Understanding FEMA's Environmental and Historic Preservation review process
What are your fire department’s obligations and options when it comes to meeting FEMA’s requirement for EHP?
Applicants who submitted a 2020 Assistance to Firefighters Grants (AFG) application may soon receive notification that their application is being considered for an award, pending completion of needed documents by FEMA. One reason for this message is the need to complete an Environmental and Historic Preservation review.
It’s important to understand your obligations and your options under the Environmental and Historic Preservation (EHP) review process.
Why Is an EHP Review Needed?
As a federal agency, FEMA is required by law to consider the effects of funding grant applications that may impact the environment or historic properties. This ensures all activities and programs funded by the agency comply with applicable federal EHP regulations, laws, Executive Orders, regulations and policies.
AFG applicants proposing projects that have the potential to impact the environment, such as modification or renovation of existing buildings, must participate in the FEMA EHP review process. This includes activities like installation of a diesel exhaust removal system, a fire alarm system, sprinkler system, telecommunications tower, washer, dryer or a breathing air station.
The Environmental and Historic Preservation review process involves the submission of a screening form that includes a detailed project description along with supporting documentation so that FEMA may determine whether the proposed project has the potential to impact environmental resources and/or historic sites. In some cases, FEMA may also be required to consult with other regulatory agencies and the public to complete the review process.
When Does EHP Review Occur?
The Environmental and Historic Preservation review must be addressed before starting your project. Federal law requires EHP review to be completed before federal funds are released to carry out proposed projects. Grant recipients must receive confirmation of a completed EHP review from FEMA prior to beginning project activities. FEMA may not be able to fund projects that are not in compliance with applicable EHP laws, Executive Orders, regulations and policies. FEMA will also deny your request to draw down funds from your AFG award if an EHP review has not been submitted and approved.
In the past applicants had to wait until awards were announced to start their Environmental and Historic Preservation review. With the opening of the FEMA GO portal in 2019, applicants can now submit their completed EHP review at the same time as their AFG application. Submitting your EHP review in this fashion does not guarantee that you will be funded, but it can speed up the funding process if you are selected.
In recent years FEMA has developed a library of EHP resources, including checklists and other guidance, to assist with the EHP review process, plus funding guidance, cultural and structural mitigation considerations, and more. In addition, FEMA has developed a four-hour online course, Overview of FEMA's Environmental and Historic Preservation Review, for interested individuals. The interactive computer-based course provides an overview of FEMA's environmental and historic preservation compliance responsibilities. It is designed to provide the user with the basic background and practical knowledge needed to participate in FEMA's Environmental and Historic Preservation review process and provide the resources necessary for the user to accomplish EHP review responsibilities.
Recently FEMA has permitted appropriate AFG awardees to file for a waiver from completing the Environmental and Historic Preservation review. FEMA has opened this avenue to applicants whose projects don’t propose to disturb any environmental or historic resources. For example, a fire department was awarded AFG funding to purchase and install a dryer. The department decided to go with a free-standing cabinet-style dryer that did not require a vent. The placement of the dryer would be at a location in their station that already had an appropriate electrical outlet. FEMA allowed the department to apply for a waiver rather than completing an EHP review, and the waiver was granted.
If you feel your FEMA grant-funded project meets the benchmark for an EHP review waiver, speak with your program officer about submitting one as soon as you receive your award notification.
An Important Step
Although Environmental and Historic Preservation review may seem like another bureaucratic step in an already onerous grant award process, understanding your obligations and options can take some of the pain out of it. If you can reasonably conclude your project will be subject to EHP review, you might want to use the resources FEMA provides to prepare your review form when submitting your application. And if you think your project will fall outside the realm of EHP review, start working to secure a waiver now.