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FEMA's Draft Environmental Assessment.
cityparknola.org
3/23/2015

Despite City Park officials claim to FEMA that the CPIA had kept the public informed concerning redevelopment of the City Park Golf Course Complex, the decision to grab 5.5 acres of Couturie Forest land for conversion into golf course was never publicly announced or addressed. The first inkling of the plan to destroy this land was outlined in FEMA's May 2013 Draft Environmental Assessment of the Golf Complex, whose purpose was "to analyze potential environmental impacts of the proposed project." The Draft EA and draft Finding of No Significant Impact (FONSI) by FEMA was first made available for review to the public and other interested parties in April 2013 at the Orleans Parish Main Library, or by download from FEMA's website. The public notices apparently ran on May 22, 24 and 26, 2013 (where they ran, it doesn't say), and the comment period began May 27, 2013 and ended June 10, 2013. Not surprisingly, FEMA received no comments, so the Draft EA became the Final EA.

Since the National Environmental Policy Act of 1969 (NEPA) process consists of an evaluation of the environmental effects of a federal undertaking, including its alternatives, four golf course alternatives were outlined in the Draft EA:
Alternative 1 - No Action: Golf Complex would not be repaired or reconstructed.
Alternative 2 – Repair Back to Original Configuration/Footprint (of 526 acres).
Alternative 3 – Repair in Same (526 acre) Footprint to Different Configuration.
Alternative 4 – Consolidate/Reconfigure in Substantially Same Footprint (Proposed Action, and the alternative that was chosen).

The word "substantially" hides a multitude of sins in this case, and was undoubtedly the terminology used by City Park officials when they presented Alternative 4 as the chosen alternative to FEMA.

"Under this alternative, the North Golf Course would keep its existing location and configuration and continue to operate as a moderately priced golf course offering a moderate skill level golf experience. The entire West Golf Course and a portion of the East Golf Course would be combined, reduced, reconfigured, and repaired within the existing 526 acre footprint allocated for golf uses, to form a single, professional level, 18-hole golf course capable of offering a championship golfing experience and hosting a wide variety of golf tournaments. The balance of the East Course not incorporated into the new golf course (approximately 96 acres) would be converted into green space; and five and one-half acres not previously allocated for golf uses would be added to the new golf course to provide a buffer to the fifth hole. [on page 80 of the document, it is stated as convert for golf uses an additional 5.5 acres of previously unused park space.] The new professional level 18-hole golf course would not extend south of Harrison Avenue and, including the 5.5 acres of new space, would only use approximately 250 acres of the space already allocated for golf uses, instead of the 310 acres proposed under Alternative 3. A total of one-hundred-eight (108) trees would be removed or relocated throughout the proposed project site. Twenty-one (21) large live oaks would be removed, including at least fifteen (15) due to struggling health issues; four (4) of the twenty-one (21) would be relocated on site. Forty-eight (48) cypress, ten (10) pines, three (3) palms, eight (8) deciduous oak or other deciduous trees, and eighteen (18) crepe myrtles would be removed."

In addition to the extensive tree removal, both from the previous golf course areas and the previously unused-for-golf areas of Couturie Forest, much of the area qualifies as wetland.

"FEMA conducted site visits on February 27, and April 26, 2013, and determined that several vegetated and other wetland areas are located on the site, including a wooded area on or near the five (5) acres of previously unused land proposed to be added as buffer for new fairway number 5. Jurisdictional wetlands and other waters of the U.S. are subject to permitting under § 404 of the Clean Water Act. The Proposed Action Alternative includes enlargement of existing bodies of water, installation of culvert pipes within the canal system at the City Park Golf Course site, construction of a weir and well system, and other work which would require excavation and trenching of existing bodies of water, and the deposit or redistribution of fill material."

For Alternative 4, in correspondence dated April 2, 2013, USACE (Corps of Engineers) stated that a federal permit would be required for the placement or redistribution of dredged or fill material on the project site. (On October 19, 2011, the USACE issued a Final Determination of Eligibility letter and § 404 permit for "Alternative 3-Repair in Same Footprint to Different Configuration", but not for Alternative 4, the chosen one.)

FEMA also requires "Public Involvement", and cites the public meetings held by the CPIA prior to the March 22, 2011 announcement of the downsized plan as evidence that the public was in fact kept informed: "Post-Katrina and throughout development of the proposed undertaking, the CPIA has engaged in public meetings and kept the public informed concerning redevelopment of the City Park Master Plan and of its intentions regarding the Golf Course Complex. Public hearings were held in February 2005, November 2007, March 2009, and on Tuesday, March 22, 2011. The March 22, 2011 public hearing was held at the Pavilion of the Two Sisters in the Botanical Garden in City Park and considered, inter alia, “amendments to the City Park Master Plan to (1) reduce the acreage allocated to golf uses by modifying the golf plan, [and] (2) modify and broaden the land use category in the land use plan pertaining to the acreage removed from golf uses pursuant to the modified golf plan …”

However, the CPIA held no further public meetings after March 22, 2011 in order to inform the public of their NEW plans to bulldoze 5.5 acres of the Couturie Forest for golf course use, nor did they ever reflect these Land Use changes in the public maps used in the revisions to their Master Plan 2018, new versions of which were produced in 2011 and AS RECENTLY AS 2014—but are still not showing the reduction in land area of the Couturie Forest. Because of their subterfuge, there is no way the CPIA has truly met the "Public Involvement" requirement set by FEMA.

FEMA Draft Environmental Assessment, May 2013

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