered in a separate pw, this 
historic review is for the replacement ofthe structure within its pre-<iisaster footprint only. The elevation and rebuild ofthe 
structure constitutes ground disturbing activities. Upon consultation ofSHPO data, there are no known archaeological sites 
within .5 miles ofthe project area. Therefore, scope ofwork meets Programmatic Agreement (12/312004) Allowance, 
Appendix A, section I, A. If during the course ofwork, 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 turn 
contact FEMA Historic Preservation staff. The applicant will not proceed with work until FEMA Historic Preservation staff 
have completed consultation with the Louisiana State Historic Preservation Officer (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 ofthe jurisdiction where the remains are located within twenty-four 
hours ofthe discovery. The applicant shall also notifY FEMA and the Louisiana Unmarked Burial Sites Board (call the 
Louisiana Division or Archeology at 225-342-8170) within seventy-two hours ofthe discovery. Failure to comply with these 
stipulations may jeopardize receipt ofFEMA funding. Ifthe scope of work changes, this project will need to be 
resubmitted for further historic review. Katherine Zeringue, Historic Preservation Specialist/Archaeologist. 

Correspondence/Consultation/References: 

B. Endangered Species Act 

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

o Listed species andlor 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 


determination/USFWSINMFS 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 

IZl 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 

IZl Project would not affect any waters of the U.S. (Review Concluded) 

o Project would affect \vaters, including wetlands, of the U.S. 

o Project exempted as in kind replacement or other exemption. (Review Concluded)
o Project requires Section 404/40 llor Section 9/10 (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 ofthe 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) 

[:gJ Project is located in a coastal zone area and/or affects the coastal zone 
[8J Stale administering agency does not require consistency review. (Review Concluded). 

o Stale administering agency requires consistency review. 
Arc project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

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

CorreJPondence/C onsul tat ion/References: 

F. Fish and Wildlife Coordination Act 

[8J 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) 


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

G. Clean Air Act 

[8J Project will not result in permanent air emissions. (Review Concluded) 

o 11roject is located in an attainment area. (Review Concluded) 
o Project is located in a non-attainment area. 


o Coordination required with applicable state administering agency .. 
Arc project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: Project will not result in permanent air emissions. 
Correspondence/Conslt1tation/References: 

H. Farmland l>rotection Policy Act 

[8J Project does not affect designated prime or unique farmland. (Review Concluded)

o Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Form AD-I 006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/C onsu Ifation! References: 


I. Migrato."y Bird Treaty Act 

o Project not located within a flyway zone, (Review Concluded) 
[8J Project located within a flyway zone. 

[8J Project docs not have potential to take migratory birds. (Review Concluded) 
Arc project conditions required? 0 Yes (see section V) [:gJ No (Review Concluded)

o Project has potentiaito take migratory birds. 

o Contact made with USFWS 
Arc project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

06/29/06


Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has 
determined that restoration projects runded with federal resources will not have adverse impacts on migratory birds or other 
/ish and wildlire reserves. These determinations are based on the understanding that the conditions outlined in the Louisiana 
Endangered Species Summary are met 

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

.T. Magnuson-Stevens Fishery Conservation and Management Act 

[8J Project not located in or ncar Essential Fish Habitat. (Review Concluded) 

o Project located in or ncar Essential Fish Habitat. 

o Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Arc project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Project adversely arrects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS concurrence on file) 
o NOAA fisheries provided no recommendation(s) (Review Concluded). 
Arc project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o NOAA fisheries provided recommendation(s) 






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

Comments: None 
CorrespondencelC onsul tat ion! References: 


K. Wild and Scenic Rivers Act 

o 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 arrects WSR as determined by NPSIUSFS. FEMA cannot fund the action. 
(NPS/USFS/USFWS/BLM consultation on file) (Review Concluded) 
o Project does not adversely arfect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) 
Are project conditions rcquired? 0 YES (see section V) 0 NO (Review Concluded) 






Comments: None 
CorrespondenceiConsult at ionlR eferences: 


L. Other Relevant Laws and Environmental Regulations 

II. Compliance Review for Executive Orders 

A. E.O. 11988 -Floodplains 

o No Efrect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) 
o Located in 17100dplain or Efrects on Floodplains/Flood 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) 
o Beneficial Effect on Floodplain OccupancyNalues {Review Concluded}. 
o Possible advcrse efrects associated with investment in floodplain, occupancy or modification offloodplain 
envirollment 






08 Stcp Process Complete -documentation on file 
Are project conditions required? [8J YES (see section V) 0 NO (Review Concluded) 


Comments 06/21/06 -The City of New Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) 
08/0311970. Per flood insurance rate map 225203 0115e, dated 03/01/1984, project is located in zone Al, area of lOOyr 
flood; base flood elevations and flood hazard factors detennined. Applicant is required to coordinate with the local 
floodplain administrator regarding floodplain penn it prior to the start ofany activities. Applicant is responsible for meeting 
all requirements of the penn it. All coordination pertaining to these activities should be documented and forwarded to 
GOHSEP and FEMA as part of the permanent project files. 8-step process has been completed and attached. Rezwan 
Karim,CFM 

Correspondence/Consultation/References: 

B. E.O. 11990 -Wetlands 

[gJ 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: None 
Correspondence/Consultation/References: 

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

[gJ 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) 


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. If the circumstance can be mitigated, 
please explain in comments. Ifno, leave blank. 

Yes 

o (i) Greater scope or size tllan 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, 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 lones, 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: None 

V. Environmental Review Project Conditions 

Project Conditions: 

1. Applicant is required to coordinate with the local flood plain administrator 
regarding floodplain permit prior to the start of any activities. Applicant is 
responsible for meeting all requirements of the permit. All coordination pertaining 
to these activities should be documented and forwarded to GOHSEP and FEMA as 
part of the permanent project files. 
2. Ifduring the course of work, archaeological artifacts (prehistoric or historic) or 
human remains are discovered, the applicant shall stop work in the vicinity of the 
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 turn contact FEMA Historic Preservation staff. The applicant will not 
proceed with work until FEMA Historic Preservation staff have completed 
consultation with the Louisiana State Historic Preservation Officer (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 of the discovery. The applicant shall also notify 
FEMA and the Louisiana Unmarked Burial Sites Board (call the Louisiana 
Division of Archeology at 225-342-8170) within seventy-two hours of the 
discovery. Failure to comply with these stipulations may jeopardize receipt of 
FEMA funding. If the scope of work changes, this project will need to be 
resubmitted for further historic review. 


Monitoring Requirements: None