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B. ENVIRONMENTAL PLANNING AND HISTORIC PRESRVATION (EHP) COMPLIANCE <br />As a federal agency, FEMA is required to consider the effects of its actions on the environment and/or <br />historic properties to ensure that all activities and programs funded by the agency, including grants - <br />funded projects, comply with federal EHP regulations, laws and Executive Orders as applicable. Sub - <br />Recipient's proposing projects that have the potential to impact the environment including but not limited <br />to construction of communication towers modification or renovation of existing buildings, structures and <br />facilities, or new construction including replacement of facilities must participate in the FEMA EHP review <br />Process. The EHP review process involves the submission of a detailed project description that explains <br />the goals and objectives of the proposed project along with supporting documentation so that FEMA may <br />determine whether the proposed project has the potential to impact environmental resources and/or <br />historic properties. In some cases, FEMA also is required to consult with other regulatory agencies and <br />the public in order to complete the review process. The EHP review process must be completed and <br />approved before funds are released to carry out the proposed project. FEMA will not fund projects that <br />are initiated without the required EHP review. <br />Additionally, all Sub -Recipients are required to comply with DHS/FEMA EHP Policy Guidance FEMA <br />Policy #108-023-1. The EHP screening form is located https://www.fema.gov/media- <br />Preparedness Grants Manual I April 2019 Page 19 <br />library/assets/documents/90195, and further EHP guidance can be found at https://www.fema.gov/media- <br />Iibrary/assets/documents/118323. <br />C. CONSTRUCTION AND RENOVATION <br />Construction and renovation projects for a state, local, territorial, or Tribal government's principal <br />Emergency Operations Center (EOC) as defined by the State Administrative Agency are allowable under <br />the EMPG Program. <br />Written approval must be provided by FEMA prior to the use of any EMPG Program funds for construction <br />or renovation. Requests for EMPG Program funds for construction of an EOC must be accompanied by <br />an EOC Investment Justification (located in the Related Documents tab of the EMPG grants.gov posting) <br />to their Regional EMPG Manager for review. Additionally, recipients are required to submit a SF -424C <br />Form and Budget detail citing the project costs. <br />When applying for funds to construct communication towers Sub -Recipients must submit evidence that <br />the Federal Communication Commission's (FCC) Section 106 review process has been completed and <br />submit all documentation resulting from that review to Grants Program Directorate (GPD) prior to <br />submitting materials for EHP review. Sub -Recipients are also encouraged to have completed as many <br />steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination <br />with their State Historic Preservation Office to identify potential historic preservation issues and to discuss <br />the potential for project effects, compliance with all state and EHP laws and requirements). Projects for <br />which the Sub -Recipient believes an Environmental Assessment (EA) may be needed, as defined in as <br />defined in DHS Instruction Manual 023-01-001-01 Revision 01 FEMA Directive 108-1 and FEMA <br />Instruction 108-1-1, must also be identified to the FEMA EMPG 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 <br />gpdehpinfofema.aov. <br />EMPG Program Sub -Recipients using funds for construction projects must comply with the Davis -Bacon <br />Act (40 U.S.C. §§ 3141 et seq.). Grant Sub -Recipients must ensure that their contractors or <br />subcontractors for construction projects pay workers no less than the prevailing wages for laborers and <br />mechanics employed on projects of a character similar to the contract work in the civil subdivision of the <br />state in which the work is to be performed. Additional information regarding compliance with the Davis - <br />Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following <br />website: hftps://www.dol.gov/whd/govcontracts/dbra.htm <br />In general, Sub -Recipients should consult with their Grant Manager prior to making any investment that <br />does not clearly meet the allowable expense criteria established in this Guidance. <br />39 <br />