Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasttrlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Center 

Record of Environmental Consideration 

See 44 Code of Federal Regulation Part 10. 

Project NamelNumber: New Orleans High School Signature Center I PW 13317 

Project Location: 2600 Rocheblave Street, New Orleans, Louisiana, Orleans Parish, 70125 
(N29.94936, W-90.0976) 

Project Description: Project activities include cleaning and sanitizing concrete floors, landings, stairs, 
glass windows, aluminum frames, concrete-surfaced walkways, ceramic floor and wall tiles; asbestos 
abatement for the damaged asbestos-containing materials; and replacing suspended ceiling tiles, 
window glass, roof vent caps, shutters, rubber roof material, gravel ballast layer, acoustic ceiling tiles, 
vinyl composite tiles, rubber base molding, window panes, condensate removal pump, wood floor 
planks, gypsum wall boards, wood base molding, rubber base molding, solid wood doors, wood 
frames, hardware, push-bars, kick-plates, wire mesh exterior window covers, solid wood cabinets, 
wood shelves, porcelain/cast iron sinks, baseboards, chalk boards, corkboards, air conditioning units, 
HV AC units, outdoor switchgear enclosure, disconnect switches, breaker boxes, switch boxes, 
electrical panel boards, transformers, public address system, electrical boxes, emergency pull boxes, 
speaker boxes, aluminum conduit (electrical), wiring, light switches, electrical outlet/receptacles, 
bubblers, toilet paper dispensers, toilet partitions, metal doors, metal frames, metal security mesh 
doors, metal security mesh partitions, metal security mesh screens, metal vault doors, aluminum 
frames, plexi-glass windows, metal frames, plastic utility sinks, toilets, and urinals. Some mitigation 
will be achieved by compliance with current codes and standards and by good construction practices. 

Documentation Reguirenlents 

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) 

[8J (Long version) All applicable laws and executive orders were reviewed. Additional information for 
compliance is attached to this REC. 

N adonal 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) 

Record of Environmental Consideration 1 08129/06 


Reviewer Name: Letha Dawson Applieant: Recovery School district 
DisasterlEmergeneylProgramlProjeet Tide: DR 1603 LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Center 

[gI Environmental Impact Statement 

Comments: This project meets the criteria for an Alternative Arrangement (Pennanent 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 of Environmental Review in the Project Worksheet. Any changes to this approved scope 
ofwork 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 pennits and requirements. Non-compliance with the requirements noted above may jeopardize the receipt of 
federal funding. 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha Dawson, Environmental Specialist 


Signature ct~0;.l~ . Date _--=..:08=/2=9;.:.:/2=0=0=.6______''' 

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

Signature ~1j . Date __0=8=/2=9~/2=0=06~____---,


I. Compliance Review for Environmental Laws (other than NEPA) 

A. National Historic Preservation Act 

o Not type of activity with potential to affect historic properties. <Review Concluded)

I8l Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. 
I8l Activity meets Programmatic Allowance # Appendix A, Section {II-A4, II-C2, II-El, II-A2, II-B 1,1-0, II-CI, 
II-H} 
Are project conditions required? I8l Yes (see section V) 0 No <Review Concluded) 

HISTORIC BUILDINGS AND STRUCTURES 

o 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 Detennination of No Historic Properties Affected (FEMA findingiSHPOITHPO concurrence on file) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Detennination of Historic Properties Affected (FEMA fmdingiSHPOITHPO concurrence on file) 
o Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. Ifnot, explain in comments 
o No Adverse Effect Oetennination (FEMA findingiSHPOITHPO concurrence on file). 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 
o Adverse Effect Determination (FEMA findingiSHPOITHPO concurrence on file) 










o Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required 0 Yes (see section V) 0 No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 
I8l Project affects only previously disturbed ground. (Review Concluded) 

o Project affects undisturbed ground. 

o Project area has no potential for presence of archeological resources 


Reviewer Name: letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramlProject Title: DR 1603 LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Center 

o Detennination of no historic properties affected (FEMA findinglSHPOrrHPO conculTence or 
consultation on file). <Review Concluded)

o Project area has potential for presence ofarcheological resources 

o Detennination of no historic properties affected (FEMA findinglSHPOrrHPO conculTence on file) 
Are project conditions required 0 Yes (see section V) 0 No (Review Concluded) 
D Detennination ofhistoric properties affected 
D NR eligible resources not present (FEMA findinglSHPOrrHPO conculTence on file). 

Are project conditions required Dyes (see section V) 0 No (Review Concluded) 
D NR eligible resources present in project area. (FEMA fmding! SHPOrrHPO concurrence on 
file) 

o No Adverse Effect Detennination. (FEMA findingl SHPOrrHPO concurrence on file) 
Are project conditions required? D Yes (see section V) 0 No (Review Concluded) 
o Adverse Effect Detennination. (FEMA findingl 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) 

Comments: 0812612006 -FEMA's Programmatic Agreement (PA), dated December 3, 2004, provides for expedited project 
review under Section 106 of the National Historic Preservation Act (NHPA). The scope of work as submitted in this PW 
has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section {II-A4, II-C2, II-EI, 
II-A2, II-BI, 1-0, II-CI, I1-H}, of the document. In accordance with the PA, FEMA is not required to detennine the 
National Register eligibility of properties or to submit projects to the State Historic Preservation Officer (SHPO) for review 
where the work perfonned meets these allowances. In keeping with the stipulations of the P A, all proposed repair activities 
should be done in-kind to match existing materials and fonn. Any change to the approved scope of work will require 
resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the 
receipt of federal funding. This concludes the Section 106 review for this project. V. Gomez, Historic Preservation 
Specialist 

Correspondence/Consultation/References: 

B. Endangered Species Act 

I:8l No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
<Review Concluded)
D Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. 


D No effect to species or designated critical habitat. (See comments for justification) 

Are project conditions required? D Yes (see section V) D No <Review Concluded)
D May affect, but not likely to adversely affect species or designated critical habitat (FEMA 
detenninationlUSFWSINMFS conculTence on file) (Review Concluded) 


Are project conditions required? D Yes (see section V) D No <Review Concluded)
D Likely to adversely affect species or designated critical habitat 
D Fonnal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: None 
CorrespondenCe/Consultation/References: 

C. Coastal Barrier Resources Act 

I:8l Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded>. 
D Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA detenninationlUSFWS consultation on 


file) 
D Proposed action an exception under Section 3505.a.6? <Review Concluded)
D Proposed action not excepted under Section 3505.a.6. 


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

Comments: None 
Correspondence/Consultation/References: 


Rtviewtr Namt: Letha Dawson Applicant: Recovery School district 
DlsasttrlEmtrgtnc:ylProgramIProject Titlt: DR I603 LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Center 

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 404/40l/or Section 9/10 (Rivers and Harbors Act) pennit, including qualification 
under Nationwide Pennits. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
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) 

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). 

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 detennined that 
receipt offederal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the Coastal 
Zone may still require a Coastal Use Pennit or other authorization from DNR. Projects may be coordinated by 
contacting LA DNR at 1-800-267-4019. 

Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modifY a waterwaylbody ofwater. (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: None 
Correspondence/Consultation/References: 

G. Clean Air Act 

t8l Project will not result in pennanent air emissions. (Review Concluded) 

o Project is located in an attainment area. (Review Concluded) 
o Project is located in a non-attainment area. 


o Coordination required with applicable state administering agency .. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

181 Project does not affect designated prime or unique farmland. (Review Concluded)

o Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

o Fannland Conversion Impact Rating, Fonn AD-I006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramIProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Cenler 

I. Migratory Bird Treaty Act 

o 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) 
Are project conditions required? 0 Yes (see section V) 181 No <Review Concluded) 


o Project has potential to take migratory birds. 

o Contact made with USFWS 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

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: http://pacificflyway.gov/DocumentsiMississippi map.pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

181 Project not located in or near Essential Fish Habitat. <Review Concluded) 

o Project located in or near Essential Fish Habitat. 

o Project does not adversely affect Essential Fish Habitat. <Review Concluded) 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 
o Project adversely affects Essential Fish Habitat (FEMA 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: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

181 Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) 

o Project is along or affects WSR 

o Project adversely affects WSR as 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 
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 Floodplains/Flood levels and project outside Floodplain -(Review Concluded) 
[8J Located in Floodplain or Effects on FloodplainslFlood levels 

o No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Beneficial Effect on Floodplain OccupancyNalues <Review Concluded). 
[8J Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain 
environment 


[8J 8 Step Process Complete -documentation on file 
Record ofEnvironmental Consideration 5 08/29{06 


Comments: None 
Reviewer Name: Letha DawS()n Applicant: Recovery School district 
DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Cenler 

Are project conditions required? t8:I YES (see section V) 0 NO (Review Concluded) 

Comments: 0811 112006 -The City ofNew Orleans 1Orleans Parish enrolled in the National Flood Insurance Program 
(NFIP) as of08/0311 970. Facility is located within an "A8" zone, area of 100-yr flooding, base flood elevations and flood 
hazard factors as determined per Flood Insurance Rate Map (FIRM) panel number 2252030160 E, dated 03/01/1984. 
Project is repair of building and replacement of equipment and components. In compliance with EO 11988, an 8-step 
process was completed and is attached. As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where 
possible, building contents, materials, components and equipment (mechanical or electrical) must be elevated to or above 
Advisory Base Flood Elevations. Per 44 CFR 9.12, a final public notice is to be published 15 days prior to the start ofany 
construction activities. Documentation of completed public notice is to be forwarded to FEMA and LA GOHSEP for 
inclusion in the permanent project files. A. C. Clark, Floodplain Specialist 
Correspondence/consultation/references: 8-Step Process 

B. E.O. 11990 -Wetlands 
t8:I No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 


o Located in Wetland or effects Wetland(s) 

o Beneficial Effect on Wetland -(Review Concluded) 
o Possible adverse effect associated with constructing in or near wetland 
D Review completed as part of floodplain review 


o 8 Step Process Complete -documentation on file 
Are project conditions required? D 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 
t8:I 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) 


Corres ondence/Consultation/References: 

III. Other Environmental Issues 

Identify other potential environmental concerns in the comment box not clearly falling under a law or 
executive order (see environmental concerns scoping checklist for guidance). 

Comments: None 
Correspondence/Consultation/References: 

IV. Extraordinary Circumstances 

Based on the review of compliance with other environmental laws and Executive Orders, and in 
consideration of other environmental factors, review the project for extraordinary circumstances. 

• A "Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of (ii) 
which should be applied in conjunction with controversy on an environmental issue. If the circumstance can 
be mitigated, please explain in comments. Ifno, leave blank. 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergeneylProgramlProject Title: DR1603LA' Hurricane Katrina' Public Assistance Program I EOR 2097 New Orleans High School 
Signature Center 

Yes 

o (i) Greater scope or size than nonnally experienced for a particular category of action 
o (ii) Actions with a high level ofpublic controversy 
o (iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; 
o (iv) Employment ofunproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
o (v) Presence of endangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
o (vi) Presence of hazardous 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 of the 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 of the 
proposed action may not be significant by themselves. 

IComments: None 

v. Environmental Review Project Conditions 


General comments: None 

Project Conditions: 

1. As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, 
building contents, materials, components and equipment (mechanical or electrical) must be 
elevated to or above Advisory Base Flood Elevations. Per 44 CFR 9.12, a final public notice is 
to be published 15 days prior to the start of any construction activities. Documentation of 
completed public notice is to be forwarded to FEMA and LA GOHSEP for inclusion in the 
permanent project files. 
2. In keeping with the stipUlations of the P A, all proposed repair activities should be done in-kind 
to match existing materials and form. Any change to the approved scope of work will require 
resubmission for re-evaluation under Section 106 and consultation with the SHPO. Noncompliance 
may jeopardize the receipt of federal funding. 
3. 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 
implemel\tation of the project applicant shall handle, manage, and dispose ofpetroleum 
products, hazardous materials and/or toxic waste in accordance to the requirements and to the 
satisfaction of the governing local, state and federal agencies. 
4. 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, CFC'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 



Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramlProjed Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 2097 New Orleans High School 
Signature Center 

to comply with applicable legal requirements in debris collection and/or disposal operations 
will jeopardize federal ftmding. The clean-up or restoration/repair of sites damaged as a result 
of such operations are ineligible for federal ftmding. Previously obligated ftmding is subject to 
de-obligation if a detennination of ineligibility is made. Applicants managing debris staging, 
processing, burning or disposal sites (other than previously pennitted landfills) that have been 
pennitted by Louisiana Department of Environmental Quality must also complete an 
Emergency Debris Management Site Certification (Self Certification) regarding compliance 
with all applicable substantive laws and executive orders. 

5. In accordance with the Fonnosan Tennite 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, 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 ofthe 
Louisiana Department of Agriculture and Forestry or his Designee(s). 
6. 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 "Sixth Amended Declaration of Emergency and 
Administrative Order" dated June 30, 2006 or latest amended declaration, incorporating the 
provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 
the Louisiana Administrative Code (LAC) 33.I1I.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. 
7. Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise 
concentrating LBP shall comply with applicable provisions of29 CFR Parts 1910 and 1926 
(OSHA -Worker Safety), and 40 CFR 260 through 268 (EPA -Hazardous Waste). The 
applicant is responsible for ensuring that renovation or demolition activities are coordinated 
with the Louisiana Department of Environmental Quality for abatement activities and is also 
responsible for ensuring proper disposal in accordance with the previously referenced 
regulations. 
8. This project potentially involves the disposal of metallic 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 of Environmental Quality (LDEQ) 
"Declaration of Emergency; Mercury-Containing Devices and Electronic Equipment as 
Universal Waste" letter dated October 3,2005. 


Monitoring Requirements: None