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FEMA Section 106 Notices for Louisiana
Comment on "Public Notice Regarding Section 106 Review of Interior Rehabilitation; New Addition Construction; and Demolition of Outbuildings and Custodial Lodge
Audubon-Montessori School, 428 Broadway Street, New Orleans, LA
Applicant: Orleans Parish School Board (OPSB)
Seeking Public Comment
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Name: Stephen C. Picou
City: New Orleans LA
Comments: Based on the rather inadequate amount of information provided by FEMA and partners in providing for this public comment, I submit the following:
1. Mature trees on the site should be protected by following all appropriate protocols for construction around trees. These trees provide shade, reducing energy use not only for the school, but for the surrounding neighbors. They also provide for significant stormwater management.
2. Low Impact Development principles, as defined by EPA, should be followed. This includes the use of pervious surfaces in all possible instances, including sidewalks, parking lots and any other hard surfaces planned for ground cover whether it is currently paved or not. Any impervious surfaces due to be demolished and replaced should be replaced by permeable surfaces.
3. The site should be required to meet LID standards for stormwater management. The site and structures should be capable of holding the first inch of rain on site via detention, retention and infiltration. The use of natural systems and existing trees should be the highest priority in designing stormwater systems.
The architects and contractors should be held accountable (much like they are on Tulane's campus) for damage to existing trees both on site and on nearby properties.

The main cause of tree death and damage during construction is compaction of soils. Information about proper protective measures are readily available online. In the absence of well-crafted tree ordinances, the neighbors and pubic must take steps to ensure compliance with commonly held values and demand adherence to best practices. FEMA, CRT and the local government should follow the principles of Low Impact Development as defined by EPA in every stage of planning and implementation of capital projects such as this.