For purposes of the PAS Pilot, FEMA will not delegate the environmental and historic preservation (EHP) review of HMGP and HMGP Post Fire subapplicant applications and pre-award amendments and subrecipient post-award amendments to the recipients. The statutory provision for the PAS Pilot does not provide sufficient authority to delegate EHP review to recipients for compliance with HMGP and HMGP Post Fire eligibility and EHP requirements. FEMA has final review and approval authority on the EHP impact of any proposed federal action or undertaking. However, recipients may assist FEMA with EHP review preparation (see refer to Part 3.I). Activities that assist FEMA with the preparation of the EHP review include completing project scope, describing the proposed activity and providing background information for assessing the environmental impact of the federal action on historic properties, threatened and endangered species, critical habitats, wetlands, floodplains and low-income and minority populations. Recipients should work with their subapplicants/subrecipients to evaluate and document environmental and cultural resource information involved with the proposed HMGP and HMGP Post Fire projects to consider alternatives to avoid, minimize and/or mitigate potential adverse impacts to the human environment and to integrate sustainable practices as early as possible in project formulation.
Before approving any subapplicant applications, pre-award amendments or subrecipient post-award amendments, recipients must coordinate with FEMA regional EHP staff to receive EHP clearance for approving HMGP and HMGP Post Fire subapplications and pre-award amendments and post-award amendments. HMGP and HMGP Post Fire assistance cannot be obligated until FEMA has completed the EHP review process. The Minimum Eligibility Criteria Checklist or equivalent documentation and the project summary that recipients agree to submit will provide the FEMA regional EHP staff with the information needed to complete EHP review in most cases. Recipients will be required to submit to FEMA regional EHP staff any additional information or documentation needed for FEMA to complete the review. Recipients must coordinate with the subapplicant/subrecipient to obtain additional information.