I I ! Record of Environmental Consideration Reviewer Name: Letha Dawson Applicant: Dillard University DisasterlEmergencylProgramlProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR06321Henson Hall See 44 Code of Federal Regulation Part 10. Project NamelNumber: Henson Hall! PW 8960 Project Location: 2601 Gentilly Blvd., New Orleans, Louisiana, Orleans Parish 70122 (N29.59735, W-90.04016) Project Description: Project activities include mold remediation; removing and replacing doors and frames, ceiling insulation, gym wall felt padding, metal stud partition, fiberglass insulation, gypsum wallboard, 70 gallon water heater, HVAC unit, and electrical service; installing drinking water station, toilet fixtures, wash basin, toilet partitions with doors, ADA assist bars, resilient flooring, cove base, glass window, domestic water distribution, ductwork, diffusers, return air grill, lighting and wiring, and fire alarm system; and cleaning and painting gym floor, walls and ceilings. Hazard mitigation will be achieved by compliance with current codes and standards and by good construction practices. Documentation Requirements D No Documentation Required (Review Concluded) 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) [8J (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attached to this REC. National Environmental Policy Act (NEP A) Determination D Statutorily excluded from NEP A review. (Review Concluded) D Programmatic Categorical Exclusion -Category (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 D Supplemental Environmental Assessment (Reference EA or PEA in comments) [8J 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. Reviewer and Approvals D Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. N.~e:Leilia~= Signature ~ . Date _-..::..:06::.;..;/2=9;..:...:/2=0=0..:..6_____.....:. FEMA Regional Environmental Officer or delegated approving official. Name: Donald Fairley, ELO Signature --;;;? d-=-~ . Date __0=6~/2=9:..:...:/2=0=0=6_____-= I. Compliance Review for Environmental Laws (other than NEPAl A. National Historic Preservation Act D Not type of activity with potential to affect historic properties. (Review Concluded) 181 Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. 181 Activity meets Programmatic Allowance # Appendix A, Section {II-A2, II-El, II-CI, II-F2, II-BI, II-B2} Are project conditions required? 181 Yes (see section V) D No (Review Concluded) mSTORIC BUILDINGS AND STRUCTURES D No historic properties that are listed or 45150 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 findinglSHPOrrHPO concurrence on file) Are project conditions required? D Yes (see section V) D No (Review Concluded) D Determination of Historic Properties Affected (FEMA fmdinglSHPOrrHPO concurrence on file) D Property a National 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 fmdinglSHPOrrHPO concurrence on file). Are project conditions required? D Yes (see section V) D No (Review Concluded) D Adverse Effect Determination (FEMA findinglSHPOrrHPO concurrence on file) D Resolution ofAdverse 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 of archeological resources D Determination of no historic properties affected (FEMA findinglSHPO/THPO 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 findinglSHPO/THPO 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 findinglSHPOrrHPO concurrence on file). Are project conditions required DYes (see section V) D No (Review Concluded) D NR eligible resources present in project area. (FEMA findingl SHPOrrHPO concurrence on file) D No Adverse Effect Determination. (FEMA findingl SHPO/THPO concurrence on file) Are project conditions required? D Yes (see section V) D No (Review Concluded) D Adverse Effect Determination. (FEMA findingl SHPO/THPO concurrence on file) o Resolution of Adverse Effect completed. (MOA on file) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) Comments: 06/29/2006 • 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 of work as submitted in this PW has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section {II-A2, II-El, II-CI, II-F2,Il-Bl, II-B2} , of the document. In accordance with the PA, FEMA is not required to determine the National Register eligibility of properties 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 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 reevaluation 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. V. Gomez, Historic Preservation Specialist Correspondence/Consultation/References: B. Endangered Species Act [81 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. eview 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 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: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act [81 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) o Proposed action not excepted under Section 3505.a.6. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act r8J 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) o Project requires Section 404/40 1lor Section 9110 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: Project is not in or adjacent to any waterways ofthe US. Correspondence/Consultation/References: 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) ~Project is located in a coastal zone area and/or affects the coastal zone ~State administering agency does not require consistency review. (Review Concluded). D State administering agency requires consistency review. Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: FEMA has detennined that this project is consistent with the Coastal Zone Management Act (CZMA) and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ~Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) D Project affects, controls or modifies a waterwaylbody ofwater. D Coordination with USFWS conducted D No Recommendations offer ed by USFWS. (Review Concluded) D Recommendations provided by USFWS. Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: Project is not in or adjacent to any waterways ofthe US. Correspondence/Consultation/References: G. Clean Air Act ~Project will not result in pennanent air emissions. (Review Concluded) D Project is located in an attainment area. (Review Concluded) D Project is located in a non-attainment area. D Coordination required with applicable state administering agency .. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act 181 Project does not affect designated prime or unique farmland. (Review Concluded) o Project causes unnecessary or irreversible conversion ofdesignated prime or unique fannland. D Coordination with Natural Resource Conservation Commission required. D Fannland Conversion Impact Rating, Fonn AD-I 006, completed. Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: None Correspondence/Consultation/References: 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) Are project conditions required? D Yes (see section V) 181 No (Review Concluded) o Project has potential to take migratory birds. D Contact made with USFWS Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/1412005. Specifically, FEMA has detennined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other Record of Environmental Consideration 4 06/29/06 fish and wildlife reserves. These detenninations are based on the understanding that the conditions outlined in the Louisiana Endangered Species Summary are met Correspondence/Consultation/References: htt:p:llpacificflyway.gov/Documents/Mississippi map.pdf, J. Magnuson-Stevens Fishery Conservation and Management Act ~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) 0 No (Review Concluded) o Project adversely affects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS concurrence on file) o NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o NOAA Fisheries provided recommendation(s) o Written reply to NOAA Fisheries recommendations completed. Are project conditions required? 0 YES (see section V) 0 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) o Project is along or affects WSR o Project adversely affects WSR as detennined by NPSfUSFS. FEMA cannot fund the action. (NPSfUSFSfUSFWSIBLM consultation on file) (Review Concluded) o Project does not adversely affect WSR. (NPSfUSFSfUSFWSIBLM consultation on file) Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: L. Other Relevant Laws and Environmental Regulations II. Compliance Review for Executive Orders A. E.O. 11988 -Floodplains oNo Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) ~Located in Floodplain or Effects on FloodplainslFlood levels ~No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), Are project conditions required? ~Yes (see section V) 0 No (Review Concluded) oBeneficial Effect on Floodplain OccupancyNalues (Review Concluded). o Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment o 8 Step Process Complete -documentation on file Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: 06/28/2006 -The City ofNew Orleans/Orleans Parish enrolled in the National Flood Insurance Program 08/03/1970. Per Flood Insurance Rate Map 225203 0095E, dated 03/0111984, project is located in Zone B, area protected from the 100-yr flood by levee, dike or other structure subject to failure or overtopping during larger floods. Project is for the repair/replacement ofbuilding and building contents damaged by flood, wind, and wind-driven rain and is not likely to affect the floodplain. Per flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents should be elevated at least 3 ft. above the highest adjacent grade elevation. -Kimberly R. Rogers, Floodplain Management Specialist Correspondence/Consultation/References: B. E.O. 11990 -Wetlands 18I 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: None Correspondence/Consultation/References: C. E.O. 12898 -Environmental Justice For Low Income and Minority Populations 18I No Low income or minority population in, near or affected by the project -(Review Concluded) o Low income or minority population in or near project area oNo 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) 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" 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 o (i) Greater scope or size than normally experienced for a particular category ofaction o (ii) Actions with a high level of public controversy o (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; o (iv) Employment ofunproven technology with potential adverse effects or actions involving unique or unknown environmental risks; o (v) Presence of endangered or threatened species or their critical habitat, or archaeological, cultural, historical or other protected resources; 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 of the 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 General comments: None Project Conditions: 1. In keeping with the stipulations of the P A, 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. Noncompliance may jeopardize the receipt of federal funding. 2. Per flood recovery guidance, dated 04/1212006, where possible, all equipment and contents should be elevated at least 3 ft. above the highest adjacent grade elevation. Monitoring Requirements: None