Reviewer Name: Adam Borden, Env. Specialist Proj«t NamclEnv. Database No: Thomy Lafon Elementary School-Building C 
FEMA-I603/Ui07-DR-LA PW#13708 
Parish: Orleans 

Record of Environmental Consideration 


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

Project NamelNumber: Thorny Lafon Elementary School-Building C 1PWHI3708 
FIPSH033-UA9M2-00 

Project Location: 2601 Seventh Street, New Orleans, LA 70115 
Latitude: 29.93808, Longitude: -90.09417 

Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior 
and interior damage to Thorny Lafon Elementary School-Building C ofthe Recovery School District. This pw reimburses 
the eligible applicant for replacement ofroofing/components, ceiling tile, insulation. lighting. flooring, drywall, doors, 
lavatory components. and windows. The new building material 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 or other bodies of water. 

Documentation Requirements 

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) 

I8J (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 (NEP A) Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 
o Programmatic Categorical Exclusion -Category (Reference PCE in comments) <Review Concluded) 
o Categorical Exclusion -Category
o No Extraordinary Circumstances exist. 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Extraordinary Circumstances exist (See Section IV).


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


o Environmental Assessment 
o Supplemental Environmental Assessment (Reference EA or PEA in comments)
I8J 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 Environmental and Historic Preservation (EHP) laws which 
are listed under the NEPA level ofenvironmental 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 ofany 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 

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

Record of Environmental Consideration (Version 08/31/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Thomy Laron Elementary Scbool-Building C 
FEMA-l60J/l607-DR-LA PWII13708 
Parish: Orleans 

FEMA Environmental Reviewer: 

Name: Adam Borden, 

Signature _-----.&~~J::.=:::::!~_-=,.Date _-\,i~I--.;_3_1_~_O..l-/o-----' 

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

Signature rp~~ Date _--,,80:...'_-_3_,_'e_("._-----'" 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act (NHP A) 

D Not type ofactivity with potential to affect historic properties. 
181 Activity meets Programmatic Agreement, December 3,2004. Appendix A: Section: II-El, II-A4, II-F2, II-A2, II-Bl, IICI, 
II-H, II-AI 


Are project conditions required? 181 Yes (see Section V) D No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

mSTORIC BUILDINGS 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 45/50 years or older in project area and activity not exempt from review. 


D Determination ofNo Historic Properties Affected (FEMA fmdingiSHPOtrHPO concurrence on file) 
Are project conditions required? Dyes (see Section V) D No (Review Concluded) 
D Determination ofHistoric Properties Affected (FEMA fmdingiSHPOtrHPO 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 fmdingiSHPOtrHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findingiSHPOtrHPO 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 
181 Project affects only previously disturbed ground. (Review Concluded) 
D Project affects undisturbed ground. 


D Project area has no potential for presence ofarcheological resources 
D Determination ofno historic properties affected (FEMA fmdingiSHPOfTHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence of archeological resources 
D Determination of no historic properties affected (FEMA fmdingiSHPOtrHPO 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 fmdingiSHPOtrHPO concurrence on file). 

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

o No Adverse Effect Determination. (FEMA fmdingl SHPOtrHPO concurrence on file) 
Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 
o Adverse Effect Determination. (FEMA fmdingl SHPOtrHPO concurrence on file) 


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

Record of Environmental Consideration (Version 08/31/06) 


Reviewer Name: Adam Borden, Env. Sp«ialist Project NamelEnv. Database No: Thomy Lafon Elementary Scllool-Building C 
FEMA-I603/1607-DR-LA PWlt13708 
Parish: Orlnns 

Comments: 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 ofwork as submitted in this PW has been 
reviewed and meets the criteria outlined in appendix A, programmatic allowances, Section {n-El, II-A4, n-F2, II-A2, lIB), 
II-CI, noH, II·AI}. of the document. In accordance with the PA, FEMA is not required to determine the National 
Register eligibility ofproperties or to submit projects to the State Historic Preservation Officer (SHPO) for review where 
the work performed meets these allowances. In keeping with the stipulations ofthe PA, 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. Non-<:ompliance may jeopardize the receipt of federal 
funding. This concludes the Section 106 review for this project. 
Correspondence/Consultation/References: NHPA effect determinations made by V.Gomez, Historic Preservation 
Specialist 

B. Endangered Species Act 
t8I 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 Conduded) 


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 finds there will be no effect to threatened or endangered species. 
Correspondence/Consultation/References: USFWS emergency consultation provisions determined in letters dated 
September 15, 2005 for Katrina. 

C. Coastal Barrier Resources Act 
t8I Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded). 


o Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 
file) 

o Proposed action an exception under Section 3505.a.6 (Review Concluded) 

D Proposed action not excepted under Section 3505.a.6. 
Are project conditions required? D 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 08/31106. 


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) 

D Project requires Section 404/40 1I0r Section 9/10 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 

Comments: No jurisdictional waters ofthe U.S., including wetlands, occur in or near the project area. 
Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil) queried 
on 08/31/06. 

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) 
Record ofEnvirorunental Consideration (Version 08/31106) 


Reviewer Name: Adam Borden, Env. Sp«lalist Project Name!Env. Database No: Thomy Lafon Elementary School· Building C 
FEMA·16CI3/16417·DR·LA PWI#13708 
Parish: Orleans 

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 Department ofNatural Resources 
(DNR) has detennined that receipt of federal 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 1-800-276-4019. 
Correspondence/ConsultatloniRe/erences: LDNR Louisiana Coastal Zone map 2002. 

F. Fish and Wildlife Coordination Act 
181 Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) 


o Project affects controls or modifies a waterwaylbody 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: No streams or water bodies are located in or near the project area. 
Correspondence/ConsultationiRe/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD queried 08/31/06. 

G. Clean Air Act 

o Project will not result in pennanent air emissions. (Review Concluded) 
181 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: 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 
of Environmental 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 
of EPA'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 
orders. 
Correspondence/Consultation/Re/erences: EPA Region 6 Non-attainment Map. 

H. Farmland Protection Policy Act 
181 Project does not affect designated prime or unique farmland. (Review Concluded) 


o Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required.

o Farmland Conversion Impact Rating, Fonn AD-1006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No 
prime or unique farmland present. 
Correspondence/ConsultationiRe/erences: National Resource Conservation Service, Web Soil Survey 
(hl:tD:/Iwebsoilsurvev.nrcs.usda.Q:ov/aoo/ )referenced 08/31/06. 


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) 
Record of Environmental Consideration (Version 08/31/06) 


Reviewer Name: Adam Borden, Env. Spetialist Project NamelEnv. Database No: Thomy Lafon Elementary School-Building C 
FEMA-I60J/I6417-DR-LA PWI#lJ708 
Parish: Orleaos 

Are project conditions required? 0 Yes (see section V) l8l 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. 

Corres ondence/ConsultationlRe erences: USFWS uidance letter dated Se tember 15,2005 for Katrina 

J. Magnuson-Stevens Fishery Conservation and Management Act 

l8l 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? 0 Yes (see Section V) D No (Review Concluded) 
D Project adversely affects Essential Fish Habitat (FEMA determinationlUSFWSlNMFS concurrence on file) 

o 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: Project is not located in or near any surface waters with the potential to affect EFH species. 
Correspondence/ConsultationlReferences: Louisiana Map (hUp:llwwwlamap.doa.louisiana.govD referenced 08/30/06. 

K. Wild and Scenic Rivers Act 

l8l 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 NPSlUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 
D Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM 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/riverslwildriversIist.html. 
referenced 08/31106 . 


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, S1. Charles, S1. John the 
Baptist, S1. 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 ofAgriculture 
and forestry or his designee{s). 

-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, 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 of sites 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. 

Record of Environmental Consideration (Version 08/31/06) 


-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 Ibp 
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 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. 

Reviewer Name: Adam Borden, EDV. Specialist Project NamelEnv. Database No: Thomy Laron ElemeDtary School-Building C 
FEMA-I603/1607-DR-LA PWII13708 
Parisb: Orleans 

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


o No Effect on FloodplainsIFlood levels and project outside Floodplain -(Review Concluded) 
o 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), 
cgJ Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 






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

Comments: The site is located in Zone A I. 

http://store.msc.fema.gov/webapplwcs!stores/servletIFemaWelcomeView?storeld= 1 000 l&catalogld= 1 000 l&langId=-I. 
The city of New Orleans I Orleans Parish enrolled in the National Flood Insurance Program (NFIP) as of08/03/1970. 
Facility is located within an "AI" 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 03/0111984. Project is repair of 
building and replacement ofequipment and components. In compliance with EO 11988, an 8-step process was completed 
and is attached. As per 44 CFR 9.11, mitgation 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. T.Magilke FP Specialist 
Correspondence/ConsultationlReferences: FEMA Flood Insurance Rate Map, Community Panel No. # 2252030160 E, 
dated 03/0111984 

B. E.O. 11990 -Wetlands 
cgJ 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) 






Comments: No wetlands were observed during site visit or determined to be present by checking the USFWS National 
Wetlands Inventory (NWI) maps. 
Correspondence/Consultation/References: USFWS NWI map accessed on·line 
(http://wetiandsfws.er.usgs.gov/wtlnds/launch.htmi) 08/31106. 


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) 

cgJ Low income or minority population in or near project area 
cgJ 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) 


Record of Environmental Consideration (Version 08131/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamtlEnv. Database No: Thomy Lafon Elementary School-Building C 
FEMA-160J/J607-DR-LA PWNIJ708 
Parish: Orleans 

Comments The percent populations of70 115 are: 51.0% Black, 45.6% White, and 3.2% Hispanic. The median household 
income in 1999 was $ 27,094 and 24.4% of families are below poverty level. 
Com!spondence!ColISultationlRe/ermces: U.S. Census bureau 2000 data at http://factfmder.census.gov, referenced 
08/31106. 


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 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 ofAgriculture 
and forestry or his designee(s). 

-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, 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 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 ofa public structure that may contain surfaces coated with lead-based 
paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBPshall 
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/ColISultationIRefermce: 

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. 

Yes 
D (i) Greater scope or size than normally experienced for a particular category of action 
D (ii) Actions with a high level ofpublic 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; 
D (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 


Record of Environmental Consideration (Version 08/31/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Thomy Lafon Elementary School-Building C 
FEMA-1603/1607-DR-LA PWI#13708 


Parish: Orleans 

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 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: 

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 ofEnvironmental 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 of EPA'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 orders. 
• In accordance with the Formosan Termite Initiative Act, (LA RS. 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 of the 
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 
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 to comply with 
applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The 
clean-up or restoration/repair of sites damaged as a result ofsuch operations are ineligible for federal funding. 
Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. 
• In keeping with the stipulations of the PA, all proposed repair activities should be done in-kind to match existing 
materials and form. Any change to the approved scope ofwork 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. 
• 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 
concentrating Ibp 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. 
• As per 44 CFR 9.11, mitgation 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 ofcompleted public notice is to be forwarded to FEMA and LA GOHSEP for inclusion 
in the permanent project files. 


Record of Environmental Consideration (Version 08/31/06)