HMGP EHP Checklist

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Safeguarding Tomorrow Through Ongoing Risk Mitigation Revolving Loan Fund 
Loan Recipient Project Environmental and Historic Preservation Information Checklist 
Overview 
The Loan Recipient Project Environmental and Historic Preservation Information Checklist is a resource to enable loan recipients to compile all relevant information required by a FEMA Environmental Planning and Historic Preservation (EHP) review. This checklist should be used once loan recipients have confirmed their proposed project will receive funding from a loan distributing entity’s (entity) entity loan fund under the Safeguarding Tomorrow Through Ongoing Risk Mitigation Revolving Loan Fund (Safeguarding Tomorrow RLF) program. Hazard Mitigation Assistance (HMA) Environmental Review Job Aids are available to help in completing the checklist. Information on accessing these Job Aids is available in the “Direction for Completing this EHP Checklist” section below. Loan recipients should submit completed checklists to the entity, who will manage the submission of checklists to FEMA for EHP review. 
During the EHP review process, the potential impacts of a project on the human and natural environment are evaluated to comply with federal laws, regulations, and executive orders, and may require formal consultation with federal, state, tribal, regulatory, and permitting agencies. The EHP review process requires the loan recipient to submit a detailed project description along with any associated photographs, maps, and other relevant documents and any supporting documentation requested by the entity or FEMA. FEMA will collaborate with entities to ensure the EHP review is completed in accordance with all applicable requirements. 
Loan Types that Do Not Require Checklist Submittal
Capability and Capacity-Building Activities
FEMA has determined that some loan activity types are administrative in nature and do not have the potential to have a significant effect on the human environment. Entities and loan recipients do not need to submit the checklist for the activity types listed below:
    • Building Code Adoption and Enforcement: The use of funds to enable units of local government to establish and carry out the latest published editions of relevant building codes, specifications, and standards
    • Zoning and Land-use Planning: The use of funds for the development and improvement of zoning and land use codes, creation of agricultural risk compensation districts, the study and creation of land use incentives, or the study and creation of an erosion response plan
    • Hazard Mitigation Planning: The use of funds to develop a mitigation plan that outlines a process for identifying natural hazards, risks, and vulnerabilities under the jurisdiction of the government
HMA Cost-Sharing
An entity loan fund may provide loans to be used as matching funds for the non-federal cost share of a grant under one of FEMA’s HMA grant programs, provided that the use is otherwise in accordance with all applicable legal and programmatic requirements. In this situation, FEMA will conduct the EHP review process following the procedures of the FEMA HMA grant program. Thus, projects in this category do not require submission of the EHP checklist for Safeguarding Tomorrow RLF loan compliance. Environmental and historic preservation information should be submitted to FEMA through the HMA grant application process.
Direction for Completing this Checklist
Submit the completed form and all other pertinent project information to your entity point of contact. The entity will then manage all EHP Checklists and submit them to FEMA. Please use the following format for the subject line: “EHP Submission: [Project Proposal List ID Number], [Activity Title], [Loan Recipient]” (For example: EHP Submission: 12345, Stormwater Management Project, Any Town, Entity). Failure to provide all of the information required by this EHP checklist may result in delays in the release of loan funds because this information would likely be obtained through a Request for Information (RFI) process. Be advised that completion of this form does not complete the EHP review process. You will be notified by the entity when your review is complete or if additional information is required. 
This checklist should be used in conjunction with the HMA Environmental Review Job Aids, which provide detailed information about documentation required to carry out the EHP review of a project. The Job Aids are published in FEMA’s library, https://www.fema.gov/grants/mitigation/job-aids. To access these guides, search “environmental review” in the search box and select the job aid for the correct project type. 
Standard Hazard Mitigation Projects
Standard Hazard Mitigation Projects are projects that require construction, including but not limited to retrofits, acquisition of flood-prone properties, hazardous fuels reduction, and flood risk reduction projects. Because of the potential to impact environmental and historical resources from construction and operational activities, an EHP review is generally required. Loan recipients must not start physical work before the FEMA EHP review of the project is complete. Projects where actual physical activity such as groundbreaking, construction, or demolition has commenced prior to completion of EHP review, are ineligible.
As part of the project application development, the loan recipient should provide documentation that accurately describes the project so that a federal EHP compliance review can be conducted. The level of detail should provide information on the environmental and cultural resources that may be impacted by the proposed project, its purpose and location, existing environmental conditions in the project area, potential project impacts, best management practices (BMPs), different alternatives considered for the project, and mitigation strategies to address environmental impacts of the project.
The gathering of this information may include readily available information or data from relevant sources but may also necessitate completing relevant EHP-specific technical studies or surveys, coordination with relevant regulatory and permitting agencies, and pertinent documentation completed by local, state, or federal agencies. Completion of some technical EHP studies may require the hiring of a consultant. 
Designs for projects should be developed to the point where the design clearly identifies the location, as well as the methodology for project construction, implementation, and operation. For some projects, the design may be conceptual or preliminary engineering. For others, it may require at least 60 percent design to allow for those details to be clearly defined. 
Any ground disturbing studies (including borings for Geotechnical studies, shovel test pits for archaeological surveys, and wells for subsurface water testing) must be identified in these project applications, and their location and methodology described using the same checklist criteria as a standard project review.

Standard Project EHP Review
The following checklist provides instructions to identify the key details needed to conduct an EHP review for a project and is intended to reduce the need for an exhaustive RFI. It is organized by section to first list information needed for all projects, with additional sections for specific project types and resource impacts that require additional analysis and information. The Project Information, Section 1, and Section 2 must be completed for all checklists. Sections 3, 4, or 5 should be completed when relevant to the proposed project. Not all line items are relevant to every proposed project, so where appropriate, the “not applicable” boxes should be selected, and sections skipped. If the information is relevant but not provided, please check the third column.
The sections of the EHP Checklist are organized in the following manner:
Project Information:  This section provides identifying information for the loan project
Section 1 – Scope of Work Information required for All Projects. This section is scope and location information of the critical project details– the “where” and the “how.” 
Section 2 – EHP Considerations required for All Projects. This section requires specific information to determine existing compliance actions already completed and project elements that prompt EHP compliance with specific laws or Executive Orders.
Section 3 – EHP Considerations for Projects Impacting Buildings/Structures. This section identifies additional information relevant to a project directly impacting a building/structure (including, but not limited to, activities such as seismic or wind retrofit, fire hardening, floodproofing, elevation, and acquisition).
Section 4– EHP Considerations for Hazardous Fuels Reduction and Defensible Space Projects. This section requires additional information relevant to vegetative fuels reduction/wildfire mitigation projects.
Section 5 – EHP Considerations for Flood Risk Reduction Projects. This section requires additional information for projects that impact water flow conditions and/or flood hazard areas.

Project Information
Project Proposal List ID Number: Click or tap here to enter text.
Activity Type: Click or tap here to enter text.
Entity
Entity Revolving Loan Fund: Click or tap here to enter text.
Entity POC: Click or tap here to enter text.
Mailing Address: Click or tap here to enter text.
Email: Click or tap here to enter text.
Loan Recipient
Loan Recipient POC: Click or tap here to enter text.
Mailing Address: Click or tap here to enter text.
Email: Click or tap here to enter text.
Estimated Cost of Project: Click or tap here to enter text.
Project Title: Click or tap here to enter text.
Street Address or nearest intersection: Click or tap here to enter text.
Site Coordinates (latitude-longitude): Click or tap here to enter text.



Section 1 - Scope of Work Information – ALL PROJECTS
For ALL PROPOSED PROJECTS, the following information is the minimum required to determine EHP compliance requirements.
Basic Project Description: ALL PROJECTS
Location of Provided Information
(PDF title, link, document reference, etc.)
Not Applicable
Not Provided (Project may not proceed to EHP review)
Provide a description of the proposed work to be completed, inclusive of related work that would not be financially covered under this loan but completed concurrently. Include design drawings, maps, photographs and other documents that provide a clear picture of the proposed project.


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Provide project alternatives that could be used if the proposed project is determined to be not feasible or is located in a floodplain. Include a “no action” alternative. These should be reasonable and realistic options.


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Provide the geographic coordinates (latitude/longitude) and the physical site address of the project area.


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Provide a geographic information system (GIS), computer-aided design (CAD), Google Earth files (.KMZ), map, or image that clearly shows the boundaries of the project area. The information provided should include the boundaries of project activities (temporary and permanent), including staging areas, access routes, any areas of vegetation removal, and the affected structure(s).


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If the project would disturb the ground for any reason: 
Provide a description of the activities (both temporary and permanent) that would require ground disturbance and the method of disturbance (e.g., grading, trenching, excavating). Provide a map or image that clearly shows the activities (both temporary and permanent) that would require ground disturbance, inclusive of the depth and extent.

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Provide an estimate of the area of ground disturbance in acres or square feet.

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Provide a description of the existing ground surface conditions that would be disturbed at each site (e.g., pavement, landscape shrubs and trees, previously undisturbed soils with vegetation).

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Provide a description of all vehicles and equipment that would be used to implement the project. Describe any local restrictions on equipment use (e.g., seasonal or daily restrictions, work hours, local noise ordinances).


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Describe how the project area would be accessed. Describe where materials and equipment would be stored and staged during construction. Ensure access routes and staging areas are marked on a map or in GIS or KMZ files. 


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Provide a schedule that includes construction, operation, and maintenance activities, including the months or seasons when work would occur and the typical number of workdays/work hours.


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Provide a description of any known hazardous or contaminated materials that may be present in the project area or that are needed to implement the project.

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If your project would use any hazardous materials, describe the Best Management Practices (BMPs) that would be used to minimize exposure of people and the environment to those materials and how they would be discarded. Common examples include:
    • Keep vehicle and equipment run times to a minimum and all engines properly maintained.
    • Inspect vehicles and equipment daily for fuel and leaks. 

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Provide an explanation of any controversy that exists or could exist related to the project.

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Provide a description of any existing or planned public engagement activities for the project. 


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Provide a description of any low income or minority communities that may be within or near the project area (e.g., a mobile home park is near the project area, project area is within a tribal reservation). 

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Provide a list of all Best Management Practices (BMPs) to be implemented, as part of the project, to reduce potential impacts. Most projects require BMPs to limit noise, dust and erosion while the project is being implemented. Common examples include:
    • Install erosion control measures (e.g., silt fences) prior to any excavation to minimize potential soil erosion during construction.
    • Construction would not occur during nighttime sensitive hours as determined by the local noise ordinance.


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If any portion of this proposed project will occur on private land, notification and/or coordination must occur prior to review by EHP. Provide details about what portions of the project area this entails, and documentation of the coordination inclusive of a response from the landowner(s). EHP may require a right-of-entry to conduct environmental and historic preservation studies in support of compliance activities and having this in place before EHP review can expedite these activities. EHP may also require a clean site certificate for acquisition/demolition projects.

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Section 2 – EHP Considerations – ALL PROJECTS
For ALL PROPOSED PROJECTS, the following information is the minimum required to determine EHP compliance requirements.
EHP Considerations: ALL PROJECTS
Location of Provided Information
(pdf. title, link, document reference, etc.)
Not Applicable
Not Provided (Project may not proceed to EHP review)
State and/or Federal Agency Coordination
Provide a description of any agency coordination and permits obtained from federal, state or local agencies to implement the project. Provide copies of any coordination materials, permit applications or approvals.

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Provide copies of the US Fish & Wildlife Service Species List from the Information for Planning and Consultation for Project Area: https://ecos.fws.gov/ipac/


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Provide copies of previous biological reports/studies/surveys for the project area. 

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Provide copies of any known archaeological, built environment, and/or other cultural resources studies. Provide appropriate point-of-contact (POC) and contact information in the “Location of Provided Information” column. The POC could be contacted during the EHP Project review if additional cultural resource information is needed. (If the studies include confidential information, do not attach it to the checklist but note it here along with the POC)

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Does the project require a Section 404 Clean Water Act jurisdictional determination and/or permit from the US Army Corps of Engineers? 
If Yes, provide the delineation report, jurisdictional determination, permit, permit application, or identified permit type (for future application; i.e. Nationwide Permit, Individual Permit). 

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Does the project require a Section 401 Clean Water Act certification?
If one has been obtained, provide the documentation. 

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Are there any known historic properties within the immediate or surrounding project area? Such historic properties may include buildings, structures, sites (including archaeological sites), or districts, listed in, or eligible for, the National Register of Historic Places.

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If any portion of this proposed project will occur on public lands managed by a Federal Agency (US Forest Service, Bureau of Land Management, National Park Service, US Fish & Wildlife Service, Bureau of Reclamation, etc.), notification and/or coordination must occur prior to review by EHP. Provide details about what portions of the project area this entails, the project point of contact at the Federal Agency, and documentation of the coordination inclusive of a response from the Agency.

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Impacts to Surface Waters (e.g., ponds, lakes, rivers, streams, wetlands, or other waterbodies).
NOT APPLICABLE ☐
Provide a description of any surface waters in or near the project area. 


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Provide a description of any measures that would be used to avoid waterbodies or to avoid impacting water (e.g., setbacks, cofferdams, silt fence).


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Provide any permits or applications that were developed related to project impacts on surface waters.


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Project Impacts to and from the Floodplain
Provide a Flood Insurance Rate Map (FIRM) showing the project location in proximity to mapped floodplains. 


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If the project and any elements (temporary or permanent) are within, adjacent to, or have any potential to impact or be impacted by a floodplain provide a narrative that details the impact and if/how impacts would be minimized.

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If the project has any potential to impact a floodplain or involves new activities related to channeling water flows (culverts, stormwater drainages) that may alter the flow, provide a narrative that details the impact (including upstream and/or downstream impacts). Additionally, if an existing hydrologic and hydraulic (H&H) study exists, the loan recipient can attach the document. If no H&H study exists, the loan recipient may need to conduct a study.

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Vegetation Removal (see Section 4 for hazardous vegetative fuels projects)
NOT APPLICABLE ☐
Provide a description of the location, type and amount of vegetation (e.g., two oak trees, a one-quarter acre of turf grass) that will be removed to complete the project activities.


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Provide a description of how vegetation would be removed (e.g., rootball removal, flush cut, dug up, chemical weed killer, mechanical vs. hand removal, etc.).


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Provide photographs of the vegetation to be removed in the project area.


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Would you restore vegetation after the project is complete or is restoration and mitigation required as a condition of a permit, and if so, identify the type of permit (e.g., Section 401 Clean Water Act permit)? Provide a description of where and how vegetation will be planted (e.g., by hand, with machinery, broadcast seeding), as well as the types and species of vegetation to be planted.

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Would any special techniques be used to ensure the survival of the plants/seeds (e.g., mulch, irrigation, protective fencing)? Provide a description of the techniques to be used. 

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Use of fill material
NOT APPLICABLE ☐
If your project involves the use of fill, describe the type and source of the fill material.


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Section 3 – EHP Considerations – PROJECTS INVOLVING STRUCTURES
For projects that impact existing STRUCTURES, in addition to the information required for all projects, the following information is the minimum required to determine EHP compliance requirements.
Additional Information: ALL STRUCTURES
Location of Provided Information
(pdf. title, link, document reference, etc.)
Not Applicable
Not Provided (Project may not proceed to EHP review)
Provide a description of the structure(s) that would be physically modified as part of the implementation of the project, including the year that they were originally constructed. “Structures” can include any element of the built environment that would be altered (e.g. bridges, culverts, lampposts, utility lines, or buildings).


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Provide a description of the proposed structural modifications (e.g., roof, eave, overhang, soffit, exterior wall, vent, gutter, downspout, window, or door modifications) for each structure.



Provide a description of any prior improvements or additions that have been made to the structure(s) (e.g., new windows, change in roofing material from original construction), changes to the original location (relocation), or other modifications to the original structure(s). 


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Provide photographs of each impacted structure. External photos should be taken that include an overall photo of the structure from the front and photos of the sides of the structure. Additional photos should include detailed photos of the area where work will take place. 
For interior modifications, provide photographs of the elements that would be altered or impacted.



If the structure(s) are designated historic properties or in a designated historic district, provide the name of any listed or eligible historic properties or districts, and specify if they are listed in the local, state, or national register.

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For Retrofit Projects (Ignition-Resistant Construction, Seismic Retrofit, Wind Retrofit), provide any engineering drawings.

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Structure Elevation 
NOT APPLICABLE ☐
Provide a description of the number of structures to be elevated, including the size and type of structure(s), and foundation type.


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Provide a description of the elevation method and the steps required to implement the project. What mechanism would be used to elevate the structure(s) (e.g., continuous foundation walls; elevation on open foundations, such as piles, piers, posts, or columns; or elevating on fill)?


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Provide a description of the existing conditions of the ground surface that would be disturbed at each site (e.g., pavement, landscape shrubs and trees, or previously undisturbed soils with vegetation) and the extent of the proposed disturbance at each site due to the construction activities. Include the length, width, and depth of the ground disturbance.


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Acquisition/Demolition
NOT APPLICABLE ☐
Provide a description of the type of foundation of each structure to be acquired and how it will be removed/demolished.


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Provide a description of how the property would be restored to open space.


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Description of the activities that would require ground disturbance (e.g., foundation excavation, utility line removal, staging area clearing) and show locations on a map or plan view; include the length, width, and depth of the ground disturbance.


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Is there a well or septic system on-site that will be abandoned? 

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Are there above-ground or underground fuel tanks?  

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Is there known asbestos or lead paint in/on the building?

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Infrastructure Retrofit
NOT APPLICABLE ☐
Is the project considered part of the critical infrastructure1 of your community? If yes, describe. 

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Provide a description of how the project would change the capacity of the infrastructure in the area where the project is being implemented.


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Section 4 – EHP Considerations – HAZARDOUS FUELS REDUCTION AND DEFENSIBLE SPACE
For projects that include HAZARDOUS FUELS REDUCTION, in addition to the information required for all projects, the following information is the minimum required to initiate EHP compliance review.
Hazardous Fuels Reduction 
Location of Provided Information
(pdf. title, link, document reference, etc.)
Not Applicable
Not Provided (Project may not proceed to EHP review)
Provide a description of the type of vegetation (e.g., species, sizes, invasive/native) to be removed and where it would be removed from (e.g. within 100 feet of structures).


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Provide a description of methods proposed to remove vegetation (e.g., herbicides, hand tools, mechanical equipment).


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Provide a description of any limits on vegetation removal (e.g., only trees less than 12 inches at diameter breast height, limbs up to 10 feet above the ground).


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Provide a description of any hazardous trees to be removed, including the felling and removal method (dragging, skidding, etc.).

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Provide a description of the method of disposal and location of vegetation to be disposed (e.g., burned on-site, chipped and mulched on-site and at other applicant properties, removed off-site to landfill or compost facility, left in place as snags).


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Provide photos illustrating current vegetation conditions in the project area.


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Provide a description of the topography within the project area (e.g., steep slopes/mountainous, rolling hills, relatively flat). Are there any restrictions related to the slope where the project activities would occur (e.g., skid-steer masticators would only be used on gentle slopes)?


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If your project involves the seeding or planting of vegetation, describe the species to be planted and the methods that would be used (e.g., by hand, with machinery, broadcast seeding, aerial application).

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If burning is proposed, identify any state or local permits required and provide copies of permits.

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Herbicide Use – Hazardous Fuels Reduction 
NOT APPLICABLE ☐
Identify the types of herbicides proposed and describe whether the herbicides would be used in riparian areas near streams, wetlands, or other waterbodies. Provide an estimate of the distance from the waterbody.


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Provide a description of any BMPs that would be used to minimize the impact of herbicides on the environment and people in the project area.



Riparian Areas – Hazardous Fuels Reduction 
NOT APPLICABLE ☐
Provide an estimate of the distance from waterbodies within the project area (streams, wetlands, or other waterbodies) and any BMPs related to work near these areas.


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Describe methods and BMPs for work in these riparian areas.


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Section 5 – EHP Considerations – FLOOD RISK REDUCTION
For projects that include FLOOD RISK REDUCTION, in addition to the information required for all projects, the following information is the minimum required to initiate EHP compliance review.

FLOOD RISK REDUCTION 
Location of Provided Information
(pdf. title, link, document reference, etc.)
Not Applicable
Not Provided (Project may not proceed to EHP review)
Provide a description of the proposed project’s scope of work and clearly explain how the project elements relate or connect to existing flood control or drainage components.


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Provide a description of how the project will reduce flood risks and the area that would benefit from flood risk reduction.


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Provide an estimate of the size of the area that would benefit from the flood risk reduction.


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Will the project increase or decrease the base flood elevation (BFE) in any part of the community? 

If yes, please explain and provide H&H study data that documents the increase or decrease in BFE.


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