INTRODUCTION TO GPDs ENVIRONMENTAL PLANNING

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INTRODUCTION TO GPDs ENVIRONMENTAL PLANNING
HISTORIC PRESERVATION (EHP) REVIEW
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GPD EHP Review Process

• GPD responsibility to integrate environmental and
  historic preservation considerations into its
  program planning and emergency preparedness
  activities.
• This is accomplished through GPDs Environmental
  Planning and Historic Preservation (EHP) Review
  process.

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GPD EHP Review Process

• Responsibility of the Grantee to provide EHP
  materials
• Mandated by Federal laws, regulations and
  Executive Orders included as a special condition
  in grant award
• Must be submitted before projects are initiated
• Grantee must comply with any conditions placed on
  project as result of EHP review

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Roles and Responsibilities

• GPD
• Incorporate EHP compliance requirements into
  grant programs, processes, and guidance
• Grantees
• Responsible for EHP compliance
• Submittal of all EHP Reviews packets to GPD
• GPD Program Analysts (PA)
• POC between the grantee, Regional Environmental
  Officer (REO), and GPD EHP
• Approval of projects with no environmental
  impacts

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Roles and Responsibilities

• GPD-EHP
• POC for PAs, OEHP, and REOs
• Approval of projects with minimal potential for
  environmental impact
• Office of Environmental Planning Historic
  Preservation (OEHP)
• POC for GPD EHP
• Oversight of projects with potential for
  environmental impacts
• REO
• Review and approval of project with potential for
  environmental impacts
• Responsible for State Historic Preservation
  Office (SHPO) consultation
• Follow up with grantees
• 1st reach out via email cc PA cc GPD EHP Liaison

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What are EHP Considerations?

• Endangered Species
• Cultural Resources
• Historic properties
• Archaeological sites
• Air water quality
• Noise
• Fish, Habitat Wildlife
• Floodplains
• Wetlands
• Coastal Zones
• Agricultural Lands

• Environmental Justice
• Land Use
• Hazardous Materials
• Traffic
• Geology (Topography, Soils)
• Socioeconomic Resources

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Environmental Impacts

• Ground disturbance
• Air/water pollution
• Habitat destruction
• Impacts to breeding/
• feeding areas or patterns
• Altered view sheds
• Alteration of historic properties

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EHP Laws and Executive Orders
Endangered Species Act
Executive Orders
Environmental Justice
National Historic
Floodplains
Preservation Act
Wetlands
NEPA
Clean Air Act
Coastal Barrier
Clean Water Act
Resources Act
Resource Conservation
Coastal Zone
Recovery Act
Management Act
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Purpose of EHP Review

• NEPA requires informed decision-making
• Protect our nations water, air, coastal, fish
  and wildlife, agricultural, historical, and
  cultural resources, as well as to minimize
  potential adverse effects to children,
  low-income, and minority populations

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EHP Resource Agencies

• EHP review may require consultation with but not
  limited to
• State Historic Preservation Office
• US Fish and Wildlife Service
• US Army Corps of Engineers
• National Marine Fisheries Service
• Natural Resources Conservation Service

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Additional Documentation

• May require preparation of written analyses or
  agreements required under EHP laws,
  including
• Environmental Assessment (NEPA)
• Biological Assessment (ESA)
• Memorandum of Agreement (NHPA)
• Some EHP laws and Executive Orders may require
  public involvement a public comment period

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Consequences of Non-Compliance

• Project delays
• De-obligation of funding
• Negative publicity
• Civil penalties
• Lawsuits

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Project Types that Trigger EHP Review

• New construction
• Modification of buildings / structures 50 years
  old
• Physical security enhancements
• Communication towers

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New Construction

• Security guard shed
• Dock/pier
• Boat house
• EOC
• Towers

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Physical Security Enhancements

• Installation of fencing, lighting,
• cameras, pedestrian or vehicle
• barriers, ID card readers, x-ray
• machines, etc.
• In particular
• Does the project involve ground
• disturbance or clearance of vegetation?
• Will work occur in the vicinity of
• historic properties?
• Will work occur in or near water?

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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)

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Communication Towers

• Tower height and design
• (lattice or guy wires)
• Use of aviation lighting
• Security fencing and lighting
• Equipment building
• Equipment staging area, access road

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Project Planning

• Take the following into consideration
• Complexity of the project
• Project location the types of resources
  affected
• Consultation with State Historic Preservation
  Office (SHPO) Fish and Wildlife Service (FWS)
  etc. (required under certain laws) if needed
• Grant funds may be used for preparation of EHP
  analyses

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Tips for a Timely EHP Review

• Take EHP considerations into account during
  project planning and budgeting
• Provide a complete EHP Review packet
• See Information Bulletin 271
• What work is being proposed, where will it take
  place, and how will it be carried out?

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Tips for a Timely EHP Review

• EHP review may increase timeline for project
  implementation
• Include Master Plans if available including
  previous environmental analysis or public
  involvement

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EHP Review Packet

• Complete and accurate project description is
  crucial to determine the applicability of EHP
  review and to expedite consultation with other
  federal, state and tribal agencies
• Dimensions/acreage/square footage of structure
  and/or land affected, in particular note height
  of communication towers

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EHP Review Packet

• Extent and depth of ground disturbance for new
  construction and structure modification,
  including laying of utility lines, installing
  fencing and light posts
• Special equipment that will be used, staging
  areas, and access roads, etc.
• Year any affected building or structure was built

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Visual Documentation

• Documentation to be included (equipment
  installation, ground disturbance, or
  construction/renovation of any kind)
• Aerial photograph with project area shown
  (http//earth.google.com/)
• Site photographs showing where equipment will be
  installed or where construction will occur
• FEMA Flood Insurance Rate Map (FIRM)
  (http//www.fema.gov/hazard/map/firm.shtm)
• Wetlands map (http//wetlandsfws.er.usgs.gov/)
• All photographs and maps MUST be color and good
  quality

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Helpful Resources

• FEMAs EHP website
• http//www.fema.gov/plan/ehp/
• EHP Guidance for FEMA Grant Applicants
• http//www.fema.gov/plan/ehp/ehp-applicant-help.sh
  tm
• Useful Information for Expediting the EHP Review
• eLearning Tool for FEMA Grant Applicants
• FCC Environmental and Historic Preservation
• http//wireless.fcc.gov/siting/environment.html

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EHP Points of Contact

• Adria Martínez
• adria.martinez_at_dhs.gov
• 202-286-2566
• Jeff Hall
• jeffery.hall1_at_dhs.gov
• 202-786-9778
• CSID
• 1-800-368-6498
• askcsid_at_dhs.gov

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