Agenda

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FEMA
GRANT PROGRAMS DIRECTORATE
FY 2013 Port Security Grant Program (PSGP)
Funding Opportunity Announcement (FOA) Outreach
FEMA Grant Programs Directorate and United States Coast Guard
May 21 – June 24, 2013
Agenda
 Program Overview
 Funding Priorities
 Application Process
 Post-Award Administration
 Environmental Planning and Historic Preservation Compliance
 Appendix
2
Program Overview
3
Overview
FY 2013 Transportation Grant Programs
 The Port Security Grant Program (PSGP) is one of three funded grant
programs within the Transportation Infrastructure Security Branch for FY 2013
 PSGP provides funds for transportation infrastructure security activities to
implement Area Maritime Security Plans and Facility Security Plans among port
authorities, facility operators, and State and local government agencies
required to provide port security services
Transportation
Infrastructure
Transportation
Security Branch
Infrastructure Security
Branch (TISB)
Port Security
Grant Program
(PSGP)
Transit Security
Grant Program
(TSGP)
Intercity
Passenger Rail
(IPR)
4
Overview
FY 2013 Appropriation
Available Funding
Group
FY 2012
FY 2013
Group I
$58,500,000
$55,924,388
Group II
$29,250,000
$37,282,925
Group III
$4,875,000
Not Applicable
All Other Port Areas
$4,875,000
Not Applicable
$97,500,000
$93,207,313
TOTAL
 Authorizing Statutes
(p. 24-25)
– The Consolidated Appropriations Act, 2013 (Public Law 113-6)
 Congress appropriated $1,511,880,033 to be distributed among all state and local
preparedness grant programs at the Secretary’s discretion. This figure represents an
8.8% increase in funding from the FY 2012 appropriation
– Section 102 of the Maritime Transportation Security Act of 2002, as amended (46
U.S.C. §70107)
5
Overview
FY 2013 PSGP
 The FY 2013 port program closely resembles the FY 2012 program:
– Eligible applicants apply directly to FEMA without the use of a Fiduciary Agent
– Applicants may apply for up to three projects
– Applicants will be required to provide a cost-match (50% for private entities and
25% for public entities/consortia) for submitted projects
– The period of performance for the award remains 24 months
– Operational expenses must be approved as an allowable costs
 Two key changes were made for FY 2013:
– Funding will be distributed between two Port Area Group Designations rather than
the traditional four groupings in prior years (Group I, Group II, Group III, and All
Other Port Areas)
 Group I consists of 8 Port Areas
 Group II includes all other Port Areas not specifically identified as Group I
(legacy Group II, Group III, and All Other Port Areas)
– Cybersecurity has been added as a specific program priority
6
Basic Eligibility Requirements
 Eligible applicants include port authorities, facility operators, and state and
local government agencies required to provide port security services (p. 8)
– Applicants must be fully compliant with relevant Maritime Security Regulations (i.e.,
33 CFR Parts 101-106; Maritime Transportation Security Act (MTSA) regulations)
 By law, DHS must direct PSGP funds to the nation’s highest risk ports
– 145 ports, aggregated into 90 discrete port areas, are eligible to apply for funds in
two PSGP funding pools
– Applicants will compete for funding within their group without target allocations for
specific port areas
FY 2013 PSGP Funding Groups
Group I
Group II
$55,924,388
8 Port Areas: Los Angeles, San Francisco, San Diego, New Orleans,
Delaware Bay, New York/New Jersey, Houston-Galveston, Puget Sound
$37,282,925
All other eligible port areas not specifically identified above, to include
the 82 legacy Group II and III Port Areas and the legacy All Other Port
Areas Group
(p. 24-25)
7
Funding Priorities
8
Overarching Funding Priorities
 Two priorities are paramount in the overall DHS investment strategy: riskinformed funding and regional security cooperation (p.29-30)
 Available port security grant dollars will focus on the highest-risk port areas
– Determination is based on intelligence analysis, extensive security reviews, and
consultations with port industry partners
– Eligible port areas were identified using a compressive, empirically-grounded risk
analysis model
– Risk will be evaluated using an analytical model defining risk as the product of
three principal variables:
1. Threat - the likelihood of an attack occurring
2. Vulnerability - the relative exposure to an attack
3. Consequence - the expected impact of an attack
 DHS places a high priority on ensuring that all PSGP applications reflect
robust regional coordination and an investment strategy that institutionalizes
and integrates a regional maritime security risk strategy
9
Overview
FY 2013 PSGP Funding Priorities
1. Enhancing Maritime Domain Awareness (MDA) (p. 30)
– Port areas should seek to enhance MDA through projects that address knowledge
capabilities within the maritime domain
– Projects should reflect a regionalized approach and coordinated effort among public
and private sector organizations
– MDA efforts could include access control/standardized credentialing, communications,
enhanced intelligence sharing and analysis, construction and/or enhancement of
Interagency Operations Centers, etc.
2. Enhancing Improvised Explosive Device (IED) and Chemical, Biological,
Radiological, Nuclear, Explosive (CBRNE) prevention, protection, response, and
recovery capabilities (p. 31)
– Port areas should continue to enhance their capabilities to prevent, detect, respond to,
and recover from attacks employing IEDs, CBRNE devices, and other nonconventional weapons
– IEDs delivered via small craft, underwater swimmers, or on ferries are of particular
concern
10
FY 2013 PSGP Funding Priorities (continued)
3. Enhancing Cybersecurity Capabilities
(p. 31)
– Port Areas should seek to enhance their capability to strengthen the Nation's
critical infrastructure including distributed networks, varied organizational
structures and operating models, interdependent functions and systems in both the
physical space and cyberspace, and governance constructs that involve multi-level
authorities, responsibilities, and regulations
– Projects should reflect the unique position of critical infrastructure owners and
operators in managing risks to their individual operations and assets, and
determining effective strategies to make them more secure and resilient
4. Port Resilience and Recovery Capabilities
(p. 31)
– Ensuring resilience to disasters is one of the core DHS missions
– PSGP funds are intended to enable continuity of operations and/or rapid recovery
of the port in the event of a disaster
– Ports that have not already done so are encouraged to develop a Business
Continuity/Resumption of Trade Plan
11
FY 2013 PSGP Funding Priorities (continued)
5. Training and Exercises (p. 32)
– Exercises must follow the Area Maritime Security Training Exercise Program
(AMSTEP) or the Transportation Security Administration (TSA) Intermodal
Security Training Exercise Program (I-STEP) guidelines
6. Equipment Associated with Transportation Worker Identification Credential
(TWIC) Implementation (p. 32)
– Infrastructure and installation projects that support TWIC implementation will be
given a higher priority than the purchase of TWIC card readers in the FY 2013
PSGP
12
Application Process
13
FY 2013 PSGP Application Process
 Applying for FY 2013 PSGP funding is a two-step process:
– Step 1: Applicants must submit Standard Form 424 (SF-424) to Grants.gov no later
than Monday, June 17, 2013 in order for FEMA to determine eligibility
 Applicants are encouraged to initiate this process as soon as possible
– Step 2: Applicants must submit the full application package via the Non Disaster
(ND) Grants system no later than Monday, June 24, 2013
Application
Period Opens
May 21, 2013
SF-424
Due Date
IJ Submission
(All groups)
June 17, 2013
Award
Announcement
June 24, 2013
On or before
September 30, 2013
*Completed applications must be received via ND Grants no later than
11:59pm EST, Monday, June 24, 2013
14
ND Grants
 ND Grants is a consolidated grants management system used to facilitate all
aspects of grant administration throughout the grant lifecycle
– Release 1.0.2.0 supports grant application through award package
creation/acceptance, administrative amendments, and performance reports
– New applicants will need to register with NDGrants prior to submitting applications
– Existing applicants should verify accessibility prior to submitting applications
– ND Grants registration at https://portal.fema.gov
If you have any questions, please send an email to:
ndgrants@fema.gov or contact the ND Grants Help Desk at
1-800-865-4076
15
Initiating an Application (p. 20-22)
 Before submitting an application, applicants must verify their System for Award
Management (SAM) registration and Dun & Bradstreet Data Universal Numbering
System (DUNS) Number (p. 21)
– Confirm SAM registration at http://www.sam.gov
– Request and receive a DUNS number at no cost by calling the DUNS number request
line at (866) 705-5711
 Application forms and instructions are available at http://www.grants.gov
– To access application:
 Select “Apply for Grants,” then “Download a Grant Application Package”
 Enter CFDA number (97.056) and/or Funding Opportunity Number (DHS-13-GPD056-000-01)
 Select “Download” under Instructions and Application column and follow the prompts
to download both the application package and the instructions
16
Step 1: Submitting SF-424 in Grants.gov (p. 18)
 Applications are initiated by submitting Standard Form 424, Application for
Federal Assistance (SF-424), to Grants.gov at http://www.grants.gov
 The SF-424 is the only form submitted using Grants.gov and must be
submitted first in order to complete the rest of the application process
Complete SF-424s must be received by Grants.gov no later than
11:59pm EST, Monday, June 17, 2013
 The form is electronically migrated to ND Grants and the system
automatically populates the relevant data fields
 All other documentation required to complete the application process will be
submitted using ND Grants
– Fillable templates for supporting documents are available on Grants.gov by
selecting “Find Grant Opportunities,” conducting a basic search by CFDA (97.056),
selecting the correct PSGP Opportunity Title, and selecting “Full Announcement”
17
Step 2: Submitting Application Forms in ND Grants (p. 20-22)
 The following required forms and submissions must be submitted via ND Grants:
– Standard Forms
 SF-424A, Budget Information
 SF-424B, Standard Assurances
 SF-424C, Budget Information – Construction Form
 SF-424D, Assurances – Construction Programs
 SF-LLL, Disclosure of Lobbying Activities
 Lobbying Form – Certification Regarding Lobbying
 Certification Regarding Debarment, Suspension, and Other Responsibility Matters
–
–
–
–
 Certification Regarding Drug-Free Workplace Requirements
Investment Justification(s) for each individual project
Detailed Budget Worksheet(s) containing only allowable costs (different from the SF424A/C)
MOUs/MOAs (if applicable)
EHP Screening Forms (recommended)
All submissions must be received no later than
11:59pm EST, Monday, June 24, 2013
18
Application
Investment Justifications (IJ) (p. 15-17)
 The IJ template is provided in Appendix D (p. 47-49) of the FOA
 IJs must demonstrate how projects address gaps and deficiencies in current
programs/capabilities and provide enhancements consistent with the purpose of
the PSGP program
 A separate IJ is required for each proposed project
– Applicants may apply for up to three projects
– All IJs must be properly identified as SSI and password protected prior to submission
 The passwords for these protected documents must be sent separately to
askcsid@dhs.gov prior to the application deadline
 All IJs must be consistent with all applicable requirements outlined in the guidance
 IJs must provide information in the following categories for each project:
1. Background
2. Strategic and Program Priorities
3. Impact
4. Funding and Implementation Plan
19
Application
Detailed Budget (p. 17)
 The Detailed Budget Worksheet is provided in Appendix D (p. 50-53) of the
Funding Opportunity Announcement
– While this format is not required, it is highly recommended that applicants use the
template provided
 SF 424A/C forms do not replace the Detailed Budget requirement – both the
Detailed Budget AND the SF424 A/C must be submitted with the application
 Budgets must be complete, reasonable, cost-effective, and provide the
appropriate level of detail to clarify intent
 Budgets should provide the basis of computation of all project-related costs,
including Management and Administrative costs (M&A), and any appropriate
narrative
20
Post-Award
Administration
21
Application
Allocation Announcement & Award Notification
 Final allocations are first announced by the Secretary no later then 65 days
after the close of the application period
– An Information Bulletin (IB) is distributed with a list of allocations to those entities
receiving awards
– The IB is sent out through AskCSID and posted to both the FEMA and
HOMEPORT websites
 Official awards are made on a rolling basis and grantees will receive an
electronic notification on or before September 30, 2013
 Grantees must officially accept their award upon notification
– The electronic notification will include instructions on how to access and accept the
award in ND Grants
– Failure to accept the award in a timely manner may result in the award being
permanently de-obligated
22
Post-Award
Financial and Programmatic Reporting (p. 12-13)
 Federal Financial Reports (FFR) are required quarterly in the form of an SF425
– Must be filed online through the PARS website
– Reporting periods and due dates:
 October 1 through December 31, due January 30
 January 1 through March 31, due April 30
 April 1 through June 30, due July 30
 July 1 through September 30, due October 30
 Performance Progress Report (SF-PPR)
– Formerly titled SAPR
– Template can be accessed online at http://www.na.fs.fed.us/fap/SFPPR_Cover%20Sheet.pdf
– Submitted to ND Grants on a semi-annual basis
– Reporting periods and due dates:
 January 1 through June 30, due July 30
 July 1 though December 31, due January 30
23
EHP Compliance
Environmental Planning and Historic Preservation
(EHP) Compliance

All projects funded with Federal grant dollars must comply with EHP laws,
regulations, and Executive Orders

An EHP review is an analysis of pertinent project information to determine
whether a project may have the potential to impact environmental or
cultural resources
– Complex projects will typically require more information to reach a determination
– FEMA may be required to consult with the relevant State Historic Preservation
Office (SHPO), the U.S. Fish and Wildlife Service (FWS), the U.S. Army Corps of
Engineers (USACE), and others to determine impacts to sensitive resources

Projects must be EHP approved before initiation

Grantees are responsible for completing the EHP Screening Form and
providing all relevant EHP materials to GPD via the GPD-EHP Mailbox at
GPDEHPinfo@dhs.gov

Grant funds may be used for preparation of EHP documentation
24
Appendix
25
Resources
 FY 2013 PSGP Funding Opportunity Announcement, FAQs, Fact Sheets,
forms, templates, and other information is available at
http://www.fema.gov/government/grant/psgp/
 Information Bulletins available at
http://www.fema.gov/government/grant/bulletins/index.shtm
 GPD State Assignment Map and Program Office Contact Information
 Contact Information for questions regarding Grants.gov, ND Grants, EHP,
PARS, etc.
26
Resources
Information Bulletins
IB #
Title
IB 329 Environmental Planning and
Historic Preservation
Requirements for Grants
IB 345 Grant Programs Directorate
Programmatic Environmental
Assessment
Description
Provides guidance for those programs that will fund communication towers,
physical security enhancements, new construction, renovation, and
modifications to buildings or structures. Project descriptions are required to be
submitted to GPD electronically via the Centralized Scheduling and Information
Desk (CSID) at askcsid@dhs.gov prior to the initiation of the project.
Augments IB 329 with information concerning the recently finalized
Programmatic Environmental Assessment (PEA) and its impact on EHP
compliance requirements. Provides detailed instructions on projects that do not
require further EHP documentation.
IB 359 Sensitive Security Information Provides guidance for properly identifying, handling, and marking SSI in grant
Guidance
IB 293 Repair and Replacement
Costs within PSGP
IB 371 Streamlined Submission of
Environmental and Historic
Preservation (EHP) Review
Packets and Narrowbanding
EHP Requirements
application materials. Grantees must follow these guidelines when submitting
all Investment Justifications to ND Grants.
Rescinds replacement costs as unallowable costs within the FY 2007, FY 2007
Supplemental, and FY 2008 PSGP
Provides updates on measures to streamline the EHP process to include new
contact information, a revised EHP screening form, responses to requests for
additional information, and the required documentation for narrowbanding
projects
27
Information Bulletins (continued)
IB #
Title
Description
IB 193 Cooperative Training Outreach Designed to decentralize first responder training and to facilitate access to the
Program (CO-OP)
Office for Domestic Preparedness (ODP) courses in a cost effective manner
and augment the capacity of States, territories, and tribal entities to deliver
State and Local Government Coordination and Preparedness (SLGCP)/ODP
courses
IB 333 Use of Standard Form (SF)
SF-425, also known as the Federal Financial Report (FFR), replace the SF425, Federal Financial Report, 269, SF-269A, SF-272, and SF-272A, currently used by Federal grant
in lieu of SF-269, SF-269A,
recipients to report the financial status of grant funds and cash transactions
SF-272, and SF-272A for
using grant funds. Beginning October 1, 2009, all Federal agencies and Federal
Recipient Financial Reporting grant recipients will be required to use the SF-425 for financial reporting.
IB 336 Maintenance Costs
Using FEMA preparedness grant funds for maintenance contracts and
warranties, repair and replacement costs, upgrades, and user fees is
allowable. If your program previously purchased these items with State or local
funds, those funds cannot be replaced with Federal grant funding.
IB 372 Changes to Grants.gov
Informs grantees of Grants.gov system’s enforcement of active Central
Contractor Registration (CCR) accounts in order to submit applications. If the
applicant does not have an active CCR, the application cannot be submitted.
http://www.fema.gov/government/grant/bulletins/index.shtm
28
PSGP State Assignment Map
29
Resources
Program Office Contact Information
Name
Role
Email Address
Alex Mrazik
TISB Branch Chief
Alexander.Mrazik@fema.dhs.gov
Duane Davis
Section Chief East
Duane.Davis@fema.dhs.gov
Cynthia Simmons-Steele
Section Chief West
Cynthia.Simmons-Steele@fema.dhs.gov
Rene Phillips
Program Analyst
LurrandaRene.Phillips@fema.dhs.gov
Alex Berberian
Program Analyst
Alexander.Berberian@fema.dhs.gov
Jackie Jackson
Program Analyst
Jacqueline.Jackson1@fema.dhs.gov
Jeff Hall
Program Analyst
Jeffrey.Hall1@fema.dhs.gov
Kevin Groves
Program Analyst
Kevin.Groves@fema.dhs.gov
Khori Torrence
Program Analyst
Khori.Torrence@fema.dhs.gov
Mel Vanterpool
Program Analyst
Melvin.Vanterpool@fema.gov
Omid Amiri
Program Analyst
Omid.Amiri@fema.gov
30
Resources
Contact Information
Questions Regarding:
Contact Information
Grants.gov
(800) 518-4726
www.grants.gov
ND Grants
(800) 865-4076
ndgrants@fema.gov
Application process; financial-related; pre- and post-award
administration; technical assistance; PARS
(866) 927-5646
ASK-GMD@dhs.gov
Specific grant programs
(800) 368-6498
ASKCSID@dhs.gov
DUNS number
SAM Registration
EHP Submissions and Compliance
(866) 705-5711
http://www.sam.gov
GPDEHPinfo@dhs.gov
31
Questions?
32
Additional EHP
Resources
33
Why is EHP Review Required?
 The National Environmental Policy Act of 1969 (NEPA) requires that the
Federal Government examine the proposed impacts of its actions before
project implementation:
– NEPA does not mandate preservation, only informed decision-making
 NEPA serves as an “umbrella regulation” and provides a process which other
EHP laws and regulations can be considered
 Materials prepared for state compliance may be submitted with the EHP
review packet for GPD; however, state compliance activities cannot replace
Federal requirements
 EHP compliance requirements have always been included in the special
conditions and the grant guidance kits
34
Relevant Laws and Executive Orders
National Environmental Policy Act (NEPA), (1969)
Biological Laws:
• Endangered Species Act (ESA), 1973
• Fish and Wildlife Coordination Act (FWCA), 1934
• Migratory Bird Treaty Act (MBTA), 1918,
• Bald and Golden Eagle Protection Act (BGEPA),
1940
• Magnuson-Stevens Fishery Conservation Act
(FCA), 2006
• Executive Order (EO) 13112 Invasive Species
(1999)
Water Resources Laws:
• EO 11988 Floodplain Management (1977)
• EO 11990 Protection of Wetlands (1977)
• Clean Water Act (CWA) (1972)
• Wild and Scenic Rivers Act (WSRA), 1968
Coastal Laws:
• Coastal Barrier Resources Act (CBRA), 1982
• Coastal Zone Management Act (CZMA), 1972
Socioeconomic Laws:
• Farmland Protection Policy Act
(FPPA), 2007
• EO 12898 Environmental Justice
(1994)
Historic Properties:
• National Historic Preservation Act
(NHPA), 1966
Pollution Control and Debris
Management:
• Clean Air Act (CAA), 1970
• Resource Conservation and
Recovery Act (RCRA), 1976
• Comprehensive Environmental
Response, Compensation and Liability
Act (CERCA),1990
35
EHP Compliance
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)
36
Importance of Compliance
Compliance
Non-Compliance
 Protection of natural and cultural
resources
 Project delays

De-obligation of funding
 Improved project planning

Negative publicity
 Cost efficient

Civil penalties
 Programmatic and financial
compliance

Lawsuits
 Efficient project implementation
 Improved community relations
37
EHP Compliance
FEMA EHP Resources
 44 CFR Part 10 – FEMA’s NEPA Implementing Regulations
 Information Bulletin # 271 (December 5, 2007) – Requirements of the EHP
Review Process for Grants
 Information Bulletin # 329 (September 2, 2009) – Further guidance on the GPD
EHP Review Process and Introduction of the EHP Screening Form
 Information Bulletin # 345 (September 9, 2010) – The GPD Programmatic
Environmental Assessment (PEA)
 Information Bulletin # 351 (January 14, 2011) – Advisory Council on Historic
Preservation’s (ACHP) Program Comment
 Information Bulletin # 356 (February 17, 2011) – Revised EHP Screening Form
 Information Bulletin #371 (August 31, 2011) – Streamlined Submission of
Environmental and Historic Preservation (EHP) Review Packets and
Narrowbanding EHP Requirements
38
EHP Compliance
EHP Review Packet
 A complete EHP review packet will provide the necessary information to
complete the EHP review
 What are the required contents?
– Detailed project description
 What will be installed/constructed?
 How will work be accomplished?
 Where will the project take place?
– Project location: physical address or latitude/longitude
– Labeled ground-level and aerial color photographs; photos must indicate where:
 all equipment will be installed
 ground disturbance will take place (if applicable)
39
EHP Review Packet (Continued)
 Required Contents (Continued)
– Extent and depth of ground disturbance for:
 New construction and/or building renovations
 Utility line placement
 Physical security enhancements (e.g., fencing, light posts)
 Generators – Include ground disturbance for the
–
–
–
–
Pad for the generator
Fuel line
Electrical line
Fuel tank (Note whether the tank will be stored above or below ground)
– Communication towers
 New: Total height and whether the tower has guyed wires or is self supporting
 Existing: Current height and height following the equipment installation
– Age of the building or structure on/in/near which equipment will be installed
40
Type A Projects
 Projects with no potential for adverse impacts to environmental or cultural
resources
 Review completed by Program Analyst
 Examples of Type A Project Activities:
– Management and Administration
– Planning
– Classroom-based Training
– Tabletop Exercises and Functional Exercises
– Training and Operational Exercises in Existing Facilities
– Purchase of Mobile and Portable Equipment
– Plug and play equipment (e.g, base radios and repeaters that are placed on/in
existing communications racks)
41
Type B Projects
 Projects with no potential for environmental and/or historic preservation
impacts if certain conditions apply; resources most commonly considered
include:
– Floodplains
– Wetlands
– Historic / Cultural Resources
 Review completed by GPD EHP Team
 Examples of Type B projects include:
– Physical security enhancements
– Renovations, modifications, and upgrades to structures
42
Type C Projects
 Projects that may have the potential for environmental and/or historic
preservation impacts
 Review completed by FEMA Regional Environmental Officer (REO)
– REO may require additional information in order to consult with resource
management agencies such as:
 State Historic Preservation Officer (SHPO)
 U.S. Fish and Wildlife Service (USFWS)
 U.S. Army Corps of Engineers (USACE)
– Environmental Assessments (EAs), Biological Assessments (BAs), or Memoranda
of Agreement (MOAs) may be required
– Public involvement may be required
43
Type C Projects (Continued)
 Examples of Type C Projects include:
– Communications Towers
– New Construction / Renovation
– Potential impacts to historic and/or cultural resources:
 Buildings over 50 years of age
 Projects located near National Register-listed buildings
 Projects located in/adjacent to National Register Historic Districts
– Projects that involve ground disturbance within the 100 year floodplain
44
EHP Review – What to Expect
 Once an EHP review packet is submitted to GPDEHPinfo@dhs.gov,
grantees will receive confirmation and a Case ID number, usually within 5 –
10 business days
 The GPD EHP Team reviews the materials submitted and notifies the
grantee if further information is required
 The GPD EHP Team typically completes a review within 25 days of receipt of
sufficient information
– Projects are either approved at GPD or are sent to the appropriate FEMA Region
for further analysis
 Grantees will be notified of the outcome of the EHP review by their Program
Analyst
45
EHP Compliance
Tips for a Timely EHP Review
 Provide a clear and detailed project description, with labeled color photos
and maps
 Provide the year in which any affected buildings or structures were built
 Include any previous Master Plans or other completed environmental
documentation
 Clearly describe what work is being proposed, where it will take place, and
how it will be carried out
46
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