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• Other equipment or software which may be required to support the implementation of the homeland security strategy `trr. The following are allowable only within the period of performance of the contract: • Recurring fees/charges associated with certain equipment,such as cell phones,faxes,etc. • Leasing and/or renting of space for newly hired personnel during the period of performance of the grant program 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 Project construction using SHSP and UAS I funds may not exceed the greater of$1,000,000 or 15%of the grant award. For the purposes of the limitations on funding levels,communications towers are not considered construction. Written approval must be provided by FEMA prior to the use of any HSGP funds for construction or renovation. When applying for construction funds,including communications towers,at the time of application,grantees are highly encouraged to submit evidence of approved zoning ordinances,architectural plans,any other locally required planning permits and documents,and to have completed as many steps as possible for a successful EHP review in support of their proposal for funding(e.g.,completing the FCC's Section 06 review process for tower construction projects;coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects). Projects for which the grantee believes and Environmental Assessment(EA)may be needed,as defined in 44 CFR 10.8 and 10.9,must also be identified to the FEMA Program Analyst within six(6)months of the award and completed EHP review packets must be submitted no later than 12 months before the end of the Period of Performance. EHP review packets should be sent by the SAA to FEMA for review. FEMA is legally required to consider the potential impacts of all HSGP projects on environmental resources and historic properties. Grantees must comply with all applicable environmental planning and historic preservation (EHP)laws, regulations,and Executive Orders(EOs)in order to draw down tlieir FY 2012 HSGP grant funds. To avoid unnecessary delays in starting a project,grantees are encouraged to pay close attention to the reporting requirements for an EHP review. For more information on FEMA's EHP requirements please refer to Bulletins 329 and 345 (htti)Hwww.fema.gov/govern men t/grantibu I leti ns/in desshtm). FY 2012 HSGP Program grantees using funds for construction projects must comply with the Davis-Bacon Act(40 U.S.C. 3141 et seq.). Grant recipients trust 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: httn'//w\anvdol gov/compliance/laws/comm-dbra,hun. In addition,the erection of communications towers that are included in a jurisdiction's interoperable communications plan is allowed,subject to all applicable laws,regulations,and licensing provisions.Communication tower 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 towers are not subject to the$],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 bnp 'S,r ria Ienua.�ov.'ylan,el7w: Note:Written approval must be provided by FEMA prior to the use of any funds for construction or renovation. G. Overtime and Backfill Guidance Personnel(SHSP and UASI)—Personnel hiring,overtime,and backfill expenses are permitted under this grant in order to perforin allowable FY 2012 HSGP planning,training,exercise,and equipment activities. A personnel cost cap of up to 50 25 132