1. 1 Environmental Planning and Historic Preservation (EHP) Compliance (p. 43-45) EHP Compliance

2. 2 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 EHP Compliance

3. 3 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 EHP Compliance

4. 4 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) EHP Compliance

5. 5 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 location http://www.fema.gov/hazard/map/firm.shtm EHP Compliance

6. 6 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 EHP Compliance

7. 7 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 EHP Compliance

8. 8 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. EHP Compliance

9. 9 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) EHP Compliance

10. 10 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 EHP Compliance

11. 11 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 EHP Compliance

12. 12 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? EHP Compliance

13. 13 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 EHP Compliance

14. 14 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) EHP Compliance

15. 15 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) EHP Compliance

16. 16 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=2 27106&relationtype=12311&overridesubtype=893&expand=1 https://www.rkb.us/FEMAGrants/LinkedToAELCats.cfm?content_id=2 27106&relationtype=12311&overridesubtype=893&expand=1  EHP Mailbox GPDEHPinfo@dhs.govGPDEHPinfo@dhs.gov - For EHP related questions EHP Compliance

17. 17 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? EHP Compliance

18. 18 EHP Points of Contact NameContact Information Adria Martínez adria.martinez@dhs.gov 202-286-2566 Marquietta Davismarquita.davis@associates.dhs.gov Brian Krevor brian.krevor@associates.dhs.gov Emily Luxemily.lux@associates.dhs.gov Marshall Popkinmarshall.popkin@associates.dhs.gov CSID askcsid@dhs.gov 800-368-6498 GPD EHP InformationGPDEHPinfo@dhs.gov EHP Compliance

19. Questions?