Reviewer Name: Letha Dawson Applicant: Dillard University Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EOR0636 Permanent Building Repairs- Cook Communications Center Record of Environmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number: Permanent Building Repairs-Cook Communications Center/PW 8945 Project Location: Orleans Parish, Louisiana (N29.59735, W-90.03869) Project Description: Project activities include mold remediation; removing and replacing vinyl composite floor tile, drywall, acoustic ceiling tiles, ceramic tiles, carpeting, auditorium seats, asphalt roofing shingles, fiberglass insulation, galvanized steel furring, wood block flooring, vinyl cove base, fluorescent fixtures, exterior incandescent light fixtures andwindows, and painting walls and floors. In addition, hazard mitigation will beachieved bycompliance with current codes and standards and by good construction practices. Documentation Requirements I I 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) 123 (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) I I Categorical Exclusion -Category I | No Extraordinary Circumstances exist. Are project conditions required? Q Yes (see section V) • No (Review Concluded) I I Extraordinary Circumstances exist (See Section IV). I I Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? O Yes (see section V) • No (Review Concluded) Environmental Assessment Supplemental Environmental Assessment (Reference EA or PEA in comments) [X] Environmental Impact Statement Comments: ThisprojectmeetsthecriteriaforanAlternativeArrangement(PermanentSchools)typeofproject. This project has conditions and requires mitigation under the other EHP laws. Reviewer and Approvals LJ ProjectisNon-Compliant(Seeattacheddocumentationjustifyingselection). Record of Environmental Consideration 1 06/21/06 Reviewer Name: Letha Dawson Applicant: Dillard University Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EOR0636 Permanent Building Repairs- Cook Communications Center FEMA Environmental Reviewer. Name: Letha Dawson, Environmental Specialist Signature (U}Ah&MjaAAXA(p^ 06/21/2006 (U^QJiklnUXJ^p^J Date FEMA Regional Environmental Officer or delegated approving official. Name: Michael tfirisham, DELO ncj<*** Signature /™**J \£S) M***"* ; Date 06/21/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act S Not type ofactivity with potential toaffect historic properties. (Review Concluded) • Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. I IActivity meets Programmatic Allowance # Areproject conditions required? • Yes (see section V) Q No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES ^ No historic properties that are listed or45/50 years orolder in project area. (Review Concluded) [J Building or structure listed or 45/50 years or older in project area and activity not exempt from review. • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) Areproject conditions required? Q Yes (see section V) • No (Review Concluded) • Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence on file) O Property aNational Historic Landmark and National Park Service was provided early notification during the consultation process. If not, explain in comments D No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? • Yes (seesection V) • No (Review Concluded) • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) [J Resolution ofAdverse Effect completed. (MOA on file) Areproject conditions required Q Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES E<3 Project affects only previously disturbed ground. (Review Concluded) O Project affects undisturbed ground. • Project areahasno potential forpresence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) IIProject area has potential for presence ofarcheological resources • 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 • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required [Z]Yes (see section V) • No (Review Concluded) • NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? Q Yes (see section V) O No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) • Resolution ofAdverse Effect completed. (MOA onfile) Are project conditions required? \Z\ Yes (seesection V) Q No (Review Concluded) Record of Environmental Consideration 2 06/21/06 Reviewer Name: Letha Dawson Applicant: Dillard University Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EOR0636 Permanent Building Repairs- Cook Communications Center Comments: None Correspondence/Consultation/References: B. Endangered Species Act £3No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) • Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. O No effect to species ordesignated critical habitat (See comments for justification) Are project conditions required? • Yes(seesection V) • No(ReviewConcluded) • May affect, but not likely to adversely affect species ordesignated critical habitat (FEMA determination/USFWS/NMFS concurrence on file) (Review Concluded) Are project conditions required? • Yes(seesection V) • No(Review Concluded) LZI Likely toadversely affect species ordesignated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (seesection V) • NO(Review Concluded) Comments: None C. Coastal Barrier Resources Act [X] Projectisnotonor connectedtoCBRAUnitorOtherwiseProtectedArea (Review Concluded). • Project is on orconnected toCBRA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on file) J Proposed action an exception under Section 3505.a.6? (Review Concluded) • Proposed actionnotexcepted underSection 3505.a.6. Are project conditions required? • YES (seesection V) • NO (ReviewConcluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act £3 Project would not affect any waters ofthe U.S. (Review Concluded) • Project would affect waters, including wetlands, ofthe U.S. J Project exempted as in kind replacement or other exemption. (Review Concluded) • Project requires Section 404/401/or Section 9/10 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? • 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 O Projectisnot locatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Review concluded) [x] Project islocated ina coastal zone area and/or affects thecoastal zone ^ State administering agency does not require consistency review. (Review Concluded). I IState administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: FEMAhasdetermined thatthisprojectisconsistent withtheCoastal ZoneManagement Actandthe Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act Record of Environmental Consideration 3 06/21/06 Reviewer Name: Letha Dawson Applicant: Dillard University Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EOR0636 Permanent Building Repairs- Cook Communications Center [3 Project does not affect, control, or modify a waterway/body ofwater. (Review Concluded) [_j Project affects, controls ormodifies awaterway/body ofwater. • Coordination with USFWS conducted • No Recommendations offer ed by USFWS. (Review Concluded) O Recommendations provided by USFWS. Are project conditions required? • 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 K Project will not result inpermanent airemissions. (Review Concluded) J Project is located in an attainment area. (Review Concluded) l~lProjectislocated ina non-attainment area. [J Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act ^ Project does not affect designated prime orunique farmland. (Review Concluded) \_\ Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. I I Coordination with Natural Resource Conservation Commission required. • Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act J Project not located within a flywayzone. (Review Concluded) ^ Project located within a flyway zone. ^ Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) [K] No (Review Concluded) I IProject has potential totake migratory birds. • Contact made with USFWS Are project conditions required? • 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 nothave adverse impacts onmigratory birds orother fish andwildlife reserves. These determinations arebased onthe understanding thatthe conditions outlined inthe Louisiana Endangered Species Summary are met Correspondence/Consultation/References: http://pocificflYway.qov/Documents/Mississippi rnap.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act £3Projectnotlocatedinor nearEssentialFishHabitat. (ReviewConcluded) • Project located inornear Essential Fish Habitat. • Project does not adversely 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 provided no recommendation(s) (Review Concluded). Record of Environmental Consideration 4 06/21/06 Reviewer Name: Letha Dawson Applicant: Dillard UniversityDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EOR0636 Permanent Building Repairs- Cook Communications Center Are project conditions required? • Yes (see section V) • No (Review Concluded) • NOAA Fisheries provided recommendation(s) D 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 ^ Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) • Project isalong oraffects WSR • Project adversely affects WSR as determined by NPS/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 on file) 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 • No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) H Located in Floodplain or Effects on Floodplains/Flood levels B2 No adverse effect onfloodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? E] Yes (see section V) • No (Review Concluded) • Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). • Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment LJ 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: 06/17/2006 -THECITYOFNEW ORLEANS/ORLEANS PARISH ENROLLED INTHE NATIONAL FLOOD INSURANCE PROGRAM 08/03/1970. PER FLOOD INSURANCE RATE MAP 225203 0095E, DATED 03/01/1984, PROJECT IS LOCATED IN ZONE B, AREA PROTECTED FROM THE 100-YR FLOOD BY LEVEE, DIKEOROTHERSTRUCTURE SUBJECTTOFAILUREOROVERTOPPING DURINGLARGERFLOODS. PROJECTISFORTHEREPAIROFA BUILDINGDAMAGEDBYFLOOD, WIND, AND WIND-DRIVENRAINTO PRE-DISASTER CONDITION AND IS NOT LIKELY TO AFFECT THE FLOODPLAIN. PER FLOOD RECOVERY GUIDANCE, DATED 04/12/2006, WHERE POSSIBLE, ALL EQUIPMENT AND CONTENTS SHOULD BE ELEVATEDATLEAST3FT. ABOVETHEHIGHESTADJACENTGRADEELEVATION. -KIMBERLYR ROGERS, FLOODPLAIN MANAGEMENT SPECIALIST Correspondence/Consultation/References: B. E.0.11990-Wetlands 13No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) • Beneficial Effect onWetland -(Review Concluded) • Possible adverse effect associated with constructing in or near wetland • Review completed as part offloodplain review D 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Record of Environmental Consideration 5 06/21/06 Reviewer Name: Letha Dawson Applicant: Dillard University Disaster/Emergency/Program/Project Title: DR 1603LA / Hurricane Katrina / Public Assistance Program / EOR0636 Permanent Building Repairs- Cook Communications Center Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations £3No Low income or minority population in, near oraffected by the project -(Review Concluded) • Low income orminority population inornearproject area J Nodisproportionatelyhighand adverseimpactonlow incomeorminoritypopulation-(Review Concluded) [j 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 Identify other potential environmental concerns in the comment box not clearly falling under a law or executive order (see environmental concerns scoping checklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based on the review of compliance with other environmental laws and Executive Orders, and in consideration of other environmental factors, review the project for extraordinary circumstances. * A"Yes"underanycircumstance mayrequire anEnvironmental Assessment (EA)withtheexception of(ii) which should beapplied inconjunction with controversy onan environmental issue. Ifthe circumstance canbe mitigated, please explain in comments. Ifno, leave blank. Yes (i)Greaterscopeorsizethan normally experienced foraparticularcategory ofaction (ii) Actions with a high level of public controversy • (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; • (iv)Employmentofunproventechnologywithpotentialadverseeffectsoractionsinvolving unique or unknown environmental risks; • (v) Presence ofendangered or threatened species or their critical habitat, orarchaeological, cultural, historical or other protected resources; [U (vi) PresenceofhazardousortoxicsubstancesatlevelswhichexceedFederal,stateorlocal regulations or standards requiring action or attention; • (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; (viii) Potentialforadverseeffectson healthor safety;and O (ix)Potentialtoviolateafederal,state,localortriballaworrequirementimposedforthe protection of the environment. LJ (x)Potentialforsignificantcumulativeimpactwhentheproposedactioniscombinedwith other past, present and reasonably foreseeable future actions, even though the impacts of the proposed action may not be significant by themselves. Comments: None Record of Environmental Consideration 6 06/21/06 ReviewerName: Letha Dawson Disaster/Emergency/Program/Project Title: DR1603LA/Hurriran,> kr^rinwo mi . Applicant: Dillard University Cook Communications Center "KloUJLA/Hurncane Katnna/Public Ass.stance Program/EOR0636 Permanent Building Repairs- V. Environmental Review Project Conditions General comments: Project Conditions: L ExlluPsionCt^ C°mPly Wi* a11 C°nditi0nS °f^ attaCh6d Prcgnanmatic Categorical 2. Per flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents should be elevated at least 3feet above the highest adjacent grade elevTttn. Monitoring Requirements: None Record ofEnvironmental Consideration 06/21/06