Reviewer Name: Letha Dawson Applieaot: Dillard University DisasterlEmergeoeylProgramIProjeet Tide: DRI603LA I Hurricane Katrina I Public Assistance Program I EORl178 Hartzell Hall Roof, Dillard University Record of Environmental Consideration See 44 Code ofFedeml Regulation Part 10. Project NamelNumber: Hartzell Hall Roof, Dillard University I PW 11293 Project Location: 2601 Gentilly Blvd., New Orleans, Louisiana, Orleans Parish Project Description: Project activities include removing and replacing copper downspout, copper gutters, damaged built-up roof and clay tile roof. Mitigation will be achieved by compliance with current codes and standards and by good construction practices by replacing the damaged gravel roof with a polyethylene and rubberized elastomeric water proofsystem. 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. Comments: None Correspondence/Consultation/References: G. Clean Air Act 181 Project will not result in permanent air emissions. (Review Concluded) o Project 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.. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection 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 fannland. o Coordination with Natural Resource Conservation Commission required. o Farmland Conversion Impact Rating, Form AD-l 006, completed. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act o Project not located within a flyway zone. (Review Concluded) [8j Project located within a flyway zone. [8j Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? 0 Yes (see section V) 181 No (Review Concluded) o Project has potential to take migratory birds. o Contact made with USFWS Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Reviewer Name: Letha Dawson Applieaat: Dillard University DisasterlEmergeaeylProgramIProjeet Title: DRl603LA I Hurricane Katrina I Public Assistance Program I EORl178 HlII'tD:lI Hall Roof, DiUard University Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has detennined 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://pacificflvway.govlDocumentslMississippi map.pdf, J. Magnuson-Stevens Fishery Conservation and Management Act 181 Project not located in or near Essential Fish Habitat. (Review Concluded) o Project located in or near Essential Fish Habitat. o Project does not adversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o Project adversely affects Essential Fish Habitat (FEMA detennination/USFWSINMFS concurrence on file) o NOAA Fisheries provided no recommendation(s) (Review Concluded). Are 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 Correspondence/Consultation/References: K. Wild and Scenic Rivers Act 181 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 affects WSR as detennined by NPSIUSFS. FEMA cannot fund tbe action. (NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) o Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) Are project conditions required? 0 YES (see section V) 0 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 o No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) 181 Located in Floodplain or Effects on FloodplainslFlood 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). 181 Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment rgJ 8 Step Process Complete -documentation on file Are project conditions required? rgJ YES (see section V) 0 NO (Review Concluded) Comments: 07/14/2006 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program 08/03170. Per Flood Insurance Rate Map 2252030095 E, dated 03/01/84, 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 of a building and replacement ofcomponents to pre-disaster footprint, which per flood recovery guidance, dated 04112/2006, all equipment and contents should be elevated at least 3 ft. above the highest grade elevation. In compliance with EO 11988, a completed 8-step process showing considered alternatives is attached. Per 44 CFR 9.12, applicant must publish a fmal public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOHSEP Record of Environmental Consideration 5 08/29/06 Reviewer Name: Letha Dawson Applicallt: Dillard University DisasterlEmergellcylProgramIProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 1178 Hartzell Hall Roof. Dillard University and FEMA for inclusion in the pennanent project files. A. C. Clark Floodplain Spec. Correspondence/consultation/references: 8-Step Process 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 Wetland(s) o Beneficial Effect on Wetland -(Review Concluded) oPossible adverse effect associated with constructing in or near wetland oReview 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 181 No Low income or minority population in, near or affected by the project -(Review Concluded) oLow income or minority population in or near project area oNo 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 o o o o o (i) Greater scope or size than nonnally experienced for a particular category of action (ii) Actions with a high level ofpublic controversy (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; (iv) Employment of unproven technology with potential adverse effects or actions involving unique or unknown environmental risks; (v) Presence of endangered or threatened species or their critical habitat, or archaeological, cultural, historical or other protected resources; (vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; Reviewer Name: Letha Dawson Applicant: Dillard University DisasterlEmergenc:ylProgramIProject Tide: DR1603LA I Hurricane Katrina I Public Assistance Program I EORl178 Hartzell Hall Roof, Dillard University 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, all equipment and contents should be elevated at least 3 ft. above the highest grade elevation. 2. 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 permanent project files. 3. In keeping with the stipulations ofthe PA, all proposed repair activities should be done in-kind to match existing materials and form. Refer to the National Park Service -Preservation Brief# 4 Roofing for Historic Structures and Preservation Brief# 39 the Preservation and Repair of Historic Clay Tile Roofs. Any change to the approved scope of work will require resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt offederal funding. 4. 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. 5. In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana Parishes ofCalcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement of wood or cellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure) may not leave the quarantined parishes without written authorization from the Commissioner ofthe Louisiana Department ofAgriculture and Forestry or his Designee(s). 6. Regardless of the 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 "Sixth Amended Declaration ofEmergency and Administrative Order" dated June 30, 2006 or latest amended declaration, incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.III.5151 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 order. Record ofEnvironmental Consideration 7 Reviewer Name: letha Dawson Applicant: Dillard University DlsasterlEmel'1encylProgramIProject Tide: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR1178 Hartzell Hall Roof, Dillard University 7. Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with applicable provisions of29 CFR Parts 1910 and 1926 (OSHA -Worker Safety), and 40 CFR 260 through 268 (EPA -Hazardous Waste). The applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. Monitoring Requirements: None