Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board Disa.terlEmergencylProgramIProject TIUe: DRl603LA I Hurricane Katrina I Public Assistance Program I EOR 1854 Abramson Senior High School Building A Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project NamelNumber: EOR 1854 Abramson Senior High School Building AI PW 13028 Project Location: 5552 Read Road, New Orleans, Louisiana Orleans Parish 70127 (N30.02947 W89.97108) Project Description: Project activities include replacing 4,404 SF of floor vct, 1,168 SF ofvinyl base, 3,754 SF of ceiling act and grid, 980 SF ofceiling drywall, 1,504 SF of wood paneling, 6,912 SF of drywall, 8 hollow metal doors, 30 metal door frames, 24 SF ofvision panel, 2 toilet and flush valve, 2 lavatory and faucets, 2 mirrors, 16 aluminum double windows, 16 insulated panels, 15 ton compressor condensing unit, heat pump, air handling unit, 5,750 SF of distributions, 5,750 SF ofequipment connections and disconnections, fIre alarm systems (5,750 SF), intercom system (5,750 SF), sound system security system (5,750 SF), clock system (5,750 SF) and video distribution system (5,750 SF). Hazard mitigation will be achieved by compliance with codes and standards. 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) [8J (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 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) [8J Environmental Impact Statement Comments: Although this project would have qualified as a CATEX (xv) under 44 CFR part I 0.8 (d) (2), this project meets the definition ofcritical infrastructure (Permanent Schools) under the Alternative Arrangements for NEPA compliance. This project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) laws which are listed under the NEPA level of environmental 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 of any Record of Environmental Consideration 09/05/06 Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board DisalterlEmergencylProgramIProject Title: DR1603LA I Hurricane Katrina I Public Assislance Program I EOR 1854 Abramson Senior High School Building A compliance with the National Environmental Policy Act. The applicant is required to obtain and comply with all local, state and federal pennits and requirements. Non·compliance with the requirements noted above may jeopardize the receipt of federal fundin . Reviewer and Approvals D Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Signature'_~...:...!..._-+--'f---1I..:..-..~:""'-____---:" Date _.....;0::..::9;..:..;/0=5=/2=0:..::;0=6____---:. FEMA Regional Environmental Officer or delegated approving official. Name: Howard R. Bush, ELO Signature ~~ z~ . Date _~09,-,-/0=5;.:..::/2=0=06=--___---:. I I. Compliance Review for Environmental Laws (other than NEP A) A. National Historic Preservation Act 181 Not type ofactivity with potential to affect historic properties. (Review Concluded) o Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. QActivity meets Programmatic Allowance # Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) mSTORIC BUILDINGS AND STRUCTURES 181 No historic properties that are listed or 45150 years or older in project area. (Review Concluded) o Building or structure listed or 45150 years or older in project area and activity not exempt from review. o Determination ofNo Historic Properties Affected (FEMA fmdingiSHPOrrHPO concurrence on file) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o Determination ofHistoric Properties Affected (FEMA fmdingiSHPOrrHPO concurrence on file) o Property a National Historic Landmark and National Park Service was provided early notification during the consultation process. If not, explain in comments o No Adverse Effect Detennination (FEMA fmdingiSHPOrrHPO concurrence on file). Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o Adverse Effect Determination (FEMA findingiSHPOrrHPO concurrence on file) o Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required 0 Yes (see section V) D No (Review Concluded) ARCHEOLOGICAL RESOURCES t8J Project affects only previously disturbed ground. (Review Concluded) o Project affects undisturbed ground. D Project area has no potential for presence ofarcheological resources o 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) Record ofEnvironmental Consideration 2 Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board Dlsaster{EmergencylProgramIProjed Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 1854 Abl1llllson Senior High School Building A o No Adverse Effect Determination. (FEMA finding! SHPOrrHPO concurrence on file) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o Adverse Effect Determination. (FEMA fmding! SHPOrrHPO concurrence on file) o Resolution of Adverse Effect completed. (MOA on file) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) Comments: 9/05/2006 -Main building was built in 1969 (Portable in 1985). 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 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 [8J 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 404/401l0r Section 9/lO (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 of the 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) [8J Project is located in a coastal zone area and/or affects the coastal zone [8J 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 09/05/06 ,.. Reviewrr Name: Catherine Jones Applica.t: Orleans Parish School Board DinsterlEmergencylProgramIProject nUe: DR 1603 LA I Hurricane Katrina I Public Assistance Program I EOR 1854 Abramson Senior High School Building A 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.). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act 181 Project does not affect, control, or modifY a waterwaylbody of water. (Review Concluded) o Project affects controls or modifies a waterwaylbody of water. 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 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. oCoordination 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 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-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) [8J 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: 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 Swnmary are met. Correspondence/Consultation/References: htto:/IpacificflvwaY.gov/DocumentsiMississippi map.pdf, J. Magnuson-Stevens Fishery Conservation and Management Act [8J Project not located in or near Essential Fish Habitat. (Review Concluded) Record of Environmental Consideration 4 09/05/06 Rtviewtr Namt: Catherine Jones Applieant: OrlClUlS Parish School Board DisasttrlEmtl'ltntylProgrlmJProjtet Titlt: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 1854 Abramson Senior High School Building A o Project located in or near Essential Fish Habitat. oProject does not adversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) oProject adversely affects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS concurrence on file) oNOAA Fisheries provided no recommendation(s) (Review Concluded), Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) oNOAA 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 oProject adversely affects WSR as detennined by NPSIUSFS. FEMA cannot fund the action. (NPSIUSFSIUSFWSlBLM consultation on file) (Review Concluded) oProject 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 oNo Effect on FloodplainsIFlood levels and project outside Floodplain -(Review Concluded) 181 Located in Floodplain or Effects on FloodplainsIFlood 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) oBeneficial Effect on Floodplain OccupancyNalues (Review Concluded), 181 Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment 181 8 Step Process Complete -documentation on file Are project conditions required? 181 YES (see section V) 0 NO (Review Concluded) Comments: 08/05/06-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 number 22520301I5e, dated 03-01-84. Facility is located within an "A4" zone, area of IOO-yr flooding, base flood elevations and flood hazard factors .. The project is the repair of building and the replacement ofequipment 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 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. A Cramer, FPM Specialist. Correspondence/Consultation/References: 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) oBeneficial Effect on Wetland -(Review Concluded) Record ofEnvironmental Consideration 5 09/05/06 Reviewer Name: Catherine Jones Applicant: Orleans P8I'ish School B08I'd DI.a.terlEmergencylProgramIProjett Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 1854 Abramson Senior High School Building A 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 I8J 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 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 dearly 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. If no, leave blank. o (i) Greater scope or size than 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; D (iv) Employment of unproven technology with potential adverse effects or actions involving unique or unknown environmental risks; D (v) Presence of endangered 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 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. Reviewer Name: Catherine Jones Applicant: Orleans Parish School Board Diu.terlEmergencylProgramIProjed TItle: DR1603LA / Hurricane Katrina / Public Assistance Program / EOR 1854 Abramson Senior High School Building A IComments: None V. Environmental Review Project Conditions Project Conditions: 1. 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 final public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LaGOHS/OEP and FEMA for inclusion in the permanent project files. 2. 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. 3. 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, S1. Charles, S1. John the Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement ofwood 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 of Agriculture and Forestry or his designee(s). 4. This project potentially involves the disposal ofMetallic Mercury Containing Electronic Devices. The applicant is responsible for ensuring that these devices are recovered, recycled, reused or sequestered in accordance with the Louisiana Department ofEnvironmental Quality (LDEQ) "Declaration ofEmergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3,2005. 5. 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 ofsuch operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. Monitoring Requirements: None