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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 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 proposal for funding (e g , coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects, compliance with all State and EHP laws and requirements) Projects for which the grantee believes an Environmental Assessment (EA) may be needed, as defined in 44 C F R §§ 10 8 and 10 9, must also be identified to the FEMA Regional Program Manager within six months of the award and completed EHP review materials must be submitted no later than 12 months before the end of the period of performance EHP review packets should be sent to Grant Program Manager EMPG Program grantees 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 (DOL) wage determinations, is available from the following website http://www dol gov/compliance/aws/comp-dbra htm K. Maintenance and Sustainment The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair, or replacement costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted EMPG Program grant funds are intended to support the Goal and fund activities and projects that build and sustain the capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation In order to provide grantees the ability to meet this objective, the policy set forth in GPD's IB 379 (Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding) allows for the expansion of eligible maintenance and sustainment costs which must be in 1) direct support of existing capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program, (3) be tied to one of the core capabilities in the five mission areas contained within the National preparedness Goal, and (4) shareable through the Emergency Management Assistance Compact. Additionally, eligible costs must also be in support of equipment, training, and critical resources that have previously been purchased with either Federal grant or any other source of funding other than DHS/FEMA preparedness grant program dollars Additional guidance is provided in FEMA Policy FP 205-402-125-1, Maintenance Contracts and Warranty Coverage Funded by Preparedness Grants, located at: http://www.fema gov/media- library/assets/documents/32474 L. Unallowable costs Unallowable costs include, but shall not be limited to • Expenditures for weapons systems and ammunition, • Costs to support the hiring of sworn public safety officers for the purposes of fulfilling traditional public safety duties or to supplant traditional public safety positions and responsibilities, or 32