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ENVIRONMENTAL PLANNING & HISTORIC PRESERVATION (EHP) COMPLIANCE GUIDELINES Recipients must comply with all applicable EHP laws, regulations, and Executive Orders (EOs) in order to draw down their FY 2013 EMPG Program grant funds Any project with the potential to impact natural resources or historic properties cannot be initiated until FEMA has completed the required FEMA EHP review. Recipients that implement projects prior to receiving EHP approval from FEMA risk de -obligation of funds. For these types of projects, Recipients must complete the FEMA EHP Screening Form (OMB Number 1660-0115/FEMA Form 024-0-01) and submit it, with all supporting documentation to their Grant Manager. Recipients should submit the FEMA EHP Screening Form for each project as soon as possible upon receiving their grant award The Screening Form must be submitted prior to funds being expended Refer to IBs 329, 345, and 356 (located at http://www.fema.goy/government/grant/bulletins/index.shtm) The following types of EMPG projects are to be submitted to FEMA for compliance review under EHP laws and requirements prior to initiation of the project: • Any involvement with the installation of equipment; • Ground -disturbing activities; • New construction (installation and renovation), including communication towers, or modification/renovation of existing buildings or structures; • Proposed construction or renovation projects that are part of larger projects funded from a non -FEMA source (such as an EOC that is part of a larger proposed public safety complex), • Renovation of and modification to buildings and structures that are 50 years old or older; • Any other construction or renovation efforts that change or expand the footprint of a facility or structure including security enhancements to improve perimeter security; • Physical Security Enhancements, including but not limited to: • Lighting; • Fencing; • Closed-circuit television (CCTV) systems; • Motion detection systems; and • Barriers doors, gates and related security enhancements. • Field based training and exercises including activities that involve ground disturbance, use of explosives, toxic agents or otherwise have the potential to cause impact to the environment or historical resources. This is only a requirement if the exercise or field training is not being conducted by a certified professional or at an existing facility with established procedures; or • Communication tower projects. The following activities do not require the submission of the FEMA EHP Screening Form: planning and development of policies or processes; management and administration; classroom -based training table top exercises and functional exercises; and, acquisition of mobile and portable equipment (no installation) All recipients of financial assistance will comply with the requirements of the NEPA, as amended, 42 U.S.C. §4331 et seq., which establishes national policy goals and procedures to protect and enhance the environment, including protection against natural disasters. To comply with NEPA for its grant -supported activities, DHS requires the environmental aspects of construction grants (and certain non -construction projects as specified by the component and awarding office) to be reviewed and evaluated before final action on the application. For more information on FEMA's EHP requirements, see Informational Bulletins below: • Information Bulletin 329, Environmental Planning and Histor'c Preservation Requirements for Grants, available at http://www.fema.gov/pdf/government/arant/bulletins/info329.0df • Information Bulletin 345 Programmatic Environmental Assessment, available at http://www.fema.qov/pdf/governmentIQrant/bulletins/info345.pdf; and • Information Bulletin 356, EHP Screening Form, available at http://www.fema.gov/pdf/government/grant/bulletins/info356.pdf. 27 38 2%1