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■ 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 . gov/pdf/government/grant/bulletins/info329 . pd ; • 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/pdf/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 . The FY 2012 EMPG Program recipients using funds for construction projects must comply with the Davis- Bacon Act (40 U . S . C . 3141 et seq. ) . Grant recipients must ensure that their contractors or subcontractors for construction projects pay workers employed directly at the work- site no less than the prevailing wages and fringe benefits paid on projects of a similar character . Additional information , including Department of Labor wage determinations , is available from the following website : http://www. dol. gov/compliance/Jaws/comp- dbra . htm . 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 Program Analyst for review . When applying for construction funds , including communications towers , at the time of application , recipients are highly encouraged to submit evidence of approved zoning ordinances , architectural plans , any other locally 17