1 Demystifying Environmental and Historic Preservation (EHP) Compliance EHP Compliance

Agenda Why EHP Reviews Are Required Pete Lara / State Administrative Agency / Grant Coordinator Kevin Jaynes / DHS–Region VI / Regional Environmental Officer How to Submit an EHP Packet Ana-Jo Mounce / State Administrative Agency / Grant Coordinator Questions 2

WHY EHP REVIEWS ARE REQUIRED 3

4  All projects funded with Federal grant dollars must comply with EHP laws, regulations, and Executive Orders  Projects must be EHP approved before initiated  FEMA may be required to consult with State Historic Preservation Office (SHPO), the U.S. Fish and Wildlife Service (FWS), etc. EHP Compliance Before We Begin…

WHEN Do I Need EHP Approval for a Project? 5

Typical Projects Requiring EHP:  Generators  Repeaters  Antennas  Base Stations  Cameras  Access Readers  Cabling  Satellite Equipment 6  New Construction  Concrete Pads  Communications Towers  Roads  Bridges  Exercises – When not at specialized facilities

7 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

8 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

9 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 = $0 goes to Sub-grantee  Negative publicity  Civil penalties  Lawsuits EHP Compliance

SAA Notifies the Subrecipient GPD Approves/Denies Project & Sends Notification to the SAA 10 Subrecipient Completes EHP Submission Packet SAA Reviews the EHP Packet SAA Submits the Packet to GPD GPD Returns to SAA for Corrections or Additional Information SAA Returns to Subrecipient for Corrections or Additional Information GPD Submits to SHPO for Review EHP Submission Process How It Flows…

11 Roles and Responsibilities  Sub-grantees - Responsible for EHP compliance - Submittal of EHP review packet to SAA after gathering information, photos and maps. NOTE: Grant funds may be used for preparation of EHP documentation  Grantee (SAA) - Responsible for EHP compliance - Review Sub-grantee Packet - Submit packet to GPD-EHP Team - Serve as the official Liaison More Information, if necessary Submit “status check” inquiries Notify Sub-grantee of FEMA project approval EHP Compliance

12 Roles and Responsibilities – cont.  Grants Program Directorate (GPD) – FEMA/EHP Team - Approval of projects with no potential for environmental and/or historic preservation impacts if certain conditions apply (Type A and Type B)  Regional Environmental Officer (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

13 Type A Projects 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

14 Type B Projects Projects with 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) 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

15 Type C Projects Projects that may have the potential for historic and/or environmental preservation impacts - Additional analysis and documentation may be required to adequately address the impacts in compliance with applicable EHP laws and regulations EHP Compliance - Environmental Assessments (EAs), Biological Assessments (BAs), or Memoranda of Agreement (MOAs) may be required - Public involvement may be required

16 Type C Example: Modification of Buildings & Structures 50 + Years Old  Equipment installation on/in/or in the vicinity of historic buildings, piers, bridges, etc.  Building renovations and/or hardening  Examples: - Gates - Bollards - Access Control Systems - Security Cameras EHP Compliance

HOW TO SUBMIT AN EHP REVIEW PACKET 17

18  Subject matter experts review submissions to determine if the project will have an historical or environmental impact  Complex projects will typically require more information and more time to reach a determination  Sub-grantees are responsible for providing all relevant EHP materials to the SAA for submission to GPD EHP Compliance Before We Begin…

19 EHP Review Packet A properly completed EHP review packet will provide the necessary information to expedite the EHP review. Always Required:  Screening Form  Photographs Sometimes Required:  Maps EHP Compliance

Screening Form - Project Information 20

21 The DHS Grant Award Number can be found on your Sub Recipient Award (SRA) or a Grant Adjustment Notice (GAN)

Screening Form - Project Type 22 Enter additional information where indicated

Screening Form - Project Description 23 The project description should contain a brief summary of WHAT specific action is proposed, WHERE it is proposed, and HOW it will be implemented.

Screening Form – Project Description Samples 24

Screening Form – Project Type Sample 25

Screening Form – Project Type Sample 26

Screening Form –Resource Impacts 27

Screening Form – Other Information 28 Double Click on Box or Entry Fields to Open Window

Screening Form – Migratory Birds 29

Photographs & Graphics – Best Practices  Photographs and other Graphics should show the installation location and context  Copy the image, and paste it into Microsoft Paint, Microsoft Power Point, or graphics software  Using the tools such as line drawing and fill colors, label exactly where project features will take place  Cut and paste completed drawing into Word document and include explanatory text 30

31 Photographs & Graphics - Aerial

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Photographs & Graphics – Aerial 33

Photographs & Graphics – Ground Level 34

Photographs & Graphics – Ground Level 35

Photographs & Graphics – Installation Labels 36

Photographs & Graphics – Installation Labels 37

Photographs & Graphics – Installation Labels 38

Photographs & Graphics – Installation Labels 39

Photographs & Graphics – Installation Labels 40

Photographs & Graphics – Installation Labels 41

Photographs & Graphics – Installation Labels 42

Photographs & Graphics – Topographic Map 43

Photographs & Graphics – Floodplain Map 44

45 Photographs & Graphics – Floodplain Map

Photographs & Graphics – Wetlands Map 46

47 Online Mapping and Information Resources National Register of Historic Places: FEMA’s Flood Insurance Rate Maps (FIRMs): National Wetlands Inventory: USDA Soil Survey Map:

48 In Summary - Tips for a Timely EHP Review  Submit materials as soon as you receive your award notice or in your planning phase  A clear and thorough project description: What work is being proposed, where will it take place, and how will it be carried out  Properly labeled color photos and maps  Include any previous Master Plans or other environmental documentation LOOK at Authorized Equipment List (AEL) under the Responder Knowledge Base (RKB) to identify equipment that may require EHP review. EHP Compliance

49 When You Need Help… SAA GRANT COORDINATORS Pete H. Lara txdps.state.tx.us / Ana-Jo txdps.state.tx.us Bryan Hatfield txdps.state.tx.us Arturo txdps.state.tx.us Sherry txdps.state.tx.us Bill txdps.state.tx.us Kenneth txdps.state.tx.us Shane txdps.state.tx.us EHP Compliance /

Resources State Administrative Agency Website FEMA EHP Program Homepage SPARS Forms (Admin Menu) 50

Questions?