AFG awards: When is an EHP review required?
You must complete an Environmental and Historical Preservation review for AFG awards to ensure reimbursement
Recently, we have received several calls and emails from departments inquiring if their AFG award requires them to go through an Environmental and Historic Preservation Review. One department received an award for an in-station breathing air compressor and cannot access their funding because an EHP Review has not been completed and submitted to FEMA. Even though this sounds like a simple project, it has the potential to impact the environment and your building, and as such, a review is mandatory.
All modifications to facility activities and any renovation to facilities that would qualify as a modification to facilities supporting activities under training, equipment, PPE or wellness and fitness categories will require an EHP Review. Some equipment activities will require an EHP Review as well. Such activities include, but are not limited to, the installation of:
- Air compressor/fill station/cascade system (fixed) for filling SCBA
- Air quality systems
- Alarm/alerting systems
- Generators (fixed)
- Vehicle exhaust systems (fixed)
Why is a review required?
As a federal agency, DHS/FEMA is required to consider the effects of its actions on the environment and historic properties to ensure that all activities and programs funded by the agency, including grants-funded projects, comply with Federal EHP regulations, laws, and executive orders as applicable. Recipients proposing projects that have the potential to impact the environment, including but not limited to modification or renovation of existing buildings, structures and facilities must participate in the DHS/FEMA EHP Review process.
What do I have to do?
For a majority of AFG awardees, the EHP Review process involves the submission of a screening form that includes detailed project description that explains the goals and objectives of the proposed project. Basically, this is the information contained in the project description narrative of your AFG grant. Photos along with supporting documentation help DHS/FEMA to determine whether the proposed project has the potential to impact environmental resources and/or historic properties.
In some cases, DHS/FEMA is also required to consult with other regulatory agencies and the public to complete the review process. After submitting your EHP Review, you must wait until you receive notification that your review has been approved before expending any AFG funds.
EHP Policy Guidance can be found in FP 108-023-1, Environmental Planning and Historic Preservation Policy Guidance, and FP 108.24.4, Environmental Planning and Historic Preservation Policy.
What happens if I don’t complete an EHP Review?
The EHP Review process must be completed and approved before funds are released to carry out the proposed project. If you expend any funds prior to completing your EHP Review, FEMA will not reimburse you for these expenditures. In a similar fashion, if your EHP review has been completed but you have not received approval, you will not be able to draw down federal funds and any funds that you may have expended will not be reimbursed.
Failure to follow the EHP Review process could result in your grant award being disallowed and, in some cases, any grant funding that may have been expended recaptured.
If you have questions, please contact your regional FEMA office or your grant specialist.