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Written approval must be provided by FEMA prior to the use of any EMPG Program funds for <br />construction or renovation Requests for EMPG Program funds for construction of an EOC must be <br />accompanied by an EOC Investment Justification (FEMA Form 089-0-0-3, OMB Control Number; <br />1660-0124 (available through ND grants) to their Grant Program Manager for review <br />When applying for funds to construct communication towers, grantees and sub -grantees must submit <br />evidence that the FCC's Section 106 review process has been completed and submit all <br />documentation resulting from that review to GPD prior to submitting materials for EHP review <br />Grantees and sub -grantees are also encouraged to have completed as many steps as possible for a <br />successful EHP review in support of their proposal for funding (e g , coordination with their State <br />Historic Preservation Office to identify potential historic preservation issues and to discuss the <br />potential for project effects, compliance with all State and EHP laws and requirements) Projects for <br />which the grantee believes an Environmental Assessment (EA) may be needed, as defined in 44 <br />C F R §§ 10 8 and 10 9, must also be identified to the FEMA Regional Program Manager within six <br />months of the award and completed EHP review materials must be submitted no later than 12 months <br />before the end of the period of performance EHP review packets should be sent to Grant Program <br />Manager <br />EMPG Program grantees using funds for construction projects must comply with the Davis -Bacon Act <br />(40 U S C 3141 et seq) Grant recipients must ensure that their contractors or subcontractors for <br />construction projects pay workers employed directly at the work -site no less than the prevailing <br />wages and fringe benefits paid on projects of a similar character Additional information, including <br />Department of Labor (DOL) wage determinations, is available from the following website <br />http://www dol gov/compliance/aws/comp-dbra htm <br />K. Maintenance and Sustainment <br />The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair, or <br />replacement costs, upgrades, and user fees are allowable under all active and future grant awards, <br />unless otherwise noted <br />EMPG Program grant funds are intended to support the Goal and fund activities and projects that <br />build and sustain the capabilities necessary to prevent, protect against, mitigate the effects of, <br />respond to, and recover from those threats that pose the greatest risk to the security of the Nation In <br />order to provide grantees the ability to meet this objective, the policy set forth in GPD's IB 379 <br />(Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant <br />Funding) allows for the expansion of eligible maintenance and sustainment costs which must be in 1) <br />direct support of existing capabilities, (2) must be an otherwise allowable expenditure under the <br />applicable grant program, (3) be tied to one of the core capabilities in the five mission areas <br />contained within the National preparedness Goal, and (4) shareable through the Emergency <br />Management Assistance Compact. Additionally, eligible costs must also be in support of equipment, <br />training, and critical resources that have previously been purchased with either Federal grant or any <br />other source of funding other than DHS/FEMA preparedness grant program dollars Additional <br />guidance is provided in FEMA Policy FP 205-402-125-1, Maintenance Contracts and Warranty <br />Coverage Funded by Preparedness Grants, located at: http://www.fema gov/media- <br />library/assets/documents/32474 <br />L. Unallowable costs <br />Unallowable costs include, but shall not be limited to <br />• Expenditures for weapons systems and ammunition, <br />• Costs to support the hiring of sworn public safety officers for the purposes of fulfilling traditional <br />public safety duties or to supplant traditional public safety positions and responsibilities, or <br />32 <br />