U.S.

Department of Homeland Security

Federal Emergency Management Agency
FEMA-1603/1607/1786/1792-DR-LA
Louisiana Transitional Recovery Office
FEMA Mail Center 1st floor
Environmental/Historic Preservation
1 Seine Court
New Orleans, Louisiana 70114

December 29, 2009

Reid Nelson, Director

Office of Federal Agency Programs
Advisory Council on Historic Preservation
Old Post Office
1100 Pennsylvania Ave., NW, Suite 809
Washington, D.C. 20004

RE: Section 106 Review Consultation, Hurricane Katrina

Undertaking: Purchase of the Chevron building (935 Gravier St) to house the City of New
Orleans’ operational and administrative functions resulting in the abandonment of New
Orleans City Hall (1300 Perdidio Street)
Applicant: City of New Orleans
Determination: Adverse Effect to Historic Properties

Dear Mr. Nelson:

The Federal Emergency Management Agency (FEMA) has initiated Section 106 review for New
Orleans City Hall in accordance with the “Programmatic Agreement among FEMA, the Louisiana
State Historic Preservation Officer (SHPO), the Louisiana Governor’s Office of Homeland Security
and Emergency Preparedness (GOHSEP), the Alabama-Coushatta Tribe of Texas, the Caddo
Nation, the Chitimacha Tribe of Louisiana, the Choctaw Nation of Oklahoma, the Coushatta Tribe
of Louisiana, the Jena Band of Choctaw Indians, the Mississippi Band of Choctaw Indians, the
Quapaw Tribe of Oklahoma, the Seminole Nation of Oklahoma, the Seminole Tribe of Florida, the
Tunica-Biloxi Tribe of Louisiana, and the Advisory Council on Historic Preservation” dated August
17, 2009 (2009 Statewide PA). The City of New Orleans (Applicant) intends to use FEMA Public
Assistance Program funding to purchase the Chevron building resulting in the abandonment of New
Orleans City Hall (Undertaking)..

The scope of the FEMA undertaking includes the purchase of and potential interior renovations to
the Chevron building, located at 935 Gravier Street. The City of New Orleans would move all of
the city’s operational and administrative functions to this new facility which would result in the
abandonment of City Hall, bounded by Perdido, LaSalle, Poydras Street and Loyola Boulevard.
The applicant intends to make the current City Hall building safe and secure, however it is unclear
at this time what steps the applicant intends to make to ensure this action.

The Area of Potential Effects (APE) is determined to be the footprint of the Chevron Building and
the footprint of City Hall and its garage. The Civil Courts Building, which is attached to the City
Hall, is not included in the APE and will remain occupied by the Civil Court function. There are no
ground disturbing activities proposed for the undertaking at this time. Should the undertaking
change, this APE may be modified based upon any new, submitted scope of work.
Page 2 of 3
12/29/2009
Historic Properties Adversely Affected
Purchase of the Chevron Building resulting in the abandonment of City Hall
Orleans Parish

FEMA has determined that the Chevron building is not eligible for the National Register of Historic
Places (NRHP) individually or as part of a listed or eligible National Register Historic district. The
Chevron building does not meet the 50-year-criterion nor criteria consideration G of the National
Register guidelines to be considered eligible for the NRHP.

In a previous Section 106 consultation dated November 12, 2005, FEMA determined that City Hall
was eligible for the NRHP under criterion A and C. SHPO responded on December 8, 2005 stating
that City Hall was potentially eligible for the NRHP under Criterion A but not under Criterion C. In
2009, for purposes of this consultation, FEMA has undertaken additional research necessary to
determine that City Hall is eligible under Criteria A and C. FEMA has formally consulted with the
Louisiana State Historic Preservation Officer (SHPO) and requested SHPO’s comments on its
adverse effect determination in a letter dated December 29, 2009.

FEMA applied the criteria of adverse effect, pursuant to 36 CFR 800.5(a)(1), and determined that
the abandonment of City Hall has the potential to cause an adverse effect to New Orleans City Hall
that is reasonably foreseeable and may occur later in time or be cumulative. In accordance with 36
CFR part 800.5(a)(2)(iv), the removal of the operational and administrative functions from City
Hall constitutes a change in the character of the property’s use that contribute to its historic
significance. Additionally, 36 CFR part 800.5(a)(2)(vi), states that the neglect of a property which
causes its deterioration is also an example of an adverse effect. Since the applicant has not yet
indicated what actions it intends to take to make City Hall safe and secure, FEMA will take steps to
consider the effects of the abandonment of the building through the development of a Memorandum
of Agreement (MOA) for this Undertaking.

This letter, pursuant to 36 CFR §800.6(a)(1), is intended to notify the Advisory Council on Historic
Preservation (ACHP) of the adverse effect. We have enclosed maps and photographs required by
36 CFR §800.11(e). FEMA is inviting the ACHP to participate in this consultation pursuant to 36
CFR §800.6(a)(1)(i)(A). In addition FEMA has reviewed Appendix A to Part 800, Criteria for
Council Involvement in Reviewing Individual Section 106 Cases, and suggests that the involvement
of the ACHP is warranted because the undertaking has the potential for presenting procedural
problems. Please advise FEMA by January 14, 2010 if the ACHP intends to participate in this
consultation.

FEMA will provide a reasonable opportunity for Indian tribes to identify concerns about historic
properties that may be affected by this Undertaking and to advise FEMA on the identification and
evaluation of historic properties, including those of traditional religious and cultural importance.
FEMA will provide these Indian tribes with the opportunity to participate in the resolution of
adverse effects.

FEMA will also notify potential Consulting Parties of this adverse effect consultation by e-mailing
them a copy of this letter and the background information.

We propose to send future notices, draft agreements, and other background information to the
SHPO and Consulting Parties by e-mail to minimize communication delays and expedite the