Reviewer Name: Adam Borden, Env. Spedalist Project NamelEnv. Database No: Alfred Lawless High School-Building D 
FEMA-I603/1607-DR-LA PWNl3579 
Parisb: Orleans 

Record of Environmental Consideration 


REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 
See 44 Code ofFederal Regulation Part 10 

Project NamelNumber: Alfred Lawless High School-Building D 1PW#13579 
FIPS#033-UA9M2-00 
Project Location: 5300 Law St., New Orleans, LA 70117 
Latitude: 29.9767, Longitude: -90.01444 
Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior 

and interior damage to Alfred Lawless High School-Building D of the Recovery School District. This pw reimburses the 
eligible applicant for replacement of the building within its pre-disaster footprint. The new building will be replaced 
according to codes and standards upgrades. All work will be performed in a previously disturbed area with no indication of 
nearby waterways~r~r-bodies~water. 

Documentation Requirements 

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) 

IZI (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is 
attached to this REC and/or included in project files, as applicable. 

National Environmental Policy Act (NEPAl Determination 

D Statutorily excluded from NEPA review. (Review Concluded) 
D Programmatic Categorical Exclusion -Category (Reference PCE in comments) (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 

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

Comments: This project meets the criteria for an Alternative Arrangement (Permanent Schools) type of project. This 
project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) laws which 
are listed under the NEPA level 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. 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). 


Rtvitwtr Namt: Adam Bordtn, Env. Sptc:ialist Projtc:t NamtlEnv. Oatabast No: Alrrtd LawlH' High School· Building 0 
FEMA·160311607·0R·LA PWN13S79 
Parish: Orltans 

Signature ---.....c~~~:1.:::::~::::..:::::::::=:::::... Date ---,9"--~_·_~__·_~

__",,, 

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

Signature ~~'-L---,,,,<?,,,,,,, Date __I_,.l_I,._._b....:"':-__..... 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act (NHP A) 

t8l Not type ofactivity with potential to affect historic properties. 
D Activity meets Programmatic Agreement, December 3, 2004. Appendix A: 
Areprojeeteonditions-reqtrire<wB-ves(seeSection VyB·No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

mSTORIC BUll..DINGS AND STRUCTURES 
181 No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) 
D Building or structure listed or 45150 years or older in project area and activity not exempt from review. 


D Determination ofNo Historic Properties Affected (FEMA finding/SHPOffHPO concurrence on file) 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Determination ofHistoric Properties Affected (FEMA fmding/SHPOffHPO concurrence on file) 
D Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. Ifnot, explain in comments 
D No Adverse Effect Determination (FEMA finding/SHPOffHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA fmding/SHPOffHPO concurrence on file) 
D Resolution of Adverse Effect completed. (MOA on file) 
Are project conditions required D Yes (see Section V) D No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 

t8l Project affects only previously disturbed ground. (Review Concluded)

o Project affects undisturbed ground. 
D Project area has no potential for presence ofarcheological resources 
D Determination of no historic properties affected (FEMA fmding/SHPOffHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA finding/SHPOffHPO concurrence on file) 
Are project conditions required D Yes (see Section V) D No (Review Concluded) 
D Determination ofhistoric properties affected 
D NR eligible resources not present (FEMA fmding/SHPOffHPO concurrence on file). 

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

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

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


Reviewer Name: Adam Bonien, Env. Specialist Project NamelEnv. Database No: Alfred Lawless Higb Scbool-Building 0 
FEMA-I603/1607-DR-LA PWN13579 
Parish: Orleaas 

Comments: The structure does not meet the SO-year-criterion, nor does it possess the level ofexceptional importance 

required by criteria consideration G ofthe National Register guidelines to be considered eligible for the National Register of 

Historic Places. Therefore, the proposed work will have no effect on standing historic properties. Scope ofwork: indicates 

ground disturbing activities associated with the demolition and rebuild of the structure within its pre-disaster footprint only. 

Upon consultation ofdata provided by the State Historic Preservation Officer (SHPO), there are no known archaeological 

sites within.S miles ofthe project area. Demolition must follow the low impact demolition stipulations & additional 

protocols which are attached. The stipulations and protocols should be explicit in the demolition contract. Failure to 

comply with these stipulations & additional protocols will jeopardize receipt of federal funding. If during the course of 

work, archaeological artifacts (prehistoric or historic) or human remains are discovered, the applicant shall stop work in the 

vicinity ofthe discovery and take all reasonable measures to avoid or minimize harm to the finds. The applicant shall 

inform their Public Assistance (P A) contacts at FEMA, who will in turn 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 

Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is required. The applicant shall notify the 

law enforcement agency ofthe jurisdiction where the remains are located within twenty-four hours of the discovery. The 
applicant shall also notify FEMA and the Louisiana Unmarked Burial Sites Board (call the Louisiana Division of 
AtCliOO1ogyit7ZS=342=8170) witliiii sevemy.;two1iotii'S Of the aiscovery."lftlUsscopeeifwoncanOlOrthef6Olj>fuit11ocati6if 
ofthe new building changes, this project will need to be resubmitted for further Section 106 review prior to ground 
disturbing activities taking place outside of the pre-disaster footprint of the building. 
Correspondence/ConsultatlonIReferences: NHPA effect determinations made by Katherine Zeringue, Historic Preservation 
Specialist! Archaeologist 

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}


o Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. 


o No effect to species or designated critical habitat. (See comments for justification) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 
o May affect, but not likely to adversely affect species or designated critical habitat (FEMA 


determinationlUSFWSINMFS concurrence on file) (Review Concluded) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 


o Likely to adversely affect species or designated critical habitat 

o Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 

Comments: Project is located in an urban or previously developed area. Neither listed species nor their habitat occur in or 
near this site, thus FEMA fmds there will be no effect to threatened or endangered species. 
Correspondence/ConsultationIReferences: USFWS emergency consultation provisions determined in letters dated 
September 15,2005 for Katrina. 

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 3S0S.a.6 (Review Concluded) 
o Proposed action not excepted under Section 3S0S.a.6. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: Project is not within a CBRA zone. 
Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced 08126/06. 


D. Clean Water Act 
~Project would not affect any waters of the 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) 

Record of Environmental Consideration (Version 08/26/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Alrred Lawless High School-Building 0 
FEMA-160J/1607·0R·LA PWt#13579 
Parish: Orleans 

D Project requires Section 404/401l0r Section 9/10 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments: No jurisdictional waters ofthe U.S., including wetlands, occur in or near the project area. 
Correspondence/ConsullallonfRe/erences: USFWS National Wetlands Inventory map (http://www.fws.gov/nwi/) queried 
on 08126106. 

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) 

[81 Project is located in a coastal zone area and/or affects the coastal zone 
[81 State administering agency does not require consistency review. (Review Concluded). 
DState administering agency requires consistency review. 


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

.. 

Commmts:-'f'his]mJjectis'1ocatedwithin;beLooisiana-eoastat~ManagementZnne; LA Departrrrent ofNaruralRes-ourees ~(
DNR) has determined that receipt of federal assistance is consistent with the Louisiana Coastal Resource Program. Projects 
within the coastal zone may still require a coastal use permit or other authorization from DNR. Projects may be coordinated 
by contacting LA DNR at 1-800-276-4019. 
Correspondence!ConsullalionfRe/erences: LDNR Louisiana Coastal Zone map 2002. 


F. Fish and Wildlife Coordination Act 

[81 Project does not affect, control, or modifY a waterway/body ofwater. (Review Concluded)
D Project affects controls or modifies a waterway/body 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: No streams or water bodies are located in or near the project area. 
Correspondence/ConsullalionfRe/erences: Louisiana Map (http://wwwlamap.doa.1ouisiana.govD queried 08126106. 

G. Clean Air Act 

D Project will not result in permanent air emissions. (Review Concluded) 
[81 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) 0 NO (Review Concluded) 

Comments: This project involves the demolition or renovation of a public structure. Regardless ofthe asbestos content, the 
applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department 
ofEnvironmental Quality (LDEQ) in accordance with the LDEQ "Sixth Amended Declaration ofEmergency and 
Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March I, 2006, incorporating the provisions 
ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code 
(LAC) 33.1II.5151 and Chapter 27. Should Asbestos Containing Materials (ACMs) be present at the project site, the 
applicant is also responsible for ensuring proper disposal in accordance with the previously referenced administrative 
orders. 
Correspondence/ConsultationIRe/erences: EPA Region 6 Non-attainment Map. 

H. Farmland Protection Policy Act 

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

o Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 
D Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Form AD-I 006, completed. 
Are project conditions required? D YES (see section V) 0 NO (Review Coneiuded) 

Record ofEnvironmental Consideration (Version 08126/06) 


Revlrwer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Alfred Lawless Higb Scbool-Building 0 
FEMA-160J/l(i07-0R-LA PW#1J579 
Parisb: Orlnns 

Comments: The project site is in a developed urbanized area and Fannland Protection Policy Act (FPPA) is precluded. No 
prime or unique fannland present. 
Co"espondence/Consultatlon!References: National Resource Conservation Service, Web Soil Survey 
Chtto:llwebsoilsurvev.nrcs.usda.l!ov/aDDI )referenced 08126/06. 


I. Migratory Bird Treaty Act 

o Project not located within a flyway zone. (Review Concluded) 
I:8J Project located within a flyway zone. 

I:8J Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) I: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) 

·CommenlSTlnesifins an exlsfing aislw'tioo'areawifh IittIevruueloffiigra1Orybirds-llI1d woUlifnofoemcluaoo iii the· 
USFWS migratory bird management program. 
COTTespondence/Consultatlon!References: USFWS guidance letter dated September 15,2005 for Katrina 
.. 
J. Magnuson-Stevens Fishery Conservation and Management Act 

I:8J 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) D 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? D Yes (see Section V) 0 No (Review Concluded) 
o NOAA Fisheries provided recommendation(s) 






D Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? D YES (see Section V) 0 NO (Review Concluded) 

Comments: Project is not located in or near any surface waters with the potential to affect EFH species. 
Correspondence/Consultation!Re/erences: Louisiana Map (bttp:llwwwlamap.doa.louisiana.govD referenced 08126/06. 

K. Wild and Scenic Rivers Act 
I:8J Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) 
D Project is along or affects WSR 

o Project adversely affects WSR as determined by NPS/uSFS. FEMA cannot fund the action. 
(NPS/uSFS/uSFWSIBLM consultation on file) (Review Concluded) 
o Project does not adversely affect WSR. (NPS/uSFS/uSFWSIBLM consultation on file) 
Are project conditions required? D YES (see Section V) D NO <Review Concluded) 


Comments: None 
Correspondence/Consultation/References: National Wild and Scenic Rivers http://www.nps.gov/riverslwildriverslist.html. 
referenced 08126/06 . 


L. Other Relevant Laws and Environmental Regulations 


State Hazardous Materials and Solid Waste Laws 
Comments: -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana 
parishes ofCalcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the 
Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement of wood or cellulose material, 
temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure) may not leave 
the quarantined parishes without written authorization from the commissioner ofthe Louisiana Department of Agriculture 
and forestry or his designee(s). 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Alfred Lawless High .SchooJ -Building D 
FEMA-I603/1607-DR-LA PWII13579 
Parish: Orleans 

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

-Lead-Based paint -this project involves the demolition ofa public structure that may contain surfaces coated with leadbased 
paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating 
LBP shall comply with applicable provisions of29 CFR parts 1910 and 1926 (OSHA -worker safety), and 40 CFR 260 
through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with 
the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper 
disposal in accordance with the previously referenced regulations. 

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


o No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) 
l'8l 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) 
o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). 
l'8l Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain 
environment 


l'8l8 Step Process Complete -documentation on file 
Are project conditions required? l'8l YES (see Section V) 0 NO (Review Concluded) 

Comments: The site is located in Zone A2. 

http://store.msc.fema.gov/webapp/wcs/stores/servletlFemaWelcomeView?storeld= 1 000 l&catalogJd= 1 000 l&langId=-l, 
The city ofNew OrleanslOrleans Parish is enrolled in the National Flood Insurance Program (NFIP), as of08/0311970. Per 
Flood Insurance Rate Map (FIRM) panel number 2252030115E dated 03/0111984, project is located within an "A2" zone, 
area of IOO-yr flooding, base flood elevations and flood hazard factors as determined. Project is replacement ofbuilding, 
including electrical components. In compliance with EO 11988, a completed 8-step process showing considered alternatives 
is attached. New construction must coordinate and comply with local floodplain ordinances. Appropriate permits and 
certifications must be obtained and attached. Per 44 CFR 9.1 I (d)(9), the replacement of building contents, materials and 
equipment, where possible, disaster proofmg ofthe building and/or elimination of such future losses by relocation of those 
building contents, materials and equipment to or above the advisory base floodplain elevation. Per 44 CFR 9.12, applicant 
must publish a fmal public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded 
to the LA GOHSEP and FEMA for inclusion in the permanent project files. K. Roof, Floodplain Management Specialist 
CorrespondenceiConsultationiRe/erences: FEMA Flood Insurance Rate Map, Community Panel No. # 2252030115E 
dated 03/0111984, 

B. E.O. 11990 -Wetlands 

l'8l 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 
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) 







Reviewer Name: Adam Borden, Env. Spedalist Project NamelEov. Database No: Alfred Lawless Higb Scbool -Building 0 
FEMA-I603/1607-0R-LA PWI#13579 
Parisb: Orleaas 

Comments: No wetlands were observed during site visit or detennined to be present by checking the USFWS National 
Wetlands Inventory (NWI) maps. 
Correspondence/ConsultallonIRejerences: USFWS NWI map accessed on-line 
(http://wetlandsfws.er.usgs.gov/wtlndsllaunch.html) 08126/06. 


c. E.O. 12898 -Environmental Justice for Low Income and Minority Populations 

o No Low income or minority population in, near or affected by the project -(Review Concluded) 

I2?J Low income or minority population in or near project area 
I2?J 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) D NO (Review Concluded) 


Comments The percent populations of70 117 are: 88.8% Black, 9.4% White, and 2.0% Hispanic. The median household 

income in 1999 was $ 19,567 and 34,0% of families are below poverty level. 

Correspondence/Consu!JatlonIRejerences: U,S. Census bureau 2000 data at http://factfmder.census.gov, referenced 
08126100;-----------. ----


III. Other Environmental Issues 

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

State Hazardous Materials and Solid Waste Laws 
Comments: -In accordance with the Fonnosan Tennite Initiative Act, (LA KS. 3:3391.1 thru 3391.13) the Louisiana 
parishes ofCalcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, S1. 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 ofthe Louisiana Department of Agriculture 
and forestry or his designee(s). 

-Removal and disposal of debris containing household hazardous waste and certain categories of liquid wastes must be 
perfonned 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 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 
detennination of ineligibility is made. 

-Lead Based-paint -this project involves the demolition ofa public structure that may contain surfaces coated with leadbased 
paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating 
LBP shall comply with applicable provisions of29 CFR parts 1910 and 1926 (OSHA -worker safety), and 40 CFR260 
through 268 (EPA -hazardous waste), The applicant is responsible for ensuring that project activities are coordinated with 
the Louisiana Department ofEnvironmental Quality for abatement activities and is also responsible for ensuring proper 
disposal in accordance with the previously referenced regulations. 

Correspondence/Consultation/Reference: 

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. 

Record of Environmental Consideration (Version 08126/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Alrred Lawless High School-Building D 
FEMA-I60J/l'07-DR-LA PWII13579 
Parish: OrleallS 

• 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. Ifthe circumstance can be mitigated, 
please explain in comments. If no, leave blank. 

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 of unproven technology with potential adverse effects or actions involving 
unique or unknown environmental risks; 
D (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
D (vi) Presence ofhazardous 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 


sUcnaswelraiiQi,coastarzones:wrraJUei:eruge-andwiIaernesSareas~-wiId'andscenic"riverS; 

sole or principal drinking water aquifers; 
D (viii) Potential for adverse effects on health or safety; and 
D (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 


protection of the environment. 

D (x) Potential for significant cumulative impact when the proposed action is combined with 
other past, present and reasonably foreseeable future actions, even though the impacts of the 
proposed action may not be significant by themselves. 


IComments: None 

v. Environmental Review Project Conditions 

Project Conditions: 

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

• This project involves the demolition or renovation 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 "Fifth Amended Declaration of 
Emergency and Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March 1, 2006, 
incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 
the Louisiana Administrative Code (LAC) 33.II1.5151 and Chapter 27. Should Asbestos Containing Materials 
(ACMs) be present at the project site, the applicant is also responsible for ensuring proper disposal in accordance 
with the previously referenced administrative orders. 
• In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes of 
Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the 
Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement of wood or cellulose t 
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 f 
Louisiana Department ofAgriculture and forestry or his designee(s). 
• Removal and disposal of debris containing household hazardous waste and certain categories of liquid wastes must I 
be performed in accordance with all applicable federal and state laws, regulations, executive orders and guidelines. 


I

J

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 wil\jeopardize federal funding. The 

clean-up or restoration/repair ofsites damaged as a result of such operations are ineligible for federal funding. 

Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. 

• Lead-based paint -this project involves the demolition of a public structure that may contain surfaces coated with 
lead-based paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise 



Reviewer Name: Adam Borden, Eav. Spedalist Project Name/Euv. Database No: Alfred Lawless Higb School-Buildiug D 

FEMA-.603/1607-DR-LA PWII13579 
Parish: Orleaas 

concentrating LBP shall comply with applicable provisions of 29 CFR parts 1910 and 1926 (OSHA -worker 

safety). and 40 CFR 260 through 268 (EPA -hazardous waste). The applicant is responsible for enswing that 

project activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities 

and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. 

• Mercury containing devices -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. 
• Ifdwing 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 fmds. 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 staff have completed consultation with the Louisiana State Historic Preservation Officer (SHPO). In 
addition, if unmarked graves are present, compliance with the Louisiana Unmarked Human Burial Sites 
Preservation Act (R.S. 8:671 et seq.) is required. The applicant shall notify the law enforcement agency of the 


jurisdiction where the remainsare-tocatedwithinlWenty-fmIrhours-ufth-e discovery. "I'he-applicantmrtllllso notify 
FEMA and the Louisiana Unmarked Burial Sites Board (call the Louisiana Division of Archeology at 225-3428170) 
within seventy-two hours ofthe discovery. If this scope ofwork 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 outside ofthe pre-disaster footprint of the building. 

• New construction must coordinate and comply with local floodplain ordinances. Appropriate permits 
and certifications must be obtained and attached. Per 44 CFR 9.11 (d)(9), the replacement of building 
contents, materials and equipment, where possible, disaster proofing ofthe building and/or elimination 
of such future losses by relocation of those building contents, materials and equipment to or above the 
advisory base floodplain elevation. 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 LA 
GOHSEP and FEMA for inclusion in the permanent project files.