Rfviewfr Namf: Adam Bordfn, Env. Sptcialist Projfd NamflEnv. DatabaSf No: Abramson High School-Modular Building ## 4 (Facility) 
FEMA·1603/1607·DR·LA PW##l1896 
Parish: Orlnns 

Record of Environmental Consideration 


REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 

See 44 Code of Federal Regulation Part 10 

Proiect NamelNumber: Abramson High School-Modular Building # 4 (Facility) / PW# 12896 
FIPS#071-UFTI3-00 

Project Location: 5552 Read Blvd, New Orleans, LA 70127 
Latitude: 30.02947, Longitude: -89.97108 

Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior 
and interior damage to Abramson High School-Modular Building # 4 (Facility) ofthe Orleans Parish School Board. This 
pw reimburses the eligible applicant for replacement ofthe building within the pre-disaster footprint. The new building will 
be replaced according to codes and standards upgrades. All work will be performed in a previously disturbed area with no 
indication ofnearby waterways or other bodies ofwater. 

Documentation Reg uirements 

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) 

18I (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 (NEP A) Determination 

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


Comments: This project meets the criteria for an Alternative Arrangement (Permanent Schools) type of project. This 
project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) laws which 
are listed under the NEPA level ofenvironmental review in the project worksheet. Any changes to this approved scope of 
work will require submission to, and evaluation and approval by, the state and FEMA prior to initiation ofany work, for 
compliance with the National Environmental Policy Act. The applicant is required to obtain and comply with all local, state 
and federal permits and requirements. Non-compliance with the requirements noted above may jeopardize the receipt of 
federal funding. 

Reviewer and Approvals 

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


Reviewer Name: Adam Borden, Env. Sptc:laUst Project Name!Env. Database No: Abramson High School·Modular Building II 4 (Facility) 
FEMA·1603/1607·0R·LA PWIII1896 
Parish: Orleans 

Signature _~~~~~~....-....::--___Date _~_-_3.,£--.1..(_-_O...:......gb,-,--....:. 

FEMA Regional Environmental Officer or Delegated Approving Official: 
Name: Howard R. Bush, Environmental Liason Officer 

Signature ?~~ ;~ Date __i_"_l_'_.o_~__....:. 

I. Compliance Review for Environmental Laws (other than NEPAl 

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: 
Are project conditions required? D Yes (see Section V) D No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

HISTORIC 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 fmding/SHPOrrHPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmding/SHPOrrHPO 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 fmding/SHPOrrHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA fmding/SHPOrrHPO 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 ofarcheological resources 
D Determination ofno historic properties affected (FEMA finding/SHPOrrHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA finding/SHPOrrHPO 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 fmding/SHPOrrHPO concurrence on file). 

Are project conditions required DYes (see Section V) D No (Review Concluded) 
D NR eligible resources present in project area. (FEMA finding/ SHPOffHPO concurrence on 
file) 

D No Adverse Effect Determination. (FEMA finding/ SHPOrrHPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No <Review Concluded) 
D Adverse Effect Determination. (FEMA fmding/ SHPOrrHPO concurrence on file) 

D Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required? D Yes (see Section V) D No 
<Review Concluded) 


Reviewer Name: Adam Borden, Env. Specialist Project NamtlEnv. Database No: Abfamson Hlgb Scbool-Modulaf Building II .. (Facility) 
FEMA-160l/1607-DR-LA PWIIl2896 
Parisb: Orleans 

Comments: The structure does not meet the 50-year-criterion, nor does it possess the level ofexceptional importance 
required by criteria consideration g of the National Register guidelines to be considered eligible for the National Register of 
Historic Places. Therefore, the proposed work will have no effect on standing historic properties. Scope of work indicates 
minor ground disturbing activities associated with the demolition and replacement of the modular/non-permanent structure 
within its original location. Upon consultation of data provided by the State Historic Preservation Officer (SHPO), there are 
no known archaeological sites within .5 miles of the project area. Demolition must follow the low 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 harm to the fmds. The 
applicant shall inform their Public Assistance (PA) contacts at FEMA. who will in tum 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, ifunmarked 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 seventy-two hours ofthe discovery. Ifthis scope of work 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. 

Correspondence/ConsultlltioniRe/erences: 

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 


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: 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. 
Correspondence/ConsultlltioniRe/erences: USFWS emergency consultation provisions determined in letters dated 
September 15,2005 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 3505.a.6 (Review Concluded) 
o Proposed action not excepted under Section 3505.a.6. 
Are project conditions required? D YES (see Section V) 0 NO (Review Concluded) 


Comments: Project is not within a CBRA zone. 
Correspondence/ConsultationIRej'erences: Louisiana Coastal Barrier Resource System Maps referenced 08/31106. 


D. Clean Water Act 
181 Project would not affect any waters ofthe U.S. (Review Concluded) 


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

o Project exempted as in kind replacement or other exemption. (Review Concluded) 
o Project requires Section 404/401/or Section 9110 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 


Record of Environmental Consideration (Version 08/31106) 


Comments: No jurisdictional waters ofthe U.S., including wetlands, occur in or near the project area. 
Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil)queried 
on 08/31106. 

Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Abramson High School·Modular Building 1# 4 (Facility) 
FEMA·1603/1607·DR·LA PW1#12896 
Parish: Orleans 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

E. Coastal Zone Management Act 
D Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 
I:8l Project is located in a coastal zone area and/or affects the coastal zone 

I:8l State administering agency does not require consistency review. (Review Concluded). 
D State administering agency requires consistency review. 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments: This project is located within the Louisiana Coastal Management Zone. LA Department ofNatural Resources 
(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 1-800-276-4019. 
Correspondence/Consultation/References: LDNR Louisiana Coastal Zone map 2002. 

F. Fish and Wildlife Coordination Act 
I:8l Project does not affect, control, or modify a waterway/body of water. (Review Concluded) 
D Project affects controls or modifies a waterway/body of water. 


D Coordination with USFWS conducted 
D No Recommendations offered by USFWS. (Review Concluded) 
D Recommendations provided by USFWS. 


Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments: No streams or water bodies are located in or near the project area. 
Correspondence/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana.govD queried 08/31/06. 

G. Clean Air Act 
D Project will not result in permanent air emissions. (Review Concluded) 
I:8l 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: This project involves the demolition or renovation of a public structure. 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 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.III.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. 
CorrespondenceiConsultation/References: EPA Region 6 Non-attainment Map. 

H. Farmland Protection Policy Act 
~Project does not affect designated prime or unique fannland. (Review Concluded) 
D Project causes unnecessary or irreversible conversion of designated prime or unique fannland. 


D Coordination with Natural Resource Conservation Commission required.
D Fannland Conversion Impact Rating, Form AD-I 006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 


Reviewer Name: Adam Borden, Env. Spec:lalist Project NamtlEnv. Database No: Abramson High School-Modular Building II 4 (Fac:llity) 
FEMA·1603/1607·0R-LA PWIII2896 
Parish: Orleans 

Comments: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No 
prime or unique farmland present. 
CorrespondenceiConsultatlonIRe/erences: National Resource Conservation Service, Web Soil Survey 
(htto:llwebsoilsurvev.nrcs.usda.20v/aool )referenced 08/31/06. 


I. Migratory Bird Treaty Act 

o Project not located within a flyway zone. (Review Concluded) 
[81 Project located within a flyway zone. 

[81 Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) [81 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) 

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. 
CorrespondenceiConsultatlonIRe/erences: USFWS guidance letter dated September 15,2005 for Katrina 
J. Magnuson-Stevens Fishery Conservation and Management Act 
[81 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 determinationlUSFWSINMFS 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: Project is not located in or near any surface waters with the potential to affect EFH species. 
CorrespondenceiConsultationIRe/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD referenced 08131/06. 

K. Wild and Scenic Rivers Act 
[81 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 determined by NPSIUSFS. FEMA cannot fund the 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 
CorrespondenceiConsultatlonIRe/erences: National Wild and Scenic Rivers htto:llwww.nps.gov/riverslwildriverslist.html. 
referenced 08/31106 . 


L. Other Relevant Laws and Environmental Regulations 


State Hazardous Materials and Solid Waste Laws 
Comments: -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana 
parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the 
Baptist, S1. 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). 


Reviewer Nlme: Adlm Borden, Env. Spedilist Project NlmelEnv. Dltablse No: Abrlmson High School-Modular Building # 4 (Facility) 
FEMA-I603/1607-DR-LA PW#1Z896 
Parish: Orlelns 

-Removal and disposal of debris containing household hazardous waste and certain categories of liquid wastes must be 
performed in accordance with all applicable federal and state laws, regulations, executive orders and guidelines. LAC title 
33 part VII requires that specified items, including lead acid batteries, used oil filters, used motor oil, scrap tires, efc's 
(refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous 
debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris 
collection and/or disposal operations will jeopardize federal funding. The clean-up or restoration/repair ofsites damaged as 
a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a 
determination of ineligibility is made. 

-Lead-Based paint this project involves the demolition ofa public structure that may contain surfaces coated with leadbased 
paint (LBP). 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 project 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. 

II. Compliance Review for Executive Orders 
A. E.O.11988 -Floodplains 


o No Effect on FloodpJains/Flood levels and project outside Floodplain -(Review Concluded) 
18I Located in Floodplain or Effects 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), 
18I Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 


t8l 8 Step Process Complete -documentation on file 
Are project conditions required? t8l YES (see Section V) 0 NO (Review Concluded) 

Comments: The site is located in Zone A4. 

http://store.msc.fema.gov/webapp/wcs/stores/servletiFemaWelcomeView?storeId=10001 &catalogld= 1 0001 &langId=-l, 
The city of New Orleans I Orleans Parish is enrolled in the National Flood Insurance Program (NFIP) as of08-03-70, as 
determined per Flood Insurance Rate Map (FIRM) panel number 2252030 liSE, dated 03-01-84. Facility is located within 
an "A4" zone, area of I OO-yr flooding, base flood elevations and flood hazard factors.. The project is the repair of 
building and the replacement of equipment and components, as per 44 CFR 9.11, mitigation or minimization standards must 
be applied. Where possible, building contents, materials, and equipment (mechanical or electrical) 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 fmal public notice 15 days prior to the start ofconstruction activities. Final public 
notice is to be forwarded to the LAGOHSIOEP and FEMA for inclusion in the permanent project files. A Cramer FPM 
Specialist. 
CorrespondenceiConsultationlRe!erences: FEMA Flood Insurance Rate Map, Community Panel No. # 2252030 lISE, 
dated 03-01-84 

B. E.O. 11990 -Wetlands 
18I No Effects on Wetland(s) and project located outside Wedand(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 offloodplain review 

08 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see Section V) 0 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. 


Reviewer Name: Adam Borden, Env. Specialist Project NamtlEnv. Database No: Abramson High Scbool-Modular Building 114 (Facility) 
FEMA-1603/1607-DR-LA PWlIl1896 
Parish: Orleans 

Correspondence!ConsllltlltlonlRe/erences: USFWS NWI map accessed on-line 
(http://wetlandsfWs.er.usgs.gov/wtIndsllaunch.html) 08131/06. 

C. E.O. 12898 -Environmental Justice for Low Income and Minority Populations 
D No Low income or minority population in, near or affected by the project -(Review Concluded) 
t8J Low income or minority population in or near project area 

t8J 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 of 70 127 are: 85.6% Black, 11.3% White, and 1.6% Hispanic. The median household 
income in 1999 was $ 30,954 and 15.3% offamilies are below poverty level. 
Correspondence/ConsllltlltlonJRe/erences: U.S. Census bureau 2000 data at http://factfinder.census.gov, referenced 
08131106. 


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: -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:339 Ll 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 of the Louisiana Department ofAgriculture 
and forestry or his designee(s). 

-Removal and disposal of debris containing household hazardous waste and certain categories of liquid wastes must be 
performed in accordance with all applicable federal and state laws, regulations, executive orders and guidelines. LAC title 
33 part VII requires that specified items, including lead acid batteries, used oil filters, used motor oil, scrap tires, efc's 
(refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous 
debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris 
collection and/or disposal operations will jeopardize federal funding. The clean-up or restoration/repair ofsites damaged as 
a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation ifa 
determination of ineligibility is made. 

-Lead-Based paint this project involves the demolition ofa public structure that may contain surfaces coated with leadbased 
paint (LBP). 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 CFR260 
through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with 
the Louisiana Department ofEnvironmental Quality for abatement activities and is also responsible for ensuring proper 
disposal in accordance with the previously referenced regulations. 

Correspondence/ConsllltationJRe/erence: 

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. If no, leave blank. 

Yes 


Reviewer Name: Adam Borden, [nv. Specialist Project NamtlEnv. Database No: Abramson High School-Modular Building 114 (Facility) 
FEMA-I603/1607-DR-LA PWII12896 


Parish: Orleans 

D (i) Greater scope or size than normally experienced for a particular category ofaction 

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 of hazardous 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: 

The following conditions apply as a condition of FEMA funding reimbursement: 

• 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 ofEnvironmental 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 I, 2006, 
incorporating the provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 
the Louisiana Administrative Code (LAC) 33.111.5151 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 orders. 
• In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes of 
Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, S1. Bernard, S1. Charles, S1. John the 
Baptist, S1. 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 of Agriculture and forestry or his designee(s). 
• Removal and disposal of debris containing household hazardous waste and certain categories of liquid wastes must 
be performed in accordance with all applicable federal and state laws, regulations, executive orders and guidelines. 
LAC title 33 part VII requires that specified items, including lead acid batteries, used oil filters, used motor oil, 
scrap tires, efc's (refrigerants), radioactive waste or regulated infectious wastes must be segregated from and 
excluded from non-hazardous debris collection, staging, processing and disposal sites. Failure to comply with 
applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The 
clean-up or restoration/repair of sites damaged as a result ofsuch operations are ineligible for federal funding. 
Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. 
• Lead-based paint -this project involves the demolition of a public structure that may contain surfaces coated with 
lead-based paint (LBP). 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 
project activities are coordinated with the Louisiana Department ofEnvironmental Quality for abatement activities 
and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. 



Reviewer Name: Adam Berden, Env. Spedallst Project NamelEnv. Database No: Abramson Higb Scbool·Modular Building N4 (Fadlity) 
FEMA·1603/1607·DR·LA PWNll896 
Parish: Orleans 

• Demolition must follow the low 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 harm to the finds. The applicant shall inform 
their Public Assistance (PA) contacts at FEMA, who will in tum contact FEMA Historic Preservation staff. The 
applicant will not proceed with work until FEMA Historic Preservation staffhave 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 seventy-two hours ofthe discovery. Ifthis scope of 
work 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. 
• As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, building contents, 
materials, and equipment (mechanical or electrical) 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 fmal 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 permanent project files.