Reviewer Name: Catherine Jones Applieant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 211 S Dunbar Elementary School Fences 
and Canopy 

Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: EOR 2115 Dunbar Elementary School-Fences and Canopy, / PW 13152 

Project Location: 9330 Forshey Street, New Orleans, Louisiana Orleans Parish (N29.9707 W90.1237) 


Project Description: Project activities include replacing 370 Lf of 8' three strand barb wire, 100 LF of 
4' chain link fencing, one 5'x 10' chain link double gate, 550 LF of 10' of sidewalk, 716 LF of 10' of 
wood canopies, 72 SF of roll roofing, 716 LF ofaluminum gutters, 20' of8' aluminum canopy, 4 
basketball.b1lCkhoard combo and 3.00.0 CYJ:)f backfill. Hazard.mitigationwill..be.llCbielledJJ;y.. 
compliance with codes and standards. 

Documentation Reg uirements 

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) 


[8] (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 NEPA review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category (Review Concluded) 
o Categorical Exclusion -Category
o No Extraordinary Circumstances exist. 
Are project conditions required? D Yes (see section V) 0 No (Review Concluded) 
o Extraordinary Circumstances exist (See Section IV). 






D Extraordinary Circumstances mitigated. (See Section IV comments) 
Are project conditions required? D Yes (see section V) 0 No (Review Concluded) 

o Environmental Assessment 
o Supplemental Environmental Assessment (Reference EA or PEA in comments) 


[8] Environmental Impact Statement 

Comments: This project meets the criteria for an alternative arrangement (Permanent Schools) type ofproject. This project 
has conditions and requires mitigation under the other 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 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. Noncompliance 
with the requirements noted above may jeopardize the receipt of federal funding. 


Reviewer Name: Catherine Jones Appliunt: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR 2115 Dunbar Elementary School· 
Fences and Canopy 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 

Name: Catherine Jones, Environmental Spe ialist 
Signature_..l.6-~:::.II-'::"=T--+-+-~_____""':" Date _--:::.8/=3=O/:..::2:..:.:.0~06~____....:. 


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

Signature ~:--;> ~/7' . Date _-=8/=3=O/-=2=OO~6,,-----___----:. 

"7 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

o Not type of activity with potential to affect historic properties. (Review Concluded) 
[81 Applicable executed Programmatic Agreement 12/0312004 Otherwise, conduct standard Section 106 review. 


t8'J..Activity meets Programmatic Allowance # {I-A, ID, IE} 
Are project conditions required? [81 Yes (see section V) D No (Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 
[81 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. 

D Determination ofNo Historic Properties Affected (FEMA fmdinglSHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmdinglSHPOffHPO 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 fmdinglSHPOffHPO concurrence on file). 
Are project conditions required? 0 Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA fmdinglSHPOffHPO 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) 

ARCHEOLOGICAL RESOURCES 
~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 of no historic properties affected (FEMA fmdinglSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination of no historic properties affected (FEMA fmdinglSHPOffHPO concurrence on file) 
Are project conditions required D Yes (see section V) D No (Review Concluded) 
D Determination of historic properties affected 
D NR eligible resources not present (FEMA fmdinglSHPOffHPO 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 SHPOffHPO concurrence on 
file) 

o No Adverse Effect Determination. (FEMA findingl SHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 

D Adverse Effect Determination. (FEMA findingl SHPOffHPO concurrence on file) 
D Resolution of Adverse Effect completed. (MOA on file) 


Comments: None 
Reviewer Name: Catherine Jones Applkant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 211 S Dunbar Elementary School· 
Fences and Canopy 

Are project conditions required? 0 Yes (see section V) 0 No 
<Review Concluded) 

Comments: 8/30/06 -Scope of Work indicates ground disturbing activities associated with replacing a sidewalk, replacing 

fence and gate posts and backfilling. Upon consultation ofdata provided by the State Historic Preservation Officer 

(SHPO), there is one known archaeological sites within .25 miles ofthe project area. However all work will occur within 

previously disturbed areas. Therefore, the scope ofwork as submitted meets the criteria outlined in the Programmatic 

Agreement dated December 3, 2004, Appendix A, Section I A, D and E. In accordance with this document, FEMA is not 

required to submit projects to the SHPO for review where the work performed meets these allowances. Any fill or borrow 

material used in the repair activities must be sourced from sites that do not contain any buried cultural materials (i.e. wells, 

cisterns, foundations, basements, prehistoric Indian artifacts, human burials, and the like). 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 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, if unmarked graves are present, compliance with the 
Louisialla-UAmal:ked-llumaD~..$ites~tioo.A~S,3"71·et~~pplieantshall ootity the 

law enforcement agency ofthe 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 (caU the Louisiana Division of 
Archeology at 225-342-8170) within seventy-two hours ofthe discovery. Failure to comply with these stipulations may 
jeopardize receipt ofFEMA funding. -Dana Linck, Historic Preservation Specialist/Archaeologist 

Correspondence/Consultation/References: 

B. Endangered Species Act 
[8J 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) 

Corres ondence/Consultation/References: 

C. Coastal Barrier Resources Act 
[8J 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.61 (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 
I:8J 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 404/401l0r Section 91 I 0 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 


Record of Environmental Consideration 3 08130/06 


Reviewer Name: Catherine Jones Applicant: Rerovery School District 
DisasterlEmergencylPrognmIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 211 SDunbar Elementary School· 
Fences and Canopy 

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

Comments: Project is not in or adjacent to any waterways of the US. 
Correspondence/Consultation/References: 

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) 

181 Project is located in a coastal zone area and/or affects the coastal zone 
181 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 DNR has determined that receipt of 
federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still 

.. rcquir.e.a-COUtal.u.se.pemit or gtha-...au~4T~mDNR.·P-{'.ojeGt&maybe-ooordinated.ey«lRtaGting-M DNR--et 1800-
267-4019.). 
Corres ondence/Consultation/Re erences: 

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) 
D Project affects controls or modifies a waterwaylbody ofwater. 

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: Project is not in or adjacent to any waterways ofthe US. 
Correspondence/Consultation/References: 

G. Clean Air Act 

181 Project will not result in permanent air emissions. (Review Concluded) 
D 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: None 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

181 Project does not affect designated prime or unique farmland. (Review Concluded) 
D Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 
D Coordination with Natural Resource Conservation Commission required.
D Farmland Conversion Impact Rating, Form AD-l 006, completed. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

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


181 Project does not have potential to take migratory birds. (Review Concluded) 

08/30/06


Reviewer Name: Catherine Jones Applicant: Recovery School District 
DlsuterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2115 Dunbar Elementary SchoolFences 
and Canopy 

Are project conditions required? 0 Yes (see section V) 1:81 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: 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. 

Co"espondence/Consultation/Rejerences: h1tll:/lPacifictlvwav.2ov/DocumentslMississinni man.ndf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

1:81 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-projectwnditions I'equbed?-G-Ves (see-settion V)~ GNo1Iteview Concluded)
o Project adversely affects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS 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 

1:81 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. (NPSIUSFSIUSFWSlBLM 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) 

1:81 Located in Floodplain or Effects on FloodplainslFlood levels 

IZI No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 0 Yes (see section V) IZI No (Review Concluded) 

o Beneficial Effect on Floodplain OccupancyNalues <Review Concluded).
o 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) D NO (Review Concluded) 


Reviewer Name: Catherine Jones Applicant: Recovery School District 
Di.a.terlEmergencylProgramlProject Title: DR I603 LA I Hurricane Katrina I Public Assistance Program I EOR 211 S Dunbar E\ementMy School· 
Fences and Canopy 

Comments: 08/05/06 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program (NFIP) 
08/0311970. Per Flood Insurance Rate Map (FIRM) 2252030095 e, dated 03/01/1984, project is located in zone "A3"; area 
of 100-yr flood, base flood elevation and flood hazard factors detennined. Project is to repairlreplace fence, canopy, and 
sidewalk facilities to pre-disaster footprint. Project should have no effect on floodplain. Casey Barefield, FPM. 

Correspondence/Consultation/References: 

B. E.O.11990 -Wetlands 
~No Effects on WetJand(s) and project located outside Wedand(s) -(Review Concluded) 


oLocated 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 
o8 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 
~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) 
oDisproportionately 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. If no, leave blank. 

o (i) Greater scope or size than nonnally 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, ofalready existing poor environmental 
conditions; 
o (iv) Employment of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
o (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 


cultural, historical or other protected resources; 


Reviewer Name: Catherine Jones Applicant: RecoveJy School District 
DisasttrlEmergmcylProgramIProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 211 SDunbar Elementary SchoolFences 
and Canopy 

o (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local 
regulations or standards requiring action or attention; 
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 

Project Conditions: 

1. If during the course of work, 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 Staffhave 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 of the 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 of the discovery. Failure to comply 
with these stipulations may jeopardize receipt ofFEMA funding. 
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 of petroleum 
products, hazardous materials and/or toxic waste in accordance to the requirements and to 
the satisfaction of the 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, St. Charles, st. 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 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 of Environmental Quality (LDEQ) 
in accordance with the LDEQ "third amended Declaration of Emergency and Administrative 
Order" dated June 30, 2006, incorporating the provisions of EP A'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 order. 


Record of Environmental Consideration 7 


Reviewer Name: Catherine Jones Applicant: Recovery School District 
DlsasterlEmergeac:ylProgramIProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 211 S Dunbar Elementary SchoolFences 
and Canopy 

5. This project involves the demolition or renovation 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 
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