Record of Environmental Consideration 


REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 
See 44 Code of Federal Regulation Part 10 

Project NameINumber: Mandeville High School-Contents, PW#94 I8, FIPS#103-UH9IO-00 
Project Location: 1 Skipper Dr., Mandeville LA 70471, St. Tammany Parish, 
Latitude: 30.3817, Longitude: -90.10079 
Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant 

exterior and interior damage to Mandeville High School. Cumulative repair work to the building includes 
removaVreplacement of insulation, ceiling tile, ceiling lights, floor tile, roofing components, metal canopy with 
posts, and chain link fencing with rail and posts. 
Hazard mitigation has been proposed for 2 -24' x 32' portables and 2 classrooms at Mandeville high school that 
had over 50% of their asphalt shingles roof damaged due to force winds from hurricane Katrina. The portables 
were replaced with metal roofs put on top ofthe damaged asphalts shingles. The metal roofs have a 2 to 3 times 
longer life span and they are faster to install than a asphalt shingle roof. All work will be performed in a 
previously disturbed area with no indication of nearby waterways or other bodies ofwater. 

Documentation Requirements 

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) 

[8] (Long version) All applicable laws and executive orders were reviewed. Additional information 
for compliance is attached to this REC and/or included in project files, as applicable. 

National Environmental Policy Act (NEPAl Determination 

D Statutorily excluded from NEPA review. (Review Concluded) 
D Programmatic Categorical Exclusion -Category (Reference PCE in comments) <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) 
~ Environmental Impact Statement 

Comments: This project meets the criteria for the alternative arrangement, permanent school, type ofproject. This project 
has conditions and r uires miti ation under the other EHP laws. 

Reviewer and Approvals 

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

FEMA Environmental Reviewer: 
Record of Environmental Consideration (Version 06/19/06) 



N,mne: Adam ~-tr07~WJi~ 

SIgnature .~ Date -~-jf~-'ct_IIr-°_b__---=


FEMA Regional Environmental Officer or Delegated Approving Official: 
N.ame: MiCham'n!~ronmentalLiason Officer 

SIgnature ~ Date L, ... 21... 0,", 

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

A. National Historic Preservation Act (NHP A)

181 Not type of activity with potential to affect historic properties. 
D Activity meets Programmatic Agreement, December 3, 2004. Appendix A: Allowance No. 
Are project conditions required? D Yes (see Section V) D No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

mSTORIC BUILDINGS AND STRUCTURES 
181 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 findingiSHPO/THPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA findingiSHPOITHPO 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 fmdingiSHPOITHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) 0 No (Review Concluded) 
D Adverse Effect Determination (FEMA fmdingiSHPOITHPO 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 
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 ofno historic properties affected (FEMA fmdingiSHPOITHPO concurrence or 
consultation on file). (Review Cogcluded) 
D Project area has potential for presence of archeological resources 
D Determination ofno historic properties affected (FEMA fmdingiSHPOITHPO concurrence on file) 
Are project conditions required Dyes (see Section V) D No (Review Concluded) 
D Determination ofhistoric properties affected 
D NR eligible resources not present (FEMA findingiSHPO/THPO concurrence on file). 
Are project conditions required DYes (see Section V) D No (Review Concluded) 

o NR eligible resources present in project area. (FEMA fmdingl SHPOITHPO concurrence on 
file) 
D No Adverse Effect Determination. (FEMA fmdingl SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Adverse Effect Determination. (FEMA findingl SHPOITHPO 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: None 
Correspondence/Consultation/References: 

Record of Environmental Consideration (Version 06119/06) 


B. Endangered Species Act 

181 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 


determinationlUSFWSfNMFS 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) 

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. 
Co"espondence/ConsultatlonIRejerences: USFWS emergency consultation provisions determined in letters dated 
September IS, 200S for Katrina. 

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 determinationlUSFWS 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. 
Co"espondence/ConsultationIRejerences: Louisiana Coastal Barrier Resource System Maps referenced 06119/06. 


D. Clean Water Act 

181 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 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: No jurisdictional waters ofthe U.S., including wetlands, occur in or near the project area. 
Co"espondence/ConsultationIRejerences: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil) queried 
on 06/19/06. 

E. Coastal Zone Management Act 

181 Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 

o Project is located in a coastal zone area and/or affects the coastal zone 

o 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 determined that receipt of 
federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still 
require a coastal use permit or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1800
·276-4019. 

Co"espondence/ConsultationIRejerences: 

1) LDNR Louisiana Coastal Zone map 2002. 

Record ofEnvironmental Consideration (Version 06/19/06) 


F. Fish and Wildlife Coordination Act 

1:8:1 Project does not affect, control, or modify a waterwaylbody ofwater. (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: No streams or water bodies are located in or near the project area. 
Com!spondenceiConsultationlRe/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD queried 06119/06. 

G. Clean Air Act 

o Project will not result in pennanent air emissions. (Review Concluded) 

1:8:1 Project is located in an attainment area. (Review Concluded) 

o Project is located in a non-attainment area. 

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

Comments: This project involves the demolition or renovation of a public structure. Regardless ofthe asbestos content, the 
applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department 
of Environmental Quality (LDEQ) in accordance with the LDEQ "Fifth Amended Declaration of Emergency and 
Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March 1,2006, incorporating the provisions 
of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code 
(LAC) 33.m.515t and Chapter 27. Should Asbestos Containing Materials (ACMs) be present at the project site, the 
applicant is also responsible for ensuring proper disposal in accordance with the previously referenced administrative 
orders. 
CorrespondenceiConsultationIRe/erences: EPA Region 6 Non-attainment Map. 

H. Farmland Protection Policy Act 
181 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-t006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: The project site is in a developed urbanized area and FPPA is precluded. No prime or unique farmland present. 
CorrespondenceiConsultationIRe/erences: 

I} National Resource Conservation Service, Web Soil Survey (http://websoilsurvey.nrcs.usda.gov/app/ )referenced 
06119/06. 

I. Migratory Bird Treaty Act 
D Project not located within a flyway zone. (Review Concluded) 
181 Project located within a flyway zone. 


D Project does not have potential to take migratory birds. eview Concluded 
Are project conditions required? 0 Yes (see section V) No (Review Concluded) 

o Project has potential to take migratory birds. 

D Contact made with USFWS 
Are project conditions required? 0 YES (see section V) 0 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. 
CorrespondenceiConsultationIReferences: USFWS guidance letter dated September 15,2005 for Katrina 
J. Magnuson-Stevens Fishery Conservation and Management Act 

Record of Environmental Consideration (Version 06/19/06) 


[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) 0 NO (Review Concluded) 

Comments: Project is not located in or near any surface waters with the potential to affect EFH species. 
Correspondence/Consultation/Re/erences: Louisiana Map Orttp:llwwwlamap,doa.louisiana.govD referenced 06/19/06. 

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 

o 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/ConsultationiRe/erences: National Wild and Scenic Rivers http://www.nps.gov/riverslwildriverslist.html. 
referenced 06119106 . 


L. Other Relevant Laws and Environmental Regulations 


State Hazardous Materials and Solid Waste Laws 
Comments: Unusable equipment, debris and material shall be disposed of in an approved manner and location. 
In the event significant items (or evidence thereof) are discovered during implementation of the project 
applicant shall handle, manage, and dispose of petroleum products, hazardous materials and/or toxic waste in 
accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. 

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 


[81 No adverse effect on floodplain and not adversely affected by the floodplain. {Review Concluded), 
Are project conditions required? 0 Yes (see Section V) t8j No (Review Concluded) 

o Beneficial Effect on Floodplain OccupancyNalues {Review Concluded), 

D Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain 
environment 

o 8 Step Process Complete· documentation on file 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 

Comments: The site is located in Zone AIO. 
http://store.msc.fema.gov/webawlwcs/stores/servletlFema Welcome View?storeld= 1 000 l&catalogld= 1 000 l&langId=-1 , 
click on Map search and enter latllong for the site. 
Correspondence/ConsultationiRe/erences: FEMA Flood Insurance Rate Map, Community Panel No. 2202020001C, 
revised 4/4/83. 


B. E.O.11990 -Wetlands 

[81 No Effects on WetIand{s) and project located outside Wetland(s) -{Review Concluded) 
Record ofEnvironmental Consideration (Version 06/19/06) 


Reviewer Name: Adam Borden, Environmental Speeialist Project NamelEnv. Database No: Mandeville Hlgb Sc:bool·ContentsIPWII9418 
FEMA·1603/1607·DR·LA Pamb: Sf. Tammany 
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 
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: No wetlands were observed during site visit or determined to be present by checking the USFWS National 
Wetlands Inventory (NWI) maps. 

CorrespondenceiConsultationIRejerences: 

USFWS NWI map accessed on-line (http://wetlandsfws.er.usgs.gov/wtlndsllaunch.html) 06119/06. 

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) 
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:The percent populations of7047 I are: 95.3% white,2.1% black and 2.5% hispanic. The median household 
income in 1999 was $ 73,042 and 2.4 % of families are below poverty level. 
CorrespondenceiConsultationIRejerences: U.S. Census bureau 2000 data at http://factfmder.census.gov, referenced 

06119/06. 

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). 

State Hazardous Materials and Solid Waste Laws 
Comments: Unusable equipment, debris and material shall be disposed of in an approved manner and location. 
In the event significant items (or evidence thereof) are discovered during implementation ofthe project 
applicant shall handle, manage, and dispose ofpetroleum products, hazardous materials and/or toxic waste in 
accordance to the requirements and to the satisfaction of the governing local, state and federal agencies. 

CorrespondenceiConsultationIRejerence: 

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 ofOi) 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 
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 ofunproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 


Record of Environmental Consideration (Version 06/19/06) 


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 of the 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 ofthe 
proposed action may not be significant by themselves. 

IComments: None 

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 of FEMA funding 
reimbursement: 

• This project involves the demolition or renovation ofa public structure. Regardless ofthe asbestos 
content, the applicant is responsible for ensuring that renovation or demolition activities are 
coordinated with the Louisiana Department ofEnvironmental Quality (LDEQ) in accordance with the 
LDEQ "Fifth Amended Declaration ofEmergency and Administrative Order" dated March 31, 2006, 
and the LESHAP protocol dated March 1,2006, incorporating the provisions ofEPA's National 
Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code 
(LAC) 33.m.SlS1 and Chapter 27. Should Asbestos Containing Materials (ACMs) be present at the 
project site, the applicant is also responsible for ensuring proper disposal in accordance with the 
previously referenced administrative orders. 
• Unusable equipment, debris and material shall be disposed of in an approved manner and location. In 
the event significant items (or evidence thereof) are discovered during implementation ofthe project 
applicant shall handle, manage, and dispose ofpetroleum products, hazardous materials and/or toxic 
waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal 
agencies. 


Record ofEnvironmental Consideration (Version 06/19/06)