Record of Environmental Consideration REVISED FOR FEMA ENVmONMENTAL --LOUISIANA -April 2007 See 44 Code of Federal Regulation Part 10 Project NamelNumber: Recovery School District PW 13418V2 / FIPS 033-UA9M2-00 Applicant Name: E0R2189 Edison Elementary School Project Location: 1339 Forstall Street, New Orleans, Louisiana, Orleans Parish, Latitude: 29.96476, Longitude: -90.02047 Project Description: On August 29.2005, high winds, heavy rain and flooding from levee breaks generated by Hurricane Katrina severely impacted and disrupted the Recovery School District. Edison Elementary School was built in 1967 and consists of a central 3-story concrete tilt-up structure with 16,61 Osf per floor in an open concept design along with a single-story 12,000sf CMU Cafeteria which is attached to the south side of the 3story main building. This project worksheet addresses replacement ofthe facility to the pre-disaster location and the pre-disaster condition with upgrades to codes and standards. National Environmental Policy Act (NEP A) Determination o Statutorily excluded from NEP A review (Review Concluded) o Programmatic Categorical Exclusion -Category (Reference PCE in comments) (Review Concluded) I:8l Categorical Exclusion -Category xii, xv I:8l No Extraordinary Circumstances exist. Are project conditions required? I:8l Yes (see section V) 0 No (Review Concluded) D Extraordinary Circumstances exist (see Section IV). Extraordinary Circumstances mitigated. (see Section IV comments) Are project conditions required? 0 Yes (see section V) D No (Review Concluded) D Environmental Assessment D Supplemental Environmental Assessment (Reference EA or PEA in comments) o Environmental Impact Statement D Scope of work requires public involvement plan Comments: This project is consistent with categorical exclusion xii, xv: Demolition of structures and other improvements or disposal of uncontaminated structures and other improvements to permitted off-site locations, or both; repair, reconstruction, restoration, elevation, retrofitting, upgrading to current codes and standards, or replacement of any facility in a manner that substantially conforms to the preexisting design, function, and location. D Project is Non-Compliant (see attached documentationjustitying selection). Reviewer and Approvals FEMA Environmental Reviewer: Name: Tiffan Signature ----r+--t-~-~<---===---Date ~I--f--.JjlL.l....l~\~~~----'- FEMA Environmental r; aison fficer 0 eiegated Approving Official: Date t&'~O( . Teeter, Deputy Environmental Liaison Officer, FEMA LA TRO Signature.1L~~~~'~-L!:::!:.~..... I. pliance Review for Environmentall(aws (other than NEPAl Record of Environmental Consideration (Version April 2007) · ... Re"iewer Name: Tiffany Spann Project NamelEnv Database No: Recovery School DistrictlEORl189-Edison Elementary School PW 13418V2 FEMA-160J/1607-DR-LA Parish: Orleans A. National Historic Preservation Act (NHP A) o Not type ofactivity with potential to affect historic structures or archaeological resources (Review Concluded) o Activity meets Programmatic Agreement, December 3, 2004. Appendix A: Allowance No. IA Are project conditions required? 0 Yes (see Section V) 0 No ~Programmatic Agreement not applicable for historic structures or archeological sites, must conduct standard Section 106 Review (see below). . o Other Programmatic Agreement dated insert date ofPA applies HISTORIC BUILDINGS AND STRUCTURES ~No historic properties that are listed or 45/50 years or older in project area. o Building or structure listed or 45/50 years or older in project area and activity not exempt from review. ~Determination of No Historic Properties Affected (FEMA findinglSHPO/THPO concurrence on file) Are project conditions required? ~Yes (see Section V) 0 No (Review Concluded) o Determination of Historic Properties Affected (FEMA findinglSHPO/THPO concurrence on file) Property a National Historic Landmark and National Park Service was provided early notification during the consultation process. If not, explain in comments No Adverse Effect Determination (FEMA findinglSHPO/THPO concurrence on file) Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) Adverse Effect Determination (FEMA findinglSHPO/THPO 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 o Project scope of work has no potential to affect archeological resources (Review Concluded) ~Project affects only previously disturbed ground. (Review Concluded) o Project affects undisturbed ground or grounds associated with an historic structure o Project area has no potential for presence ofarcheological resources o Determination ofno historic properties affected (FEMA findinglSHPO/THPO concurrence on file) (Review Concluded) o Project area has potential for presence of archeological resources o Determination of no historic properties affected (FEMA findinglSHPO/THPO concurrence on file) Are project conditions required 0 Yes (see Section V) 0 No (Review Concluded) o Determination of historic properties affected o NR eligible resources not present (FEMA findinglSHPO/THPO concurrence on file) Are project conditions required 0 Yes (see Section V) 0 No (Review Concluded) o NR eligible resources present in project area (FEMA findinglSHPO/THPO concurrence on file) o No Adverse Effect Determination (FEMA fmdingl SHPO/THPO concurrence on file) Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) o Adverse Effect Determination (FEMA findinglSHPO/THPO concurrence on file) Resolution of Adverse Effect completed (MOA on file) Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) Comments: FEMA, in consultation with the State Historic Preservation Officer (SHPO), has determined that the demolition, removal offoundations, and rebuilding of the Thomas A. Edison Elementary, 1339 Forstall St., New Orleans, will have No Effect on Historic Properties. Correspondence/Consultation/References: NHPA effect determinations made by -Jerame Cramer, FEMA Historic Preservation! Archaeology Specialist. B. Endangered Species Act ~No listed species andlor designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) o Listed species andlor 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 determination!USFWSINMFS concurrence on file) (Review Concluded) Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) Record of Environmental Consideration (Version April 2007) Reviewer Name: Tiffany Spann Project Name/Env [)atabase No: Recovery School OistrictlEORl189-Edison Elementary School PW 13418V2 FEMA-160J/1607-DR-LA Parish: Orleans 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: Correspondence/Consultation/References: Endangered Species Summary for USFWS Consultation, letter to Don Fairley dated September IS, 200S 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) Proposed action an exception under Section 3S0S.a.6 (Review Concluded) Proposed action not excepted under Section 3S0S.a.6. Are project conditions required? 0 YES (see Section V) NO (Review Concluded) Comments: Project is not within a CBRA zone. Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced December 4, 2007 D. Clean Water Act ~Project would not affect any waters of the U.S. (Review Concluded) o Project would affect waters, including wetlands, of the U.S. Project exempted as in kind replacement or other exemption. (Review Concluded) Project requires Section 404/401 of Clean Water Act or Section 9/10 of Rivers and Harbors Act permit, including qualification under Nationwide Permits. Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) Project would affect waters of the U.S. by discharging to a surface water body. Comments: Project scope of work possibly includes grading or other ground disturbing activities associated with replacing a facility. Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil) queried on December 4, 2007 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) ~Project is located in a coastal zone area andlor affects the coastal zone o Project would disturb <1 acre, state administering agency does not require consistency review. (Review Concluded). ~Project triggers the Clean Water Act or could affect a waterway, state administering agency requires consistency review. Are project conditions required? ~YES (see Section V) 0 NO (Review Concluded) Comments: Project scope of work possibly includes grading or other ground disturbing activities associated with replacing a facility. Correspondence/Consultation/References: Louisiana Coastal Zone Map queried December 4, 2007 F. Fish and Wildlife Coordination Act ~Project does not affect, control, or modifY a waterwaylbody of water. (Review Concluded) o Project affects controls or modifies a waterwaylbody of water. Coordination with USFWS conducted o No Recommendations offered by USFWS. (Review Concluded) D Recommendations provided by USFWS. Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) IComments: Record of Environmental Consideration (Version April 2007) · ... Reviewer Name: Tiffany Spann Project Name/Env Database No: Recovery School DistrictlEOR2189-Edison Elementary School PW 13418V2 FEMA-1603/1607-DR-LA Parish: Orleans ICorrespondence/Consultation/References: Tiffany Spann, Environmental Specialist G. Clean Air Act t8J Project will not result in pennanent 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: This project involves the demolition or renovation of a public structure. The proposed project includes activities that would produce a minor, temporary, and localized impact on air quality from vehicle emissions and fugitive dust particles. No long-tenn air quality impact is anticipated. Correspondence/Consultation/References: EPA Region 6 Non-attainment Map H. Farmland Protection Policy Act t8J Project will not affect undisturbed ground. (Review Concluded) D Project has a zoning classification that is other than agricultural or is in an urbanized area. (Review Concluded) D 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 Resources Conservation Service required. D Fannland Conversion Impact Rating, Fonn AD-I 006, completed. Are project conditions required? D YES (see section V) D NO (Review Concluded) I. Migratory Bird Treaty Act D Project not located within a flyway zone (Review Concluded) t8J Project located within a flyway zone. t8J Project does not have potential to take migratory birds (Review Concluded) Are project conditions required? D Yes (see section V) t8J No (Review Concluded) D Project has potential to take migratory birds. D Contact made with USFWS Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: 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. Correspondence/Consultation/References: USFWS guidance letter dated September 27,2005. J. Magnuson-Stevens Fishery Conservation and Management Act t8J Project not located in or near Essential Fish Habitat (Review Concluded) D Project located in or near Essential Fish Habitat. D Project does not adversely affect Essential Fish Habitat (Review Concluded) Are project conditions required? D Yes (see Section V) D No (Review Concluded) D Project adversely affects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS concurrence on file) D NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? D Yes (see Section V) D No (Review Concluded) D NOAA Fisheries provided recommendation(s) D Written reply to NOAA Fisheries recommendations completed. Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments:. Correspondence/ConsuLtation/References: Tiffany Spann, Environmental Specialist K. Wild and Scenic Rivers Act Record of Environmental Consideration (Version April 2007) '. Reviewer Name: Tiffany Spann Project NamelEnv Database No: Recovery Scbool DistrictlEOR2189-Edison Elementary Scbool PW 13418V2 FEMA-1603/1607-DR-LA Parisb: Orleans r8J Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) D Project is along or affects WSR D Project adversely affects WSR as determined by NPSIUSFS. FEMA cannot fund the action. (NPSIUSFS/USFWSIBLM consultation on file) (Review Concluded) D Project does not adversely affect WSR. (NPSIUSFSIUSFWS/BLM consultation on file) Are project conditions required? YES (see Section V) NO (Review Concluded) Comments: Correspondence/Consultation/References: National Wild and Scenic Rivers http://www.nps.gov/rivers/wildriverslist.html. L. Resource Conservation and Recovery Act 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 of the project, applicant shall handle, manage, and dispose ofpetroleum products, hazardous materials (such as asbestos and lead based paint) and/or toxic waste in accordance to the requirements and to the satisfaction of the governing local, state and federal agencies. M. Other Relevant Laws and Environmental Regulations Formosan Termite Initiative Act: 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, 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 of Agriculture and Forestry or his designee(s). II. Compliance Review for Executive Orders A. E.O. 11988 -Floodplains D No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) r8J Located in Floodplain or Effects on FloodplainslFlood levels D No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), Are project conditions required? r8J Yes (see Section V) D No (Review Concluded) D Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). r8J Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment r8J 8 Step Process Complete -documentation on file Are project conditions required? r8J YES (see Section V) D NO (Review Concluded) Comments: The city ofNew Orleans/Orleans Parish is enrolled in the National Flood Insurance Program (NFIP) as of 08/03170. Per Flood Insurance Rate Map (FIRM) panel number 2252030180E dated 03/01184; project is located within a B zone, in area protected from the 100-yr flood by levee, dike, or other structure subject to failure or overtopping during larger floods. Correspondence/Consultation/References: FEMA Flood Insurance Rate Map, Community Panel No. 2252030 180E, dated 03/01184. B. E.O. 11990 -Wetlands r8J No Effects on Wetland(s) and/or project located outside Wetland(s) -(Review Concluded) D Located in Wetland or effects Wetland(s) D Beneficial Effect on Wetland -(Review Concluded) D Possible adverse effect associated with constructing in or near wetland D Review completed as part of floodplain review D 8 Step Process Complete documentation on file Record of Environmental Consideration (Version April 2007) Comments: .... Reviewer Name: Tiffany Spann Project :"iamelEnv Database No: Recovery School DistrictJE0R2189·Edison Elementary School PW 13418V2 FEMA-1603/1607-DR-LA Parish: Orleans Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments: . Correspondence/Consultation/References: USFWS NWI map accessed on-line December 5, 2007 C. E.O. 12898 -Environmental Justice for Low Income and Minority Populations IS;] Project scope of work has no potential to adversely impact any population (Review Concluded) D No Low income or minority population in, near or affected by the project based on information gathered from (Review Concluded) D Low income or minority population in or near project area D 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) Corres ondence/Consultation/Re erences: Tiffan S ann, Environmental S ecialist III. Other Environmental Issues Comments: None Correspondence/Consultation/Reference: IV. Extraordinary Circumstances Yes D (i) Greater scope or size than normally experienced for a particular category of action D (ii) Actions with a high level of public controversy D (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; D (iv) Employment ofunproven technology with potential adverse effects or actions involving unique or unknown environmental risks; (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 ofthe 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: V. Environmental Review Project Conditions I r Project Conditions: Record of Environmental Consideration (Version April 2007) , Reviewer Name: Tiffany Spann Project Name/Env Database No: Recovery School DistrictlEOR2189-Edison Elementary School PW 13418V2 FEMA-1603/1607-DR-LA Parish: Orleans I. Any fill or borrow material used in the repair activities must be sourced from sites that do not contain any buried cultural materials (Le. wells, cisterns, foundations, basements, prehistoric Indian artifacts, human burials, and the like) 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 fmds. The applicant shall inform their Public Assistance (PA) contacts at FEMA, who will in tum contact FEMA Historic Preservation (HP) staff. The applicant will not proceed with work until FEMA HP completes consultation with the SHPO. In addition, if unmarked graves are present, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is required. The applicant shall notify the law enforcement agency of the jurisdiction where the remains are located within twenty-four hours of the discovery. The applicant shall also notify FEMA and the Louisiana Division ofArchaeology at 225-342-8170 within seventy-two hours of the discovery. If this scope of work and/or the footprint/location ofthe new building changes, this project will need to be resubmitted for further Section 106 review prior to ground disturbing activities taking place. Failure to comply with these stipulations may jeopardize receipt of federal funding. 2. This project is located within the Louisiana Coastal Management Zone. Louisiana Department ofNatural Resources (LDNR) has determined that receipt offederal 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 LDNR. Projects may be coordinated by contacting LDNR at 1-800-267-4019. 3. The proposed project includes activities that would produce a minor, temporary, and localized impact on air quality from vehicle emissions and fugitive dust particles. No long-term air quality impact is anticipated. To reduce potential short term effects to air quality from construction related activities, the contractor will be responsible for keeping all excavated areas periodically sprayed with water (when dry), all construction vehicles should be limited to 15 mph in the work area, and all equipment maintained in good working order to minimize pollution/fugitive dust. 4. 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 of Environmental Quality (LDEQ) in accordance with the LDEQ "Tenth Amended Declaration ofEmergency and Administrative Order" dated May 14,2007, incorporating the provisions of the Environmental Protection Agency's (EPA's) National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.iii.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. 5. Unusable equipment, debris and material shall be disposed of in an approved marmer and location. In the event significant items (or evidence thereof) are discovered during implementation of the project, applicant shall handle, manage, and dispose of petroleum products, hazardous materials (such as asbestos and lead based paint) and/or toxic waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. 6. 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, 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 ofAgriculture and Forestry or his designee(s). 7. New construction must coordinate and comply with local floodplain ordinances, and be built to current codes and standards. Applicant is required to coordinate with local floodplain administrator regarding floodplain permit(s) prior to the start ofany activities. Applicant is responsible for meeting all requirements ofthe permit(s). All coordination pertaining to these permit(s), should be documented to the local floodplain administrator and copies provided to the Louisiana Governor's Office of Homeland Security and Emergency Preparedness (LA GOHSEP) and FEMA as part ofthe permanent project files. Replacement ofthe building must be elevated to or above the Advisory Base Flood Elevation (ABFE) per the ABFE maps. Elevation information, signed and sealed by a licensed surveyor, engineer, or architect must be obtained and filed for verification of compliance. Per 44 CFR 9.11 (d) (9), mitigation or minimization standards must be applied where possible. The replacement of building contents, materials and equipment should be, where possible, wet or dry-proofed, elevated, or relocated to or above the ABFE. 7Record ofEnvironmental Consideration (Version April 2007) I ~ ! I I ~ I I I ~ , r t i ! r