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FEMA POLICY 

 Grant Programs Directorate 

Environmental Planning and Historic 

Preservation Policy Guidance

FEMA Policy #108-023-1

BACKGROUND 

All Federal Emergency Management Agency (FEMA) Directorates are responsible for their 

activities’ Environmental Planning and Historic Preservation (EHP) legal compliance 

requirements. However, the Grant Program Directorate’s (GPD) recipients and subrecipients 

also have significant roles in assisting FEMA with those responsibilities and this policy directs 

recipients and subrecipients in their legal compliance. This policy applies to all non-disaster 

Preparedness Grants and Fire Grants, administered and managed by FEMA GPD. 

PURPOSE 

This policy is intended to ensure that all FEMA GPD non-disaster grant programs and activities 

comply with applicable Federal EHP laws, Presidential Executive Orders (EOs) and regulations. 

PRINCIPLES 

A. Provide clear guidance to FEMA grant recipients on their requirements for completing the 

EHP compliance review process. 

B. Provide clear, simple statements of how FEMA intends to implement its authorities, actions, 

and/or programs. 

REQUIREMENTS 

A. EHP Screening Form 

Outcome: Provide a clear and comprehensive process for applicants on the EHP review 

process required for GPD-funded projects 

1. Recipients or subrecipients proposing projects that involve changes to the natural or built 

environment, including but not limited to construction of communication towers; 

modification or renovation of existing buildings, structures, facilities, and infrastructure; or 

that involve new construction, including replacement or relocation of facilities, must 

participate in the EHP review process. The EHP review process involves submission of a 
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detailed project description, the proposed project’s purpose and need (goals and/or 

objectives), and supporting documentation to GPD for their evaluation to determine if the 

proposed project may impact environmental resources and/or historic properties. 

2. In order to standardize and streamline this review process, GPD developed an EHP 

Screening Form and received Office of Management and Budget (OMB) approval to use 

the Form. The EHP Screening Form has been assigned a FEMA Form Number (024-0-1) 

and an OMB Number (1660-0115). Recipients and subrecipients are required to submit a 

completed EHP Screening Form for all GPD-funded projects except those projects 

delineated in Section B below. The EHP Screening Form is an integral part of the GPD 

projects’ EHP review and must be completed in full and accurately, and submitted to GPD 

by the direct recipient of FEMA funds. While the EHP Screening Form has been designed 

to be a comprehensive compilation of required information, GPD may request additional 

information on the proposed project under review. 

3. The EHP Screening Form and associated photographs, maps, and other relevant 

documents are submitted to GPD in order to begin the projects’ EHP review. Recipients 

and/or subrecipients are encouraged to use the most recent version of the EHP 

Screening Form for all EHP review submissions for GPD-funded projects. 

4. To help ensure EHP compliance, recipients, including State Administrative Agencies, are 

responsible for providing the EHP Screening Form to their subrecipients before their 

subrecipients start their projects. The EHP Screening Form must be submitted to GPD, 

and the EHP review of the project must be completed, before funds are released to carry 

out the proposed project. 

5. Timelines for the completion of the EHP review for each project will vary depending on 

the proposed project’s complexity, the project grant application and supporting 

documents’ completeness and accuracy, and the project’s potential to impact 

environmental resources and/or historic properties. An EHP review may take 30 to 45 

working days for proposed activities having little potential to impact environmental

resources and/or historic properties (i.e., EHP resources). A project that has the potential 

for significant impacts on EHP resources, such as new construction or installation of 

communication towers greater than 200 feet, may take up to one year or more to review. 

During the project planning phase, recipients and subrecipients should consider these 

timelines and allot sufficient time for their projects’ EHP reviews.

6. Inadequate project descriptions or documentation of the presence of environmental 

resources and historic properties in a project site and surrounding project area may 

significantly delay the review timeliness and delay project implementation. Recipients and 

subrecipients are responsible for providing all necessary documentation, as well as 

responding to requests for additional information, in a timely manner. Recipient or 

subrecipient failure to meet all applicable Federal, State, Tribal, and local EHP legal 

requirements, to comply with project conditions established during the EHP review, or to 

obtain applicable permits and approvals may result in project delays or loss of funds. 
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7. The EHP Screening Form and Instructions will help in gathering all necessary information 

for an effective EHP review. Completed EHP Screening Forms should be forwarded to 

GPD’s EHP Team at GPDEHPinfo@fema.dhs.gov. Additionally, questions about an EHP 

Screening Form’s status, request for technical assistance, or for any questions related to 

the EHP review process, may be addressed to the assigned GPD Program Analyst or the 

GPD EHP Team by e-mail at GPDEHPinfo@fema.dhs.gov. 

8. Costs incurred to comply with FEMA’s EHP requirements are the responsibility of 

recipients. Recipients may use grant funds or the recipient’s own funds for these costs. 

FEMA will not amend grant awards to provide additional funds to cover these costs. See 

FEMA GPD Information Bulletin 404, issued on April 13, 2015, for additional information. 

B. Streamlined EHP Review of GPD Projects

Outcome: Provide a streamlined EHP review process for certain types of GPD-funded 

projects 

1. FEMA has determined that some GPD project types have no environmental impacts, as 

documented in the 2010 Programmatic Environmental Assessment (PEA).1 Recipients 

and subrecipients are not required to provide any further EHP documentation for project 

types identified in the PEA. Specifically these project types include: 

a. Planning: Development of policies, plans, procedures, mutual aid agreements, 

strategies, and other publications that comply with relevant laws, EOs, regulations, 

and guidance and are needed to perform assigned missions and tasks. 

b. Management and Administration: Hiring personnel; overtime and backfill expenses. 

This includes regular-time operational costs for existing positions assigned to full-time 

counterterrorism duties; development, revision, documentation, and/or distribution of 

regulations, directives, manuals, Information Bulletins, and other guidance 

documents; technical assistance activities that involve no resources other than 

manpower and/or funding; and other personnel, administrative, fiscal and 

management activities that involve no resources other than manpower or funding. 

c. Classroom-based Training: Training conducted in a classroom setting to include the 

establishment, support, conducting, and attendance of classroom-based training. This 

excludes training involving any hazardous activities, hazardous materials, toxic waste, 

or other controlled substances or materials. Training topics may include, among 

others, chemical, biological, radiological, nuclear, and explosives (CBRNE) 

responsiveness, national security threats and catastrophic events, 

cyber/agriculture/food security, intelligence gathering and analysis, citizen and 

community preparedness, and volunteers’ training.

 

1 http://www.fema.gov/media-library/assets/documents/18407
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d. Table-top Exercises and Functional Exercises: These include seminars, workshops, 

tabletop exercises, and games. These types of exercises are only hypothetical actions 

on the part of the participants, and are strictly notional. Functional exercises are a type 

of operations-based exercise that examine and/or validate the coordination, command, 

and control between various multi-agency coordination centers, such as emergency 

operation centers and joint field offices. A functional exercise does not involve any 

"boots on the ground", or first responders or emergency officials responding to an 

incident scenario in real time. All actions are simulated and may include CBRNE, 

cyber, agricultural, and natural or technological disaster scenarios. 

Note on drills and full-scale exercises: Recipients contemplating training and exercises 

that fall into the categories of drills or full-scale exercises (i.e., activities not exempted 

by the PEA), will need to submit the EHP Screening Form. Examples of drills or fullscale exercises are any type of explosive, chemical, biological, radiological, or fire 

scenario, including training exercises that are not executed at a facility that has been 

previously approved for such use. An EHP Screening Form will not need to be 

provided for those exercises that are planned to take place at previously approved 

facilities, such as, fire and police academies, search and rescue training facilities, and 

explosive testing centers. Any type of exercise that requires any type of land, water, or 

vegetation disturbance or building of temporary structures must undergo an EHP 

review. 

e. Purchase of Mobile and Portable Equipment (no installation): These are equipment 

devices that do not require any fixed installation and may be transported, such as 

hand-held radios, personal protective equipment (PPE), mobile/satellite phones, dive 

equipment, boats, response and mobile command vehicles, and other similar devices 

that do not require installation. 

C. EHP Requirements for GPD-Funded Communications Projects

Outcome: Applicants understand when an EHP Screening Form and review is required 

for GPD-funded communications projects 

1. When upgrading communications systems or otherwise implementing communications 

projects, FEMA’s recipients or subrecipients carry out a wide range of activities, from 

replacing and retuning mobile and portable equipment to replacing or upgrading fixed 

equipment to constructing communication facilities. GPD has identified several 

communications projects that will NOT require the submission of the EHP Screening 

Form or any other documentation. Those activities are: 

a. Software upgrades and/or retuning/reprogramming of existing equipment. 

b. Purchase of mobile and portable or plug-in equipment where no equipment 

requires permanent installation in or on existing buildings or structures. 
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c. Replacement of components within existing consoles, sirens or radios. 

2. FEMA-funded communications projects or activities involving installation of equipment on 

or in existing buildings or structures and all other communications projects not described 

above will require the completion of an EHP Screening Form as described in Section A 

above. 

D. National Historic Preservation Act (NHPA) Section 106 Review Requirements for 

Communication Facilities

Outcome: Applicants understand and comply with the process and requirements for the 

collaborative approach for NHPA Section 106 Review for Communications Facilities. 

1. GPD funds a variety of projects related to communication facilities, including the 

construction, replacement, or repair of towers as well as the installation or repair of

associated equipment such as antennas or repeaters. NHPA Section 106 requires

Federal agencies to take into account the effect of their undertakings on historic properties 

through consultation with the relevant State Historic Preservation Office (SHPO), Tribal 

Historic Preservation Office for Federally-recognized tribes, and Native Hawaiian 

organizations. 

2. Many GPD-funded towers are also regulated by the Federal Communications Commission 

(FCC), and the FCC as a Federal agency is required to comply with Section 106. The FCC 

has executed two Programmatic Agreements (PAs) with the Advisory Council on Historic 

Preservation (ACHP) which were put in place to streamline and expedite the Section 106 

review of the project. These PAs are as follows: 

a. The Nationwide Programmatic Agreement for Review of Effects on Historic Properties 

for Certain Undertakings Approved by the Federal Communications Commission 

(Nationwide PA) (October 2004) 

b. The Nationwide Programmatic Agreement for the Collocation of Wireless Antennas 

(FCC Collocation PA) (March 2001). 

3. The ACHP issued a Program Comment (Issued in 2009, amended in 2015) on the 

Nationwide PA and the FCC Collocation PA to avoid duplicating the FCC’s Section 106

reviews when other Federal agencies are funding communications projects and, thus, 

required to comply with Section 106. Under this guidance, FEMA may adopt the FCC’s

Section 106 findings and, as such, does not have to complete its own Section 106 

process for the effects of the construction or modification of communication facilities. If, 

however, the proposed GPD-funded communication facilities project contains additional

components not covered by the FCC’s Section 106 review, GPD must ensure compliance 

with Section 106 and complete appropriate consultations. 
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4. For GPD-funded projects, the Program Comment only provides exemptions from Section 

106 requirements; the Program Comment does not provide exemption from any other 

EHP laws, EOs, regulations, or consultation process. 

5. GPD recipients and subrecipients must complete the FCC’s Section 106 review process

using the National Historic Preservation Act Section 106 Review Requirements for 

Communication Facilities when submitting the EHP Screening Form to GPD for review. 

This will enable FEMA and GPD to determine if the proposed project complies with 

Section 106 under FCC’s PAs and process or if FEMA must comply through its own 

Section 106 consultation. 

6. Questions about the Section 106 review process should be directed to the designated

GPD Program Analyst or through email at GPDEHPinfo@fema.dhs.gov.

E. Projects Initiated or Completed without EHP Review 

Outcome: Applicants and FEMA/GPD comply with Federal environmental planning and 

historic preservation laws and executive orders by completing EHP reviews before GPDfunded projects are initiated or completed. 

1. It is FEMA policy to coordinate with applicants as early as possible in order to comply with 

Federal EHP laws and executive orders, including the review process required by NEPA. 

2. GPD grant applicants proposing actions described in Section A of this Policy must submit an 

EHP Screening Form and wait for the completion of EHP review before work on the project 

can begin. 

3. If an EHP Screening Form is submitted for a project that has already been initiated and/or 

completed, or if work is initiated and/or completed during the course of EHP review, the 

project may not be funded, depending on the scope of work, the level of NEPA review 

required, and any EHP regulations that apply. These reviews are limited to the criteria 

defined in FEMA Instruction 108-1-1 Section 3.7. (link to FEMA Instruction 

(https://www.fema.gov/media-library/assets/documents/118323)

4. It is at the discretion of FEMA to determine if a project complies with Federal EHP laws 

and executive orders. 
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F. Contact Information 

Outcome: Provide a single point of contact for applicants to submit EHP review information, 

and to get answers to EHP review questions.

1. All EHP materials should be submitted to the GPD-EHP Inbox 

(GPDEHPinfo@fema.dhs.gov) which is capable of receiving files up to 15 MB in size. 

This policy represents FEMA's interpretation of a

____________________________________

Bridget Bean 

Acting Assistant Administrator for Grant Programs

____________________________________ 

Date 

 statutory or regulatory requirement and/or sets forth 

standard operating procedures. The policy itself does not impose legally enforceable rights and 

obligations, but sets forth a standard operating procedure or agency practice that FEMA employees 

must follow to be consistent, fair, and equitable in the implementation of the Agency's authorities.
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ADDITIONAL INFORMATION

REVIEW CYCLE

FEMA Policy 108-023-1, Grant Programs Directorate Environmental Planning and Historic

Preservation Policy Guidance will be reviewed, reissued, revised, or rescinded within four (4)

years of the issue date. 

AUTHORITIES

Environmental planning and historic preservation legal compliance is governed by the following

authorities:

A. National Environmental Policy Act of 1969, as amended (PL 91-190)

B. National Historic Preservation Act of 1966, as amended (PL 89-665)

C. Endangered Species Act of 1973, as amended (PL 93-205)

D. Fish and Wildlife Coordination Act, as amended (PL 73-121)

E. Migratory Bird Treaty Act of 1918, as amended (PL 65-186)

F. Bald and Golden Eagle Protection Act of 1940, as amended (PL 76-567)

G. Magnuson-Stevens Fishery Conservation and Management Act, as amended (PL 94-265)

H. Clean Water Act, as amended (PL 92-500)

I. Wild and Scenic Rivers Act, as amended (PL 90-542)

J. Coastal Barrier Resources Act, as amended (PL 97-348)

K. Coastal Zone Management Act, as amended (PL 92-583)

L. Clean Air Act of 1963, as amended (PL 88-206)

M. Resource Conservation and Recovery Act, as amended (PL 94-580)

N. Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as 

amended (PL 96-510)

O. Farmland Protection Policy Act (PL 97-98)

P. FEMA Directive 108-1: Environmental Planning and Historic Preservation Responsibilities 

and Program Requirements

Q. FEMA Instruction 108-1-1: Instruction on Implementation of the Environmental Planning and 

Historic Preservation Responsibilities and Program Requirements

R. Department of Homeland Security Directive 023-01: Implementation of the National 

Environmental Policy Act

S. 40 CFR Part 1508, Protection of Environment, Terminology and Index

T. 36 CFR Part 800, Protection of Historic Properties

U. Executive Order 11988, Floodplain Management, May 24, 1977

V. Executive Order 11990, Protection of Wetlands, May 24, 1977

W. Executive Order 12898, Federal Actions to Address Environmental Justice in

Minority Populations and Low-Income Populations, February 16, 1994

X. Executive Order 13112, Invasive Species, February 3, 1999
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DEFINITIONS

A. Environmental Assessment is defined as a National Environmental Policy Act (NEPA)

document consisting of the analysis of a proposed federal action on the quality of the 

human environment.

B. Historic Property is defined as a property that is listed in, or eligible for listing in, the 

National Register of Historic Places.

C. Major Federal Action is defined as an action with effects that may be major and 

potentially subject to Federal control and responsibility. “Major” reinforces but does not 

have meaning independent of “significantly” (see 40 CFR § 1508.27). Actions include 

new and continuing activities, including programs and projects entirely or partly funded, 

assisted, conducted, regulated, or approved by Federal agencies and approval of specific 

projects such as construction or management activities located in a defined geographic 

area including actions approved by permit or other regulatory decision as well as Federal 

and Federally assisted activities.

D. National Historic Preservation Act (NHPA) Section 106 is defined as a process that 

requires Federal agencies to take into account the effects of their undertakings on historic

properties, and afford the ACHP a reasonable opportunity to comment. The historic

preservation review process mandated by Section 106 is outlined in regulations issued by

ACHP.

E. Programmatic Environmental Assessment is defined as a NEPA document 

including the analysis of multiple individual actions’ individual and cumulative 

environmental impacts, or impacts that are generic or common to a class of proposed 

Federal agency actions.

F. Recipient is a non-Federal entity that receives a Federal award directly from a 

Federal awarding agency to carry out an activity under a Federal program. The term 

recipient does not include subrecipients.

G. Regional Environmental Officer/Deputy Regional Environmental Officer is defined 

as the individuals in each of FEMA’s 10 regions that provide environmental planning and 

historic preservation technical assistance, guidance, and other services for all FEMA 

Programs in the region.

H. State Historic Preservation Office (SHPO) is defined as offices established in all States 

and Territories that were created by the Federal government in 1966 under NHPA 

Section 101 to help Federal agencies administer the Section 106 review process (see 

NHPA Section 106, above) in their state or territory. Each SHPO has a State Historic 

Preservation Officer to administer their programs.
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I. Subrecipient is defined as a non-Federal entity that receives a subaward from a passthrough entity to carry out part of a Federal program; but does not include an individual 

that is a beneficiary of such program. A subrecipient may also be a recipient of other 

Federal awards directly from a Federal awarding agency.

J. Tribal Historic Preservation Office(r) is defined as an office(r) designated by a 

Federally-recognized Indian tribe to assume SHPO functions on Tribal lands as 

authorized by NHPA Section 101(d)(2) provisions.

K. Undertaking is defined as a program, project, or activity funded in part or whole under 

the direct or indirect jurisdiction of a Federal agency, including those carried out by or on 

behalf of a Federal agency; those carried out with Federal financial assistance; and, 

those requiring a Federal permit, license or approval.

MONITORING AND EVALUATION

FEMA’s Office of Environmental Planning and Historic Preservation (OEHP) will monitor the 

GPD EHP Branch implementation of the processes outlined in this document as well as 

Regional Environmental Office (REO) involvement in GPD’s EHP review process. In 

addition, input from recipients on the clarity and usefulness of this policy will be used to 

determine if this policy is working as intended, and if and how the policy should be revised 

in the future. 

QUESTIONS

Please address any questions or concerns regarding this policy to FEMA- GPDPolicy@fema.dhs.gov.