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The following types of EMPG projects are to be submitted to FEMA for compliance review under EHP laws and requirements prior to initiation of the project: ■ Any involvement with the installation of equipment , ■ Ground -disturbing activities , ■ New construction ( installation and renovation ) , including communication towers , or modification/renovation of existing buildings or structures ■ Proposed construction or renovation projects that are part of larger projects funded from a non-FEMA source (such as an EOC that is part of a larger proposed public safety complex) ■ Renovation of and modification to buildings and structures that are 50 years old or older ■ Any other construction or renovation efforts that change or expand the footprint of a facility or structure including security enhancements to improve perimeter security ■ Physical Security Enhancements , including but not limited to: • Lighting • Fencing • Closed -circuit television ( CCTV) systems • Motion detection systems • Barriers , doors , gates and related security enhancements ■ Field based training and exercises including activities that involve ground disturbance , use of explosives , toxic agents or otherwise have the potential to cause impact to the environment or historical resources . This is only a requirement if the exercise or field training is not being conducted by a certified professional or at an existing facility with established procedures . ■ Communication tower projects The following activities do not require the submission of the FEMA EHP Screening Form : planning and development of policies or processes ; management and administration ; classroom-based training ; table top exercises and functional exercises ; and , acquisition of mobile and portable equipment ( no installation ) . All recipients of financial assistance will comply with the requirements of the NEPA , as amended , 42 U . S . C . §4331 et seq . , which establishes national policy goals and procedures to protect and enhance the environment , including protection against natural disasters . To comply with NEPA for its grant-supported activities , DHS requires the environmental aspects of construction grants (and certain non -construction projects as specified by the component and awarding office) to be reviewed and evaluated before final action on the application . For more information on FEMA' s EHP requirements , see Informational Bulletins below' • Information Bulletin 329 , Environmental Planning and Historic Preservation Requirements for Grants , available at http : //www. fema . 4ov/r)df/government/grant/bulletins/info329 , pdf; • Information Bulletin 345 , Programmatic Environmental Assessment, available at http ://www, fema . gov/pdf/government/grant/bulletins/info345 , pdf; and • Information Bulletin 356 , EHP Screening Form , available at http ://www .fema . gov/r)df/government/grant/bulletins/info356 , pdf. III . Construction and Renovation Construction and renovation activities for a local government' s EOC as defined by the SAA are allowable under the EMPG Program . Written approval must be provided by FEMA prior to the use of any EMPG Program funds for construction or renovation . Requests for EMPG Program funds for construction of an EOC must be accompanied by an EOC Investment Justification ( FEMA Form 089-0-0-3 ; OMB Control Number; 1660-0124 (available through ND grants) to their Grant Program Manager for review. Additionally, grantees are required to submit a SF424C Budget and Budget detail citing the project costs . When applying for funds to construct communication towers , grantees and sub-grantees must submit evidence that the FCC ' s Section 106 review process has been completed and submit all documentation resulting from that review to GPD prior to submitting materials for EHP review. Grantees and sub-grantees are also encouraged to have completed as many steps as possible for a successful EHP review in support of their 19