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E. Unauthorized Expenditures • Activities unrelated to the completion and implementation of the grant program • Other items not in accordance with the Authorized Equipment List or previously listed as allowable costs • Funding may not be used to supplant ongoing, routine public safety activities of state and local emergency responders, and may not be used to hire staff for operational activities or backfill . Funds cannot not replace (supplant) funds that have been appropriated for the same purpose . F. Construction and Renovation Use of FISGP funds for construction and renovation is generally prohibited except as outlined below. Such construction and renovation shall be strictly limited and allowable only when it is a necessary component of a security system at critical infrastructure facilities . Project construction and renovation not exceeding S 1 ,000,000 is allowable, as deemed necessary . The following types of projects are considered to constitute construction or renovation , and must be submitted to FEMA for compliance review under Federal environmental planning and historic preservation ( EHP) laws and requirements prior to initiation of the project : • Construction and renovation of guard facilities • Renovation of and modifications, including the installation of security and communication equipment, 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 : o Lighting o Fencing o Closed-circuit television (CCTV) systems o Motion detection systems o Barriers, doors, gates and related security enhancements In addition, the erection ofcommunications Corners that are included in ajurisdiction 's interoperable communications plan is allowed, subject to all applicable laws, regulations, and licensing provisions. Connuunieation ton7er projects must be submitted to FEMA for EHP review. Per the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act of2009 ( Public Law 110-329 ), communications torners are not subject to the$ 1 , 000, 000 construction and renovation cap. Approval Process: In order for grantees to drawdown funds for construction and renovation costs, the grantee must provide the Division with : • A description of the asset or facility, asset location, whether the infrastructure is publicly or privately owned , and the construction or renovation project ; • Certification that a facility vulnerability assessment has been conducted • An outline addressing how the construction or renovation project will address the identified vulnerabilities from the assessment • Consequences of not implementing the construction or renovation project • Any additional information requested by FEMA to ensure compliance with Federal environmental and historic preservation requirements Additional information may also be found on the FEMA ' s website located at 1atU://uiru . fema. ¢ov1U/an/e{u�L Note : Written approval must be provided by FEMA prior to the use of any funds for construction or renovation . G. Overtime and Backfill Guidance Overtime — These expenses are limited to the additional costs which result from personnel working over and above 40 hours of weekly work time as a direct result of their performance of FEMA-approved activities specified in this guidance. Overtime associated with any other activity is not eligible. Backfill-related Overtime — Also called "Overtime as Backfill ," these expenses are limited to overtime costs which result from personnel who are working overtime (as identified above) to perform the duties of other personnel who are temporarily assigned to FEMA-approved activities outside their core responsibilities . Neither overtime nor backfill expenses are the result of an increase of FTE employees . H . National Incident Management System ( NIMS ) Compliance FISPD-5, "Management of Domestic Incidents," mandated the creation of NIMS and the National Response Plan (NRP) .' NiMS provides a consistent framework for entities at all jurisdictional levels to work together to manage domestic incidents, regardless of cause, size, or complexity. To promote interoperability and compatibility among Federal , State, 26