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What is an EHP Review? Involves an analysis of pertinent project information used to
determine the appropriate amount of documentation required for EHP compliance
All projects funded with Federal grant dollars must comply with EHP laws, regulations, and Executive Orders
Projects must be EHP approved before initiation GPD certifies that a grant-funded project is in compliance with
applicable EHP laws, regulations, and Executive Orders Complex projects will typically require more information to
reach a determination
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EHP Laws and Executive Orders
NEPA
National Historic Preservation Act
Endangered Species Act
Resource Conservation & Recovery Act
Clean Water Act
Coastal Zone Management Act
Coastal Barrier Resources Act
Clean Air Act
Executive Orders:Environmental Justice
Floodplains Wetlands
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What are EHP Considerations? Endangered Species Cultural Resources
•Historic properties •Archaeological sites
Air and Water Quality Noise Fish, Habitat & Wildlife Floodplains Wetlands Coastal Zones Agricultural Lands
Environmental Justice Socioeconomic Resources Land Use Hazardous Materials Traffic Geology (Topography, Soils)
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Floodplains and Wetlands Avoid to the extent possible adverse impacts to wetlands and
actions within or affecting floodplains If there is a reasonable alternative outside the wetland or
floodplain, FEMA will not fund the project within the wetland or floodplain
If the project impacts or may impact wetlands or a floodplain you should submit:- Section 404 and Section 10 permits (Wetlands)- National Wetlands Inventory Map showing project location
http://www.fws.gov/wetlands/Data/mapper.html- FEMA Flood Insurance Rate Map (FIRM) showing project
locationhttp://www.fema.gov/hazard/map/firm.shtm
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Coastal Zone Management Act (CZMA)
Goals: - Reduce uncontrolled development
on islands, beaches, salt marshes, transitional or inter-tidal areas, and other coastal areas
Applicability:- States with a shoreline in the
coastal zone or ones that border the Great Lakes
- All states in the coastal zone have a Coastal Zone Management Plan (CZMP)
- Be aware of the states CZMP and ensure that your project is in compliance
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Importance of Compliance
Compliance Non-Compliance
Protection of natural and cultural resources
Improved project planning Cost efficient Programmatic and financial
compliance Efficient project
implementation Improved community relations
Project delays De-obligation of funding Negative publicity Civil penalties Lawsuits
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GPD EHP Review Process Grantees are responsible for providing all relevant EHP
materials to GPD Grant funds may be used for preparation of EHP
documentation FEMA may be required to consult with State Historic
Preservation Office (SHPO), the U.S. Fish and Wildlife Service (FWS), etc.
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Roles and Responsibilities Grantees
-Responsible for EHP compliance- Submittal of all EHP review packets to GPD
GPD Program Analysts (PA)- Point of contact between the grantee or Fiduciary Agent,
GPD-EHP Team, and Regional Environmental Officer (REO)- Approval of projects with no potential for environmental
and/or historic preservation impacts (Type A)
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Roles and Responsibilities GPD-EHP Team
- Point of contact for PAs and REOs- Approval of projects with no potential for environmental and/or
historic preservation impacts if certain conditions apply (Type B) REO
- Review and approval of project with potential for environmental and/or historic preservation impacts (Type C)
- Responsible for State Historic Preservation Office (SHPO) consultation, with the assistance if necessary from GPD
- Liaison with grantees and GPD
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Type A Projects Sub-grantees do NOT need to submit the EHP screening
memo/EHP packet in these cases. State clearly in IJ “project has no potential for environmental and/or historic preservation impacts”. For training – state “classroom based”.
Projects with no potential for environmental and/or historic preservation impacts:- Planning- Classroom-based training and exercises- Field-based training at existing facilities with established
procedures- Personnel- Mobile and portable equipment (PPE, radios, etc.), vehicles, and
other equipment that does not require any installation
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Type B Projects Sub-grantees do not need to complete an EHP screening
memo/review packet if these projects have no potential for environmental and/or historic preservation impacts if certain conditions apply
Examples include:- Physical security enhancements- Equipment installation (structures less than 50 yrs old)
e.g. physical security/access controls
Typical questions- Does the project involve new ground disturbance or clearance
of vegetation?- Does project utilize existing infrastructure?- Will work occur in the vicinity of historic properties?- Will work occur in or near water?
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Type C Projects Sub-grantees MUST complete EHP screening
memo/review packet Projects that may have the potential for
environmental and/or historic preservation impacts:- Additional analysis and documentation may be
required to adequately address the impacts in compliance with applicable EHP laws and regulations- Environmental Assessments (EAs), Biological
Assessments (BAs), or Memoranda of Agreement (MOAs) may be required- Public involvement may be required
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Type C Example: Modification of Buildings & Structures 50 + Years Old
Equipment installation (e.g. physical security/access controls) on, in, or in the vicinity of historic buildings, piers, bridges, etc.
Building renovation/hardening (e.g. doors, gates, windows)
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EHP Review Packet A complete EHP review packet will provide the necessary
information to expedite the EHP review What are the required contents?
- Detailed project description- Physical address of structure/facility or lat/long- Clear color photographs (ground-level and aerial)- Dimensions/acreage/square footage of structure and/or land affected- Extent and depth of ground disturbance for:
• New construction and structure modification• Utility line placement• Fencing, light posts, etc., installations
- Height of communication towers- Special equipment being used, staging areas, etc.- Year building or structure was built (to include buildings or structures that
are in the vicinity)
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GPD EHP Updates
Programmatic Environmental Assessment (PEA) Screening Memo (see CD) Authorized Equipment List (AEL) Updated to reflect appropriate equipment
https://www.rkb.us/FEMAGrants/LinkedToAELCats.cfm?content_id=227106&relationtype=12311&overridesubtype=893&expand=1
EHP Mailbox [email protected] For EHP related questions
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Tips for a Timely EHP Review A clear and descriptive project description, with clear
color photos and maps Include any previous Master Plans or other
environmental documentation What work is being proposed, where will it take place,
and how will it be carried out?
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EHP Points of Contact
Name Contact InformationAdria Martínez [email protected]
202-286-2566Marquietta Davis [email protected]
Brian Krevor [email protected]
Emily Lux [email protected]
Marshall Popkin [email protected]
800-368-6498
GPD EHP Information [email protected]
EHP Compliance
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