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<br /> <br /> HSGP Appendix | February 2021 Page A-16 <br />Construction and Renovation (SHSP and UASI) <br />Project construction using SHSP and UASI funds may not exceed the greater of $1,000,000 or 15% of the <br />grant award. For the purposes of the limitations on funding levels, communications towers are not <br />considered construction. See guidance on communication towers below. <br /> <br />All construction and renovation projects require EHP review. Recipients and subrecipients are <br />encouraged to have completed as many steps as possible for a successful EHP review in support of their <br />proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential <br />historic preservation issues and to discuss the potential for project effects, compliance with all state and <br />local EHP laws and requirements). Projects for which the recipient believes an Environmental <br />Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, <br />FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ <br />Preparedness Officer within six months of the award and completed EHP review materials must be <br />submitted no later than 12 months before the end of the period of performance. EHP policy guidance and <br />the EHP Screening Form, can be found online at: https://www.fema.gov/media- <br />library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.dhs.gov. <br /> <br />Written approval must be provided by FEMA prior to the use of any HSGP funds for construction or <br />renovation. When applying for construction funds, recipients must submit evidence of approved zoning <br />ordinances, architectural plans, and any other locally required planning permits. Additionally, recipients <br />are required to submit a SF-424C form with budget detail citing the project costs, and an SF-424D Form <br />for standard assurances for the construction project. <br /> <br />Recipients using funds for construction projects must comply with the Davis-Bacon Act (codified as <br />amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. § <br />5196(j)(9), which cross-references Davis-Bacon). Recipients must ensure that their contractors or <br />subcontractors for construction projects pay workers no less than the prevailing wages for laborers and <br />mechanics employed on projects of a character like the contract work in the civil subdivision of the state <br />in which the work is to be performed. Additional information regarding compliance with the Davis-Bacon <br />Act, including Department of Labor (DOL) wage determinations, is available online at <br />https://www.dol.gov/whd/govcontracts/dbra.htm. <br /> <br />Construction and Renovation (OPSG) <br />OPSG funds may not be used for any construction. <br /> <br />Communications Towers <br />All construction of communication towers requires EHP review. When applying for funds to construct <br />communication towers, recipients and subrecipients must submit evidence that the Federal <br />Communication Commission’s Section 106 of the National Historic Preservation Act, Pub. L. No. 89- <br />665, as amended, review process has been completed and submit all documentation resulting from that <br />review to FEMA with a GPD EHP Screening Form and supporting materials for EHP review. Recipients <br />and subrecipients are encouraged to have completed as many steps as possible for a successful EHP <br />review in support of their proposal for funding (e.g., coordination with their State Historic Preservation <br />Office to identify potential historic preservation issues and to discuss the potential for project effects, <br />compliance with all state and local EHP laws and requirements). Projects for which the recipient believes <br />an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA <br />Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness <br />Officer within six months of the award and completed EHP review materials must be submitted no later <br />than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening