Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board DisastnlEmergencylProgramlProj«t Title: DR 1603LA I Hurricane Katrina !Public Assistance ProgramlEOR 0790 McDonough I S Elementary School Record of Environmental Consideration See 44 Code of Federal Regulation Part to. Project NamelNumber: EOR 0790 McDonough 15 Elementary School / PW 9595 Project Location: 721 St. Philip Street, New Orleans, Louisiana, Orleans Parish (N29.96064, W-90.06268) Project Description: Project activities include replacing (5) 2' X 4' window shutters, 10 FT of existing 12" roof cap flashing on library parapet wall, 3600 SQ FT of floor tiles in the cafeteria, and (5) -2' X 4' ceiling tiles in the bath room. Project activities also include cleaning and disinfecting all surfaces in the kitchen area. Hazard Mitigation will be achieved by upgrading to current codes and standards. Documentation Reg uirements 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) ~ (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attached to this REC. National Environmental Policy Act (NEPAl Determination D Statutorily excluded from NEPA review. (Review Concluded) D Programmatic Categorical Exclusion -Category (Review Concluded) D Categorical Exclusion -Category o No Extraordinary Circumstances exist. Are project conditions required? 0 Yes (see section V) D 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) ~ Environmental Impact Statement Comments: 6/30/06 -This project meets the criteria for an Alternative Arrangement for (Permanent Schools) type of project. This project has conditions and requires mitigation under other EHP laws. Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board DisasterlEmergencylProgramIProject Title: DRI603LA I Hurricane Katrina !Public Assistance ProgramlEOR 0790 McDonough 15 Elementary School Reviewer and Approvals o Project is Non-Compliant (See attached documentation justifying selection). FEMA Regi al Environmental Offic or delegated approving official. Name: Donald Fairley, ELO ~ Signature~~ I . Date _---'-7--==-3==--0=6"--___-----" I. Compliance Review for Environmental Laws (other than NEPAl A. National Historic Preservation Act o Not type of activity with potential to affect historic properties. (Review Concluded) ~Applicable executed Programmatic Agreement, 03123/06. Otherwise, conduct standard Section 106 review. ~Activity meets Programmatic Allowances, Appendix A, Sections II A (1, 2, & 4), C (1& 2), E (1). Are project conditions required? ~Yes (see section V) 0 No (Review Concluded) mSTORIC BUILDINGS AND STRUCTURES o No historic properties that are listed or 45150 years or older in project area. (Review Concluded) o Building or structure listed or 45150 years or older in project area and activity not exempt from review. o Determination ofNo Historic Properties Affected (FEMA fmdingiSHPO/THPO concurrence on file) Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o Determination of Historic Properties Affected (FEMA fmdingiSHPO/THPO concurrence on file) o Property a National Historic Landmark and National Park Service was provided early notification during the consultation process. Ifnot, explain in comments o No Adverse Effect Determination (FEMA findingiSHPO/THPO concurrence on file). Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) o Adverse Effect Determination (FEMA fmdingiSHPO/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) ARCHEOLOGICAL RESOURCES ~Project affects only previously disturbed ground. (Review Concluded) o Project affects undisturbed ground. o Project area has no potential for presence of archeological resources o Determination of no historic properties affected (FEMA fmdingiSHPOITHPO concurrence or consultation on file). (Review Concluded) o Project area has potential for presence ofarcheological resources o Determination of no historic properties affected (FEMA fmdingiSHPOITHPO concurrence on file) Are project conditions required 0 Yes (see section V) 0 No (Review Concluded) D Determination ofhistoric properties affected D NR eligible resources not present (FEMA fmdingiSHPOITHPO concurrence on file). Are project conditions required DYes (see section V) 0 No (Review Concluded) o NR eligible resources present in project area. (FEMA fmdingl SHPO/THPO concurrence on file) o No Adverse Effect Determination. (FEMA fmdingl SHPOITHPO concurrence on file) Are project conditions required? 0 Yes (see section V) D No (Review Concluded) Reviewer Name: June R. Griffin Appliunt: Orleans Parish School Board DisasterlEmergeneylProgramlProjeet Title: DRI603LA I Hurricane KatrinalPublic Assistance ProgramlEOR 0790 McDonough IS Elementary School o Adverse Effect Detennination. (FEMA finding! SHPOffHPO 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: 6.26.06 -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, Sections II.A.I ;II.A.2; n.AA ; IIC.I; II.C.2; and II.E.I of the document. In accordance with the PA, FEMA is not required to submit projects to the State Historic Preservation Officer (SHPO) for review where the work perfonned meets these allowances. In keeping with the stipulations ofthe P A, all proposed repair activities should be done in-kind to match existing materials and fonn. Any change to the approved scope of work will require resubmission for re-evaluation under section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt of federal funding. All plaster repair work shall be done in accordance with the recommendations laid out in the us Department of the Interior Preservation Brief 21: Repairing Historic Flat Plaster Walls and Ceilings (http://www.cr.nps.govlhps/tpslbriefslbrief21.htm) and Preservation Brief 28: Painting Historic Interiors (http://www.cr.nps.govlhps/tps/briefs/briet28.htm) by qualified personnel with experience working on Historic Buildings. Every effort shall be 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. Failure to comply with these stipulations may jeopardize receipt ofFEMA funding. This concludes the section 106 review for this project. James Crouch, Historic Preservation Specialist Correspondence/Consultation/References: B. Endangered Species Act 181 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 detenninationlUSFWSINMFS 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 Fonnal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? 0 YES (see section V) D NO (Review Concluded) IComments: None C. Coastal Barrier Resources Act 181 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 detenninationlUSFWS 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? D YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act 181 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 404/401l0r Section 9110 (Rivers and Harbors Act) pennit, including qualification under Nationwide Pennits. Are project conditions required? D YES (see section V) D NO (Review Concluded) Record of Environmental Consideration 3 07/03/06 Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board DisasterlEmergencylProgramlProjec:t Title: DR 1603LA I Hurricane Katrina lPublic Assistance ProgramlEOR 0790 McDonough 15 Elementary School Comments: Project is not in or adjacent to any waterways of the U.S. Correspondence/Consultation/References: E. Coastal Zone Management Act o Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) I2J Project is located in a coastal zone area and/or affects the coastal zone I2J 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: FEMA has determined that this project is consistent with the Coastal Zone Management Act and the Louisiana Coastal Management Plan (LCMP). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act I2J Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) o Project affects, controls or modifies a waterwaylbody of water. oCoordination 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: Project is not in or adjacent to any waterways ofthe U.S. Correspondence/Consultation/References: G. Clean Air Act I2J Project will not result in permanent air emissions. (Review Concluded) o Project is located in an attainment area. (Review Concluded) o Project is located in a non-attainment area. oCoordination required with applicable state administering agency .. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: Project will not result in permanent air emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act I2J 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, Form AD-l 006, completed. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act o Project not located within a flyway zone. (Review Concluded) I2J Project located within a flyway zone. I2J Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? 0 Yes (see section V) I2J No (Review Concluded) o Project has potential to take migratory birds. o Contact made with USFWS Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 07/03/06 Record of Environmental Consideration 4 Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board DisallterlEmergencylProgramIProject Title: DRI603LA f Hurricane Katrina !Public Assistance ProgramlEOR 0790 McDonough IS Elementary School Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/1412005. Specifically, FEMA has determined that restoration projects funded with federal resources will not have adverse impacts on migratory birds or other fish and wildlife reserves. These determinations are based on the understanding that the conditions outlined in the Louisiana Endangered Species Summary are met. Correspondence/Consultation/References: http://pacificflyway.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 determinationlUSFWSINMFS 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 [gJ 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 determined by NPSIUSFS. FEMA cannot fund the action. (NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) o Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) Are project conditions required? 0 YES (see section V) D 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 o No Effect on FloodpJainslFlood levels and project outside Floodplain -(Review Concluded) [8J 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? D Yes (see section V) 0 No (Review Concluded) o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). [8J Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment [gJ 8 Step Process Complete -documentation on file Are project conditions required? [8J YES (see section V) 0 NO (Review Concluded) Comments: 06/27/06 -The Parish of Plaquemines enrolJed in the National Flood Insurance Program 05/0111985. Per Flood Insurance Rate Map 2201390905 C, dated 09/28/90, project is located in Zone A99; area of 100-yr flood to be protected by flood protection system under construction; base flood elevations and flood hazard factors not determined. Project is repair ofwater treatment faciltites, which were not substantially damaged. In compliance with 44 CFR 9.11, to elevate, mitigate, wet or dry flood proof; mitigation measures have been considered and are attached. Per EO 11988, an 8· step process has been completed and attached. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior Record ofEnvironmental Consideration 5 07/03/06 Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board DisasterlEmergency!Program!Project Title: DR 1603LA I Hurricane Katrina !Public Assistance ProgramlEOR 0790 McDonough IS Elementary School to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOSHEP and FEMA for inclusion in the pennanent project files. Casey Barefield, FPM. Correspondence/Consultation/References: B. E.O. 11990 -Wetlands [81 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 [81 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 (H) which should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, please explain in comments. Ifno, leave blank. Yes o o (i) Greater scope or size than nonnally experienced for a particular category of action o (ii) Actions with a high level of public controversy (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; o o o (iv) Employment of unproven technology with potential adverse effects or actions involving unique or unknown environmental risks; o (v) Presence ofendangered 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; Reviewer Name: June R. Griffin Applicant: Orleans Parish School Board DiulterlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina !Public Assistance ProgramJEOR 0190 McDonough 15 Elementary School 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 Project Conditions: 1. In keeping with the stipulations ofthe Programmatic Agreement 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-compliance may jeopardize the receipt of federal funding. All plaster repair work shall be done in accordance with the recommendations laid out in the US Department of the Interior Preservation Brief 21 : Repairing Historic Flat Plaster Walls and Ceilings (http://www.cr.nps.govlhps/tpslbriefslbrief2Lhtm) and Preservation Brief 28: Painting Historic Interiors (http://www.cr.nps.govlhps/tpslbriefslbrief28.htm) by qualified personnel with experience working on historic buildings. Every effort shall be made to minimize the loss of additional historic fabric through the use of the gentlest means of repair possible and through adequate protection ofundamaged areas. Failure to comply with these stipulations may jeopardize receipt of FEMA funding. 2. In compliance with 44 CFR 9.11, to elevate, mitigate, wet or dry flood proof; mitigation measures have been considered and are attached. Per EO 11988, an 8-step process has been completed and attached. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOSHEP and FEMA for inclusion in the permanent project files. Monitoring Requirements: None