Draft Supplemental Environmental Assessment City of … · Basins/Pervious Parking, and Urban...

Draft Supplemental Environmental Assessment City of New Orleans Pontilly Neighborhood Water Mitigation Project FEMA-1603-DR-LA Orleans Parish, Louisiana Hazard Mitigation Grant Program Project Number 1603-0178 March 2018 U.S. Department of Homeland Security Federal Emergency Management Agency, Region VI Louisiana Recovery Office 1500 Main Street Baton Rouge, LA 70802

CNO Pontilly Water Mitigation Draft Environmental Assessment i

CONTENTS

CONTENTS I

APPENDICES II

LIST OF TABLES II

ACRONYMS AND ABBREVIATIONS ......................................................................................................... III

1.0 INTRODUCTION .......................................................................................................... 1

1.1 Project Authority ..........................................................................................1 1.2 Background ..................................................................................................1

2.0 PURPOSE AND NEED ................................................................................................. 5

3.0 ALTERNATIVES .......................................................................................................... 6

3.1 Alternative 1 - No Action Alternative .........................................................6 3.2 Alternative 2 - Installation of Stormwater Lots/Parks, Street

Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) ..................................................................................................7

3.3 Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System .............................................................................................11

4.0 AFFECTED ENVIRONMENT AND POTENTIAL IMPACTS ....................................... 11

4.1 Water Resources ............................................................................11 4.2 Biological Resources .....................................................................18 4.3 Cultural Resources .........................................................................20 4.4 Socioeconomic Resources .............................................................23 4.5 Traffic ............................................................................................25

5.0 CONDITIONS AND MITIGATION MEASURES .......................................................... 27

THE FOLLOWING IS A RESTATEMENT OF THE MITIGATION AND CONDITION MEASURES FROM THE FEBRUARY 2016 EA FOR THE PROPOSED PONTILLY WATER MITIGATION PROJECT. .............................................................................. 29

6.0 AGENCY COORDINATION AND PUBLIC INVOLVEMENT ...................................... 32

6.1 Agency Coordination .................................................................................32 6.2 Public Involvement ....................................................................................32

7.0 CUMULATIVE IMPACTS ........................................................................................... 35

CNO Pontilly Water Mitigation Draft Environmental Assessment ii

8.0 CONCLUSION ............................................................................................................ 41

9.0 REFERENCES ........................................................................................................... 41

9.0 LIST OF PREPARERS ............................................................................................... 43

APPENDICES

Appendix A Hydrologic and Hydraulic Study Appendix B Pontilly Final EA and FONSI Appendix C External Agency Correspondence Appendix D USFWS Bald Eagle Management Guidelines Appendix E USFWS Bald Eagle Monitoring Guidelines Appendix F 8-Step Appendix G Draft FONSI Appendix H Public Notice

LIST OF TABLES

Table 1. The probability of a 2-, 5-, and 10-year flood occurring in four different time periods ... 4 Table 2. Preferred Alternative Impact to Floodplain .................................................................... 17 Table 3. Demographic and Economic Information of Orleans Parish and Project Area ....... Error! Bookmark not defined.5 Table 4. FEMA-funded Project Sites in Study Area by Disaster and Project Type……………..38 Table 5. Projects Identified as Having Potential to Contribute to Cumulative impacts…………40

LIST OF FIGURES Figure 1: State of Louisiana, Orleans Parish Highlighted .............................................................. 2 Figure 2: Pontilly Project Area ....................................................................................................... 3 Figure 3: Conceptual Rendering of Proposed Stormwater Lots ..................................................... 7 Figure 4: Conceptual Rendering of Typical Urban Bioswale ......................................................... 8 Figure 5: Conceptual Rendering of Proposed Improvements to Dwyer Canal .............................. 9 Figure 6: Depiction of Preferred Alternative ................................................................................ 10 Figure 7: DFIRM of Pontilly project area (FEMA 2016)………………………………………..17 Figure 8. Map Representing Large Scale FEMA-Funded Projects within the One Mile Radius Buffer (Source FEMA LRO………………………………………………………...……………37 Figure 9. Map Representing 33 Additional FEMA-Funded Project Sites and 3 EAs within the One Mile Radius Buffer (Source FEMA LRO……………………………………..……………39

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ACRONYMS AND ABBREVIATIONS

APE Area of Potential Effects ACHP Advisory Council on Historic Preservation BMP Best Management Practices CAA Clean Air Act CBRA Coastal Barrier Resources Act CBRS Coastal Barrier Resources System CEQ Council on Environmental Quality CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations cfs cubic feet per second CH4 Methane CNO City of New Orleans CO Carbon Monoxide CO2 Carbon Dioxide CPRA State of Louisiana Coastal Protection and Restoration Authority CUP Coastal Use Permit CWA Clean Water Act CZMA Coastal Zone Management Act dB Decibels DA Department of the Army DEA Draft Environmental Assessment DFIRM Digital Flood Insurance Rate Map DOTD Department of Transportation and Development DPS Drainage Pump Station EA Environmental Assessment ECD Erosion Control Device EHP Environmental and Historic Preservation EIS Environmental Impact Statement EPA Environmental Protection Agency ESA Endangered Species Act EO Executive Order FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map FIS Flood Insurance Study FONSI Finding of No Significant Impact FPPA Farmland Protection Policy Act FWCA Fish and Wildlife Coordination Act

CNO Pontilly Water Mitigation Draft Environmental Assessment iv

GHG Greenhouse Gases GOHSEP Governor's Office of Homeland Security and Emergency Preparedness HFCs Hydrofluorocarbons HMGP Hazard Mitigation Grant Program HMP Hazard Mitigation Plan HP FEMA Historic Preservation IHNC Inner Harbor Navigation Channel LAC Louisiana Administrative Code LDWF Louisiana Department of Wildlife and Fisheries HMGP PA Louisiana Hazard Mitigation Grant Program Programmatic Agreement LDEQ Louisiana Department of Environmental Quality LDNR Louisiana Department of Natural Resources LNHP Louisiana Natural Heritage Program LPDES Louisiana Pollutant Discharge Elimination System LSB Louisiana State Brownfield LSU Louisiana State University NAAQS National Ambient Air Quality Standards NAVD North American Vertical Datum NEPA National Environmental Policy Act NFI National Flood Insurance NFIP National Flood Insurance Program NHPA National Historic Preservation Act NMFS National Marine Fisheries Service N2O Nitrous Oxide NO2 Nitrogen Dioxide NOMTCB New Orleans Mosquito, Termite, and Rodent Control Board NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places NRCS Natural Resources Conservation Services NWP Nationwide Permit O3 Ozone OLD Orleans Levee District OPA Otherwise Protected Area OSHA Occupational Safety and Health Act PA Programmatic Agreement Pb Lead PFCs Perfluorocarbons RCRA Resource Conservation and Recovery Act

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RHA Rivers and Harbors Act ROW Right of Way SDWA Safer Drinking and Water Act SF6 Sulfur Hexafluoride SFHA Special Flood Hazard Area SHPO State Historic Preservation Office/Officer SO2 Sulfur Dioxide SOV Solicitation of Views SOW Scope of Work SPOC Single Point of Contact SRPE Steel Reinforced Polyethylene SWB Sewerage & Water Board SWMM Storm Water Management Model TDSRS Temporary Debris Staging and Reduction Sites THPO Tribal Historic Preservation Office/Officer TSCA Toxic Substances Control Act USACE United States Army Corps of Engineers USDA United States Department of Agriculture USFWS United States Fish and Wildlife Service USGS United States Geological Survey VOCs Volatile Organic Compounds WSRA Wild and Scenic Rivers Act

CNO Pontilly Water Mitigation Draft Environmental Assessment 1

1.0 INTRODUCTION

1.1 Project Authority

Hurricane Katrina made landfall on August 29, 2005 near Buras, Louisiana with sustained winds of more than 125 mph. The subsequent storm surge damaged levees and entered the City of New Orleans from various coastal waterways. President George W. Bush declared a major disaster for the state of Louisiana due to the damages and signed a disaster declaration authorizing the Department of Homeland Security’s Federal Emergency Management Agency (FEMA) to provide federal assistance to communities. FEMA is administering this disaster assistance pursuant to the Robert T. Stafford Disaster Relief Emergency Assistance Act (Stafford Act, PL 93-288). Section 404 of this act authorizes FEMA’s Hazard Mitigation Grant Program (HMGP) to provide funding for state and local governments to implement long-term hazard mitigation measures after major disaster declarations.

The City of New Orleans (CNO), through the State of Louisiana Governor’s Office of Homeland Security and Emergency Preparedness (GOHSEP), applied for funding under FEMA’s HMGP for a storm water mitigation project in the Pontilly neighborhood of New Orleans.

This Supplemental Environmental Assessment (SEA) has been prepared pursuant to the National Environmental Policy Act of 1969 (NEPA), the President’s Council on Environmental Quality (CEQ) regulations for implementing NEPA (40 CFR 1500-1508), Regulations for Implementing the Procedural Provisions of the National Environment Policy Act of 2005 and FEMA’s procedures for implementing NEPA (FEMA Instruction 108-1-1). The purpose of this SEA is to analyze potential environmental impacts that the proposed Pontilly Water Mitigation project would have on the environment. FEMA will use the findings in this SEA to determine whether to prepare an Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FONSI).

1.2 Background

As a result of Hurricane Katrina, the City of New Orleans suffered unprecedented damage from flood waters and high winds. The Pontilly neighborhood, located in north New Orleans, was included in this damaged area.


Figure 1: State of Louisiana, Orleans Parish Highlighted

The Pontilly project area encompasses approximately 856 acres, which includes both Pontchartrain Park and Gentilly Wood neighborhoods (Figure 2), and is bounded by Norfolk Southern Railroad to the west and north, the Inner Harbor Navigational Canal levee to the east, and Chef Menteur Highway (Highway 90) to the south. The project area is mostly single family residential with approximately 40 acres of commercial property along Chef Menteur Highway. The project area also contains the following schools: Southern University of New Orleans, New Orleans Baptist Seminary, Mary D. Coghill Elementary School, St. Benedict the Moor Catholic School, and Parkview Fundamental Magnet School; the following churches: Holy Cross Lutheran Church, St. Gabriel the Archangel Catholic Church, Bethany United Methodist Church, and Morning Star Missionary Baptist Church; and three parks: Joseph Bartholomew Golf Course, Harris Playground, and Morrison Play spot (CDM Smith, 2012).


Figure 2: Pontilly Project Area

Pontchartrain Park was one of the first neighborhoods in New Orleans to provide home ownership opportunities to middle and upper class African-Americans. It is a suburban-style neighborhood characterized by its curvilinear streets. The first phase of construction of homes in Pontchartrain Park was in 1957. Gentilly Woods was also established in the 1950s in a similar manner as Pontchartrain Park. At that time the homes were concentrated to the east of Pontchartrain Park.


The drainage infrastructure servicing the Pontilly project area is over 50 years old and was designed for much different conditions than currently exist. The level of development that has occurred in the study area has overstressed the storage and conveyance capacity of the existing stormwater infrastructure. The Pontilly neighborhood has received extensive flooding in the past and continues to flood during 2-, 5-, and 10-year 24-hour storm events. Table 1 shows the probability of these storm events occurring in four time periods.

Table 1. The probability of a 2-, 5-, and 10-year flood occurring in four different time periods

2-year flood event probability



1 year 50% 20% 10% 2 years 75% 36% 19% 5 years 97% 67% 41% 10 years 99.99% 89% 65%

Based on flood claim information through the National Flood Insurance Program (NFIP), there have been numerous rainfall events, which caused flooding of property (structures and vehicles), and forced temporary road closures in the project area. As a result of repetitive flooding, the CNO considered this area during its Hazard Mitigation Planning process. The Pontilly project is listed within the CNO Hazard Mitigation Plan as one of the strategies to “Reduce Risk and Vulnerability to the Built Environment including current and future structures; critical facilities; historical structures; and, infrastructure including communications” (City of New Orleans, 2015).

The Pontilly Water Mitigation Project is one of 91 projects identified in the City of New Orleans Hazard Mitigation Plan. As part of the effort to update the 2010 Hazard Mitigation Grant Program Mitigation Plan, an updated and expanded planning process was used to review and update the plan to ensure broad representation from the community. Stakeholders for this planning effort included non-profits, community organizations, environmental groups, and regional governmental agencies with an interest in and/or responsibility for hazard mitigation planning. In addition to a CNO City Hall Working Group and Advisory Committee, two additional groups were convened for the purpose of holding discussions specific to their responsibilities (i.e., Public Safety Group and Non-Profits and Community Organizations Group). The Hazard Mitigation Plan includes 91 mitigation actions that meet the goals established by the City, meet one or more of the FEMA mitigation action categories, and will reduce or eliminate risks to human life and property from one or more of the identified hazards. Once the final list of hazard mitigation actions was established, the City Hall Working Group and Advisory Committee used the Social, Technical, Administrative, Political, Legal, Economic, and Environmental (STAPLEE) methodology to evaluate and prioritize the mitigation actions for the 2015 Plan. This methodology was used to examine opportunities (benefits) and constraints (costs) of implementing each action from the perspective of all seven of the STAPLEE criteria. By using the STAPLEE methodology, the City was able to evaluate and prioritize mitigation actions to determine whether the actions addressed specific goals and objectives and appropriate for Orleans Parish. The Pontilly Water Mitigation Project received a ranking of High, similar to


other Green Infrastructure drainage projects within the same drainage basin and throughout New Orleans (City of New Orleans, 2015). The CNO had broad public involvement and used many vehicles to gain insight on the public’s thoughts and to consider recommendations made by the public. A summary of these meetings is provided in Section 6.0 Public Involvement. FEMA previously prepared an Environmental Assessment (EA), pursuant to Section 102 of the National Environmental Policy Act of 1969 (NEPA), as implemented by the regulations promulgated by the President’s Council on Environmental Quality (CEQ) (40 Code of Federal Regulations [CFR] Parts 1500-1508). To comply with NEPA, FEMA has determined the need to prepare a supplemental environmental assessment (SEA) to evaluate the potential impacts that could result from changes to original proposal. This Supplemental Environmental Assessment (SEA) supplements the February 2016 EA for the Proposed Pontilly Water Mitigation Project. The final 2016 EA addressed the potential direct and indirect effects of the proposed construction, installation, operation, and maintenance of the stormwater lots/parks, street basins, and urban bioswales and the widening of the Dwyer Canal. The HMGP proposal was redesigned prompting FEMA to reanalyze the environmental effects.

For some environmental resources, the potential effects are expected to be similar in extent and/or magnitude to those assessed in the original EA. The provision of financial assistance for the Proposed Project is conditional upon the completion of the NEPA process whereupon a final decision would then be made by FEMA.

2.0 PURPOSE AND NEED

FEMA provides grants to states and local governments to implement long-term hazard mitigation measures through the HMGP. The purpose of HMGP is to reduce the loss of human life and property due to natural disasters and to enable mitigation measures to be implemented during recovery from a disaster. The Pontilly Water Mitigation project has been selected to receive these grant funds. The purpose of this project is to reduce damages caused by flooding to property in the project vicinity during 2-, 5-, and 10-year storm events. The project is needed to protect structures, facilities, and residents in the Pontilly neighborhood from damages incurred by flooding resulting from 2-, 5- and 10-year storm events. The need for this project is demonstrated by the project area vicinity’s current susceptibility to flooding. There have been numerous rainfall events that caused flooding of property (structures and facilities), and forced temporary road closures in the Pontilly area. Based on NFIP flood claim information, the most noteworthy flood claims filed for past rainfall events occurring in the Pontilly area are listed below:

• May 1978: A line of stalled rainstorms had a peak intensity of 2 inches per hour with 1.36 inches and 1.69 inches falling in the two subsequent hours. This event resulted in more than $44K in flood insurance claims.

• April 1980: This rain event included two peak hours in excess of 1.5 inches, each preceded or followed by an additional 0.74 inches of rain, and a total of 8.5 inches over a period of 24 hours. This event resulted in more than $58K in flood insurance claims.


• April 1983: More than 7.5 inches of rain fell over a period of 21 hours, resulting in more than $240K in flood insurance claims.

• April 1988: A series of squall lines passed through the New Orleans area dropping nearly 9 inches of rain across the area, including three peak hours of at least 1.2 inches of rainfall per hour. This event resulted in more than $40K in flood insurance claims.

• May 1995: Between May 8th and May 11th, 1995, the New Orleans area was hit with nearly 15.5 inches of rainfall in closely spaced bands of rain. In one 4-hour period on May 8th, over 12 inches of rain fell on the city. This event resulted in more than $6.5M of flood insurance claims.

• May 2001: A rain event dropped over 5 inches of rain within a 9 hour period, with more than two-thirds of the rain falling in two back-to-back hours. This event resulted in more than $82K of flood insurance claims.

• September 2002: Tropical Storm Isidore produced heavy rainfall in a wide area before and shortly after landfall. 4 to 8 inches of rainfall occurred within 6 hours. The storm’s total rainfall measured from 10 to 15 inches across southeast Louisiana. This event resulted in more than $431K of flood insurance claims.

The degradation of the stormwater sewer infrastructure has reduced the system’s capacity to drain the project area during a 2-year storm event. Both localized street flooding and property damage have been recurring neighborhood problems for several decades. After Hurricanes Katrina and Rita in 2005, these more minor flooding events have received higher scrutiny.

3.0 ALTERNATIVES

A basic principle of NEPA is that the federal government must consider reasonable alternatives to a proposed action. Considering alternatives helps avoid unnecessary impacts and allows analysis of reasonable ways to achieve the stated purpose. To warrant detailed evaluation, an alternative must be reasonable. As determined by CEQ, “reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant” (CEQ 1981). The following sections identify alternatives considered by the applicant that are subject to detailed evaluation in this SEA. Two alternatives were developed to address the purpose and need stated in the preceding section. The three alternatives that are evaluated throughout this SEA are:

• Alternative 1– No Action Alternative

• Alternative 2 – Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative)

• Alternative 3 – Upgrade and Improve the Existing Stormwater Sewer System (Considered Alternative)

3.1 Alternative 1 - No Action Alternative


The No Action Alternative is included to identify the baseline conditions against which potential impacts of implementation alternatives are evaluated. The No Action Alternative represents the baseline condition of the environment if the proposed action is not implemented. Under the No Action Alternative, the proposed drainage improvements would not be constructed in the project area and the neighborhood would continue to experience flooding effects similar to those that have occurred during past events. This alternative will be evaluated throughout this SEA.

3.2 Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative)

The Preferred Alternative would incorporate the use of both green and gray infrastructure that function collectively to reduce the risk of localized flooding. The project would implement short-term runoff storage within green infrastructure improvements and improving existing underground stormwater sewage infrastructure to effectively move stormwater out of the project area.

The first component of this alternative includes the incorporation of empty lots and alleyways as detention areas to reduce peak runoff discharge by allowing stormwater to infiltrate into the ground rather than immediately going into the drainage system. The parcels proposed for this work are scattered vacant lots where private residences existed prior to Hurricane Katrina. As a result of Hurricane Katrina and subsequent State and Federal programs, these properties have been demolished and are now under the jurisdiction of the New Orleans Recovery Authority (NORA). These stormwater lots and stormwater parks (multiple contiguous lots) would also incorporate planting native vegetation (Figure 3).

Figure 3: Conceptual Rendering of Proposed Stormwater Lots


A second component of Alternative 2 would be the installation of street basins and pervious pavement. The street basins would be planted with native vegetation to catch runoff flowing along street curbs and gutters. Mid-block street basins would replace two on-street parking places and the corner street basins would replace one on-street parking place on each street. Approximately 2,320 linear feet of pervious pavement would be installed throughout parking lanes of Press Drive between Emmett W. Bashful Boulevard and Caddie Road. Additional pervious pavement would be installed along alleyways proposed to serve as water detention areas. These street basins and pervious pavement sections would provide additional capability for stormwater to infiltrate the ground.

A third component of this alternative would be the installation and utilization of urban bioswales (Figure 4). Bioswales are proposed along Stephen Girard Avenue, Mirabeau Avenue, and the southern perimeter of the Joseph Bartholomew Sr. Golf Course. These bioswales would incorporate planting of native vegetation and would help filter and retain stormwater before it makes its way to the drainage system in the project area (i.e., both the existing drainage system and proposed stormwater lots). These bioswales would also facilitate the infiltration of stormwater into the ground. For the proposed Stephen Girard Avenue bioswale, the existing 42-foot wide street would be reduced in size to an overall width of 37 feet. These “road diets” would allow the installation of additional corner and mid-block street basins. The Joseph Bartholomew Sr. Golf Course bioswale would be installed between the existing golf cart path and the street and would not impede play at the golf course or alter existing landscape features such as mature trees.

Figure 4: Conceptual Rendering of Typical Urban Bioswale

A fourth component of this alternative would consist of dredging and widening the existing Dwyer Canal (Figure 5) because it is located at a low point between the two neighborhoods and is


currently underutilized. The widening would occur within previously disturbed right-of-way and the banks of the canal would be stabilized to prevent erosion by planting vegetation.

Lastly, this alternative would include the installation of approximately 2,500 feet of new or improved stormwater drainage piping at various locations throughout the project area.

Figure 5: Conceptual Rendering of Proposed Improvements to Dwyer Canal

In Summary, the final design of this alternative would include the following elements:

• Dredging & regrading of the Dwyer Canal with increased volume • Installation of approximately 2,500 LF of new or improved stormwater drainage pipes • Improvements of 16 green alleyway to include bioswales and 3,600 LF of associated

pervious sidewalk sections • Installation approximately 4,750 CF of bioswale on the south side of the Pontchartrain

Golf Course • Installation of approximately 2,320 LF of permeable paver parking • Installation of street basins at 21 intersections and three (3) at midblock locations • Installation of 36 stormwater lots • Installation of three (3) stormwater parks • Installation of urban bioswale along 22 blocks on Mirabeau and Stephen Girard Avenues

Scope of work changes from FEMA’s original EA for this project include:

• Removal of proposed railroad bioswale • Proposed installation of 2,320 LF of permeable paver parking


• Proposed installation of 2,500 LF of new or improved stormwater drainage piping • Slight reconfiguration of proposed Golf Course bioswale. • The removal of proposed stormwater lots closest to the Inner Harbor Navigational Canal

The railroad bioswale was removed from the proposal due to issues obtaining required right of way to install the bioswale. The proposed permeable paver parking areas and stormwater drainage piping provide added benefits to the project. Additionally, the proposed golf course bioswale has been slightly altered in the final design to maximize benefit and impact to the area.

Figure 6: Depiction of Preferred Alternative, (National Geographic Society, Esri et al, 2013)


3.3 Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System

Alternative 3 would entail upgrading the neighborhood’s stormwater sewer infrastructure from its current capacity to a 10-year level of protection. To accomplish this, more than 60,000 linear feet of pipe network in the Pontilly project area would be removed and replaced. The applicant would excavate and remove existing stormwater sewer pipes; install new infrastructure and reconnect it to existing basins; then back fill and asphalt repair the area. Collector streets are assumed to receive 48-inch pipes, while minor streets would receive 36-inch pipes to achieve positive drainage for the 10-year storm event. Collector streets receiving the 48-inch pipes would be Press Drive, 9,000 LF; Louisa Drive, 3,200 LF; Congress Drive, 8,500 LF; Mirabeau Avenue, 3,600 LF; Prentiss Avenue. 1,000 LF; and Bashful Boulevard, 850 LF. All other streets in the Pontilly area would be minor streets. This alternative meets the purpose and need of the action and will be further evaluated throughout this SEA.

4.0 AFFECTED ENVIRONMENT AND POTENTIAL IMPACTS

This section describes the existing environmental and socioeconomic conditions potentially affected by the proposed action. This section also provides information to serve as a baseline against which to identify and evaluate environmental and socioeconomic changes potentially resulting from implementation of the proposed action or alternatives. This section describes any potential impacts that would occur with the No Action Alternative; the preferred action alternative – (Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements), and Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System. The Supplemental EA evaluates the potential individual and cumulative impacts of the proposed project. For purposes of comparison, this Supplemental EA also evaluates the impacts that could occur if FEMA did not provide funding (the No-Action Alternative) under which FEMA assumes the project would not proceed. This supplemental assessment will only focus on environmental issues specific to the proposed action and its alternatives.

4.1 Water Resources

4.1.1 Water Quality

Existing Conditions The Southern Hills Regional Aquifer System is under Lake Pontchartrain in the vicinity of the project area; however, the Pontilly project area is not located within an USEPA designated sole source aquifer watershed area per the USEPA groundwater office (EPA Region 6, Sole Source Aquifers).

According to the Hydrologic & Hydraulic Study (H&H) Technical Memorandum conducted on May 2012 (Appendix A), New Orleans aquifer system includes the shallow aquifers, the Mississippi River alluvial, Gramercy aquifer, Norco aquifer, Gonzales‐New Orleans aquifer, and the “1,200‐foot” sand aquifer. This system of aquifers supplies fresh water along the Mississippi


River corridor for industrial and public use. The shallow aquifers are found no more than 200 feet below sea level and are discontinuous and local. Aquifers near the Lake Pontchartrain shoreline do not contain fresh water. Approximately 300 feet below sea level at the Industrial Canal is the Norco Aquifer. This aquifer is approximately 50 feet thick and is separated from the Gonzales-New Orleans Aquifer by a 200 foot clay bed. The Gonzales-New Orleans Aquifer is found approximately 400 feet below sea level and is 250 feet deep. Its base is underlain by saltwater. It supplies fresh water to the greater New Orleans area, beginning at Lake Pontchartrain and extending southward toward the Industrial Canal.

Hydrologic & Hydraulic modeling was updated to reflect the final design of the proposal. The results are documented in a technical memorandum dated February 16, 2018 and discussed in the Environmental Consequences section below. The memorandum is included in Appendix A.

FEMA-EHP submitted Solicitations of Views (SOVs) to LDEQ and USEPA on November 2, 2015 for the original EA. Follow-up SOVs concerning the revised scope of work for the project and SEA were submitted to LDEQ and USEPA on August 18, 2017.

Regulatory Setting The U.S. Environmental Protection Agency (USEPA) regulates discharges to waters of the United States through permits issued under Section 402 of the CWA, entitled the National Pollutant Discharge Elimination System (NPDES), which authorizes and sets forth standards for state administered permitting programs regulating the discharge of pollutants into navigable waters within each state’s jurisdiction. On August 27, 1996, USEPA Region VI delegated the authority to administer the NPDES program for matters within the jurisdiction of the State of Louisiana. Having assumed NPDES responsibilities, Louisiana directly issues NPDES permits and has primary enforcement responsibility for facilities located within the State, with certain exceptions such as Indian Country Lands. Louisiana administers the NPDES Program and surface water discharge permitting system under the Louisiana Pollutant Discharge Elimination System (LPDES) program. The LPDES requires permits for the discharge of pollutants/wastewater from any point source into waters of the State. Per the CWA, the term “point source” is defined as “any discernible, confined, and discrete conveyance such as a pipe or a ditch.” Prior to assumption of the program, permittees were required to hold both a valid state and federal permit. Today, all point source discharges of pollutants to waters in the state of Louisiana are subject to a LPDES permit issued by the Louisiana Department of Environmental Quality (LDEQ). Additionally, the LDEQ requires a Stormwater Pollution Prevention Plan (SWPPP) for land disturbing activities greater than 1 acre. For land disturbing activities greater than 5 acres the LDEQ requires: 1) a SWPPP 2) a Notice of Intent and 3) a Notice of Completion. The City of New Orleans currently operates under the auspices of a NPDES Municipal Separate Storm Sewer Systems (MS4s) permit. The NPDES MS4 permit requires, permittees to develop and implement a comprehensive Storm Water Management Program (SWMP) that must include pollution prevention measures, treatment or removal techniques, monitoring, use of legal authority, and other appropriate measures to control the quality of storm water discharged to the storm drains and thence to waters of the United States (LAS000301). Under Section 303(d) of the CWA, states, territories and authorized tribes, are required to develop lists of impaired waters. These are waters for which technology-based regulations and other


required controls are not stringent enough to meet the water quality standards set by states. The law requires that states establish priority rankings for waters on the lists and develop Total Maximum Daily Loads (TMDLs) for these waters. A TMDL includes a calculation of the maximum amount of a pollutant that can be present in a waterbody and still meet water quality standards.

Environmental Consequences Alternative 1 – No Action Alternative The No Action Alternative would have no effects on water resources in the project area and Orleans Parish.

Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) The applicant submitted consultation letters to the USEPA and the LADEQ on July 17, 2013. FEMA submitted follow up consultations on August 18, 2017. The USEPA’s response, dated July 26, 2013, stated the project does not overlie a Sole Source Aquifer and is not subject to review under the Sole Source Aquifer program. USEPA responded to FEMA’s follow-up SOV dated August 21, 2017, stating that it had no further comments. The LDEQ responded to the applicant’s consultation on August 22, 2013 stating the agency did not have any objections to the project and offered conditions and comments which may be found in Appendix B. The LDEQ responded to FEMA’s consultation for the revised scope of work on October 12, 2017 stating the agency did not have any objections to the project (Appendix C). The LDEQ provided some conditions to ensure the protection of water quality, these may be found in section 5 of this SEA. The applicant must adhere to the conditions and procedures set forth in their NPDES MS4 permit. There could be short-term adverse impacts to surface water and water quality from the implementation of Alternative 2 due to soil disturbance and surface runoff during construction. A LPDES permit would be required for the proposed construction activities at the project location. The applicant would be required to adhere to the conditions set forth in the LADEQ response letter and section 5 of this SEA. No significant adverse impacts to surface waters or water quality are anticipated under Alternative 2. Long-term, beneficial impacts to water quality of surface water and groundwater are expected as a result of this alternative. By holding water onsite and reducing the speed of stormwater entering the stormwater sewer system, sediment loads into surface water would be reduced and groundwater infiltration would increase.

Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System A solicitation of views was sent to USEPA and LADEQ on August 18, 2017. The conditions set forth in the response letters and section 5 of this SEA would be applied to this alternative. There could be short-term adverse impacts to surface water and water quality from the implementation of Alternative 3 due to soil disturbance and surface runoff during construction. A LPDES permit would be required for the proposed construction activities at the project location.


The applicant would be required to adhere to the conditions set forth in the LADEQ response letter and section 5 of this SEA. No significant adverse impacts to surface waters or water quality are anticipated under the Alternative 3, however; this alternative does not have the potential benefits associated with the preferred alternative.

4.1.2 Floodplains

Existing Conditions In July 2005, prior to Hurricane Katrina, FEMA initiated a series of flood insurance studies for many of Louisiana’s coastal parishes as part of the Flood Map Modernization Effort through FEMA’s National Flood Insurance Fund. These studies were necessary because the flood hazard and risk information shown on the effective Flood Insurance Rate Maps (FIRMs) was developed during the 1970s. Since that time, the physical terrain had changed considerably, including the significant loss of wetland areas. After Hurricanes Katrina and Rita, FEMA expanded the scope of work to include all of coastal Louisiana. The magnitude of impacts caused by the two hurricanes reinforced the urgency to obtain additional flood recovery data for the coastal zones of Louisiana. More detailed analysis was possible because new data obtained after the hurricanes included information on levees and levee systems, new high-water marks, and new hurricane parameters. During an initial post-hurricane analysis, FEMA determined that the 100-year or 1 percent annual chance storm flood elevations on FIRMs for many Louisiana communities, referred to as Base Flood Elevations (BFEs), were too low. FEMA created recovery maps showing the extent and magnitude of the surges from Hurricanes Katrina and Rita, as well as information on other storms over the past 25 years. The 2006 advisory flood data shown on the recovery maps for the Louisiana-declared disaster areas indicated high-water marks surveyed after the storm, flood limits developed from these surveyed points, and Advisory Base Flood Elevations, or ABFEs. These recovery maps and other advisory data were developed to assist parish officials, homeowners, business owners, and other affected citizens with their recovery and rebuilding efforts. Updated preliminary flood hazard maps from an intensive 5-year mapping project guided by FEMA subsequently were provided to all Louisiana coastal parishes. These maps, released in early 2008, known as Preliminary Digital Flood Insurance Rate Maps (DFIRMs), were based on the most technically advanced flood insurance studies ever performed for Louisiana, followed by multiple levels of review. The DFIRMs provided communities with a more scientific approach to economic development, hazard mitigation planning, emergency response, and post-flood recovery. The USACE has completed work on a Hurricane and Storm Damage Risk Reduction System (HSDRRS) for the Greater New Orleans area (Miller 2011). This 350-mile system of levees, floodwalls, surge barriers, and pump stations will reduce the flood risk associated with a storm event. In September of 2011, the USACE provided FEMA with assurances that the HSDRRS is capable of defending against a storm surge with a 1 percent annual chance event of occurring in any given year (Miller 2011). The areas protected include portions of St. Bernard, St. Charles, Jefferson, Orleans, and Plaquemines Parishes. FEMA has revised the preliminary DFIRMS within the HSDRRS to incorporate the reduced flood risk associated with the system improvements. In November 2012, FEMA revised the 2008 preliminary DFIRMS within the HSDRRS to incorporate the reduced flood risk associated with the system improvements. The preliminary DFIRMs were subsequently revised in 2013 and 2014. On September 30, 2016, the 2014 Revised


Preliminary DFIRMs for Orleans Parish became effective. The 2016 Effective DFIRMs are the best available flood risk data for Orleans Parish. The Parish of Orleans enrolled in the National Flood Insurance Program (NFIP) on October 19, 1971. The project area is partially located within Special Flood Hazard Area Zone "AE", Elevation -5, and 0.2 percent annual chance of flood as per Digital Flood Insurance Rate Map Panel Number 22071C0118F, dated September 30, 2016. The project area is also partially located outside a Special Flood Hazard Area, with an elevation of -2.7, and 0.2 percent annual chance of flood as per Digital Flood Insurance Rate Map Panel Number 22071C0118F, dated September 30, 2016. The project area with its flood zones is depicted in Figure 7.

Figure 7: DFIRM of Pontilly project area (FEMA 2016).

Regulatory Setting Executive Order 11988, Floodplain Management, requires federal agencies to avoid direct or indirect support or development within or affecting the 1 percent annual chance special flood hazard area (i.e., 100-year floodplain) whenever there is a practicable alternative (for “Critical Actions”, within the 0.2 percent annual chance special flood hazard area, i.e., the 500-year floodplain). FEMA uses the National Flood Insurance Program FIRM to determine the flood hazard zone for proposed project locations. FEMA’s regulations for complying with EO 11988 are codified in 44 CFR 9, Floodplain Management and Protection of Wetlands.

This EA forms part of the “Eight-Step Planning Process” (44 CFR 9.6) that decision-makers must


use when considering projects either located within the floodplain or with the potential to affect the floodplain. The Eight-Step Planning Process: assesses the action regarding human susceptibility to flood harm and impacts to wetlands; analyzes principle flood problems, risks from flooding, history of flood loss, and existing flood protection measures; and includes public notice and opportunity for the public to have early and meaningful participation in decision-making and alternative selection. If impacts cannot be avoided, the Eight-Step Planning Process includes requirements to incorporate measures to minimize and mitigate potential risks from flooding and impacts to wetlands as appropriate.

Under 44 CFR 9, FEMA is required to avoid activities in a floodplain unless it is the only practicable alternative. If undertaking a proposed project in the floodplain is the only practicable alternative, then FEMA must minimize the impacts to the floodplain and the impacts from floods to the facility or structure being proposed. Minimization techniques apply to the location of structures, equipment, and building contents in floodplain areas. This could include elevating facilities or structures above the base flood elevation. Minimization techniques may include flood-proofing structures or facilities.

Environmental Consequences Alternative 1 – No Action Alternative With no action, flood damage would likely continue to occur and both insured and uninsured losses would be experienced at its current frequency. With no improvements, the area would continue to flood every time there is a storm greater than a 2-year flood storm.

Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) As required by Section 9.6 of EO 11988, the Eight-Step Planning Process was conducted. The findings of the process indicate that no adverse impacts to or within the floodplain are anticipated. The Preferred Alternative would construct gray and green infrastructure to provide flood mitigation and increased storm water storage capacity at the project site. This alternative would have no discernible benefit or cost during a 1% (100-year) rainstorm flooding event in the Pontilly Basin. The benefits and costs associated with this project are for more frequent, lower discharge events (1-year, 2-year, 5-year, and 10-year). Implementation of the Preferred Alternative would result in beneficial impacts to the number of structures and facilities damaged and the value of the property damaged during these more frequent, lower discharge events (Table 2).

This basin does not have any inflows coming in from the outside, so there are no “upstream” impacts to consider. The project is to decrease the flows, but especially, to decrease the water levels in the Pontilly basin, through a series of on-site collection mitigation actions. Per final upstream/downstream analysis provided by the applicant, dated 2/16/18, the project will reduce water surface elevations and areas flooded during the more frequent rainfall events. Downstream impacts will be minimal/negligible, as outfall channels carry significantly higher flow rates, but with later peaking times. Based on the analyses, some backflow from the Florida Ave. Canal in one outfall pipe, occurring after the peak Pontilly Basin outflows, will result in improved drainage outside the Pontilly Basin, because the proposed drainage improvements within the


Pontilly Basin, as described herein, will absorb the “negative” flow from downstream with no associated adverse effects within the Pontilly Basin. The proposed railroad bioswale was removed from the proposal due to issues obtaining required right of way to install the bioswale. An August 18, 2017 Technical Memorandum from CDM Smith containing project model revisions (appendix A) stated that field engineering analysis concludes that localized flooding will continue to occur as a result of the removal of this component. Because the Preferred Alternative would entail the construction of multiple green infrastructure facilities within 300 feet of levees associated with the Inner Harbor Navigational Canal, consultation with the Orleans Levee District (OLD) was required to ensure there would be no adverse impacts to the levee. CNO submitted a permit application to the OLD in accordance with conditions set forth in the original EA as a result of consultation with the USACE (see appendix B). The OLD reviewed the work in consultation with CPRA and USACE and issued a permit, dated December 21, 2017, based on a revised design to remove the proposed stormwater lots closest to the levee and reduce grading along the levee edge of the East Stormwater Park. A copy of the permit and agency consultation may be found in appendix B. Although the Preferred Alternative could facilitate an increase in population and housing within the project area by reducing flood impacts to the Pontilly neighborhood, the project area is an already densely populated urban area with little room for further development. In addition, empty lots are being repurposed for stormwater storage; therefore, restoring some of the natural function of the floodplain. Per 44 C.F.R. § 9.11(d)(6), no project should be built to a floodplain management standard that is less protective than what the community has adopted in local ordinances through their participation in the NFIP. The project is in compliance with Chapter 78 of the City of New Orleans Code of Ordinances, The Flood Damage Prevention Ordinance, according to a letter from the CNO Floodplain Administrator dated May 1, 2017. (Appendix C).

Table 2. Preferred Alternative Impact to Floodplain

Statistical Storm

Existing- # Flooded Structures

Existing- Estimated Damage

Proposed- # Flooded Structures

Proposed-Estimated Damage

Proposed Impact-

# Flooded Structures

Proposed Impact-

Estimated Damage

1-year 456 $4,116,000 315 $2,554,000 (141) ($1,562,000)

2-year 869 $9,417,000 685 $6,637,000 (184) ($2,780,000) 5-year 1077 $15,511,000 1002 $11,747,000 (75) ($3,764,000) 10-year 1091 $20,308,000 1079 $16,796,000 (12) ($3,512,000)

Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System Alternative 3 would reduce flooding within the project area by increasing the effectiveness of the existing drainage system. All work would be underground; therefore, would not affect the floodplain.

The applicant would be required to coordinate with the local floodplain administrator regarding floodplain permit(s) prior to the start of any activities. All correspondence must be submitted to FEMA and FEMA-EHP for inclusion in the project files. Should the site plans (including drainage


design) change, the applicant must submit changes to FEMA-EHP for review and approval prior to the start of construction.

4.2 Biological Resources

4.2.1 Threatened and Endangered Species and Critical Habitat

Existing Conditions The project area is completely developed with trees, grasses, and shrubs commonly found and maintained in urban areas. The vegetation species and animal species present in the area typically can adapt to an urban/developed environment. These species include raccoon (Procyon lotor), eastern gray squirrel (Sciurus carolinensis), rabbits (Sylvilagus), rodents (Mus and Rattus), and various species of snakes, turtles, and amphibians. There is one protected species known to occur within the project area, the bald eagle (Haliaeetus leucocephalus). An active bald eagle nest is present in a bald cypress tree near the green of the 11th hole of the Joseph Bartholomew Golf Course. The bald eagle is protected by the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act and is protected by the State of Louisiana. No other state or federal parks, wildlife refuges, scenic streams, or wildlife management areas are located within the bounds of the project area. According to the USFWS website and an official species list provided by the USFWS Louisiana Ecological Services Field Office (USFWS, 2017), there are multiple species listed on the Federal Endangered Species List that occur or potentially occur in Orleans Parish. Most of these species are aquatic, thus are not expected to be present. Two birds, the piping plover and Red Knot are also known to occur or potentially occur within Orleans Parish.

Regulatory Setting The Endangered Species Act (ESA) of 1973 (16 USC 1531-1543) prohibits the taking of listed, threatened, and endangered species unless specifically authorized by permit from the USFWS or the NMFS. “Take” is defined in 16 USC 1532 (19) as "to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct.” “Harm” is further defined to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns such as breeding, feeding, or sheltering (50 CFR 17.3). Section 7(a)(2) of the ESA requires the lead federal agency to consult with either the USFWS or the NMFS, depending which agency has jurisdiction over the federally listed species in question, when a federally funded project either may have the potential to adversely affect a federally listed species, or a federal action occurs within or may have the potential to impact designated critical habitat.

Migratory Bird Treaty Act Unless otherwise permitted by regulation, the Migratory Bird Treaty Act (MBTA) of 1918 (16 USC 703-712) prohibits pursuing; hunting; taking; capturing; killing; attempting to take, capture, or kill; possessing; offering for sale; selling; offering to purchase; purchasing; delivering for shipment; shipping; causing to be shipped; delivering for transportation; transporting; causing to be transported; carrying or causing to be carried by any means whatever; receiving for shipment, transportation, or carriage; or exporting; at any time or in any manner, any migratory bird or any


part, nest, or egg of any such bird, that is included on the list of protected bird species. The USFWS is responsible for enforcing the provisions of the MBTA (FEMA 2015).

Bald and Golden Eagle Protection Act The Bald and Golden Eagle Protection Act (16 USC 668-668c), enacted in 1940, prohibits anyone, without a permit issued by the Secretary of the Interior, from taking bald eagles, including their parts, nests, or eggs with the term “take” meaning to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest, or disturb.

State of Louisiana The bald eagle state status is listed as endangered. The taking or harassment of this species is a violation of state laws. State status are contained in Title 56 of the Louisiana Revised Statutes as well as relevant rules and regulations adopted by the Louisiana Wildlife and Fisheries Commission and the Secretary of the Department of Wildlife and Fisheries. The Secretary of the Department of Wildlife and Fisheries is authorized to implement additional restrictions in emergency situations in order to protect fish and wildlife resources.

Vector Control The Louisiana Department of Agriculture and Forestry (LDAF) requires records be kept on pesticide applications including the site of application, specific chemical information and rate applied. LDAF provides "Pesticide Applicator Record Keeping forms" for use by certified applicators. Applications must be made in adherence to Louisiana Pesticide La (L.R.S. 3:3201-3310), state pesticide regulations (LAC7:XXIII) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and also under the rules set forth in the Louisiana Pollutant Discharge Elimination System General Permit (LAG870000) These records must be kept on file and available for inspection.

Environmental Consequences Alternative 1 – No Action Alternative Because the proposed projects would not be implemented, the No Action Alternative would result in no significant impacts to urban vegetation or animal species.

Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) FEMA has determined the proposed project would not affect any federally listed species or modify designated critical habitat in accordance with USFWS stamped letter dated August 24, 2017. The eagles nesting on the Bartholomew Golf Course may be impacted from construction activities planned along Press Drive. In a letter dated September 14, 2017, LDWF stated that all bald eagle nests (active, inactive or seemingly abandoned) should be protected, and no large trees should be removed. No major activities should occur within the nesting period (September 1-June 1). Please refer to the USFWS Bald Eagle Management Guidelines for more information on avoiding impacts to this species including suggested buffer distances http://www.fws.gov/southeast/es/baldeagle/ (Appendix C). These management guidelines may be found in appendix D. In addition, The Bald Eagle Final Determination Form from the

http://www.fws.gov/southeast/es/baldeagle/


USFWS online assessment tool stated that to avoid disturbing nesting eagles and their young, we recommend that you: Maintain a buffer of at least 660 feet (201 meters) between your activities and the nest (including active and alternate nests), or as close as existing tolerated activity of similar scope, i.e. maintain a buffer at least as far from the nest as the existing tolerated activity, and within 660 feet (201 meters) of the nest (including active and alternate nests), restrict any clearing, external construction or landscaping activities to outside the nesting season (outside the nesting season is from mid to late May through early to late September. Nesting season in the Southeast is generally Oct 1- May 15), and; maintain established landscape buffers that screen the activity from the nest (Appendix C). A follow up consultation with the USFWS, the Migratory Bird Division, was conducted and in a response dated December 14, 2017 USFWS stated that activities could occur during the nesting season using the monitoring guidelines https://www.fws.gov/southeast/pdf/bald-eagle-monitoring-guidelines-2007.pdf (Appendix C). These monitoring guidelines may be found in appendix E. In a follow up consultation dated February 6, 2018 the LDWF concurred with the December 14, 2017 response from the USFWS Migratory Bird Division. If these management practices, guidelines or construction timeframes are unable to be followed, an Eagle Take Permit would be required from the USFWS and further consultation with the LDWF Natural Heritage Program would be required prior to the start of any work. As a matter of public health and safety, an integrated mosquito management approach is used by the New Orleans Mosquito, Termite, and Rodent Control Board (NOMTCB). This involves vector population surveillance, public education, larval mosquito habitat reduction, and chemical control of larval and adult mosquitoes. Larval source reduction (i.e., the physical elimination of larval breeding sites) involves inspection and removal of man-made containers, clutter, and trash. For sites that cannot be removed or drained, biorational larvicides (those that are relatively non-toxic to people with few environmental side effects) are used to target early mosquito stages. Adult mosquitoes can be treated on a yard, block, or residential level using a variety of equipment. This project proposes several water management facilities such as rain gardens and pervious sidewalks, etc. Due to the potential for an increase in vector populations, the CNO is required to ensure that vectors are monitored, managed, and mitigated in accordance with all local, state, and federal laws which also includes public safety and health. Green infrastructure projects such as the proposed action are included in routine survey, surveillance, and mosquito control sites. Records are kept on file and available for inspection at the NOMTCB Administration building.

Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System FEMA has determined the proposed project would not affect listed species or modify designated critical habitat in accordance with USFWS stamped letter dated August 24, 2017. A response letter from LDWF letter dated September 14, 2017 stated that the proposed project may affect a bald eagle nesting site. The management practice and requisite permitting requirements would be the same as those stated under Alternative 2. Vector control under Alternative 3 would be conducted as described for Alternative 2.

4.3 Cultural Resources

4.3.1 Historic Properties

Existing Conditions

https://www.fws.gov/southeast/pdf/bald-eagle-monitoring-guidelines-2007.pdf


The Area of Potential Effect (APE) for historic properties encompasses approximately 733 acres, including both the Pontchartrain Park and Gentilly Woods neighborhoods. The boundaries are defined by Norfolk Southern Railroad to the north, the Inner Harbor Navigational Canal levee to the east, Stephen Girard Avenue to the south, and the Norfolk Southern Railroad and Seminary Place to the west. This APE encompasses the area that would benefit from the proposed drainage interventions and also accounts for the viewshed considerations for standing structures and areas of ground disturbance for potential archaeological deposits. The Louisiana Office of Cultural Development’s Cultural Resources Map, historic maps and aerial imagery, and FEMA’s previous standing structure surveys and Section 106 consultation documents were consulted in order to identify historic properties. According to the Louisiana Cultural Resources Map, no archaeological sites are recorded within the APE and only two sites are recorded within 0.5 miles of the APE. The majority of the proposed APE is within the low probability zone for archaeological deposits. The Morrison Playspot green space, within the high probability area of the APE, has been previously surveyed for cultural resources with negative results. The soils within the APE consist of mucks and clays, which are poorly drained soils located in marshes and backswamps. Historic maps and aerial imagery show the APE as swampy and undeveloped until extensive construction started in the mid-twentieth century. The APE exhibits a low potential for intact archaeological deposits based on the late date of development, the extensive construction disturbance, previous investigations with negative results, and the lack of archaeological resources recorded within or adjacent to the APE. A comprehensive standing structure survey of the APE was not conducted for this Undertaking. FEMA and SHPO surveyed the APE in the fall of 2005, as part of an effort to identify historic properties following Hurricane Katrina. FEMA determined a portion of the Pontchartrain Park neighborhood is eligible for the National Register of Historic Places (NRHP) under Criterion A for its significance related to African-American community development within the City of New Orleans from 1955 through 1957. SHPO concurred with this finding in a letter dated December 8, 2005. FEMA has re-evaluated the Pontchartrain Park historic district several times since 2005 in order to facilitate the review under Section 106 of the NHPA for Undertakings within the area. The district is defined by the park and golf courses, curvilinear streets, and post WWII housing. The green spaces within the district and the lots left vacant following Hurricane Katrina leave ample space for the implementation of the proposed action. The Southern University (SUNO) campus is also located within the APE. One building on the SUNO campus, the Administration building, has been determined by FEMA to be eligible for listing in the NRHP. No other historic districts were identified within the APE at the time of the survey.

Regulatory Setting The consideration of impacts to historic and cultural resources is mandated under Section 101(b) 4 of the National Environmental Policy Act (NEPA) as implemented by 40 CFR Part 1501-1508. Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to take into account their effects on historic properties (i.e. historic and cultural resources, including American Indian Cultural Sites) and allow the Advisory Council on Historic Preservation an opportunity to comment. Additionally, it is policy of the Federal government to consult with Indian Tribal Governments on a Government-to-Government basis as required in Executive order 13175. FEMA addresses potential impacts to historic properties through the “Section 106 consultation process” of NHPA as implemented through 36 CFR Part 800.


In order to fulfill its Section 106 responsibilities, FEMA initiated consultation on this project in accordance with the FEMA is initiating Section 106 review for the above referenced properties in accordance with the Louisiana State-Specific Programmatic Agreement among FEMA, the Louisiana Governor’s Office of Homeland Security and Emergency Preparedness (GOHSEP), the Louisiana State Historic Preservation Officer of the Department of Culture Recreation and Tourism (SHPO), the Alabama-Coushatta Tribe of Texas (ACTT), the Chitimacha Tribe of Louisiana (CTL), the Choctaw Nation of Oklahoma (CNO), the Jena Band of Choctaw Indians (JBCI), the Mississippi Band of Choctaw Indians (MBCI), the Seminole Tribe of Florida (STF), and the Advisory Council on Historic Preservation (ACHP) regarding FEMA’s Hazard Mitigation Grant Program (LA HMGP PA) dated January 31st, 2011. The LA HMGP PA was created to streamline the Section 106 review process. Since the initiation of consultation, FEMA has negotiated a new statewide programmatic agreement among the SHPO, ACHP and Participating Tribes to streamline the Section 106 review, dated December 21, 2016 (LA 2016 Statewide PA). The 2016 Statewide PA supersedes the LA HMGP PA. The “Section 106 process” outlined in both the LA HMGP the LA 2016 Statewide PA requires the identification of historic properties that may be affected by the proposed action or alternatives within the project’s APE. Historic properties, defined in Section 101(a)(1)(A) of NHPA, include districts, sites (archaeological and religious/cultural), buildings, structures, and objects that are listed in or determined eligible for listing in the National Register of Historic Places (NRHP). Historic properties are identified by qualified agency representatives in consultation with interested parties. Below is a consideration of various alternatives and their effects on historic properties.

Environmental Consequences Alternative 1 – No Action Alternative Under the no action alternative, no construction would occur and no cultural resources or historic properties would be affected.

Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) The interventions proposed are designed to be low impact and they are proposed for areas of existing green spaces and asphalt. The character of the existing landscape would remain much the same and the drainage would have a positive effect on the function of the neighborhood. Additionally, most of the interventions will occur outside the boundaries of the Pontchartrain Park Historic District. FEMA has determined they would not alter the characteristics of the Pontchartrain Park Historic District nor the SUNO Administration building that qualify them for listing in the NRHP. The introduction of additional vegetation and trees would not adversely affect the integrity of location, setting, materials, workmanship, design, feeling, or association. A consultation with SHPO and interested Tribes was conducted in accordance with the LA 2016 Statewide PA. SHPO concurred with the determination of no adverse effect to historic properties in a letter dated October 5, 2017. The Muscogee Creek Nation and the Choctaw Nation of Oklahoma also concurred with the determination of no adverse effect to historic properties in emails dated October 2, 2017 and October 23, 2017, respectively (Appendix C). No other Tribal responses were received. In accordance with the LA 2016 Statewide PA and the conditions set


forth by the Muscogee Creek Nation and Choctaw Nation of Oklahoma, compliance with requirements regarding unanticipated archaeological discoveries and with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) will be a condition of the grant (see section 5 of this EA for conditions and mitigation measures).

Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System A review of this alternative was conducted in accordance with the LA 2016 Statewide PA. As with Alternative 2, FEMA has determined that the Pontchartrain Park National Register eligible Historic District and SUNO Administration building is located within the project area. Upon consultation of data provided by the SHPO, FEMA has determined there are no known archaeological sites within the project area. All work will occur within the existing footprint of roadways and utility rights-of-way; excavating and removing existing pipes and replacing with larger pipes (either 36 inch or 48 inch pipes). The work meets the criteria in Appendix B: Programmatic Allowances, Tier II, Section D (1)(a) of the LA 2016 Statewide PA. Therefore, this alternative would have no or minimal effect on cultural resources or historic properties and would not require review by SHPO or Tribes.

4.4 Socioeconomic Resources

4.4.1 Environmental Justice

Existing Conditions The project area is located within census tracts 22071001701 and 22071001702. These census tracts were used as the project area for the Environmental Justice analysis. This area encompasses 1.74 square miles and has a population of 5,172 (EPA 2017) It includes the zip code 70126. Demographic Information about the project area was compiled using the EPA’s Environmental Justice Screening and Mapping Tool, EJSCREEN, Version 2017 which pulls data from the U.S. Census Bureau, American Community Survey (ACS) 2011-2015. The project area includes a higher percentage of minority population than the parish, an equal percentage of low income populations (Table 4), and is considered a low income and minority area according to the U.S. Census website.

Table 3. Demographic and Economic Percentages of Orleans Parish and Project Area

Project Area Tracts 22071001701, 22071001702

Orleans Parish Louisiana

The United States

% Minority 87% 69% 41% 38%

% low income

47% 47% 40% 34%

% Minority includes the Hispanic population and all Non-Hispanic population categories except White Alone. (U.S. Census Bureau, 2011-2015)

Regulatory Setting EO 12898 Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations requires a federal agency to “make achieving environmental justice part of its


mission by identifying and addressing, as appropriate, disproportionally high human health or environmental effects of its programs, policies, and activities on minority populations and low income populations.”

Environmental Justice is defined as “the fair treatment and meaningful involvement of all people- regardless of race, color, national origin, culture, education, or income—in the development, implementation, and enforcement of environmental laws, regulations and policies.” (FEMA, 2012). Within this definition, FEMA further defines fair treatment as “no racial, ethnic, or socioeconomic group should bear a share of negative consequences resulting from industrial, municipal, and commercial operations, or the execution of federal, state, local and tribal environmental programs and policies”.

According to the CEQ (Council on Environmental Quality, 1997) a minority individual is a member of the following population groups: American Indian or Alaskan Native, Asian or Pacific Islander, Black, not of Hispanic origin, or Hispanic. A minority population is identified where either a) the minority population of the affected area exceeds 50 percent or b) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population. Race and ethnicity are two separate categories of minority populations. A minority population can be defined by race, by ethnicity, or by a combination of the two distinct classifications.

Environmental Consequences In compliance with EO 12898, the following key questions were addressed about potential Environmental Justice concerns:

• Is there an impact caused by the proposed action? Yes

• Is the impact adverse? No

• Is the impact disproportionate? No

• Has an action been undertaken without considerable input by the affected low-income and/or minority community? No

Alternative 1 – No Action Alternative Because the proposed projects would not be implemented, the No Action Alternative would not cause disproportionally high human health or environmental effects on minority populations and/or low income populations. Flooding of streets could prevent community members from leaving their homes and going to work or school causing loss of income and absences from school. With each flooding event, community resources must be spent to repair and restore damaged properties and vehicles.

Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) Stormwater Management is a problem throughout the City of New Orleans. As part of the effort to update the 2010 Hazard Mitigation Grant Program Mitigation Plan, an updated and expanded planning process was used to review and select sites for FEMA HMGP funded drainage projects as well as other projects. Sites, including the Pontilly Water Mitigation project, were selected based


on many factors including flood risk, available land, drainage rates. This planning process included various stakeholders from across the City of New Orleans and is described in the in the background and public involvement sections of this SEA.

Implementing Alternative 2, the Preferred Alternative, would have long-term beneficial effects for the residents surrounding the project area regardless of their racial makeup or economic situation. The Pontilly neighborhood has been susceptible to flooding events in the past. Drainage improvements would reduce flooding, reducing damage to property and enabling normal traffic flow during rain events. Public Notice to the affected communities has been and would continue to be provided. The CNO maintains a resilience website, https://nola.gov/resilience/ where it updates project information. There could be short-term, minor adverse impacts on populations living in the project area during construction of the project. Impacts might include increased noise levels and traffic disruptions associated with construction activities. Noise and traffic disruptions would be temporary and consistent with construction activities typically found in urban areas. The implementation of Alternative 2 would not have disproportionately high adverse impacts on minority or low-income groups as the mitigation measures would be beneficial to the entire Pontilly neighborhood.

Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System Alternative 3 would not have disproportionately high adverse impacts on minority or low-income groups in the project area.

4.5 Traffic

Existing Conditions The Pontilly project area includes both Pontchartrain Park and Gentilly Wood neighborhoods , and is bounded by Norfolk Southern Railroad to the west and north, the Inner Harbor Navigational Canal levee to the east, and Chef Menteur Highway (Highway 90) to the south Streets crossing west to east within the project area include Mithra Street, Dreux Avenue, and Mirabeau Avenue. Louisa Street crosses south to north from Chef Menteur Highway to Dreux Avenue. Additional residential streets comprise a grid within the project area. All of the streets in the project area with the exception of Chef Menteur Hwy. are maintained by the CNO. Chef Menteur Hwy is a state highway maintained by the Louisiana Department of Transportation (LADOTD). According to the LADOTD the average daily traffic (ADT) on Press Drive between Mirtha and Mendez Street was 7,120. The Regional Planning Commission for the New Orleans Metropolitan Region also keeps traffic counts on Frantz Road at the corner of Hayne Blvd (508 in 2007) and near Highway 90 (1696 in 2007). According to Regional Planning commission’s website, traffic counts along Chef Menteur Hwy. were 19,154 in 2007 (Regional Planning Commission, 2010).

Regulatory Setting The City of New Orleans Department of Public Works maintains approximately 1,547 miles of streets and 149 bridges in the City of New Orleans including all the streets in the project area with the exception of Chef Menteur Highway, which his maintained by the LADOTD. According to the Department of Public Work’s website; “The Department of Public Works’ mission is to


construct and maintain the highest quality of safe and sustainable transportation facilities for users of vehicular, bicycle, pedestrian and rail transportation, in order to improve the quality of life and create opportunities for economic development for all New Orleanians” (City of New Orleans, 2017). The Louisiana Department of Transportation and Development (LADOTD) is responsible for developing and maintaining public transportation, state highways, interstate highways under state jurisdiction, airports and heliports, railways, waterways, and bridges located within the state of Louisiana.

Environmental Consequences Alternative 1 – No Action Alternative Because the proposed projects would not be implemented, the No Action Alternative would have no impact on traffic or roadways at any location near the site. The adverse impacts to traffic from ponding water on roads and flooding would remain.

Alternative 2 - Installation of Stormwater Lots/Parks, Street Basins/Pervious Parking, and Urban Bioswales; Widening of Dwyer Canal; and Minor Drainage Pipe Improvements (Preferred Alternative) There would be temporary disruptions in traffic flow during this project. None of the impacts to traffic would be long-term or significant. Implementation of the Alternative 2, the Preferred Alternative, would require heavy trucks and machinery for moving large volumes of soil and bringing in materials such as hay bales, silt fencing, geotextiles, stakes, plants, and hardware. A temporary increase in construction traffic may affect traffic circulation patterns and motorists’ perception of traffic movement. Installation of drainage pipes would require temporary street closures and repaving. The contractor would be responsible for handling all traffic control and warning in accordance with the Manual of Uniform Traffic Control Devices, including placing signs and signals in advance of construction activities in order to alert pedestrians and motorists of the upcoming work and traffic pattern changes (e.g., detours or lanes dedicated for construction equipment egress). There may be times when certain streets would be closed to all but local traffic and rerouting of through traffic to alternate roads might become necessary. The contractor would be expected to provide a traffic control schedule prior to starting construction. Additionally, coordination with the LADOTD would be required for any work that requires the use of state highway rights-of-way. Once construction is completed less standing water and flooding would be present on the roads in and around the project area resulting in long-term beneficial impacts to roads and traffic.

Alternative 3 - Upgrade and Improve the Existing Stormwater Sewer System Alternative 3 would result in similar traffic impacts as Alternative 2. These effects are likely to be lower in intensity and shorter in duration, due to the lesser scope of work involved in implementing the project. Phasing and timing of various construction components may affect the timing of potential impacts differently than Alternative 2. Once construction is completed less standing water and flooding would be present on the roads in and around the project area resulting in long-term beneficial impacts to roads and traffic.


5.0 CONDITIONS AND MITIGATION MEASURES

The following conditions must be met as part of the implementation of the project. Failure to comply with these conditions may jeopardize federal funds.

The applicant is required to comply with all federal, state, and local laws, EOs, and regulations. Failure to do so will jeopardize federal funding.

• Please take any necessary steps to obtain and/or update all necessary approvals and environmental permits regarding this proposed project.

• If your project results in a discharge to waters of the state, submittal of a Louisiana Pollutant Discharge Elimination System (LPDES) application may be necessary.

• If the project results in a discharge of wastewater to an existing wastewater treatment system, that wastewater treatment system may need to modify its LPDES permit before accepting the additional wastewater.

• All precautions should be observed to control nonpoint source pollution from construction activities. LDEQ has stormwater general permits for construction areas equal to or greater than one acre. It is recommended that you contact the LDEQ Water Permits Division at (225) 219-9371 to determine if your proposed project requires a permit.

• If your project will include a sanitary wastewater treatment facility, a Sewage Sludge and Biosolids Use or Disposal Permit is required. An application or Notice of Intent will be required if the sludge management practice includes preparing biosolids for land application or preparing sewage sludge to be hauled to a landfill. Additional information may be obtained on the LDEQ website at http://www.deq.louisiana.gov/portal/tabid/2296/Default.aspx or by contacting the LDEQ Water Permits Division at (225) 219- 9371.

• If any of the proposed work is located in wetlands or other areas subject to the jurisdiction of the U.S. Army Corps of Engineers, you should contact the Corps directly regarding permitting issues. If a Corps permit is required, part of the application process may involve a water quality certification from LDEQ.

• All precautions should be observed to protect the groundwater of the region.

• Please be advised that water softeners generate wastewaters that may require special limitations depending on local water quality considerations. Therefore if your water system improvements include water softeners, you are advised to contact the LDEQ Water Permits to determine if special water quality-based limitations will be necessary.

• Any renovation or remodeling must comply with LAC 33:III.Chapter 28, Lead-Based Paint Activities; LAC 33:III.Chapter 27, Asbestos-Containing Materials in Schools and State Buildings (includes all training and accreditation); and LAC 33:III.5151, Emission Standard for Asbestos for any renovations or demolitions.

• If any solid or hazardous wastes, or soils and/or groundwater contaminated with hazardous constituents are encountered during the project, notification to LDEQ’s Single-Point-of-Contact (SPOC) at (225) 219-3640 is required. Additionally, precautions should be taken to protect workers from these hazardous constituents.


• The applicant is required to comply with all conditions within the letter of no objection from USACE, dated Dec. 20, 2017 (17-0648)

• The applicant must adhere to the conditions and procedures set forth in their NPDES MS4 permit

• The applicant is required to comply all provisions within SLFPA-E Levee Safety Permit OL2017-013, dated December 21, 2017 including construction start within 6 months and completion within one year.

• A stormwater pollution prevention plan (SWPPP) utilizing BMPs should be developed once a detailed flood mitigation alternative is selected in order to mitigate any adverse impact that the stormwater runoff from the construction activities would have on the waters surrounding the Pontilly project area.

• All precautions must be observed to control nonpoint source pollution from construction activities. LDEQ has stormwater general permits for construction areas equal to or greater than 1 acre. The applicant must contact the LDEQ Water Permits Division at 225-219-9371 to determine if the proposed project requires a permit.

• Additional information may be obtained on the LDEQ website at http://www.deq.louisiana.gov/portal/tabid/2296/Default.aspx or by contacting the LDEQ Water Permits Division at 225-219- 9371.

• Erosion control devices must be used and maintained extensively to prevent any potential direct or indirect adverse impacts to nearby wetland areas per the CWA and EO 11990. Any adverse impacts to adjacent wetlands resulting from the construction of this project will jeopardize receipt of federal funding.

• Coordination with the LADOTD would be required for any work that requires the use of state highway rights-of-way.

• The applicant would be required to coordinate with the local floodplain administrator regarding floodplain permit(s) prior to the start of any activities. All correspondence must be submitted to FEMA and FEMA-EHP for inclusion in the project files.

• The applicant is responsible for coordinating with and obtaining any required permit(s) from the Louisiana Department of Natural Resources (LDNR) Coastal Management Division prior to initiating work. The applicant shall comply with all conditions of the required permit. All coordination pertaining to these activities and applicant compliance with any conditions should be documented and copies forwarded to the state and FEMA for inclusion in the permanent project files.

• Offsite location of activities such as borrow, disposals, haul-and detour-roads and work mobilization site developments may be subject to Department of the Army regulatory requirements and may have an impact on a Department of the Army project.

• If human bone or unmarked grave(s) are present within the project area, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is required. The applicant shall notify the law enforcement agency of the jurisdiction where the remains are located within twenty-four hours of the discovery. The applicant shall also


notify FEMA and the Louisiana Division of Archaeology at 225-342-8170 within seventy-two hours of the discovery.

• If during the course of work, archaeological artifacts (prehistoric or historic) are discovered, the applicant shall stop work in the vicinity of the discovery and take all reasonable measures to avoid or minimize harm to the finds. The applicant shall inform their Public Assistance (PA) contacts at FEMA, who will in turn contact FEMA Historic Preservation (HP) staff. The applicant will not proceed with work until FEMA HP completes consultation with the SHPO, and others as appropriate

• Short-term traffic impacts will be mitigated through controlling construction times to minimize construction activities during the morning and evening high traffic periods. Additionally, the construction contractor(s) will be required to provide appropriate signage and placement of barriers, in accordance with the Manual of Uniform Traffic Control Devices to alert pedestrians and motorists of ongoing activities.

• Mitigation of increased, short-term noise levels during construction should include limited construction time periods, proper maintenance of construction equipment, and the selection of noise-dampening construction techniques.

• The applicant is responsible for complying with all USFWS and LDWF conditions and recommendations for avoiding impacts to the bald eagle and bald eagle nest site. This includes conducting work within 660 ft. of the known bald eagle nest outside of nesting season or complying with the monitoring conditions set forth in appendix E. For more information contact Ulgonda Kirkpatrick, USFWS Migratory Bird Division at 321-972-9089 and Carey Lynn Perry, LDWF Natural Heritage Program 225-765-2357.

• The applicant is responsible for developing plans to address the long term maintenance of the infrastructure and plans to address the structural integrity of nearby residences relative to project work.

The following is a restatement of the mitigation and condition measures from the February 2016 EA for the Proposed Pontilly Water Mitigation Project. According to the research and agency consultations completed in this EA, several conditions and mitigations measures must be met and taken by the applicant prior to and during project implementation:

• The applicant is required to comply with all federal, state, and local laws, EOs, and regulations. Failure to do so will jeopardize federal funding.

• All coordination pertaining to these activities and applicant compliance with any conditions should be documented and copies forwarded to the state and FEMA for inclusion in the permanent project files.

• BMPs during construction such as installing silt fences and re-vegetating bare soils with native vegetation should be implemented to minimize runoff and erosion.

• To reduce the emission of air quality pollution from equipment during construction, fuel-burning equipment times should be kept to a minimum and engines should be properly maintained. Dust minimization measures should be implemented during construction as well.


• A SWPPP utilizing BMPs should be developed once a detailed flood mitigation alternative is selected in order to mitigate any adverse impact that the stormwater runoff from the construction activities would have on the waters surrounding the Pontilly area.

• Construction contractor is required to obtain applicable Louisiana Pollutant Discharge Elimination System (LPDES) permit, and implement stormwater pollution prevention plan.

• Any new vegetation plantings should be native to the area, and non-invasive. • The applicant is required to coordinate with the local floodplain administrator regarding

floodplain permit(s) prior to the start of any activities. • Any hazardous materials discovered, generated, or used during construction should be

disposed and handled in accordance with applicable local, state, and federal regulations. • In the event that archaeological deposits (soils, features, artifacts, other remnants of human

activity) are uncovered during the project the applicant shall stop all work immediately in the vicinity of the discovery and take reasonable measures to avoid or minimize harm to the finds. The applicant will inform the Governor’s Office of Homeland Security and Emergency Preparedness (GOHSEP) immediately and will secure all archeological findings and restrict access to the area. GOHSEP shall notify FEMA and FEMA will consult with THPO or Tribal representatives. Work in sensitive areas cannot resume until consultations are completed or until an archeologist who meets Secretary of the Interior (SOI) Professional Qualifications determines the extent of the discovery. Work may not resume at or around the delineated archeological deposit until the applicant is notified by GOHSEP.

• If human bone or unmarked grave(s) are present within the project area, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 et seq.) is required. The applicant shall notify the law enforcement agency of the jurisdiction where the remains are located within twenty-four hours of the discovery. The applicant shall also notify FEMA and the Louisiana Division of Archaeology at 225-342-8170 within seventy-two hours of the discovery.

• Mitigation of increased, short-term noise levels during construction should include limited construction time periods, proper maintenance of construction equipment, and the selection of noise-dampening construction techniques.

• Short-term traffic impacts will be mitigated through controlling construction times to minimize construction activities during the morning and evening high traffic periods. Additionally, the construction contractor(s) will be required to provide appropriate signage and placement of barriers, in accordance with the Manual of Uniform Traffic Control Devices to alert pedestrians and motorists of ongoing activities.

• All construction activities should be performed using qualified personnel and in accordance with OSHA regulations. Appropriate signage and barriers should be in place prior to construction activities to alert pedestrians and motorists of project activities. Stormwater detention areas will be designed to limit detention time to significantly less than forty-eight hours during heavy rain events.

• Offsite location of activities such as borrow, disposals, haul-and detour-roads and work mobilization site developments may be subject to Department of the Army regulatory requirements and may have an impact on a Department of the Army project.


• The project results in a discharge to waters of the State; submittal of a Louisiana Pollutant Discharge Elimination System LPDES application is necessary.

• All precautions must be observed to control nonpoint source pollution from construction activities. LDEQ has stormwater general permits for construction areas equal to or greater than one (1) acre. The applicant must contact the LDEQ Water Permits Division at (225) 219-9371 to determine if the proposed project requires a permit.

• The applicant must obtain a permit from the Orleans Levee District for any work within 300 feet of a federal flood control structure. Performance of all subsurface work within this area is usually restricted when the stage of the Mississippi River is above elevation +11.0 feet on the Carrollton gage, at New Orleans, Louisiana. As a consequence, subsurface work should be scheduled for performance during the low-water period (typically June through November) to avoid delays in performance of the proposed work. The applicant must apply by letter to the Orleans Levee District including full-size construction plans, cross sections, and details of the proposed work. Concurrently with the application to the Orleans Levee District, the applicant must also forward a copy of the letter and plans to Operations Division, Operations Manager for Completed Works of the Corps of Engineers and to the Office of Coastal Protection and Restoration Authority (CPRA) in Baton Rouge for their review and comments concerning the proposed work.

• Additional information may be obtained on the LDEQ website at http://www.deq.louisiana.gov/portal/tabid/2296/Default.aspx or by contacting the LDEQ Water Permits Division at (225) 219- 9371.

• If any solid or hazardous wastes, or soils and/or groundwater contaminated with hazardous constituents are encountered during the project, notification to LDEQ’s Single-Point-of-Contact (SPOC) at (225) 219-3640 is required. Additionally, precautions must be taken to protect workers from these hazardous constituents.

• Erosion Control Devices (ECDs) must be used and maintained extensively to prevent any potential direct or indirect adverse impacts to nearby wetland areas per the CWA and EO 11990. Any adverse impacts to adjacent wetlands resulting from the construction of this project will jeopardize receipt of federal funding.

• The applicant is responsible for coordinating with and obtaining any required permit(s) from the LDNR Coastal Management Division prior to initiating work. The applicant shall comply with all conditions of the required permit. All coordination pertaining to these activities and applicant compliance with any conditions should be documented and copies forwarded to the state and FEMA for inclusion in the permanent project files.

• The LDNR Office of Conservation should be contacted at (225) 342-5540 if any unregistered wells of any type are encountered during construction work.

• For pipelines and other underground hazards, Louisiana One Call should be contacted at 800-272-3020 prior to commencing operations.

• If vector control becomes a problem, the applicant is required to coordinate with LDEQ and the City of New Orleans and take the appropriate measures to control any vector control issues.

• 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 of the project applicant shall handle, manage, and dispose of petroleum


products, hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction of the governing local, state and federal agencies. Applicant is responsible for acquiring LDEQ permits for the temporary debris staging and reduction sites (TDSRS) associated with this project prior to project closeout. Failure to provide FEMA with LDEQ approval may jeopardize project funding eligibility.

• To reduce potential short-term effects to air quality from construction-related activities, the contractor would be responsible for using BMPs to reduce fugitive dust generation and diesel emissions. Emissions from the burning of fuel by internal combustion engines would temporarily increase the levels of some of the criteria pollutants, including CO, NOx, O3, and PM10, and non-criteria pollutants such as Volatile Organic Compounds (VOCs). To reduce these emissions, running times for fuel-burning equipment should be kept to a minimum and engines should be properly maintained.

6.0 AGENCY COORDINATION AND PUBLIC INVOLVEMENT

6.1 Agency Coordination

U.S. Army Corps of Engineers (USACE) Louisiana Department of Environmental Quality (LDEQ) Louisiana Department of Natural Resources (LDNR) Louisiana Department of Wildlife and Fisheries (LDWF) Environmental Protection Agency (EPA) Louisiana State Historic Preservation Officer (SHPO) U.S. Fish and Wildlife Service (USFWS)

6.2 Public Involvement

The draft SEA and draft FONSI are available for review at the Norman Mayer Library, 3001 Gentilly Boulevard, New Orleans, LA 70122. The documents can also be downloaded from FEMA’s website at http://www.fema.gov/resource-document-library. Comments may be mailed to: DEPARTMENT OF HOMELAND SECURITY-FEMA EHP-Pontilly Water Mitigation, 1500 MAIN STREET, BATON ROUGE, LOUISIANA 70802. Comments may be emailed to: [email protected] or faxed to: 225-346-5848. Verbal comments will be accepted or recorded at 504-427-8000. If no substantive comments are received, the draft SEA and associated draft FONSI will become final. The CNO has conducted the following outreach for the preferred action within this SEA.

• Wednesday, March 22, 2017 at 5:30pm NORA District D. Community Meeting at NORDC Milne Campus, 5420 Franklin Avenue, NOLA, 70122 (Dissemination of project fact sheets and one on one engagement)

• Saturday, May 24, 2017 at 9am Neighborhood Engagement Roundtable Meeting (hosted by Mayor’s Neighborhood Engagement Office) at Mosquito Termite & Rodent Control Office, 2100 Leon C. Simon Drive, NOLA, 70122 (Dissemination of project fact sheets and one on one engagement)

http://www.fema.gov/resource-document-library

mailto:[email protected]


• Saturday, August 5, 2017 at 12noon Mirabeau Water Garden Community Presentation & Meeting (hosted by ORS) at Arthur Ashe Charter School, 1456 Gardena Drive, NOLA, 70122 (Dissemination of project fact sheets and one on one engagement)

• Saturday, September 23, 2017 at 9-11am Neighborhood Engagement Roundtable Meeting (hosted by Mayor’s Neighborhood Engagement Office) at Ocshner Baptist Hospital, 2700 Napoleon Avenue, NOLA, 70115 (Dissemination of project fact sheets and one on one engagement)

6.2.1 Past Public Involvement

The original EA and associated FONSI was published as a display ad for four (4) days The Times Picayune, on Sunday, December 20; Wednesday, December 23, 2015; and Friday, December 25, 2015, Sunday, December 27, 2015; and also ran in The Advocate-New Orleans Edition seven (7) days: Monday, December, 21 2015 through Sunday, December 27, 2015. The public comment period was be 15 days, beginning on December 28, 2015 and concluded on January 12, 2016 at 4 p.m. Additionally, the original EA was placed on display at the at the Norman Mayer Library. The EA was also published on FEMA’s websites.

Based on comments received regarding the timing of the ad, a second Public Notice was published as a display ad for two (2) days in The Times Picayune, on Wednesday, January 20, 2016 and Friday, January 22, 2016 and five (5) days in The Advocate-New Orleans Edition on Wednesday, January 20, 2015 through Friday, January 22, 2015. There was a 10 day comment period, beginning on January 20, 2016 and concluding on January 29, 2016 at 4 p.m. The CNO conducted the following public outreach efforts throughout the project development.

• March 28, 2012 Neighborhood Kickoff Meeting at Holy Cross Lutheran Church, 6154 Press Drive New Orleans, La. 70126

• October 25, 2013 Neighborhood Leadership Meeting at Holy Cross Lutheran Church, 6154 Press Drive New Orleans, La. 70126

• November 19, 2013 Neighborhood Outreach Meeting at Holy Cross Lutheran Church, 6154 Press Drive New Orleans, La. 70126

• November 20, 2013 Neighborhood Outreach Meeting at Holy Cross Lutheran Church, 6154 Press Drive New Orleans, La. 70126

• November 23, 2013 Neighborhood Outreach Meeting at Holy Cross Lutheran Church, 6154 Press Drive New Orleans, La. 70126 – 10 Am

• April 2014 Community Newsletter • July/August 2014 Community Newsletter • April 2015 Community Newsletter • Saturday, February 4, 2016 at 10-12noon Gentilly Resilience District Open House

(hosted by Office of Resilience & Sustainability) at Arthur Ashe Charter School, 1456 Gardena Drive, NOLA, 70122 (Dissemination of project fact sheets and one on one engagement)


• Saturday, June 4, 2016 at 10am,Pontilly Project Presentation, Pontchartrain Park Neighborhood Association Meeting at Southern University of New Orleans, 6400 Press Drive, NOLA, 70122

• Thursday, June 30, 2016 at 2:30-4pm Resilience Design Review Committee Meeting at City Hall of New Orleans, 1300 Perdido Street, 8th Floor, Suite 8E10, NOLA, 70112 (Project presentation at municipal interagency design review meeting)

• Saturday – Sunday, October 8-9, 2016 at 12-6pm each day Annual Gentilly Fest at Pontchartrain Park Playground, Press Drive, NOLA, 70122 (Dissemination of project fact sheets and one on one engagement)

• Monday, November 29, 2016 at 6:30pm Mirabeau Water Garden Presentation (meeting hosted by the Office of Resilience & Sustainability) at Dillard University Community Resource Center, 3301 Annette Street, NOLA, 70122 (Dissemination of project fact sheets and one on one engagement)

As part of the effort to update the 2010 Hazard Mitigation Grant Program Mitigation Plan, an updated and expanded planning process was used to review and update the plan to ensure broad representation from the community. Stakeholders for this planning effort included non-profits, community organizations, environmental groups, and regional governmental agencies with an interest in and/or responsibility for hazard mitigation planning. In addition to a CNO City Hall Working Group and Advisory Committee, two additional groups were convened for the purpose of holding discussions specific to their responsibilities (i.e., Public Safety Group and Non-Profits and Community Organizations Group). The CNO City Hall Working Group for the Hazard Mitigation Plan met eight times between June and October 2015. The purpose of each meeting was as follows:

• June 26, 2015 – Overview/Hazards: overview of the hazard mitigation planning process; review the 2010 Plan; hazards activity to rank hazards and discuss correlation to 2010 risk assessment.

• July 13, 2015 – Assets and Goals: share draft maps and discuss data sources; exercise to develop updated goals for 2015 Plan.

• July 31, 2015 – History of Impacts: update on risk assessment; discuss proposed goals; hazards exercise to discuss what could have been done to reduce impacts of different hazards in past 5 years.

• August 13, 2015 – Risk Assessment: update on risk assessment; overview of hazard impacts.

• September 14, 2015 – Mitigation Strategies: mitigation actions activity to determine how actions fit under updated goals.

• September 25, 2015 – Capabilities/Implementation: capability assessment and mitigation action implementation activities to determine process for city departments to implement mitigation strategies.

• October 9, 2015 – Hazards Ranking/Draft Review: activity to rank hazards; review draft of 2015 Plan Update.


• October 23, 2015 – Final Draft Review: review of final 2015 Plan Update prior to submittal to GOHSEP.

The Advisory Committee met four times between July and October 2015. The purpose of each meeting was as follows:

• July 8, 2015: Assets, Goals, Capabilities.

• August 5, 2015: Risk Assessment.

• September 18, 2015: Mitigation Strategies.

• October 7, 2015: Implementation and Draft Review. Community involvement in the development of the Hazard Mitigation Plan update was coordinated with an ongoing public engagement process through the CNO for the Resilient New Orleans Strategy and National Disaster Resiliency Competition (NDRC). Community members were informed of the planning process through a press release, as well as the City’s Hazard Mitigation website (http://www.nola.gov/hazard-mitigation/). A survey was circulated to the general public in August and September of 2015 and received over 130 responses and a public comment form was posted on the City’s Hazard Mitigation website. One community meeting was organized and held in conjunction with the NDRC public engagement process. The community engagement meeting, held on October 19, 2015, included public presentations of the risks, hazards, strategies, and implementation. Comments from the public were cataloged and noted. Comments were used to inform mitigation action strategy rankings. Community involvement in the Public Meeting included:

• Receiving information about the hazard mitigation project planning process,

• Sharing specific concerns about each phase of the planning effort,

• Reviewing the recommendations from the Planning Group,

• Identifying community priorities for hazard mitigation project planning. A preliminary list of mitigation project actions, including 2010 mitigation actions that are ongoing and potential new mitigation projects, was presented to the CNO Hazard Mitigation staff for its review and then to the City Hall Working Group and Advisory Committee. The City Hall Working Group and Advisory Committee provided feedback on the proposed actions, including their input regarding the placement of the actions relative to the goals. The list of actions was also made available to the community in October 2015.

7.0 CUMULATIVE IMPACTS

The most severe environmental degradation may not result from the direct effects of any particular action, but from the combination of effects of multiple, independent actions over time. As defined in 40 CFR 1508.7 (CEQ Regulations), a cumulative effect is the impact on the environment that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions. Principles of cumulative effects analysis are described in the CEQ guide Considering Cumulative Effects under the National Environmental Policy Act. CEQ guidance on cumulative impacts analysis states: For cumulative impacts analysis to help the decision-maker

http://www.nola.gov/hazard-mitigation/)


and inform interested parties, it must be limited through scoping to effects that can be evaluated meaningfully. The boundaries for evaluating cumulative impacts should be expanded to the point at which the resource is no longer affected significantly or the impacts are no longer of interest to affected parties (Council on Environmental Quality, 2006). Not all potential issues identified during cumulative effects scoping need be included in an EA. Because some effects may be irrelevant or inconsequential to decisions about the proposed action and alternatives, the focus of the cumulative effects analysis should be narrowed to important issues of national, regional, or local significance. To assist agencies in this narrowing process, CEQ (2007) provides a list of several basic questions to be considered, including: (1) Is the proposed action one of several similar past, present, or future actions in the same geographic area? (2) Do other activities (governmental or private) in the region have environmental effects similar to those of the proposed action?; (3) Have any recent or ongoing NEPA analyses of similar or nearby actions identified important adverse or beneficial cumulative effect issues?; and (4) Has the impact been historically significant, such that the importance of the resource is defined by past loss, past gain, or investments to restore resources?

In the Pontilly EA of February 2016, FEMA analyzed cumulative impacts within the project area and a one mile buffer (centered on latitude 30.0175, longitude -90.0396) that included zip codes 70122, 70126 and 70148. From August 2005 through November 2015, a total of 286 FEMA-funded projects occurred inside the buffer – two HMGP and 284 PA projects. (Figure 8)

Figure 8. Map Representing Large Scale FEMA-Funded Projects within the One Mile Radius Buffer (Source FEMA LRO)


These FEMA projects were reviewed for environmental impacts prior to obligation of federal funding and have thus far resulted in either no significant impacts, were categorically exempted from NEPA review due to the type of activity or statutorily exempted from NEPA review due to the emergency nature of the action. FEMA entered into an Alternative Arrangement with the CEQ following Hurricane Katrina in order to expedite the review of critical infrastructure project while observing the objectives of NEPA. Some of the projects identified during this analysis were reviewed under this agreement. More information on these projects may be found at FEMA’s alternative arrangements website https://www.fema.gov/new-orleans-metropolitan-area-infrastructure-projects-6 (FEMA, 2015).

Within this area were also numerous non-FEMA funded, debris removal, protective measures, mitigation, and repair projects that occurred, or were in the planning process, to buildings, roads and bridges, recreational and educational facilities, public utilities, waterways, and related project types. These infrastructure actions were necessary as a result of the unprecedented devastation caused by the 2005 hurricanes, both Katrina and Rita, in order to restore pre-disaster conditions.

In the Pontilly EA, FEMA determined that the incremental impact of the Pontilly project, when combined with the effects of other past, present, and reasonably foreseeable future projects, is neither cumulatively considerable nor significant. The cumulative impact of the proposed action to the built and natural environment would be minimal, beneficial rather than detrimental, and is not expected to contribute to any adverse effects or to otherwise significantly affect the human environment. For the proposed project of this SEA, FEMA sought to identify cumulative impacts that were not identified or considered in the original EA. This included new projects from 2016 to present, as well as additional scope items.

The Pontilly project area has distinct physical boundaries on three sides, with the Norfolk Southern Railroad to the west and north, the Inner Harbor Navigational Canal levee to the east. Thus, FEMA has determined that the area within one mile from center of this project area remains an appropriate project impact zone, particularly for localized impacts. Within the one mile radius buffer, there were 33 additional sites associated with FEMA-funded projects for disasters DR-1603 (Hurricane Katrina) and DR-4080 (Hurricane Isaac). (Figure 9) The majority represent existing revised projects that overlap with those analyzed in the prior Pontilly EA. All are PA projects. (Table 4)

TABLE 4. FEMA-funded Project Sites in Study Area by Disaster and Project Type

PA Category of Work DR-1603 Sites

DR-4080 Sites

B - Protective Measures 3 0 E - Public Buildings 15 0 F - Public Utilities 2 1 G - Recreational or Other 8 4

Grand Total - 33 Projects 28 5

https://www.fema.gov/new-orleans-metropolitan-area-infrastructure-projects-6

https://www.fema.gov/new-orleans-metropolitan-area-infrastructure-projects-6


Figure 9. Map Representing 33 Additional FEMA-Funded Project Sites and 3 EAs within the One Mile Radius Buffer (Source FEMA LRO)

Between 2011 and 2015, there were three FEMA EAs within the 1 mile buffer study area, with two for facilities and grounds associated with the Pontchartrain Park and Golf Course, and one for the SUNO campus facilities. Outside the buffer, but within the drainage district and approximately 1.5 miles from the project area, an EA was completed for the Dillard University Mitigation Project (HMGP Project Number 1603-0320). All EAs were for Hurricane Katrina (DR-1603) projects. These FEMA-funded EAs are further analyzed in Table 5. FEMA-funded actions are subjected to various levels of environmental review as a requirement for the receipt of federal funding. A Subgrantee’s failure to comply with any required environmental permitting or other condition is a grant violation, which can result in the loss of federal assistance, including funding.


Table 5. Projects Identified as Having Potential to Contribute to Cumulative impacts.

Project Name/Status

Lead Agency/ Location Description

(Duration) Cumulative Impact Rationale

City of New Orleans Youth Study Center Supplemental EA

FEMA (CNO)

Vicinity Streets/St. Bernard Area

Construction of a Youth Study Center. Construction planned

Minimal/ beneficial

Project will enhance social services in the area

Gentilly Resilience District

CNO, FEMA, SWBNO and HUD

Throughout drainage basin 4

Designed spaces to capture rainwater using green infrastructure and other techniques. Ongoing.

Minimal/ beneficial

Project will promote development in the floodplain cumulatively with other improvements; however the project area is an already developed urban area with little room for further development. Further, this project is designed to improve floodplain conditions by improving natural values of floodplain and drainage in the basin

City of New Orleans City-Wide Road Repairs (JIRR)

CNO and FEMA

New Orleans City-Wide

Repairs, replacements, and improvements to roads and components damaged as a result of Hurricane Katrina. Elements include upgrades to current codes and standards including mitigation measures to reduce the risk of future damages in the next flood. Currently in planning phase.

Negligible Construction will not affect drainage in the area and will cumulatively have a positive impact on infrastructure.

Drainage improvements at Dillard University. HM 320

CNO, FEMA

2601 Gentilly Boulevard, New Orleans, Louisiana 70122

Improvements to drainage and addition of green infrastructure improvements to the campus including creation of bioswales and retention pond. Construction ongoing.

Minimal/ beneficial

Project is designed to improve drainage in the vicinity by slowing runoff of rain water and increasing storage capacity, improving natural values of floodplain and drainage in the basin. This will promote utilization of an area with little room for further development.


Project Name/Status

Lead Agency/ Location Description

(Duration) Cumulative Impact Rationale

Wesley Barrow Stadium replacement AI 1409/PW 4526

CNO and FEMA

6500 Press Drive, New Orleans, Louisiana 70126

Replace the Wesley Barrow Stadium following damage by Hurricane Katrina. Improvements include reorientation for safety of players and improve field drainage. Construction completed in 2012.

Minimal/ beneficial

Project will promote development in the floodplain cumulatively with other improvements; however the project area is an already developed urban area with little room for further development. Some improvements to drainage in the vicinity of the project.

Southern University of New Orleans Construction of Five Buildings at Lake Campus AI 2148/PW 3295

FP&C 6400 Press Drive, New Orleans, Louisiana 70126

Construction of 5 buildings at the Lake Campus to restore and enhance educational support services that were lost due to Hurricane Katrina and to reduce the risk of future flooding. Construction began in 2016 and is ongoing.

Minimal/ beneficial

Project will promote development in the floodplain cumulatively with other improvements; however the project area is an already developed urban area with little room for further development. Further, this project is designed to improve floodplain conditions by improving natural values of floodplain and drainage in the basin

Joseph Bartholomew Maintenance Building, City of New Orleans, Orleans Parish, Louisiana. AI 1640/PW 18043

CNO and FEMA

4800 Hayne Boulevard, New Orleans, Louisiana 70126

Replacement of the maintenance building and drainage repairs and improvements to restore the community services lost as a result of Hurricane Katrina. Construction 2009-2012.

Negligible/ beneficial

Project will promote utilization of and development in the floodplain; however the project area is a developed urban area with little room for future development. Further, this project is designed to improve floodplain conditions by improving natural values of floodplain and drainage in the basin

SWBNO Pump Stations USACE Throughout

Orleans Parish

Drainage pump station repairs and elevation. Construction completed 2011.

Minimal

Project will promote development in the floodplain cumulatively with other improvements; however the project area is an already developed urban area with little room for further development. Further, this project is designed to mitigate against flooding and work in tandem with the proposed and considered alternatives.


8.0 CONCLUSION

The findings of this SEA conclude that the proposed action at the proposed site would result in no significant adverse impacts to water resources, biological resources, cultural resources, socioeconomic resources, traffic, or public services and utilities. Potential impacts to other environmental resources were addressed in the original EA and are incorporated in this SEA by reference.

Therefore, FEMA concludes the proposed action meets the requirements for a FONSI under NEPA and the preparation of an EIS will not be required. If additional information is received that indicates there may be significant adverse effects, then FEMA would revise the findings and issue a second public notice, for additional comments. However, if there are no changes, this Draft SEA will become the Final SEA.

Based upon the studies and consultations undertaken in the original EA and this SEA, and given the precautionary and mitigating measures, there does not appear to be any significant environmental impacts associated with the Pontilly Water Mitigation project.

9.0 REFERENCES

CDM Smith. (2012). Pontilly Stormwater Hazard Mitigation Grant Program Project Hydrologic & Hydraulic Study Technical Memorandum. New Orleans: New Orleans Redevelopment Authority.

City of New Orleans. (2015). 2015 Hazard Mitigation Plan Update. New Orleans: City of New Orleans. Retrieved October 04, 2017, from https://www.nola.gov/getattachment/Hazard-Mitigation/Hazards-and-Planning/Orleans-Parish-2015-HM-Plan-Final-v1.pdf/

City of New Orleans. (2015). 2015 Hazard Mitigation Plan Update. New Orleans: City of New Orleans.

City of New Orleans. (2017, June 22). Mayor's Office of Resilience and Sustainability. Retrieved from NOLA resiliency: https://nola.gov/resilience/

CNO. (2008, November). HMGP Grant Application for Pontilly Stormwater Mitigation Project. Council on Environmental Quality. (1997). Environmental Justice: Guidance Under NEPA.

Washington D.C. Retrieved from https://energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/G-CEQ-EJGuidance.pdf

Council on Environmental Quality. (2006). Considering Cumulative Impacts under the National Environmental Policy Act.

Environmental Protection Agency. (2017, August 17). EJSCREEN: Environmental Justice Screening and Mapping Tool. Retrieved November 2017, from EPA.gov: https://www.epa.gov/ejscreen

Environmental Protection Agency. (2017). Envirofacts. Retrieved from http://www.epa.gov/enviro/


Environmental Protection Agency. (n.d.). NEPAssist. Retrieved from http://nepassisttool.epa.gov/nepassist/entry.aspx

Environmental Protection Agency. (n.d.). Sole Source Aquifers, Region 6. Retrieved from http://www.epa.gov/earth1r6/water/swp/ssa/index.htm

FEMA. (2012). What Is Environmental Justice? U.S. Department of Homeland Security. Louisiana Department of Natural Resources. (n.d.). Office of Coastal Management. Retrieved

from http://www.dnr.louisiana.gov/index.cfm?md=pagebuilder&tmp=home&pid=93 National Geographic Society, Esri et al. (2013). aerial image. Regional Planning Commission. (2010). Regional Planning Commission. Retrieved from Traffic

Counts: http://www.norpc.org/traffic_counts.html Stantec. (2016). Hagan-Lafitte Drainage Upgrades and Green Infrastructure Preliminary

Design (30%) Report. U.S. Census Bureau. (2011-2015, October 5). U.S. Census Bureau, American Community Survey

(ACS) 2011-2015. Washington D.C.: Environmental Protection Agency. Retrieved October 2017, from EPA: https://www.epa.gov/ejscreen

USFWS. (2017, July 13). Letter regarding AI 2644 CNO - Municipal Yacht Harbor Breakwater Improved Project. Louisiana: Louisiana Ecological Servies Field Office.

USFWS. (n.d.). Endangered Species Data. Retrieved from http://www.fws.gov/endangered/ USFWS. (n.d.). National Wetlands Inventory Maps. Retrieved from

http://www.fws.gov/wetlands/Data/mapper.html


9.0 LIST OF PREPARERS

This EA was prepared under the direction of FEMA. Individuals who contributed to the preparation of this document are: Tiffany Spann-Winfield, Deputy Environmental Liaison Officer, FEMA Jerame Cramer, Environmental Liaison Officer, FEMA Amber Martinez, Environmental/Historic Preservation Team Lead, FEMA Randy Norris, Acclivity Associates, FEMA CTR Joey Chauvin, Environmental and Historic Preservation Advisor, FEMA Darren Mitchell, Acclivity Associates, FEMA CTR Cheraki Williams, Archaeologist, FEMA Jill Kelly, Environmental Specialist, FEMA Alice-Anne Krishnan, Historic Preservation Specialist, FEMA

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