ReviewerName: Perry Boudreaux Applicant: City of NewOrleans Disaster/Emergency/Program/Project Title: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/Engine#11 FireStation Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number: Engine #11 Fire Station / PW 8744 Project Location: 2314 Louisiana Avenue, New Orleans, Louisiana Orleans Parish 70115 (N29.9347, W-90.0947) Project Description: Project activities include removing and replacing 36 linear feet of cabinets and countertop,4 wooddoors, 1,000squarefeet vinylcompositetile,oneoverheaddoor,one3-tonair cooledcondensingunit,one50gallongaswaterheater, 39squaresof3-tabasphaltshingles,45pounds of ductwork, and electrical components such as panel boards, duplex receptacles, Cat. 5 cables and all wiring. Hazardmitigationproposal1willbeaccomplishedbyinstallingasteeldecktoraisethe condenser units to an elevation of five feet. Hazard mitigation proposal 2 will be accomplished by replacingthenetworkcablingwitha wirelessnetworksystem. Thenewcomponents willconsistof one wireless access point, one C.L.F Cat 5 cabling, four RJ-45 Cat 5 connectors, and five wireless PCI adapters. Hazard mitigation proposal 3 will be accomplished by adding metal insulation to the back side of the over-head doors to provide greater resistance to wind. Documentation Requirements | No Documentation Required (Review Concluded) (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) 13 (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attached to this REC. National Environmental Policy Act (NEPA) Determination Statutorily excluded from NEPA review. (Review Concluded) Programmatic Categorical Exclusion -Category(Review Concluded) ^] Categorical Exclusion -Category I | No Extraordinary Circumstances exist. Are project conditions required? O Yes (see section V) I INo (Review Concluded) ~^] Extraordinary Circumstances exist (See Section IV). O Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? Q Yes (see section V) [j No (Review Concluded) Environmental Assessment Supplemental Environmental Assessment (Reference EA or PEA in comments) £3 Environmental Impact Statement Record of Environmental Consideration 1 08/29/06 Reviewer Name: Perry Boudreaux Applicant: City ofNew Orleans Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station Comment: This project meets the criteria for an Alternative Arrangement (Permanent Police and Fire Stations) type of project. This project has conditions and requires mitigation under the other EHP laws which are listed under the NEPA level ofenvironmental review inthe project worksheet. Any changes tothis approved scope ofwork 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 offederal funding. Reviewer and Approvals Z\ ProjectisNon-Compliant (See attached documentationjustifying selection). FEMA Environmental Reviewer. Name: PerryJ. Boudreaux, Environmental Specialist Signature^W^^ 7^ •. Date 8/29/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Howard R. Bush, ELO Signature ^7^-—^,^/^-'^ .. Date 8/29/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act • Not type ofactivity with potential toaffect historic properties. (Review Concluded) ^ Applicable executed Programmatic Agreement December 3, 2004 [x] ActivitymeetsProgrammaticAllowanceSectionIl.a.l;Il.b.l;II.c.l; II.c.2;lid.1andII.e.l Are project conditions required? IEI Yes (see section V) • No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES • Nohistoricpropertiesthatarelistedor45/50yearsorolderinprojectarea. (Review Concluded) 2 Building or structure listed or45/50 years orolder in project area and activity not exempt from review. • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see section V) • No (Review Concluded) • Determination ofHistoric Properties Affected (FEMA finding/SHPO/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 • NoAdverse Effect Determination (FEMA finding/SHPO/THPO concurrence onfile). Are project conditions required? • Yes (see section V) • No (Review Concluded) • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) • ResolutionofAdverseEffectcompleted.(MOAonfile) Are project conditions required fj Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES |H Project affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. • Project areahasnopotential for presence ofarcheological resources fj Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) • Project areahaspotential forpresence of archeological resources fj Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) • No (Review Concluded) r~| Determination of historic properties affected • NReligible resources notpresent (FEMA finding/SHPO/THPO concurrence onfile). Record of Environmental Consideration 2 08/29/06 Reviewer Name: Perry Boudreaux Applicant: City ofNew Orleans Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station Are project conditions required QYes (see section V) • No (Review Concluded) • NReligible resources present inproject area. (FEMA finding/ SHPO/THPO concurrence on file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? D Yes (see section V) • No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence onfile) ] Resolutionof AdverseEffectcompleted.(MOAonfile) Are project conditions required? • Yes (see section V) • No (Review Concluded) Comments: 6.6.06-FEMA's Programmatic Agreement (PA), dated December 3,2004, provides for expedited project reviewunderSection106ofthe NationalHistoricPreservationAct (NHPA). Thescopeofworkas submittedinthisPW has been reviewed andmeets thecriteria outlined inAppendix A,Programmatic Allowances, Sections Ha.1; Il.a.1;Il.b.1; II.c.l; II.c.2; Il.d.l and II.e.l ofthe 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. All plaster repair work shall be done in accordance with the recommendations laid out in the US Department ofthe Interior's Preservation Brief21: Repairing historic flatplaster walls andceilings(http://www.cr.nps.gov/hps/tps/briefs/brief21.htm) and Preservation Brief 28: Painting historic interiors (http://www.cr.nps.gov/hps/tps/briefs/brief28.htm) by qualified personnel with experience working on historic buildings. Every effort shall be made to minimize the loss ofadditional historic fabric through the use ofthe gentelest means ofrepair possible and through adequate protection of undamaged areas. 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 offederal funding. This concludes the Section 106 review for this project. James Crouch, Historic Preservation Specialist Correspondence/Consultation/References: J B. Endangered Species Act [>3 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) j Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. • No effect to species or designated critical habitat. (See comments for justification) Are project conditions required? • Yes (see section V) • No (Review Concluded) • Mayaffect,butnotlikelytoadverselyaffectspeciesordesignatedcriticalhabitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? • Yes (see section V) • No (Review Concluded) • Likely to adversely affect species or designated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None C. Coastal Barrier Resources Act E3 Project is not on orconnected toCBRA Unit orOtherwise Protected Area (Review Concluded). 2 Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on " file) • Proposed action an exception under Section 3505.a.6? (Review Concluded) • Proposed action not excepted under Section 3505.a.6. Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 3 08/29/06 Reviewer Name: Perry Boudreaux Applicant: City ofNew Orleans Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station D. Clean Water Act ^ Project would not affect any waters oftheU.S. (Review Concluded) n Project would affect waters, including wetlands, of the U.S. • Project exempted as in kind replacement or other exemption. (Review Concluded) 2 Project requires Section 404/401/or Section 9/10 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: E. Coastal Zone Management Act • Project isnotlocated ina coastal zone area and does notaffect acoastal zone area (Review concluded) [X] Project is located in a coastal zone area and/or affects the coastal zone ^ Stateadministering agency doesnotrequire consistency review. (Review Concluded). • Stateadministering agency requires consistency review. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: ThisprojectislocatedwithintheLouisianaCoastalManagementZone. LaDepartmentofNatural Resourceshasdeterminedthatreceiptof federal assistanceisconsistentwiththeLouisiana CoastalResource Program. Projects within the Coastal Zone may still require a Coastal Use Permit or other authorization from DNR. Projectsmaybecoordinatedby contactingLaDNRat 1-800-267-4019. Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act 13 Project does notaffect, control, ormodify awaterway/body ofwater. (Review Concluded) • Project affects, controls or modifies a waterway/body of water. • Coordination with USFWS conducted • NoRecommendationsofferedby USFWS. (Review Concluded) I | Recommendations providedby USFWS. Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: G. Clean Air Act 13 Project will not result in permanent air emissions. (Review Concluded) 0 Project is located in an attainment area. (Review Concluded) 1 | Project is located in a non-attainment area. • Coordination required with applicable stateadministering agency.. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Project will not result in permanent air emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act E><3 Project does not affect designated prime or unique farmland. (Review Concluded) 2 Project causes unnecessary or irreversible conversion of designated prime or unique farmland. • Coordination withNaturalResource Conservation Commission required. • Farmland Conversion ImpactRating, FormAD-1006, completed. Are project conditions required? Qj YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: Record of Environmental Consideration 4 08/29/06 Reviewer Name: Perry Boudreaux Applicant: City ofNew Orleans Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station I. Migratory Bird Treaty Act fj Project not located within a flyway zone. (Review Concluded) [3 Project located within a flyway zone. [3 Project does nothave potential totake migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) |3 No (Review Concluded) • Project has potential to take migratory birds. • ContactmadewithUSFWS Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has determined that restoration projects funded with federal resources will not have adverse impacts on migratory birds orother fishandwildlifereserves.Thesedeterminations arebasedontheunderstanding thattheconditionsoutlinedintheLouisiana Endangered Species Summary are met. Correspondence/Consultation/References: http://pacificflywav.gov/Documents/Mississippi matxpdf, J. Magnuson-Stevens Fishery Conservation and Management Act ^ Projectnotlocatedinor nearEssentialFishHabitat. (Review Concluded) 2 Project located inornearEssential FishHabitat. • Project does notadversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? • Yes (see section V) • No (Review Concluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) • NOAA Fisheries providedno recommendation(s) (Review Concluded). Are project conditions required? • Yes (see section V) • No (Review Concluded) O NOAA Fisheries provided recommendation(s) • Written reply to NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act 13Projectisnot along and does not affect Wild orScenic River (WSR) -(Review Concluded) • Project is along or affects WSR • Project adversely affects WSR asdetermined byNPS/USFS. FEMA cannot fund the action. (NPS/USFS/USFWS/BLM consultation on file) (Review Concluded) • Project does not adversely affect WSR. (NPS/USFS/USFWS/BLM consultation onfile) Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: L. Other Relevant Laws and Environmental Regulations II. Compliance Review for Executive Orders A. E.0.11988 -Floodplains • NoEffect onFloodplains/Flood levels and project outside Floodplain -(Review Concluded) 13 Located in Floodplain or Effects on Floodplains/Flood levels • Noadverse effect onfloodplain and notadversely affected bythefloodplain. (Review Concluded), Are project conditions required? • Yes (see section V) • No (Review Concluded) • Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). Record of Environmental Consideration 5 08/29/06 Reviewer Name: Perry Boudreaux Applicant: City ofNew Orleans Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station ^ Possible adverse effects associated with investment infloodplain, occupancy ormodification offloodplain environment £3 8 Step Process Complete -documentation on file Are project conditions required? [3 YES (see section V) • NO (Review Concluded) Comments 06/21/06 -TheCity ofNewOrleans/Orleans Parish enrolled intheNational Flood Insurance Program (NFIP) 08/03/1970. PerFloodInsuranceRateMap225030160e,dated03/01/1984,projectislocatedinZoneAl:areaof 100-yr flood;basefloodelevationsandfloodhazardfactorsdetermined. Applicantisrequiredtocoordinatewiththelocal floodplain administrator regarding floodplain permit prior tothe start ofany activities. Applicant is responsible for meeting all requirements ofthe permit. All coordination pertaining tothese activities should be documented and forwarded to GOHSEPandFEMAaspartofthepermanentprojectfiles. 8-stepprocesshasbeencompletedandattached.Rezwan Karim, CFM Correspondence/Consultation/References: B. E.0.11990-Wetlands [3 NoEffects onWetland(s) andproject located outside Wetland(s) -(Review Concluded) • Located in Wetland or effects Wetland(s) • Beneficial Effecton Wetland -(Review Concluded) 2 Possible adverse effect associated with constructing inornearwetland • Reviewcompletedaspartoffloodplain review [~| 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations [3NoLowincomeorminoritypopulation in,nearoraffectedbytheproject-(ReviewConcluded) • Lowincomeorminoritypopulationinornearprojectarea • Nodisproportionatelyhighandadverseimpactonlowincomeorminoritypopulation-(Review Concluded) 2 Disproportionately high or adverse effects on low income or minority population Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: III. Other Environmental Issues Identifyotherpotential environmental concerns inthecommentboxnotclearly falling undera 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 anEnvironmental Assessment (EA) with the exception of(ii) which shouldbeappliedinconjunctionwithcontroversyonan environmentalissue. Ifthecircumstancecanbemitigated, please explain in comments. If no, leave blank. Record of Environmental Consideration 6 08/29/06 Reviewer Name: Perry Boudreaux Applicant: City ofNew Orleans Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station Yes (i)Greater scope orsizethannormally experienced fora particular category ofaction • (ii)Actionswithahighlevelofpubliccontroversy • (iii) Potential for degradation, even though slight, ofalready existing poorenvironmental conditions; • (iv)Employmentofunproventechnologywithpotentialadverseeffectsoractionsinvolving unique or unknown environmental risks; (v) Presence ofendangered orthreatened species ortheircritical habitat, orarchaeological, cultural, historical or other protected resources; (vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; n (vii)Actionswiththepotentialto affectspecialstatusareasadverselyorothercritical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principal drinking water aquifers; I"! (viii) Potential for adverse effects on health or safety; and • (ix)Potentialtoviolateafederal,state,localortriballaworrequirementimposedforthe protection of the environment, (x) Potential for significant cumulative impact when the proposed action is combined with otherpast, presentandreasonablyforeseeable future actions,eventhoughtheimpactsofthe proposed actionmaynot be significantby themselves. Comments: None V. Environmental Review Project Conditions Project Conditions: 1. Applicantisrequiredtocoordinatewiththe localfloodplainadministrator regarding floodplainpermitpriortothestartofanyactivities. Applicantisresponsiblefor meeting all requirements of the permit. All coordination pertaining to these activities should be documented and forwarded to GOHSEP and FEMA as part of the permanent project files. 2. Inkeeping withthestipulations ofthe PA, allproposed repair activities should bedone in-kind to match existing materials and form. Any change to the approved scope of work willrequireresubmissionforre-evaluation underSection 106andconsultationwiththe SHPO. Non-compliancemayjeopardizethereceiptoffederalfunding. 3. All plaster repair work shall be done in accordance with the recommendations laid out in theUSDepartment oftheInterior'sPreservation Brief21:Repairing historicflatplaster walls and ceilings (http://www.cr.nps.gov/hps/tps/briefs/brief21.htm) and Preservation Brief28:Paintinghistoricinteriors(http://www.cr.nps.gov/hps/tps/briefs/brief28.htm) by qualifiedpersonnelwithexperienceworkingonhistoricbuildings. Everyeffortshallbe made to minimize the loss of additional historic fabric through the use of the gentelest means of repair possible and through adequate protection of undamaged areas. 4. 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 oftheprojectapplicant shallhandle, manage, anddispose of petroleum products, hazardous materials and/ortoxicwaste inaccordance tothe requirements andto the satisfaction of the governing local, state and federal agencies. Record of Environmental Consideration 7 08/29/06 ReviewerName: Perry Boudreaux Applicant: City of NewOrleans Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / Engine #11 Fire Station 5. Mercurycontainingdevices-thisprojectpotentiallyinvolvesthedisposal ofmetallic mercurycontainingelectronicdevices. Theapplicantisresponsibleforensuringthat these devices are recovered, recycled, reused or sequestered in accordance with the LouisianaDepartment ofEnvironmentalQuality(LDEQ)"Declaration ofEmergency; Mercury-containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. 6. Removal and disposal of debris containing household hazardous waste and certain categories ofliquidwastesmustbeperformed inaccordance withallapplicable federal and state laws, regulations, executive orders and guidelines. LAC Title 33 Part vii requiresthatspecified items,includingleadacidbatteries,usedoilfilters, usedmotoroil, scrap tires, cfc's (refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous debris collection, staging, processing anddisposalsites. Failuretocomplywithapplicablelegalrequirementsindebris collectionand/ordisposaloperationswilljeopardizefederalfunding. Theclean-upor restoration/repair ofsitesdamaged asaresultofsuchoperationsareineligiblefor federal funding. Previously obligatedfunding is subjectto de-obligation if a determination of ineligibility is made. 7. 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 salvagedfrom astructure)maynot leavethequarantinedparisheswithoutwritten authorization from the commissioner of the Louisiana Department of Agriculture and Forestry or his designee(s). 8. This project involves the demolition or renovation of a public structure that may contain surfaces coated with lead-based paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with applicable provisionsof29 CFRParts 1910and 1926(OSHA-WorkerSafety),and40 CFR260through 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. 9. 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 "Sixth Amended Declaration of Emergency and Administrative Order" dated June 30, 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 projectsite,theapplicantisalsoresponsible forensuringproperdisposalinaccordance withthe previously referenced administrative order. Monitoring Requirements: None Record of Environmental Consideration 8 08/29/06