DHS Seal - FEMA    
FEMA Section 106 Notices for Louisiana
Comment on "Public Notice NHPA/NEPA1
Seeking Public Comment for FEMA Funded Construction
of the Mazant-Royal Housing Development,
4100 Royal Street, New Orleans
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Name: Name redacted at the request of the author
City: New Orleans, Louisiana
Square 131 in Bywater bordered by Royal, Chartres, Mazant and France Streets New Orleans, La 70117
Comments: There are so many reasons this project should not be allowed to proceed.

Federal regulations require you to identify if any of the properties are historic (listed in the National Registrar of Historic Places); to assess the effects the work would have on historic properties; to seek ways to avoid, minimize or mitigate any adverse effects to historic properties; and to evaluate the proposed actions potential for significant impacts to the human or natural environment.

This whole neighborhood is historic (Bywater National Registry Historic District) with this area (square 131) being of special significance as it was the location of the Oliver Plantation and as the archeological survey Phase I and II have shown contain important artifacts that require further protection and research (Phase III) by the same archeological consultants who understand the significance of their prior findings. Not only is Square 131 historic but many surrounding properties are as well. These will be impacted significantly by the construction of this massive project.

As anyone can see from the design drawings, this neighborhood of one and two story historic homes will be dwarfed by the unprecedented scale of this development. In their original proposal ITEX was to build 80 units across 19 different HANO sites in Bywater with 56 units on square 131 (the number previously existing on that site). How was this allowed to go to 150 units in the first place? How can there be architects who have never designed a project on this scale or experience in New Orleans Historic Districts allowed to work on this? Why is a private Houston developer with the inside tract on LIHTC and other federal monies being paid to build a development in a historic district of New Orleans that they will own? Why is a Private developer making a profit on this development allowed to sidestep all due process and regulations under the guise of Public Housing? The Architectural Review Committee (ARC) of the Historic Districts Landmark Commission(HDLC) deemed this project "fundamentally not contextual" and they would deny the proposal if they could. But they can't because public Housing is excluded from the requirements of HDLC approval of development in a Historic district. The Housing Authority of New Orleans (HANO) only owns the land while the "housing" is privately owned and developed by ITEX. How is this not under the same rules as any other private development?

In addition, this project is only one of many developments planned for this area of Bywater which will tax an already crowded corner of the neighborhood with significant impacts to water drainage, sewerage and other infrastructure issues. Traffic which is already heavy in this corner of Bywater due to the street layout and train line will become an even more serious problem. Currently, fire and emergency vehicles have difficulty accessing this corner and this development with its number of vehicles would mean gridlock. And though there are many blighted buildings that could use renovating in this area there are few green spaces and even fewer mature trees in this neighborhood especially since Katrina. There are 11 large trees on this site with 4 listed on the historic live oak registry. Any development should be designed to include and protect as many of those trees as possible. There is no way to "replace" them around the city with saplings. They are currently the greatest natural asset to this corner with the Crescent Park containing no trees of this age.

Finally, over 600 residents of this neighborhood are strongly opposed to this development. This is being forced on the people of this community who want affordable housing here but object to the outrageous scale, massing, and density of this project. The abhorrent design in addition to looking like it belongs in Houston not New Orleans, will actually pull exhaust from the cars in the garage below up the light well in the center (Texas Doughnut) to poison the residents of the building especially those living in the inside units. It is a health hazard that will see lawsuits brought against it in the future from it's residents and neighbors.

I want to see affordable housing built to fit into this historic neighborhood NOT on top of it! Thank you