Item 18 - Adopt Resolution for FY 2021 Emergency Management Performance Grant

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EMPG Program Appendix | February 2021 Page H-22 FEMA must provide written approval prior to the use of any EMPG Program funds for construction or renovation. Requests for EMPG Program funds for construction of an EOC must be accompanied by an EOC Investment Justification (located in the Related Documents tab of the EMPG Program Grants.gov posting) to their regional EMPG Program manager for review. Additionally, recipients are required to submit a SF-424C Form and Budget detail citing the project costs and an SF-424D Form for standard assurances for the construction project. The above examples are not intended to exclude other construction projects as potentially allowable costs. For example, construction of a facility for the storage of critical emergency supplies, as a Point of Distribution (POD) for emergency distribution, and/or to serve as a staging area for deployment of emergency response resources is potentially an allowable expense. Other construction or renovation projects, such as a secondary or local EOC, will be considered on a case-by-case basis, as described below in the guidance regarding advance written approval. EHP Compliance Recipients and subrecipients proposing projects that have the potential to impact the environment, including, but not limited to, the construction of communication towers, modification or renovation of existing buildings, structures, and facilities, new construction including replacement of facilities, and some training activities, must participate in the FEMA EHP review process. Recipients and subrecipients are also encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects, compliance with all state and EHP laws and requirements). Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the regional EMPG Program manager within six months of the award, and completed EHP review materials must be submitted at least 12 months before the end of the period of performance. EHP review packets should be sent to gpdehpinfo@fema.gov. Please refer to the EHP section of this Manual for additional information on EHP requirements. Advance Approval Requirement Recipients must receive advance written approval from FEMA prior to the use of any annual EMPG Program funds for construction or renovation, including such activities at the sub-recipient level. Such costs would need to fall within the scope of the recipient’s final approved Work Plan, otherwise an updated Work Plan may be required. Such requests should be submitted in writing to the applicable FEMA Regional Grant Program Office. FEMA’s review and approval will involve both the regional office and FEMA Grant Programs Directorate. Real Property Use and Disposition Requirements Real property improved under a federal award falls under the 2 C.F.R. Part 200 guidance for real property. In accordance with 2 C.F.R. § 200.311, a recipient or subrecipient may only use real property acquired or improved under a federal award for the originally authorized purpose, as long as it is needed for that purpose, during which time the recipient or subrecipient must not dispose of or encumber its title or other interests. However, upon the end of that period where it needs the property for the originally authorized purpose (i.e., the functional use of the property for which FEMA awarded the grant), the recipient or subrecipient will then dispose of the property in keeping with the requirements set forth in 2 C.F.R. § 200.311.