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library/assets/documents/90195, and further EHP guidance can be found at https://www.fema.gov/media library/assets/documents/118323. C. CONSTRUCTION AND RENOVATION Construction and renovation projects for a state, local, territorial, or Tribal government's principal Emergency Operations Center (EOC) as defined by the State Administrative Agency are allowable under the EMPG-ARPA Program. Written approval must be provided by FEMA prior to the use of any EMPG Program funds for construction or renovation. Requests for EMPG-ARPA Program funds for construction of an EOC must be accompanied by an EOC Investment Justification (located in the Related Documents tab of the EMPG- APRA grants.gov posting) to their Regional EMPG-ARPA Manager for review. Additionally, recipients are required to submit a SF -424C Form and Budget detail citing the project costs. When applying for funds to construct communication towers Sub -Recipients must submit evidence that the Federal Communication Commission's (FCC) Section 106 review process has been completed and submit all documentation resulting from that review to Grants Program Directorate (GPD) prior to submitting materials for EHP review. Sub -Recipients 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 Sub -Recipient believes an Environmental Assessment (EA) may be needed, as defined in as defined in DHS Instruction Manual 023-01-001-01, Revision 01 FEMA Directive 108-1 and FEMA Instruction 108-1-1, must also be identified to the FEMA EMPG 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 gpdehpinfo(a)fema.gov. EMPG-ARPA Program Sub -Recipients using funds for construction projects must comply with the Davis - Bacon Act (40 U.S.C. §§ 3141 et seq.). Grant Sub -Recipients must ensure that their contractors or subcontractors for construction projects pay workers no less than the prevailing wages for laborers and mechanics employed on projects of a character similar to the contract work in the civil subdivision of the state in which the work is to be performed. Additional information regarding compliance with the Davis - Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following website: https://www.dol.gov/whd/qovcontracts/dbra.htm In general, Sub -Recipients should consult with their Grant Manager prior to making any investment that does not clearly meet the allowable expense criteria established in this Guidance. D. PROCUREMENT All Procurement transactions will be conducted in a manner providing full and open competition and shall comply with the standards articulated in: • 2 C.F.R. Part 200; • Chapter 287, Florida Statues; and, • Any local procurement policy. Per 2 CFR 200.318 through 200.326, Sub -Recipients are required to adhere to certain procurement standards for entering contracts for personnel or services. This includes full and open competition, methods of procurement to follow, federal or passthrough entity review, and including federal provisions intro contracts. E. FINANCIAL CONSEQUENCES 43