Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: EOR1429 Mondy Elementary School-Modular Classroom / PW 12794 

Project Location: 2327 St. Philip, New Orleans, Louisiana Orleans Parish 70119 (N29.97062 w90.07733) 


Project Description: Project activities include removing the building, legally dispose of, including 
foundation piers and replacing the modular building space (3,072 SF) with an equivalent area modular 
structure. Hazard mitigation will be achieved by compliance with codes and standards. 

Documentation Requirements 

D No Documentation Required <Review Concluded) 

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) 

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

National Environmental Policy Act (NEP A) Determination 

D Statutorily excluded from NEPA review. (Review Concluded) 
D Programmatic Categorical Exclusion -Category <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) 
IZI Environmental Impact Statement 

Comments: This project meets the criteria for an alternative arrangement (Permanent Schools) type of project. This project 
has conditions and re uires miti ation under the other EHP laws. 


Reviewer and Approvals 

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

FEMA Environmental Reviewer. 


Signan.e____~~~~~~----__----~. Dme __-=8/~1=2/=2=OO=6~______~ 

FEMA Regional Environm 1 Officer or delegated approving official. 
Name: Howard R. Bush, ELO 

Signan.e P---:::c:L3 ) e . Date _.....;8=/~12~/2~O~O~6____...:. 

I. Compliance Review for Environmental Laws (other than NEP A) 

A. National Historic Preservation Act 

IZI Not type of activity with potential to affect historic properties. (Review Concluded) 
D Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. 
QActivity meets Programmatic Allowance # 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
IZI 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 fmdingiSHPOrrHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmdingiSHPOrrHPO 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 fmdingiSHPOrrHPO concurrence on file). 
Are project conditions required? DYes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findingiSHPOrrHPO 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 
IZI 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 fmdingiSHPOrrHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 

o Determination of no historic properties affected (FEMA findingiSHPOrrHPO 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 findingiSHPO/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 findingl SHPOrrHPO concurrence on 
file) 

D No Adverse Effect Determination. (FEMA fmdingl SHPOrrHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination. (FEMA fmdingl 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: 08/0912006 -Historic Review Complete: The structure does not meet the 50-year-criterion, nor does it possess 
the level ofexceptional importance required by criteria consideration ofthe National Register Guidelines to be considered 
eligible for the national register of historic places. Therefore, the proposed work will have no effect on historic properties. 
Scope ofwork indicates minor ground disturbing activities associated with the demolition and replacement ofthe modular 

structure within its original location. Upon consultation ofSHPO data. there are multiple archaeological sites within .5 
miles ofthe project area. Demolition must follow the lower impact demolition stipulations & additional protocols which 
are attached. The stipulations and protocols should be explicit in the demolition contract. Failure to comply with these 
stipulations & additional protocols will jeopardize receipt offederal funding. Ifduring 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 of Archeology at 225-342-8170) within seventytwo 
hours ofthe discovery. Ifthis scope ofwork and/or the location ofthe new building changes, this project will need to 
be resubmitted for further section 106 review prior to ground disturbing activities taking place outside ofthe pre-disaster 
footprint ofthe building. Katherine Zeringue, Historic Preservation Specialist/Archaeologist. 

Correspondence/Consultation/References: 

B. Endangered Species Act 

~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 


determinationlUSFWSINMFS 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: None 
Correspondence/Consultation/References: 

C. Coastal Barrier Resources Act 

~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 

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

o Project would affect waters, including wetlands, ofthe U.S. 
Record ofEnvironmental Consideration 3 

08/12/06 


o Project exempted as in kind replacement or other exemption. <Review Concluded)
o Project requires Section 404/40 1I0r Section 911 0 (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/ConsultationiReferences: 

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) 

1:&1 Project is located in a coastal zone area and/or affects the coastal zone 
1:&1 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-
267-4019.), 

Co"espondence/ConsultationiReferences: 

F. Fish and Wildlife Coordination Act 

1:&1 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 ofthe US. 
CorrespondenceiConsultationiReforences: 

G. Clean Air Act 

1:&1 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/ConsultationiReferences: 

H. Farmland Protection Policy Act 

1:&1 Project does not affect designated prime or unique farmland. (Review Concluded) 
D Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

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

Comments: None 
Correspondence/ConsultationiReferences: 


I. Migratory Bird Treaty Act 
D Project not located within a flyway zone. (Review Concluded) 
t8I Project located within a flyway zone. 


t8I Project does not have potential to take migratory birds. <Review Concluded) 
Are project conditions required? D Yes (see section V) t8I 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: htto:lloacificflvwav.2ovlDocumentsiMississiooi mao.odf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 
t8I 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)
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 
t8I 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) 
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 FloodplainsIFlood levels and project outside Floodplain -(Review Concluded) 
t8I 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) 


f 

DlsasterlEmergeatylPrognmIProject Tille: DRI603LA I Hurricane Katrina I Public Assistance Program I EORl429 Mondy Elementary SchoolModular 
Classroom f 


t 

o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). 
[8J Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 


I

environment 
[8J 8 Step Process Complete -docwnentation on file 
Are project conditions required? [8J YES (see section V) 0 NO (Review Concluded) 


I 

Comments: 07128/2006-The City ofNew Orleans 1Orleans Parish is enrolled in the National Flood Insurance Program 
(NFIP) as of08-03-70, as detennined per Flood Insurance Rate Map (FIRM) panel nwnber 2252030095e, dated 03-01-84. 

I 

i

Facility is located within an "A3" zone, area of 100-yr flooding, base flood elevations and flood hazard factors. Project is 

I•l 
~

replacement ofmodular classrooms; all new building placements must coordinate and comply with local floodplain 
ordinances and be built to codes, standards and must be elevated to or above advisory base flood elevations. In compliance 
with EO 11988, an 8-step process was completed and is attached. 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 LAGOHS/OEP and 

l 

FEMA for inclusion in the pennanent project files. A. Cramer FPM Specialist 

t 

Co"espondence/ConsultationiRejerences: 

i 

I,

B. E.O. 11990 -Wetlands 
[8J No Effects on Wedand(s) and project located outside Wetland(s) -(Review Concluded) 


i

o Located in Wetland or effects WetJand(s)

o Beneficial Effect on Wetland -(Review Concluded) I 
o Possible adverse effect associated with constructing in or near wetland 


I

o Review completed as part offloodplain review 
o 8 Step Process Complete -docwnentation on file 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


! 

I

Comments: None 

I 

Correspondence/Consultation/References: 

I 


I ; 

! 


I 
I 


I 

i 

C. E.O. 12898 -Environmental Justice For Low Income and Minority Populations 
[8J 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 
Co"espondenceJConsu[tation/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. 

Record of Environmental Consideration 6 08112/06 


• A "Yes" under any circwnstance 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 circwnstance can be mitigated, 
please explain in comments. If no, leave blank. 

D (i) Greater scope or size than normally experienced for a particular category of action 
D (ii) Actions with a high level of public controversy
D (iii) Potential for degradation, even though slight, ofalready existing poor environmental 


conditions;
D (iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks;
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 ofthe environment. 
D (x) Potential for significant cwnulative 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 

Project Conditions: 

I. All new building placement must coordinate and comply with local floodplain ordinances and be 
built to codes, standards and must be elevated to or above advisory base flood elevations. In 
compliance with EO 11988, an 8-step process was completed and is attached. 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 LAGOHS/OEP and FEMA for inclusion in the 
pennanent project files. 

2. Demolition must follow the lower impact demolition stipulations & additional protocols which are 
attached. The stipulations and protocols should be explicit in the demolition contract. Failure to 
comply with these stipulations & additional protocols will jeopardize receipt of federal funding. If 
during 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 hann to the finds. The applicant shall infonn 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 staffs 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 ofthe discovery. If 
this scope of work and/or the location of the new building changes, this project will need to be 


resubmitted for further section 106 review prior to ground disturbing activities taking place outside 
of the pre-disaster footprint ofthe building. 

Monitoring Requirements: None