 Draft Programmatic Environmental Assessment

Grant Programs Directorate Programs 

December 2009

	Federal Emergency Management Agency

	Department of Homeland Security

	500 C Street, SW

	Washington, DC 20472

EXECUTIVE SUMMARY 

This Programmatic Environmental Assessment (PEA) provides an assessment
of the expected environmental impacts associated with the implementation
of the programs funded by the Federal Emergency Management Agency’s
(FEMA) Grant Programs Directorate (GPD).  The proposed implementation of
GPD-funded grant programs would involve a wide variety of projects
designed to improve the preparedness and readiness of public safety and
first response agencies, as well as improve homeland security through
increased protection of the Nation’s critical infrastructure.

The Department of Homeland Security (DHS) Office of Grants and Training
(G&T) was transformed into GPD on April 1, 2007, as a result of the
Post-Katrina Emergency Management Reform Act of 2006.  GPD is housed
within FEMA to oversee the grant business operations, systems, training,
and policy.  FEMA coordinates the federal government's role in preparing
for, preventing, mitigating the effects of, responding to, and
recovering from all domestic disasters, whether natural or man-made,
including acts of terror.  

Background

The preparedness grant programs managed by GPD enhance the preparedness
and response capabilities of States, Territories, Tribes, private-sector
and non-governmental first responders to respond to terrorist attacks
and non-man made emergencies.  These funds are intended to develop and
administer planning, training, and equipment assistance programs for
state and local emergency response agencies to better prepare them
against the threat of terrorism as part of GPD’s mission.

GPD’s mission is to manage Federal assistance to measurably improve
capability and reduce the risks the Nation faces.  GPD is responsible
for the program management and administration of 19 preparedness grant
programs.  GPD will ensure all of their preparedness grant programs are
aligned to, and are measurable against, the National Preparedness
Guidelines and the National Priorities as authorized by the H.R. 10,
9/11 Commission Recommendations Implementation Act.  These preparedness
grant programs support the achievement of the National Preparedness Goal
by providing funds for State and local homeland security efforts, such
as planning, equipment purchase, protection of critical infrastructure
by reinforcing physical security and access controls, and hiring and
training first response personnel.  Currently, the grants administered
by GPD funds are provided to all 56 States and Territories.  

The events of September 11, 2001 highlighted critical needs in the
Nation’s security safeguards and systems.  Effective preparedness is a
critical precondition of successful response.  In order to best equip
State and local governments, as well quasi-governmental private
entities, to successfully respond to emergencies, GPD is committed to
providing funds that will allow these entities to improve preparedness. 
These grant programs are part of a comprehensive set of measures
authorized by Congress and implemented by FEMA to help strengthen the
Nation against risks associated with potential terrorist attacks.

Purpose and Need

In order to obtain the desired higher level of readiness, State,
Territory, Tribal, and private-sector and non-governmental partners
identified the need to improve their preparedness capabilities.  A
number of activities have been identified by stakeholders enabling them
to make meaningful improvements in national preparedness.  Funds from
GPD grant programs would be used to implement programs that would
satisfy a diverse range of identified needs, both programmatic and
site-specific.  Programmatic needs include integrating preparedness
programs and training into existing public safety initiatives, improving
emergency-response planning, implementing Statewide Critical
Infrastructure/Key Resource (CI/KR) protection programs, and
establishing protocols to effectively direct the flow of terrorism and
homeland security information.  Site-specific needs include physical
security enhancements that would improve infrastructure security and
resiliency, equipment and infrastructure to enhance jurisdictional
capabilities to share critical voice information in tactical settings
with other jurisdictions, upgrades to emergency response systems, and
improvements in threat detection, such as radiological and nuclear.

Scope of the PEA

This PEA examines the direct, indirect, and cumulative environmental
impacts associated with the GPD-funded grant programs.  This document
has been prepared in compliance with the National Environmental Policy
Act of 1969 (NEPA) and the FEMA regulations for implementing NEPA.

A programmatic environmental document, such as this PEA, is prepared
when an agency is proposing to carry out a broad action, program, or
policy.  FEMA has determined that the grant programs funded by GPD are a
broad action with nationwide implications.  The programmatic approach
creates a comprehensive, global analytical framework that assesses
impacts expected from the program as a whole.  It also supports
subsequent site-specific environmental evaluations, such as Records of
Environmental Considerations (REC), tiered Supplemental Environmental
Assessments (SEA) or stand-alone EAs, that may be required to determine
the nature and extent of impacts resulting from individual actions at
specific locations.  It also allows FEMA to identify those project types
that will not have any impact to the environment and distinguish them
from those that may require further analysis.

This PEA is intended to examine the project types funded by GPD, which
have been organized into the following eight groups:

Planning

Planning projects would enable grantees to engage in preparedness
activities such as:  

Prioritize needs 

Update preparedness strategies

Allocate resources 

Deliver preparedness programs across disciplines (e.g., law enforcement,
fire, Emergency Medical Services, public health, behavioral health,
public works, agriculture, and information technology) and levels of
government.  

These efforts include the development of policies, plans, procedures,
mutual aid agreements, strategies, and other publications that comply
with relevant laws, regulations, and guidance and are necessary to
perform assigned missions and tasks.

Management and Administration

Activities allowable under the GPD grant programs regarding management
and administrative actions allow grantees to enhance their preparedness
through the hiring of personnel, publication of guidance documents, and
other management activities that build capacity.  

Training

States, Territories, and urban areas are encouraged to use GPD funds to
develop a State/Territory homeland security training program.  These
training programs, primarily classroom-based, enable public safety,
preparedness, and first responder agencies at all levels to engage in
activities that build capacity and capability at all levels, enhancing
preparedness.  Training-related costs under GPD may include the
establishment, support, conduct, and attendance of training.  Training
topics may include, but are not limited to, chemical, biological,
radiological, nuclear, and explosive (CBRNE) terrorism and catastrophic
events, cyber/agriculture/food security, intelligence gathering and
analysis, citizen and community preparedness, and training for
volunteers.  For a listing of activities that are allowable expenses,
please refer to the relevant year’s grant guidance.  

Exercises

Exercise scenarios eligible for funding would be based on the Multi-Year
Training and Exercise Plan.  These exercises, both field- and
classroom-based, enhance readiness by allowing public safety,
preparedness, and first responder agencies at all levels to engage in
tabletop and field exercises that allow them to rehearse real-life
scenarios in order to better prevent and respond to acts of terrorism. 
Exercise scenarios may include CBRNE, cyber, agricultural, and natural
or technological disasters.  Grant funds can be used to design, develop,
conduct, and evaluate terrorism prevention-related exercises.

Purchase of Mobile and Portable Equipment

The GPD grant programs allow for equipment purchases within one of the
21 allowable equipment categories. The Allowable Equipment List (AEL)
can be found at   HYPERLINK "https://www.rkb.us/mel.cfm?subtypeid=549" 
https://www.rkb.us/mel.cfm?subtypeid=549 .  

The category of mobile and portable equipment is defined as devices that
do not require any installation (e.g. attached to a building, bridge,
pier, etc.) and may be transported from site to site, such as hand-held
radios, personal protective equipment (PPE), cellular phones, dive
equipment, boats, response vehicles, identification cards, and other
similar devices that do not require installation.  

Communication Towers 

Communication towers perform many essential functions, including helping
to maintain contact among first responders in the event of an emergency.
 GPD grant funds may be used to install new towers, replace older, less
capable towers, and to renovate existing towers to enhance communication
capabilities and better enhance preparedness and response capabilities.

Existing Towers

Actions under this project type would be limited to the addition of new
equipment and the upgrade or enlargement of the existing facility.  All
potential activities would be limited to the communication tower and the
area within the fenced (secured) area associated with the existing
tower.  

New/Replacement Towers

Proposed activities within this category include new construction or
replacement of existing communication towers.  Communication tower sites
are usually fenced and include the tower, an ancillary electronic
equipment building, and an emergency backup power generator.  Sites with
a backup generator also have a fuel tank for the generator, up to 1,000
gallons in rural areas.  The sites are usually unmanned, and electricity
and telecommunications lines are the only utilities at the site.  In
some cases, especially in urban areas, the communication antenna could
be located on another structure, such as a water tower, smoke stack, or
roof of a building.  

For purposes of this PEA, construction of a new communication tower is
defined as the construction on a previously undisturbed, disturbed, or
developed site.  Regardless of the setting (urban, rural or remote), the
project may require some trenching or jacking/boring to extend
electrical power to the tower area.  Replacement pertains to the
construction of a new updated communication tower on an existing
communication tower site.  

Modification of Existing Structures and Facilities

GPD grant funds can be used to improve security, and other essential
services at existing facilities through renovation, retrofitting, or
modification of existing structures.  This activity does not cover the
demolition or removal of an existing structure and its replacement.  

Projects of this type involve activities that are relatively minor
alterations to the interior or exterior of existing facilities, and may
or may not require ground disturbance.  Fixed equipment includes, but is
not limited to, closed-circuit television (CCTV) cameras, bollards,
lighting, fencing, identification card readers, tire puncture treadles,
enhanced communications equipment, loud speakers, warning sirens, and
motion detection equipment.  The installation of any fixed equipment on
communication towers will be discussed separately with communication
towers.

Eligible facilities under the GPD grant programs may include: security
guard buildings, emergency operation centers (EOCs), waterside
facilities (e.g., dock, boathouse, pier, waterside law enforcement
facility), court houses, police and fire stations, schools, places of
worship, medical facilities, stadiums, and transportation infrastructure
(e.g.  bus and railway stations, bridges, tunnels, etc.).

Actions analyzed under this alternative may or may not involve ground
disturbance.  Ground disturbance would typically be associated with
installation of utilities or fixed equipment, or enlarging a facility.

New Construction

Certain GPD grant programs allow for the construction of various
structures to house and enable the missions of various first responder,
public safety, and security entities.  These facilities and structures
play a significant role in enhancing preparedness and response
capability for these organizations.  New facilities that may be built
using specific GPD grant funds include: security guard buildings, EOCs,
fire stations, and docks/piers.  The types of new construction covered
under this project type can occur at previously undisturbed, disturbed,
or developed sites.  

All associated needs for a new facility, including utility connections,
fencing, lighting, access roads, equipment/construction staging areas,
parking and security measures, etc., are also covered under the analysis
of this project type, and are considered to contribute to the entire
project footprint.  In order to accurately assess the environmental
impacts of this project type, all features of the proposed development
must be analyzed.

Description of the Proposed Action and Alternatives to Implement the
Proposed Action 

Alternative 1 (No Action Alternative)

The No Action Alternative in the environmental analysis is defined as
maintaining the status quo.  The No Action Alternative evaluates the
effects of not providing eligible Federal assistance for a specific
action and provides a benchmark against which the action alternatives
may be evaluated.  

Under the No Action Alternative, GPD would not implement the programs
and would not provide Federal grant funding for security and response
measures to improve preparedness.  It is assumed that the proposed
program or project would not be implemented by the State, Territory,
local, or Tribal government or private entity due to lack of Federal
funding.

Alternative 2 (Program Implementation)

Programs

All actions considered in this PEA assume that the Federal action is:

Required to improve national preparedness and homeland security 

Funded under one of the GPD grant programs 

Homeland security grant programs are dynamic, and are constantly
evolving to better meet demonstrated homeland security needs.  As a
result, allowable expenses and actions under grant programs may change
from year to year.  The actions described and analyzed in this PEA are
not intended to provide a definitive list of allowable expenses and
actions for each grant program, rather they are intended to illustrate
the types of expenses and actions that may be allowable.  Grant guidance
for any given year specifically outlines allowable expenses and actions
for each specific grant program.  

Projects

Potential actions available for funding under the GPD grant programs
have been divided into eight project types: Planning, Management and
Administration, Training, Exercises, Purchase of Mobile and Portable
Equipment, Construction/Installation/Upgrading of Communication Towers
and Supporting Facilities, Modification of Existing Structures and
Facilities, and New Construction.  These eight general project types are
inclusive of actions that are central to GPD’s mission. Actions
analyzed in this PEA are not intended to supersede allowable grant
expenditures as specified in grant guidance for any given year.  Under
Alternative 2, all GPD-funded grant programs would be implemented
simultaneously.  

 

Summary of Environmental Impacts

Examination of the eight major project types revealed that
renovation/modification/retrofitting of existing critical infrastructure
facilities, projects associated with communication towers, and projects
involving new construction all have the potential to adversely impact
the environment as they would likely involve ground disturbing
activities and modification of potentially historic structures.  Through
this PEA, FEMA has determined that preparation of REC, a site-specific
SEA or stand-alone EA will be required for the purchase of sonars, the
construction, modification, and replacement of communication towers,
modifications of existing facilities, and new construction activities. 
Projects involving planning, training, exercises at existing facilities,
management and administration, and the purchase of mobile and portable
equipment (except for sonars) would not require further NEPA
documentation.  

Consequences of Alternative 1: The No Action Alternative

Under the No Action Alternative, no GPD-funded homeland security
projects would occur across any of the eight project types defined and
analyzed in this PEA.  Existing deficiencies and vulnerabilities in
public safety, preparedness, and readiness would persist.  This could
result in an adverse effect on human health and safety.

Consequences of Alternative 2:  Program Implementation

Alternative 2 would not have any significant impact on any of the
resources areas analyzed for those project types that meet the criteria
established in Section 5, Environmental Consequences, and summarized
above and in Tables ES-1 through ES-3.  Alternative 2 would also have
beneficial impacts to human health and safety by improving preparedness,
reducing vulnerabilities, and allowing State, Territorial, Tribal,
local, quasi-public, and private entities to make meaningful upgrades to
the Nation’s homeland security infrastructure.  

Table ES-1:  Summary Table:  Communication Towers: Modification to
Existing Towers, Replacement of Towers, and New Tower Construction

Criteria	Alternative 1:  No Action Alternative	Alternative 2:  Program
Implementation

Land Use	No effects.	There would be no effects to land use from upgrades
and renovations to existing towers or from tower replacement because
land use would not change.  

Given the relatively small expected footprint of proposed new
communication tower sites, substantial changes to land use are unlikely.
 Grantees and subgrantees are responsible for obtaining coastal
consistency determinations. FEMA would ensure the Coastal Barrier
Resources Act (CBRA) and the Farmland Protection Policy Act (FPPA).  No
significant effects are expected.

Geology and Soils	No effects.	There would be no significant impacts from
or to geology and soils from this project type. Projects in area
susceptible to seismic, volcanic, tsunamis, landslide or mudslide
activity, structural instability, excessive erodibility, or steep slopes
may require the use of certain engineering techniques or consultation
with State or Federal agencies to ensure their protection.  FEMA would
encourage avoidance of the projects in these hazard areas.

Ground disturbance associated with this project type would be limited
and would not be significant. Ground disturbance for this project type
would be less than one (1) acre. Grantees or subgrantees will implement
mitigation measures in Section 7.2 that would minimize the effects of
the project to soils. 

Water Resources	No effects.	There would be no significant effects to
water resources from this project type. Grantees and subgrantees would
be responsible for securing and meeting the conditions of water quality
permits such as NPDES and state permits. In addition, projects would be
implemented following mitigation measures in Section 7.2 which would
reduce  construction-related effects on water resources such as erosion
and sedimentation.

Floodplains	No effects.	Projects within floodplains will trigger
requirements under 44 CFR Part 9. FEMA is required to identify
practicable alternative outside the floodplain or minimize the
project’s impacts from or to floodplains. Towers may be consider
critical actions and would require evaluations using the 500-year BFE
standard. Projects located within the floodplain will be documented
through a REC or a site-specific SEA depending on the nature and
magnitude of the impacts. No significant impacts to or from floodplains
are expected from this project type.

Wetlands	No effects.	Projects located near or within wetlands may
trigger the requirements under 44 CFR Part 9. FEMA is required to
identify practicable alternatives that do not affect wetlands and
minimize the project’s impacts to wetlands. Projects affected wetlands
will be documented through a REC or a site-specific SEA depending on the
nature and magnitude of the impacts. In addition, grantees and
subgrantees are responsible for securing and meeting the conditions of
Federal and State permits needed for the filling of wetlands. No
significant impacts to or from floodplains are expected from this
project type.

Biological Resources 	No effects.	No significant impacts are expected on
vegetation. FEMA will document impacts analysis to sensitive vegetation
community through a REC or a site-specific SEA depending on the nature
and magnitude of the impacts. No significant impacts are expected to
aquatic animals. 

FEMA will engage in the ESA Section 7 consultation process with FWS or
NMFS if there are threatened or endangered species or critical habitat
that would be affected by the project. A site-specific SEA would be
required if a “no effect” or “not likely to adversely affect”
determination cannot be made and formal consultation is triggered.  

This project type has the potential to affect migratory birds
individually and cumulatively. FEMA will enter into a MOU with FWS for
the coordination of reviews and for addressing impacts to migratory
birds. The MOU would include recommendations for reducing the impacts of
new towers on migratory birds. Tower projects that do not meet the
guidelines will require site-specific evaluation and coordination with
FWS. This process will be documented through a REC or a site-specific
SEA depending on the nature and magnitude of the impacts of the project
to migratory birds.

Human Health and Safety	There would be adverse effects to human health
and safety because existing vulnerabilities in public safety and
homeland security preparedness would persist.  There would be no effect
on hazardous materials.	There would be no significant effect from the
use, storage, handling, and disposal of hazardous materials and wastes
that may be associated with the operation of communication tower sites.
Grantees and subgrantees are responsible for securing and meeting
conditions of permits and requirements at the Federal, State, Tribal
and/or local level for the handling of these materials.  The
construction of new or replacement tower sites, and renovations to
existing towers, would have a beneficial effect on public safety as they
would improve preparedness for public safety and homeland security
agencies.  

Minority and low-income populations	No effect.  	No significant impacts
are expected on minority and low-income populations. Tower projects are
intended to improve emergency response communication and public safety
and therefore would have a long-term beneficial impact on all segments
of the population. Grantees and subgrantees are responsible for engaging
in adequate public outreach before a new tower construction request is
made to FEMA.

Historic Properties 	No effect.	No significant impacts are expected to
historic properties. Grantees and subgrantees are encouraged to
co-locate communication equipment in existing towers whenever possible.
FEMA will require grantees and subgrantees to follow applicable
mitigation measures in Section 7 of this PEA to reduce potential adverse
effects. 

On November 3rd, 2009 the ACHP issued a program comment that states that
FEMA will not need to comply with Section 106 with regard to the effects
of communication facilities construction or modification that has either
undergone or will undergo Section 106 review, or is exempt from Section
106 review by the FCC under the FCC Nationwide Programmatic Agreement
and/or the FCC Collocation Programmatic Agreement.  FEMA must comply
with Section 106 for components that are ancillary to the construction
or modification of the communication facility itself.  Projects with
adverse effects to historic properties will require a REC or
site-specific SEA depending on the nature and magnitude of the adverse
effects. 

Infrastructure 	No significant effect, but existing deficiencies in
communications systems would persist.

	Short-term adverse construction related effects, due to interference
with availability and increases in construction and demolition wastes,
would not be significant.  No significant operations-related effects are
expected.

Short-term adverse construction-related effects due to construction
vehicles are not expected to be significant.  No significant effects
from operations.  

Air Quality	No effect.	No significant construction related effects, any
effects would be short-term.  No significant operations-related effects,
any generator use is expected to be occasional and of short duration. 
New, cleaner generators may reduce emissions. FEMA would require
grantees and subgrantees to follow applicable mitigation measures found
in Section 7.2.

Noise	No effect.	No significant construction-related effects, noise
effects are expected primarily in daytime hours.  No significant
operations-related effects, generator noise is expected to be occasional
and of short duration.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Visual Quality	No effect.

	Short-term adverse construction-related effects would not be
significant.  Long-term adverse related effects may occur. FEMA would
encourage grantees and subgrantees to take into account minimization
techniques such as selecting tower sites from areas already served by a
road, consolidating communication facilities when possible, selecting
new site locations where the features of the communication tower site
are consistent with the topography of the area, minimizing the footprint
of the affected area, painting concrete foundations with an earth-tone
paint to reduce contrast, painting communication towers to make them
less visible and distinct from the surrounding features, restoring and
landscaping disturbed areas after construction activities have been
completed, take into account other measures to buffer visual effects and
alterations to natural landscapes

FEMA would require grantees and subgrantees to follow applicable
mitigation measures found in Section 7.2.

Climate Change	No effect.	No significant impacts.  Short-term
construction impacts would not be significant, and no significant
impacts are expected from operation.  New generators that replace older
generators may reduce the amount of greenhouse gas (GHG) emissions.



Table ES-2:  Summary Table:  Modification of Existing Structures and
Facilities

Criteria	Alternative 1:  No Action Alternative	Alternative 2:  Program
Implementation

Land Use	No effects.	There would be no effects to land use from
renovation, modification, and retrofitting of existing facilities
because land use would not change.  Grantees and subgrantees are
responsible for obtaining coastal consistency determinations when
applicable. 

Geology and soils	No effects.	There would be no significant impacts from
or to geology and soils from this project type. Projects in area
susceptible to seismic, volcanic, tsunamis, landslide or mudslide
activity, structural instability, excessive erodibility, or steep slopes
may require the use of certain engineering techniques or consultation
with State or Federal agencies to ensure their protection.  FEMA would
encourage avoidance of the projects in these hazard areas.

Ground disturbance associated with this project type would be limited
and would not be significant. Ground disturbance for this project type
would be less than one (1) acre. Grantees or subgrantees will implement
mitigation measures in Section 7.2 that would minimize the effects of
the project to soils.

Water Resources	No effects.	There would be no significant effects to
water resources from this project type. Grantees and subgrantees would
be responsible for securing and meeting the conditions of water quality
permits such as NPDES and state permits. In addition, projects would be
implemented following mitigation measures in Section 7.2 which would
reduce  construction-related effects on water resources such as erosion
and sedimentation.

Floodplains	No effects.	Projects within floodplains will trigger
requirements under 44 CFR Part 9. FEMA is required to identify
practicable alternative outside the floodplain or minimize the
project’s impacts from or to floodplains. Projects located within the
floodplain will be documented through a REC or a site-specific SEA
depending on the nature and magnitude of the impacts. No significant
impacts to or from floodplains are expected from this project type.

Wetlands	No effects.	Projects located near or within wetlands may
trigger the requirements under 44 CFR Part 9. FEMA is required to
identify practicable alternatives that do not affect wetlands and
minimize the project’s impacts to wetlands. Projects affected wetlands
will be documented through a REC or a site-specific SEA depending on the
nature and magnitude of the impacts. In addition, grantees and
subgrantees are responsible for securing and meeting the conditions of
Federal and State permits needed for the filling of wetlands. No
significant impacts to or from floodplains are expected from this
project type.

Biological Resources 	No effects.	No significant impacts are expected on
vegetation. FEMA will document impacts analysis to sensitive vegetation
community through a REC or a site-specific SEA depending on the nature
and magnitude of the impacts. No significant impacts are expected to
aquatic animals. Projects in the floodplains and wetlands would require
compliance with 44 CFR 9. 

FEMA will engage in the ESA Section 7 consultation process with FWS or
NMFS if there are threatened or endangered species or critical habitat
that would be affected by the project. A site-specific SEA would be
required if a “no effect” or “not likely to adversely affect”
determination cannot be made and formal consultation is triggered.  

Human Health and Safety	There would be adverse effects to human health
and safety because existing vulnerabilities in public safety and
homeland security preparedness would persist.  There would be no effect
on hazardous materials.	There would be no significant effect from the
use, storage, handling, and disposal of hazardous materials and wastes
that may be associated with renovation, modification, and retrofitting
of existing facilities. Grantees and subgrantees are responsible for
securing and meeting conditions of permits and requirements at the
Federal, State, Tribal and/or local level for the handling of these
materials.   These facility upgrades would have a beneficial effect on
public safety as they would improve preparedness for public safety and
homeland security agencies

Low income and minority populations	No effect.  	No significant impacts
are expected on minority and low-income populations. Projects are
intended to improve emergency response and public safety capabilities
and therefore would have a long-term beneficial impact on all segments
of the population. 

Historic Properties 	No effect.	No significant impacts are expected to
historic properties. FEMA will require grantees and subgrantees to
follow applicable mitigation measures in Section 7 to reduce potential
adverse effects. 

FEMA will engage in the Section 106 consultation process for projects
with potential effects to historic properties. Projects with adverse
effects to historic properties will require a REC or site-specific SEA
depending on the nature and magnitude of the adverse effects. 

Infrastructure  	No effect.	

	Short-term adverse construction related effects, due to interference
with availability and increases in construction and demolition wastes,
would not be significant.  No significant operations-related effects are
expected.

Short-term adverse construction-related effects due to construction
vehicles are not expected t be significant.  No significant effects from
operations.  

Air Quality	No effect.	No significant construction related effects would
be expected, any effects would be short-term.  Interior renovations
would have no effect.  No significant operations-related effects would
be expected. FEMA would require grantees and subgrantees to follow
applicable mitigation measures found in Section 7.2.

Noise	No effect.	No significant construction-related effects are
expected, noise effects are expected primarily in daytime hours.  

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Visual Quality	No effect.

	Short-term adverse construction-related effects would not be
significant.  Long-term adverse effects may occur for projects involving
external renovations and would not be significant.

Climate Change	No effect	Short-term adverse construction-related effects
would not be significant.  Long-term effects from operations-related
emissions increases would not be significant.



Table ES-3:  Summary Table:  New Construction

Criteria	Alternative 1:  No Action Alternative	Alternative 2:  Program
Implementation

Land Use	No effects.	No significant impacts to land use are expected.
Grantees and subgrantees are responsible for coordinating land use
changes with local governments and obtain applicable State, Tribal, and
local construction and zoning permits. Grantees and subgrantees are
responsible for obtaining coastal consistency determinations. FEMA would
ensure the Coastal Barrier Resources Act (CBRA) and the Farmland
Protection Policy Act (FPPA). 

Geology, Soils, and Seismicity	No effects.	There would be no significant
impacts from or to geology and soils from this project type. Projects in
area susceptible to seismic, volcanic, tsunamis, landslide or mudslide
activity, structural instability, excessive erodibility, or steep slopes
may require the use of certain engineering techniques or consultation
with State or Federal agencies to ensure their protection.  FEMA would
encourage avoidance of the projects in these hazard areas.

Ground disturbance associated with this project type would be limited
and would not be significant. Ground disturbance for this project type
would be less than five (5) acres. Grantees or subgrantees will
implement mitigation measures in Section 7.2 that would minimize the
effects of the project to soils.

Water Resources	No effects.	There would be no significant effects to
water resources from this project type. Grantees and subgrantees would
be responsible for securing and meeting the conditions of water quality
permits such as NPDES and state permits. In addition, projects would be
implemented following mitigation measures in Section 7.2 which would
reduce  construction-related effects on water resources such as erosion
and sedimentation.

Floodplains	No effects.	Projects within floodplains will trigger
requirements under 44 CFR Part 9. FEMA is required to identify
practicable alternative outside the floodplain or minimize the
project’s impacts from or to floodplains. Projects located within the
floodplain will be documented through a REC or a site-specific SEA
depending on the nature and magnitude of the impacts. No significant
impacts to or from floodplains are expected from this project type.

Wetlands	No effects.	Projects located near or within wetlands may
trigger the requirements under 44 CFR Part 9. FEMA is required to
identify practicable alternatives that do not affect wetlands and
minimize the project’s impacts to wetlands. Projects affected wetlands
will be documented through a REC or a site-specific SEA depending on the
nature and magnitude of the impacts. In addition, grantees and
subgrantees are responsible for securing and meeting the conditions of
Federal and State permits needed for the filling of wetlands. No
significant impacts to or from floodplains are expected from this
project type.

Biological Resources 	No effects.	No significant impacts are expected on
vegetation. FEMA will document impacts analysis to sensitive vegetation
community through a REC or a site-specific SEA depending on the nature
and magnitude of the impacts. No significant impacts are expected to
aquatic animals. Projects in the floodplains and wetlands would require
compliance with 44 CFR 9. 

FEMA will engage in the ESA Section 7 consultation process with FWS or
NMFS if there are threatened or endangered species or critical habitat
that would be affected by the project. A site-specific SEA would be
required if a “no effect” or “not likely to adversely affect”
determination cannot be made and formal consultation is triggered.  

Human Health and Safety	There would be adverse effects to human health
and safety because existing vulnerabilities in public safety and
homeland security preparedness would persist.  There would be no effect
on hazardous materials.	There would be no significant effect from the
use, storage, handling, and disposal of hazardous materials and wastes
associated with this project type. Grantees and subgrantees are
responsible for securing and meeting conditions of permits and
requirements at the Federal, State, Tribal and/or local level for the
handling of these materials.   The construction of new facilities and
structures, would have a beneficial effect on public safety as they
would improve preparedness and for public safety and homeland security
agencies, and expand their capacity to respond effectively to an
emergency.

Low income and minority populations	No effect.  	No significant impacts
are expected on minority and low-income populations. New construction
projects are intended to improve emergency response and public safety
capabilities and therefore would have a long-term beneficial impact on
all segments of the population. Grantees and subgrantees are responsible
for engaging in adequate public outreach before a new construction
project request is made to FEMA.

Historic Properties 	No effect.	No significant impacts are expected to
historic properties. FEMA will require grantees and subgrantees to
follow applicable mitigation measures in Section 7 to reduce potential
adverse effects. 

FEMA will engage in the Section 106 consultation process for projects
with potential effects to historic properties. Projects with adverse
effects to historic properties will require a REC or site-specific SEA
depending on the nature and magnitude of the adverse effects. 

Infrastructure 	No effect.

	Short-term adverse construction related effects, due to increases in
construction and demolition wastes would not be significant.  No
significant operations-related effects are expected.

Short-term adverse construction-related effects due to construction
vehicles are not expected to be significant.  

Air Quality	No effect.	No significant construction related effects, any
effects would be short-term.  No significant operations-related effects
are expected. FEMA would require grantees and subgrantees to follow
applicable mitigation measures found in Section 7.2.

Noise	No effect.	No significant construction-related effects, noise
effects are expected primarily in daytime hours.  No significant
operations-related effects are expected.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Visual Quality	No effect.

	Short-term adverse construction-related effects would not be
significant.  Long-term adverse operations-related effects may occur and
would not be significant.

Climate Change	No effect	Short-term adverse construction-related effects
would not be significant.  Long-term effects from operations-related
emissions increases would not be significant.

Table of Contents

  TOC \o "1-5" \f \u  EXECUTIVE SUMMARY	  PAGEREF _Toc247355299 \h  1-1 

List of Acronyms	  PAGEREF _Toc247355317 \h  iv 

Section One	Introduction	  PAGEREF _Toc247355318 \h  1 

1.1	Overview	  PAGEREF _Toc247355319 \h  1 

1.2	Programmatic Environmental Assessment	  PAGEREF _Toc247355320 \h  1 

1.3	Activities Evaluated in the PEA	  PAGEREF _Toc247355321 \h  2 

Section Two	Purpose and Need	  PAGEREF _Toc247355322 \h  4 

2.1	Purpose	  PAGEREF _Toc247355323 \h  4 

2.2	Need	  PAGEREF _Toc247355324 \h  4 

Section Three	Alternatives	  PAGEREF _Toc247355325 \h  5 

3.1	Alternative 1: No Action	  PAGEREF _Toc247355326 \h  5 

3.2	Alternative 2: Program Implementation	  PAGEREF _Toc247355327 \h  5 

3.2.1	Programs	  PAGEREF _Toc247355328 \h  5 

3.2.2	Projects	  PAGEREF _Toc247355329 \h  6 

3.2.2.1	Planning	  PAGEREF _Toc247355330 \h  6 

3.2.2.2	Management and Administration	  PAGEREF _Toc247355331 \h  6 

3.2.2.3	Training	  PAGEREF _Toc247355332 \h  6 

3.2.2.4	Exercises	  PAGEREF _Toc247355333 \h  7 

3.2.2.5	Purchase of Mobile and Portable Equipment	  PAGEREF
_Toc247355334 \h  7 

3.2.2.6	Communication Towers	  PAGEREF _Toc247355335 \h  7 

3.2.2.6.1.	Existing Towers	  PAGEREF _Toc247355336 \h  7 

3.2.2.6.2.	New/Replacement Towers	  PAGEREF _Toc247355337 \h  8 

3.2.2.7	Modification of Existing Structures and Facilities	  PAGEREF
_Toc247355338 \h  10 

3.2.2.8	New Construction, including Replacement, of Facilities	  PAGEREF
_Toc247355339 \h  10 

Section Four	Affected Environment	  PAGEREF _Toc247355340 \h  12 

4.1	Land Use	  PAGEREF _Toc247355341 \h  12 

4.2	Geology, Soils and Seismicity	  PAGEREF _Toc247355342 \h  13 

4.2.1	Geology and Soils	  PAGEREF _Toc247355343 \h  13 

4.2.2	Seismicity	  PAGEREF _Toc247355344 \h  14 

4.3	Water Resources	  PAGEREF _Toc247355345 \h  14 

4.4	Floodplains	  PAGEREF _Toc247355346 \h  16 

4.5	Wetlands	  PAGEREF _Toc247355347 \h  17 

4.6	Biological Resources	  PAGEREF _Toc247355348 \h  18 

4.6.1	Vegetation	  PAGEREF _Toc247355349 \h  18 

4.6.2	Terrestrial Wildlife and Aquatic Resources	  PAGEREF _Toc247355350
\h  18 

4.6.3	Listed Species, Critical Habitat and Special-Status Species	 
PAGEREF _Toc247355351 \h  20 

4.7	Human Health and Safety	  PAGEREF _Toc247355352 \h  20 

4.8	Minority and Low Income Populations	  PAGEREF _Toc247355353 \h  22 

4.9	Historic Properties	  PAGEREF _Toc247355354 \h  23 

4.10	Infrastructure	  PAGEREF _Toc247355355 \h  25 

4.11	Air Quality	  PAGEREF _Toc247355356 \h  27 

4.12	Noise	  PAGEREF _Toc247355357 \h  29 

4.13	Visual Quality	  PAGEREF _Toc247355358 \h  29 

4.14	Climate Change	  PAGEREF _Toc247355359 \h  30 

Section Five	Environmental Consequences	  PAGEREF _Toc247355360 \h  32 

5.1	Alternative 1: No Action Alternative	  PAGEREF _Toc247355361 \h  38 

5.2	Alternative 2: Program Implementation	  PAGEREF _Toc247355362 \h  38


5.2.1	Programs	  PAGEREF _Toc247355363 \h  38 

5.2.2	Project Types	  PAGEREF _Toc247355364 \h  39 

5.2.2.1	Planning	  PAGEREF _Toc247355365 \h  39 

5.2.2.2	Training	  PAGEREF _Toc247355366 \h  39 

5.2.2.3	Management and Administration	  PAGEREF _Toc247355367 \h  40 

5.2.2.4	Exercises	  PAGEREF _Toc247355368 \h  40 

5.2.2.4.1.	Exercises within existing facilities	  PAGEREF _Toc247355369
\h  40 

5.2.2.4.2.	Exercises outside existing facilities, with major logistic
activity, or that involve release of toxic, radioactive, or biological
material/agents	  PAGEREF _Toc247355370 \h  40 

5.2.2.5	Mobile and Portable Equipment (No Installation)	  PAGEREF
_Toc247355371 \h  41 

5.2.2.6	Communication Towers	  PAGEREF _Toc247355372 \h  42 

5.2.2.6.1.	Existing communication towers	  PAGEREF _Toc247355373 \h  42 

5.2.2.6.2.	Construction of new or replacement communication towers	 
PAGEREF _Toc247355374 \h  54 

5.2.2.7	Modification of Existing Structures and Facilities	  PAGEREF
_Toc247355375 \h  66 

5.2.2.8	New Construction	  PAGEREF _Toc247355376 \h  75 

5.2.2.8.1.	New construction, including replacement, on previously
developed or disturbed sites	  PAGEREF _Toc247355377 \h  75 

5.2.2.8.2.	New construction on undeveloped or undisturbed sites	 
PAGEREF _Toc247355378 \h  82 

Section Six	Cumulative Impacts	  PAGEREF _Toc247355379 \h  91 

6.1	Alternative 1: No Action	  PAGEREF _Toc247355380 \h  91 

6.2	Alternative 2: Program Implementation	  PAGEREF _Toc247355381 \h  91


6.2.1	Programs	  PAGEREF _Toc247355382 \h  91 

6.2.2	Projects	  PAGEREF _Toc247355383 \h  91 

6.2.2.1	Migratory Birds and Communication Towers	  PAGEREF _Toc247355384
\h  92 

6.2.2.2	Construction Actions and Climate Change	  PAGEREF _Toc247355385
\h  92 

Section Seven	Mitigation	  PAGEREF _Toc247355386 \h  94 

7.1	Measures to avoid impacts to the human environment	  PAGEREF
_Toc247355387 \h  94 

7.2	Minimization Measures for ground disturbing/ construction activities
of up to five (5) acres	  PAGEREF _Toc247355388 \h  94 

7.3	Minimization/ Mitigation measures for communication towers	  PAGEREF
_Toc247355389 \h  96 

Section Eight	Documents Incorporated by Reference	  PAGEREF
_Toc247355390 \h  97 

Glossary of Terms	  PAGEREF _Toc247355391 \h  98 

References	  PAGEREF _Toc247355392 \h  99 

List of Preparers	  PAGEREF _Toc247355393 \h  101 

 List of Appendices

Appendix A	Description of GPD Grant Programs

Appendix B	FEMA CATEXs and Applicability to GPD-Funded Actions

Appendix C	Construction and Air Quality Impacts

Appendix D	Scope of EHP Review of GPD-Funded Actions

Appendix E	Adoption of Other (non-FEMA) EHP Reviews for a GPD-Funded
Action

Appendix F	Comments from the U.S. Fish and Wildlife Service Division on
Migratory Birds to the Federal Communications Commission for the Notice
for Proposed Rulemaking, “Effects of Communication Towers on Migratory
Birds”

Appendix G	Draft Memorandum of Understanding Between the Federal
Emergency Management Agency and the United States Fish and Wildlife
Service Regarding Implementation of Executive Order 12186,
“Responsibilities of Federal Agencies to Protect Migratory Birds”

Appendix H	Template of FEMA’s Record of Environmental Considerations
(REC)

Appendix I	Draft Program Comment for the National Telecommunications
Information Administration and the U.S. Department of Agriculture’s
RUS Regarding the Effects of Communication Facilities Construction or
Modification Subject to Review by the Federal Communications Commission

Appendix J	FEMA’s Comment to ACHP Draft Program Comment

Appendix K	Final Program Comment for Streamlining Section 106 Review for
Wireless Communication Facilities Construction and Modification Subject
to Review under the FCCC Nationwide Programmatic Agreement and/or the
Nationwide Programmatic Agreement for the Collocation of Wireless
Antennas.

Figures

  TOC \h \z \c "Figure 1-1: Use of PEA in FEMA's Review"    HYPERLINK \l
"_Toc227228800"  Figure 1-1: Use of PEA in FEMA's Review 

Figure 5-1:  FEMA NEPA Process for New Communication Towers

 Tables

  TOC \h \z \t "TCaption,1" \c "Table"    HYPERLINK \l "_Toc216233501" 
Table 3-1:  GPD Matrix 

Table 3-2:  GPD-Funded Actions by Program

  HYPERLINK \l "_Toc216233502"  Table 4-1:  National Ambient Air Quality
Standards 

Table 5-2:  Construction Site Pollutants (Water Quality)

Table 5-3:  Construction and Air Quality Impacts (Emissions) 

Table 5-4:  Construction and Noise Impacts

 List of Acronyms 

ACHP	Advisory Council on Historic Preservation

AEL	Authorized Equipment List

AFG 	Assistance to Firefighters Grants Program 

AGL 	above ground level 

APE	Area of Potential Effect

AQCR 	air quality control region 

BA	Biological Assessment

BLM	Bureau of Land Management

BMP	best management practice

BZPP 	Buffer Zone Protection Program 

CAA 	Clean Air Act 

CATEX 	categorical exclusion 

CBP 	Customs and Border Protection 

CBRA 	Coastal Barrier Resources Act 

CBRNE 	chemical, biological, radiological, nuclear, and explosive 

CBRS 	Coastal Barrier Resource System 

CCP 	Citizen Corps Program 

CCTV 	closed-circuit television 

CEDAP 	Commercial Equipment Direct Assistance Program 

CERCLA 	Comprehensive Environmental Response, Compensation, and
Liability Act 

CFATS	Chemical Facility Anti-Terrorism Standard

CFR	Code of Federal Regulations

CI/KR 	Critical Infrastructure/Key Resource 

CO 	carbon monoxide 

COI	chemicals of interest

CTGP 	Competitive Training Grant Program 

CWA	Clean Water Act

CZMA 	Coastal Zone Management Act 

dB 	decibel 

dB re 1 µPa2 –s	decibel referenced to 1 micropascal squared second

DHS 	Department of Homeland Security 

DOI	U.S. Department of the Interior

EA 	Environmental Assessment 

EFH 	Essential Fish Habitat 

EHP	Environmental and Historic Preservation

EHS	Extremely Hazardous Substance

EIS 	Environmental Impact Statement 

EMPG 	Emergency Management Performance Grants Program 

EO	Executive Order

EOC	Emergency Operations Center

EOP 	Emergency Operating Plan

EPCRA	Emergency Planning and Community Right to Know Act

ESA 	Endangered Species Act 

FAA 	Federal Aviation Administration 

FCC	Federal Communications Commission

FEMA 	Federal Emergency Management Agency 

FIP	Federal Implementation Plan

FIRM 	Flood Insurance Rate Map 

FONSI 	Finding of No Significant Impact 

FPPA 	Farmland Protection Policy Act 

FP&S 	Fire Prevention and Safety Grant Program 

FSGS 	Ferry Security Grant Supplemental 

FSM 	Federated States of Micronesia 

GCR 	General Conformity Rule 

GHG	Green House Gases

GPD 	Grant Programs Directorate 

G&T 	Office of Grants and Training 

Hz	hertz

HSEEP 	Homeland Security Exercise and Evaluation Program 

IAFIS 	Integrated Automated Fingerprint Identification System 

IBSGP 	Intercity Bus Security Grant Program 

ID	identification

IPP 	Infrastructure Protection Program 

kHz	kilohertz

LETPP 	Law Enforcement Terrorism Prevention Program 

µg/m3 	micrograms per cubic meter

M&A 	Management and Administration 

mg/m3 	milligrams per cubic meter

MMRS 	Metropolitan Medical Response System 

MMTCO2	Million Metric tons of carbon dioxide equivalent

MOA	Memorandum of Agreement

MOU 	Memorandum of Understanding 

MSDS	Material Safety Data Sheet

NAAQS 	National Ambient Air Quality Standards 

NEHRP 	National Earthquake Hazard Reduction Program 

NEPA 	National Environmental Policy Act of 1969 

NFIP 	National Flood Insurance Program

NHPA	National Historic Preservation Act

NMFS 	National Marine Fisheries Service 

NO2	nitrogen dioxide 

NOX 	nitrogen oxides

NOAA	National Oceanic and Atmospheric Administration

NOS	National Ocean Service

NPDES 	National Pollutant Discharge Elimination System 

NPS	National Park Service of the U.S. Department of Interior

NRCS	Natural Resources Conservation Service

NRF	National Response Framework

NRP	National Response Plan

NWP	Nationwide Permits

O3	ozone 

OC	Operating Center

PA	Programmatic Agreement or Program Analyst

Pb 	lead 

PEA 	Programmatic Environmental Assessment 

PM10	particulate matter equal to or less than 10 micrometers in
aerodynamic diameter 

PM2.5	particulate matter equal to or less than 2.5 micrometers in
aerodynamic diameter

PPE	Personal Protective Equipment

ppm 	parts per million

PSD 	Prevention of Significant Deterioration

PSGP 	Port Security Grant Program 

RCRA 	Resource Conservation and Recovery Act 

REC	Record of Environmental Consideration

RMI 	Republic of the Marshall Islands 

SDWA 	Safe Drinking Water Act 

SEA	Supplemental Environmental Assessment

SHPO	State Historic Preservation Officer

SHSP 	State Homeland Security Program 

SIP 	State Implementation Plan 

SO2	sulfur dioxide 

STQ	Screening Threshold Quantities

TCP	Traditional Cultural Property

THPO	Tribal Historic Preservation Officer

TIP	Tribal Implementation Plan

TSGP 	Transit Security Grant Program 

TSP 	Trucking Security Program 

UASI 	Urban Areas Security Initiative 

U.S.	United States

U.S.C.	United States Code

USACE 	U.S. Army Corps of Engineers 

USDA	U.S. Department of Agriculture

USEPA 	U.S. Environmental Protection Agency

USFS	U.S. Forest Service

USFWS 	U.S. Fish and Wildlife Service 

VOC	volatile organic compound

Introduction 

Overview

On December 17, 2003, the President issued Homeland Security
Presidential Directive 8 on National Preparedness.  Under the Directive,
the Secretary of Homeland Security, in coordination with the heads of
other appropriate Federal departments and agencies and in consultation
with State, Territory, and local governments, was tasked with developing
a national domestic all-hazards National Preparedness Goal (the Goal). 
Federal departments and agencies will work to achieve this goal by (a)
providing for effective, efficient, and timely delivery of Federal
preparedness assistance to State and local governments, and (b)
supporting efforts to ensure first responders are prepared to respond to
major events.

The Department of Homeland Security (DHS) Office of Grants and Training
(G&T) was transformed into GPD on April 1, 2007, as a result of the
Post-Katrina Emergency Management Reform Act of 2006.  GPD is housed
within FEMA to oversee the grant business operations, systems, training,
and policy.  FEMA supports the Nation’s citizens and first responders
to ensure that the Nation works together to build, sustain, and improves
its capability to prepare for, protect against, respond to, recover
from, and mitigate all hazards.  

Programmatic Environmental Assessment

The National Environmental Policy Act of 1969, 42 U.S.C. § 4321 et
seq., (NEPA) mandates that Federal agencies take into account the
effects of their actions, including programs, regulations, policies, and
grant-funded specific projects, on the quality of the human environment.
 The Council on Environmental Quality (CEQ) has established NEPA
Implementing Regulations at 40 Code of Federal Regulations (CFR) 1500 et
seq. for meeting these requirements, and each Federal agency has
developed its own implementing procedures specific to its mission. 
FEMA’s procedures are found at 44 CFR Part 10.  They contain a list of
actions, referred to as Categorical Exclusions (CATEX), that typically
do not individually or cumulatively have significant impacts on the
human environment. An action that would normally qualify for a CATEX may
have extraordinary circumstances that disqualify it from the CATEXs
applicability. FEMA’s list of extraordinary circumstances can be found
at 44 CFR 10.8(d)(3). Actions that are not covered by a CATEX or actions
covered by a CATEX that have unresolved extraordinary circumstances
require  the preparation of an Environmental Assessment (EA) under NEPA
to determine the nature and extent of impacts of the action and
determine whether the action has significant impacts on the quality of
the human environment. An Environmental Impact Statement (EIS) is
required when an action will have a significant impact on the quality of
the human environment.

The CEQ regulations at 40 CFR §§ 1500.4(i), 1502.4 and 1502.20
encourage the development of program-level NEPA environmental documents
and tiering for eliminating repetitive discussions and to focus on the
issues specific to the subsequent action. FEMA has developed this
Programmatic Environmental Assessment (PEA) under this CEQ authority. 

This PEA will also facilitate FEMA’s compliance with other
environmental and historic preservation requirements by providing a
framework to address the impacts of actions typically funded to aid in
national preparedness. FEMA coordinates and integrates to the maximum
extent possible the review and compliance process required under similar
requirements such as the Section 106 of the National Historic
Preservation Act (NHPA), Section 7 of the Endangered Species Act (ESA),
the eight step process of the Executive Order 11988 and 11990, and
others. This PEA provides a framework on how FEMA integrates these
requirements with NEPA.  

Finally, the PEA provides the public and decision-makers with the
information required to understand and evaluate the potential
environmental consequences of these national preparedness actions.  This
PEA meets the NEPA goals of impact identification and disclosure and
addresses the need to streamline the NEPA review process in the interest
of national preparedness.

Activities Evaluated in the PEA

This PEA evaluates typical security enhancement and associated
preparedness activities proposed under the GPD grant programs. A wide
range of activities may be funded by GPD grants, with varying expected
levels of impacts.  They may range from relatively small actions such as
the purchase of Personal Protective Equipment (PPE) and handheld radios
to the construction of communication towers and emergency operations
centers (EOCs).  While some activities are not expected to have any
impact on the quality of the human environment, others may have the
potential to impact a variety of environmental resources and/or historic
properties.  Allowable expenses under most GPD grants include such
activities as:

Planning

Management and Administration 

Training

Exercises

Purchase of Mobile and Portable Equipment

Construction/Installation/Upgrading of Communication Towers and
Supporting Facilities

Modification of Existing Structures and Facilities

New Construction

The analysis in this PEA leverages FEMA’s experiences regarding
environmental impacts that can be expected from actions funded by GPD
grant programs.  It is also based on a review of scientific literature,
consultation with regulatory agencies, and expert opinion.  FEMA will
use the analysis in this PEA to describe program-level environmental
impacts of GPD’s grant programs, and define those project types for
which no environmental impacts are expected and for which no further
NEPA documentation is required.  Furthermore, the PEA will define those
proposed GPD-funded project types that would require further analysis
before a determination of environmental impacts could reasonably be
made.  The NEPA compliance review of specific projects funded by GPD
could result in projects (1) needing to be modified or redesigned to
reduce or eliminate environmental impact, (2) needing a Record of
Environmental Considerations (REC) to account for the resolution of
requirements under other laws such as NHPA, ESA, EO 11988, and the
resolution of other extraordinary circumstances, (3) requiring a
Supplemental EA (SEA) to tier off of this PEA, (4) requiring an
individual site-specific EA to evaluate the potential for environmental
impact, or (5) needing an Environmental Impact Statement (EIS) to assess
the extent of the environmental impact of the project.

Figure 1-  SEQ Figure_1-1:_Use_of_PEA_in_FEMA's_Review \* ARABIC  1 :
Use of PEA in FEMA's Review 

 

 Purpose and Need 

Purpose

The preparedness grant programs managed by GPD enhance the capabilities
of States, Territories, Tribes, private-sector and non-governmental
first responders to prevent, prepare for, respond to, and recover from
natural and man-made disasters, and terrorist attacks.  These funds are
intended to develop and administer planning, training, personnel,
equipment, and exercise assistance efforts for state and local emergency
response agencies to better prepare them against the threat of terrorism
as part of GPD’s mission.

GPD’s mission is to manage Federal assistance to measurably improve
capability and reduce the risks the Nation faces.  GPD is responsible
for the program management and administration of 19 preparedness grant
programs.  These preparedness programs support the achievement of the
National Preparedness Goal by providing funds for State and local
homeland security efforts, such as planning, equipment purchase,
protection of critical infrastructure by reinforcing physical security
and access controls, and hiring and training first responders. 
Currently, GPD grants and associated funding are administered to all 56
States and Territories.

Need

The events of September 11, 2001 highlighted critical needs in the
Nation’s security safeguards and systems.  Effective preparedness is a
critical precondition of successful response.  State, Territory, Tribal,
and local governments, as well as quasi-governmental private entities,
need supplemental funds to improve preparedness and to successfully
respond to emergencies. 

Programmatic needs include integrating preparedness programs and
training into existing public safety initiatives, improving
emergency-response planning, implementing Statewide Critical
Infrastructure/Key Resource (CI/KR) protection programs, and
establishing protocols to effectively direct the flow of terrorism and
homeland security information.  Site-specific needs include physical
security enhancements that would improve infrastructure security and
resiliency, equipment and infrastructure to enhance jurisdictional
capabilities, public safety interoperable communications, upgrades to
emergency response systems, and improvements in intrusion and threat
detection, such as radiological and nuclear.   

Alternatives 

This section describes the proposed actions to address the purpose and
need. 

Alternative 1: No Action

FEMA has included a No Action Alternative to evaluate the potential
impacts of not providing eligible Federal assistance and to provide a
benchmark against which the proposed alternative may be evaluated. Under
the No Action Alternative, GPD would not implement the programs and
would not provide Federal grant assistance for security and response
measures to improve preparedness.  It is assumed that the proposed
program or project would not be implemented by the State, Territory,
local, or Tribal government or private entity due to lack of Federal
funding.

Alternative 2: Program Implementation

Programs

GPD grant programs are dynamic and are constantly evolving to better
meet demonstrated homeland security needs. Congress appropriates funding
annually for GPD grant programs and establishes priorities for the use
of these funds. As a result, allowable expenses and projects under grant
programs may change from year to year. Grant guidance for any given year
specifically outlines allowable expenses and actions for each grant
program; actions analyzed in this PEA are not intended to supersede
allowable grant expenditures as specified in grant guidance for any
given year. 

Currently, GPD administers 19 different grant programs. Below is a list
of current programs. 

SHSP	State Homeland Security Program 

Tribal SHSP	Tribal State Homeland Security Program

OPSG	Operation Stone Garden Security Grant

TSGP	Transportation Security Grant Program

TSP	Trucking Security Program 

UASI	Urban Areas Security Initiative 

EMPG	Emergency Management Performance Grant

IPR	Intercity Passenger Rail (AMTRAK)

EOC	Emergency Operations Center

MMRS	Metropolitan Medical Response System 

IECGP	Interoperability Emergency Communication Grant Program 

BZPP	Buffer Zone Protection Program 

FRSGP	Freight Rail System Grant Program 

DLSGP	Drivers License Security Grant Program

CCP	Citizen Corps Program 

NSGP	Nonprofit Security Grant Program 

PSGP	Port Security Grant Program

IBSGP	Intercity Bus Security Grant Program

AFG	Assistance to Firefighters Grant



Appendix A provides a brief description of each one of these programs.
New programs developed that meet the Purpose and Need in Section Two and
the impacts analysis in Section Five will be covered by this PEA. 

Projects

Potential actions eligible for funding under the GPD grant programs have
been divided into the following eight project types for discussion and
analysis in this PEA: Planning, Management and Administration, Training,
Exercises, Purchase of Mobile or Portable Equipment, Communication
Towers, Modification of Existing Structures and Facilities, and New
Construction.  

Planning

Planning projects would enable grantees to engage in
preparedness-related activities such as:  

  Prioritization of preparedness needs, 

Preparation or update of preparedness strategies,

Allocation of resources 

Delivery of preparedness programs across disciplines (e.g., law
enforcement, fire, Emergency Medical Services, public health, behavioral
health, public works, agriculture, and information technology) and
levels of government.  

These efforts include the development of policies, plans, procedures,
mutual aid agreements, strategies, and other publications that comply
with relevant laws, regulations, and guidance and are necessary to
perform assigned missions and tasks. 

Management and Administration

Activities allowable under the GPD grant programs regarding management
and administrative actions allow grantees to enhance their preparedness
through the hiring of personnel, publication of guidance documents, and
other management activities that build capacity.  Projects of this type
include:

Hiring planners and training program coordinators, exercise managers,
and grant administrators 

Overtime and backfill expenses for personnel

Regular-time operational costs for existing positions that are assigned
to full-time counterterrorism duties

Development, revision, documentation, and/or distribution of
regulations, directives, manuals, information bulletins, and other
guidance documents

Technical assistance activities that involve no resources other than
manpower and/or funding

Other personnel, administrative, fiscal and management activities that
involve 	no resources other than manpower and/or funding

Training 

States, Territories, Tribes, and urban areas are encouraged to apply for
GPD assistance to develop a State/Territory homeland security training
program.  These training programs, primarily classroom-based, enable
public safety, preparedness, and first responder agencies at all levels
to engage in activities that build capacity and capability at all
levels, enhancing preparedness.  Training-related costs under GPD may
include the establishment, support, conduct, and attendance of training.
 Training topics may include, but are not limited to, CBRNE national
security threats and catastrophic events, cyber/agriculture/food
security, intelligence gathering and analysis, citizen and community
preparedness, and training for volunteers.  For a listing of activities
that are allowable expenses, refer to the relevant year’s grant
guidance.  

Exercises 

Exercise scenarios eligible for funding would be based on a grantee’s
Multi-Year Training and Exercise Plan. These exercises, both field- and
classroom-based, enhance readiness by allowing public safety,
preparedness, and first responder agencies at all levels to engage in
tabletop and field exercises that allow them to rehearse real-life
scenarios in order to better prevent and respond to acts of terrorism. 
Exercise scenarios may include CBRNE, cyber, agricultural, and natural
or technological disasters.  Grant funds can be used to design, develop,
conduct, and evaluate terrorism prevention-related exercises.

Purchase of Mobile and Portable Equipment 

The GPD grant programs allow for equipment purchases under the 21
allowable equipment categories on the Allowable Equipment List (AEL), or
that are otherwise approved by GPD.  The AEL is available on-line at  
HYPERLINK "https://www.rkb.us/mel.cfm?subtypeid=549" 
https://www.rkb.us/mel.cfm?subtypeid=549 .  

The category of mobile and portable equipment is defined as devices that
do not require any fixed installation and may be transported from site
to site, such as hand-held radios, PPE, satellite phones, dive
equipment, boats, response vehicles, identification cards, and other
similar devices that do not require installation.  

Under the AEL, FEMA currently allows for the purchase of some types of
high frequency sonar equipment used for detection. These include, but
may not be limited to,:

Imaging sonar - a high-frequency sonar that produces video-like imagery
using a narrow field of view.

Scanning sonar - a smaller sonar system that produces a panoramic view
of the surrounding area.

Side Scan Sonar - produces strip-like images from both sides of the
device. This type of sonar emits a high frequency sound to detect a
target up to 1,500 meters away. 

Three-dimensional (3-D) sonar - produces a 3-D imagery of objects using
an array receiver. 

Generally the type of sonar equipment in the AEL operates between above
the 150 kilohertz (kHz) frequency with pings of 15 to 20 hertz (Hz). 

Communication Towers 

Communication towers facilitate contact among first responders during an
emergency event.  GPD grant funds may be used to install new towers,
replace older, less capable towers, and to upgrade existing towers to
enhance communication capabilities. This category also covers
tower-related equipment and infrastructure, as discussed below.

Existing Towers

Activities under this project type would be limited to the addition of
new equipment and the upgrade or enlargement of the existing facility. 
All potential activities would be limited to the communication tower and
the area within the fenced (secured) area associated with the existing
tower.  

Potential activities under this category could include, but are not
limited to:

Installing or upgrading electronic communication equipment on the tower
and/or inside the equipment building

Installing or upgrading security fencing

Installing or upgrading security or aviation lighting

Installing or upgrading an emergency backup generator and associated
fuel storage tank

Increasing the height of a tower on an existing concrete foundation

Enlarging or replacing an existing equipment building

Construction of concrete pad/slab/foundation on which to place equipment
building

Installing or upgrading aboveground vehicle barriers (if appropriate)

Installing or upgrading in-ground vehicle barriers (e.g., pop-up
ballast), if appropriate

Upgrading an existing access road 

New/Replacement Towers

Proposed activities within this category include new construction or
replacement of existing communication towers, associated equipment, and
supporting facilities.  

Communication tower sites are usually fenced and include the tower, a
supporting electronic equipment building, and an emergency backup power
generator.  Sites with a backup generator typically also have a fuel
tank for the generator with a capacity of up to 1,000 gallons, in remote
areas.  Tower facilities are usually unmanned and visited periodically
for maintenance or inspection, and electrical and telecommunications
lines are the only utilities at the site. A vehicular access road may be
required to reach the site, particularly in remote or undeveloped areas.
In some cases, especially in urban areas, the communication antenna
could be located on another structure, such as a water tower, smoke
stack, or roof of a building.  

For purposes of this PEA, construction of a new communication tower is
defined as the construction on a previously undisturbed, disturbed, or
developed site.  Construction of a new communication tower may involve:

Demolition of existing structures (if needed—disturbed or developed
sites only)

Clearing and grubbing the site (if needed)

Grading the site (if needed)

Construction of concrete foundations as a platform to support a steel
tower (if needed)

Construction of a vehicular access road (if needed)

Installing utilities (electricity, fiber optic, broadband, and
telecommunications lines) as appropriate, a backup generator and fuel
source, and batteries

Construction or placement of a structure for housing electronic
equipment (such buildings are often pre-fabricated)

Construction of concrete pad/slab/foundation on which to place equipment
building

Installing security fencing, lighting, and cameras

Regardless of the setting (urban, rural or remote), the proposed project
may require some trenching or jacking/boring to extend electrical power
to the tower area. Construction of the project components and
installation of the communication equipment may also include the
following activities:

Delivering construction materials to the project area

Mounting radio communication equipment on the communication tower and
within the equipment building

Ingress and egress of construction equipment and construction workers;
equipment required for the communication tower and equipment building
may include a backhoe, a plow cat, a compactor, a trencher, an auger,
concrete trucks, trucks transporting tower materials and cut/fill, and
work crew trucks  

Reclaiming all disturbed areas outside the secured area to the
pre-construction state using native vegetation

Replacement pertains to the construction of a new updated communication
tower on an existing communication tower site. Construction of a
replacement communication tower may include the following:

Demolition of existing structures 

Grading the site

Constructing concrete foundations as a platform to support a steel tower

Constructing the new tower, a building for housing electronic equipment,
and security features (e.g., fencing, lighting, etc.), as appropriate

Installing or upgrading utilities (electricity, fiber optics, broadband,
and telecommunications lines) as appropriate, a backup generator and a
fuel source, and batteries

Delivery of construction materials to the project area

Mounting of radio communication equipment on the communication tower and
within the equipment building

Ingress and egress of construction equipment and construction workers;
equipment required for the communication tower and equipment building
may include a backhoe, a plow cat, a compactor, a trencher, an auger,
concrete trucks, trucks transporting tower materials and cut/fill, and
work crew trucks  

Reclaiming all disturbed areas outside the secured area to the
pre-construction state using native vegetation

It is important to note that some of the above activities associated
with tower projects, such as upgrades to or construction of access
roads, may not be eligible for GPD funding, and must be paid for using
non-GPD funds. However, for purposes of FEMA’s EHP review, all these
tower-related activities must be taken into account and are considered
part of the overall tower project.

Modification of Existing Structures and Facilities

GPD grant funds can be used to improve security and other essential
services at existing facilities through renovation, retrofit or
expansion of existing structures.  

Projects of this type involve activities that are relatively minor
alterations to the interior or exterior of existing facilities and may
or may not require ground disturbance. This project type includes
equipment that must be installed fixed at, in, or on a facility
(hereinafter referred to as “fixed equipment”). Fixed equipment
includes, but is not limited to, closed-circuit television (CCTV)
cameras, bollards, lighting, fencing, identification card readers, tire
puncture treadles, loud speakers, warning sirens, x-ray machines, and
motion detection equipment.  

Facilities that may be eligible for security enhancements under the GPD
grant programs include: security guard buildings, emergency operation
centers (EOCs), waterside facilities (e.g., dock, dockhouse, pier,
waterside law enforcement facility), court houses, police and fire
stations, schools, places of worship, medical facilities, stadiums,
transportation infrastructure (e.g. bus and railway stations, bridges,
tunnels, etc.), and tourist sites (e.g. monuments, museums, historic
sites).

Examples of GPD-funded actions include:

Installing fixed equipment (see examples above)

Installing, replacing or upgrading blast-proof doors or windows

Installing, replacing or upgrading interior gates or barriers

Installing, replacing or upgrading plumbing, electrical lines or other
utilities

Enlarging an existing facility (e.g. adding an annex, story, etc.) 

Activities analyzed under this alternative may or may not involve ground
disturbance. For purposes of this PEA ground disturbance means any work
or activity that results in a disturbance of the earth, including
excavating, digging, trenching, plowing, drilling, tunneling,
backfilling, blasting, topsoil stripping, land leveling, peat removing,
quarrying, clearing and grating. Ground disturbance would typically be
associated with installation of utilities, enlarging a facility, and
installation of fence and light posts. Ground disturbance actions under
this project type would be less than one (1) acre. 

New Construction, including Replacement, of Facilities

Certain GPD grant programs allow for the construction of various
structures to house and enable the missions of various first responder,
public safety, and security entities.  These facilities and structures
play a significant role in enhancing preparedness and response
capability for these organizations.  New facilities that may be built
using GPD grant funds include: security guard buildings, EOCs, fire
stations, and docks/piers. For purposes of this PEA, new construction is
defined as preparation of previously disturbed or undisturbed land and
the building or assembly of new buildings (including pre-fabricated
buildings), structures, facilities, infrastructure and other real
property on that land. The types of new construction covered under this
project type can occur at previously undisturbed, disturbed, or
developed sites.  Activities associated with the construction of a new
facility may include:

Demolition of an existing structure

Site clearing and grubbing

Site grading

Excavation

Staging areas for equipment, building materials, fill, etc.

Delivery, installation, and connection of utilities

Installing supporting security measures

Use of construction equipment, such as backhoes, front-end loaders,
compactors, trenchers, augers, trucks (concrete, delivery, dump), and
air compressors

Traffic to and from the project site, including worker vehicles and
delivery vehicles

Demolishing an existing facility and replacing it with a new facility on
the same site

All associated needs for a new facility, including utility connections,
fencing, lighting, access roads, equipment staging areas, parking and
security measures, etc., are also covered under the analysis of this
project type, and are considered to contribute to the entire project
footprint.  In order to accurately assess the environmental impacts of
this project type, all features of the proposed development must be
analyzed. These activities would typically be less than five (5) acres.
Affected Environment

This section provides a description of the various areas of concern,
from an environmental and historic preservation perspective, that could
potentially be impacted by projects implemented using GPD grant funding.
It serves as a baseline from which to identify and evaluate potential
impacts.  The potential impacts of GPD-funded projects on the quality of
the human environment are discussed in Section Five, Environmental
Consequences. The areas of concern covered in this section are: land
use; geology, soils and seismicity; water resources; wetlands;
floodplains; biological resources;  human health and safety;  low-income
and minority populations; historic properties; infrastructure; air
quality; noise; visual quality; and climate change.

Land Use 

Land use is the way in which, and the purposes for which, people utilize
the land and its resources.  Land use planning varies depending on land
ownership and jurisdictional boundaries.  Land use within and in the
immediate vicinity of urban areas is generally guided by comprehensive
plans that specify the allowable types and locations of present and
future land use.  In most cases, that comprehensive plan is developed
through a public participation process and approved by publicly-elected
officials to capture local values and attitudes toward planning and
future development.  Zoning ordinances and regulations vary throughout
the U.S. and are primarily set at the regional, city, county, or local
level. 

Some GPD projects may occur on Federally-managed land, such as Bureau of
Land Management (BLM) or U.S. Forest Service (USFS) land.  Land use
planning in these Federally-managed lands do not undergo the same type
of planning process as land under the ownership of private and municipal
entities.  Most Federal land planning activities are under the
discretion of the managing agency, which has its own criteria for use,
development procedures, and public involvement.  These activities are
often exempt from local zoning ordinances and regulations. 

The proposed project sites are likely to vary greatly in their land use
characteristics given that GPD-funded activities may occur at various
locations throughout the contiguous United States, Alaska, Hawaii, and
Caribbean and Pacific Islands.  To assess the affected environment
related to zoning and land use, it may be necessary to survey the
proposed project area.  This site-specific analysis is beyond the scope
of this PEA, therefore potential impacts will be discussed on a
programmatic level.  

The following land designations are discussed below: coastal zones,
coastal barriers, and important farmlands.  

The Costal Zone Management Act (CZMA) of 1972 (16 U.S.C. § 1451 et
seq.) is administered by the Department of Commerce’s Office of Ocean
and Coastal Resource Management within the National Oceanic and
Atmospheric Administration (NOAA). It applies to all coastal States and
to all states that border the Great Lakes. The CZMA was established to
help prevent any additional loss of living marine resources, wildlife,
and nutrient-enriched areas; alterations in ecological systems; and
decreases in undeveloped areas available for public use. The CZMA gives
states the authority to determine whether activities of governmental
agencies are consistent with Federally-approved coastal zone management
programs. Each state coastal zone management program must include
provisions protecting coastal natural resources, fish, and wildlife;
managing development along coastal shorelines; providing public access
to the coast for recreational purposes; and incorporating public and
local coordination for decision-making in coastal areas. This voluntary
Federal-State partnership addresses coastal development, water quality,
shoreline erosion, public access, protection of natural resources,
energy facility siting, and coastal hazards. 

The Federal Consistency provision, contained in Section 307 of the CZMA,
allows affected states to review Federal activities to ensure that they
are consistent with the state’s coastal zone management program. This
provision also applies to non-Federal programs and activities that use
Federal funding and that require Federal authorization. Any activities
that may have an effect on any land or water use or on any natural
resources in the coastal zone must conform to the enforceable policies
of the approved state coastal zone management program. NOAA’s
regulations in 15 CFR 930 provide the procedures for arriving or
obtaining a consistency determination.

The Coastal Barrier Resources Act (CBRA) of 1982 (16 U.S.C. § 3501 et
seq.), administered by the U.S. Fish and Wildlife Service (FWS), was
enacted to protect sensitive and vulnerable barrier islands found along
the U.S. Atlantic, Gulf, and Great Lakes coastlines. The CBRA
established the Coastal Barrier Resources System (CBRS), which is
composed of undeveloped coastal barrier islands, including those in the
Great Lakes. With limited exceptions, areas contained within a CBRS are
ineligible for direct or indirect Federal funds that might support or
promote coastal development, thereby discouraging development in coastal
areas. 

Prime and unique farmlands and farmlands of state and local importance
are protected under the Farmland Protection Policy Act (FPPA) of 1981 (7
U.S.C. § 4201 et seq.). Prime farmland is characterized as land with
the best physical and chemical characteristics for the production of
food, feed, forage, fiber and oilseed crops. Prime farmland is either
used for food or fiber crops or is available for those crops; it is not
urban, built-up land, or water areas. Unique farmland is defined as land
that is used for the production of certain high-value crops, such as
citrus, tree nuts, olives, and fruits. The FPPA requires Federal
agencies to examine the potentially adverse effects to these resources
before approving any action that would irreversibly convert farmland to
non-agricultural uses. This examination is done in consultation with the
U.S. Department of Agriculture’s (USDA) Natural Resources Conservation
Service (NRCS), who uses a land evaluation and site assessment system to
complete a Farmland Conversion Impact Rating Form (Form AD-1006).
Federal regulations at 7 CFR 658 describe the process for this analysis.


Geology, Soils and Seismicity

Geology and Soils

The geology of an area refers specifically to the surface and
near-surface materials of the earth and to how those materials were
formed. These resources are typically described in terms of regional or
local geology, including mineral resources, earth materials, soil
resources, and topography. 

Descriptions of these resource areas include bedrock or sediment type
and structure, unique geologic features, depositional or erosional
environment, and age or history. Mineral resources include usable
geological materials that have some economic or academic value. Soil is
the unconsolidated loose covering of broken rock particles and decaying
organic matter overlying the bedrock or parent material. Soils are
typically described by their complex type, slope, and physical
characteristics. Topography consists of the geomorphic characteristics
of the land or sea floor surface, including the change in vertical
elevation of the earth’s surface across a given area, the relationship
with adjacent land features, and geographic location (USCG 2006).

Soil characteristics within an area depend on the parent material
located in that area.  Soil characteristics vary across the U.S. and its
territories.  Areas with similar soils are grouped and labeled as soil
series because of their similar origins and chemical and physical
properties, which cause the soils to perform similarly for land use
purposes. 

The geological makeup of the United States is broken down into
physiographic divisions, as established by the U.S. Geological Survey
(USGS). Physiographic divisions are broad-scale regions established by
common terrain texture, rock type, and geologic structure and history. 

Geologic, topographic, and soil characteristics may impose limitations
on potential uses for a particular site. Areas characterized by
susceptibility to flooding, seismic or volcanic activity, tsunamis,
landslides, mudslides, structural instability, excessive erodibility, or
steep slopes may entirely preclude the implementation of a proposed
project at a particular location, or may require the use of certain
engineering technologies or require consultation with State or Federal
agencies before the proposed project may proceed. 

Seismicity

Executive Order 12699 – Seismic Safety of Federal and Federally
Assisted or Regulated New Building Construction establishes
responsibilities regarding the seismic-related safety of buildings
owned, leased or funded by Federal agencies. Under this EO, each Federal
agency responsible for the design and construction of a Federal or
federally-funded building must ensure that the building is designed and
constructed in accordance with appropriate seismic design and
construction standards.  These standards are promulgated through the
National Earthquake Hazard Reduction Program (NEHRP) and are
subsequently incorporated into model building codes (such as the 2006
International Building Code/International Residential Code) that are
used as the basis for local building codes in most municipalities. 
NEHRP periodically publishes new standards; the latest NEHRP standards
were published in 2000 (NEHRP 2000).  The EO applies to all building
projects for which detailed plans and specifications were initiated
subsequent to its issuance.  A building means any structure, fully or
partially enclosed, used or intended for sheltering persons or property.

The purposes of these requirements are to:

Reduce the risks to persons who would be affected by the failure during
an earthquake of buildings owned by the Federal government, leased for
Federal uses, or purchased or constructed with Federal assistance;

Improve the capability of essential Federal buildings to function during
and after an earthquake;

Reduce earthquake-related losses to public buildings in a cost-effective
manner.

Water Resources

Water resources refer to the occurrence, availability and physical,
chemical, and biological characteristics of surface water and
groundwater, including hydrologic properties and water quality for
aquatic plant and animal communities and public water supplies.  Water
bodies include aquifers, springs, streams, river, lakes, reservoirs,
estuaries, and near shore and offshore marine waters.  Water quality
encompasses the level of pollutants that affect the suitability of water
for a given use.  Water use classifications generally include public
water supply, recreation, propagation of fish and other aquatic life,
agricultural use, and industrial use.

Water resources (water quality and quantity) are protected and regulated
by many Federal statutes and EOs, as well as State and local regulations
and directives.  Surface, ground, and coastal waters are protected from
pollution originating from point sources such as sewage treatment plant
discharge and industrial discharges, and from non-point sources such as
runoff from urban paved areas, mines, and livestock operations. 
Statutes, laws, and EOs governing water resources are listed below.
Wetlands and floodplains will be described separately in the following
sections.

Federal Water Pollution Control Act of 1972 (better known as Clean Water
Act (CWA)) (33 U.S.C. § 1251 et seq.): This Act regulates water quality
of all discharges into “waters of the United States.” The CWA also
establishes the National Pollutant Discharge Elimination System (NPDES)
under Section 402, permits for dredged or fill material under Section
404, and state water quality certification requirements under Section
401.  The NPDES Permit Program regulates wastewater discharges from
point sources.  A NPDES Stormwater General Construction Permit is
required before construction modification activities commence at a site
where more than 1 acre of land will be disturbed.  Construction activity
that includes “routine maintenance to maintain original lie and grade,
hydraulic capacity, or original purpose of the facility” is
specifically excluded.

Section 404 of the CWA: The U.S. Army Corps of Engineers (USACE) is
responsible for regulating the disposal of dredged and fill materials
under Section 404 of the CWA. Certain waters of the United States are
considered “special aquatic sites” under the CWA because they are
generally recognized as having particular ecological value. Such sites
include sanctuaries and refuges, mudflats, wetlands, vegetated shallow,
eelgrass beds, coral reefs, and riffle and pool complexes. Special
aquatic sites are defined in the CWA and may be afforded additional
consideration in the USACE permit process for a project.  Section 404
permits are discussed in more detail under wetlands in Section 4.5 of
this PEA.  Section 401 of the CWA specifies that States must certify
that any activity subject to a permit issued by a Federal agency, such
as a CWA Section 404 permit, meets all state water quality standards.

Safe Drinking Water Act (SDWA) of 1974 (42 U.S.C. § 300f et seq.): The
U.S. Environmental Protection Agency (USEPA) regulates primary drinking
water supplies under the SDWA. These regulations were established to
protect public health and prescribe requirements for State programs to
implement the public water supply supervisor program and underground
injection control program under the authority of SDWA.

Sole Source Aquifers (42 U.S.C. § 300h-3(e)): The SDWA authorizes USEPA
to designate aquifers that are the sole or principal source of drinking
water for an area. To meet the criteria for designation, a sole-source
aquifer must supply at least 50 percent of the drinking water to persons
living over the aquifer and no feasible alternate source of drinking
water is available. Once an aquifer is designated, USEPA can review
proposed projects that are to receive Federal funds and that have the
potential to contaminate the aquifer. Federal agencies cannot provide
financial assistance to a project for which the USEPA finds that it
would create a significant hazard to public health by contaminating a
designated SSA. 

Section 10 of the Rivers and Harbors Act (RHA) of 1899 (33 U.S.C. § 401
et seq.): This Act requires authorization from the USACE for
construction activities in or near any navigable water of the United
States. 

Wild and Scenic Rivers Act (WSRA) of 1968 (16 U.S.C. § 1271 et seq.):
This Act preserves selected rivers in a free-flowing condition and
protects their local environments. 

Floodplains

Floodplains are the lowland and relatively flat areas adjoining inland
and coastal waters including, at a minimum, that area subject to a one
percent or greater chance of flooding in any given year. Floodplains
perform a variety of essential functions including floodwater conveyance
and storage, groundwater recharge, wave attenuation, streambank erosion,
reduction in sedimentation rates, water quality maintenance, and support
of highly productive ecosystems. 

Most floodplains are adjacent to streams, lakes, or oceans.  Beaches and
small river valleys are usually easily recognizable as floodplains, but
less obvious floodplains occur in dry washes and on alluvial fans in
arid parts of the western United States, around prairie potholes, in
areas subject to high groundwater levels, and in low lying areas where
water may accumulate.  Sheet flooding and ponding occur in areas where
there is no clearly defined channel and the path of flooding is
unpredictable. 

FEMA is charged with the implementation of the National Flood Insurance
Act (NFIA) as amended. The NFIA creates the National Flood Insurance
Program (NFIP), makes flood insurance available for structures within
communities participating in the NFIP, and requires the acquisition of
flood insurance for structures in special flood hazard areas as a
pre-condition of receiving Federal assistance. As part of its
implementation of the NFIP FEMA identifies special flood hazard areas in
Flood Insurance Rate Maps (FIRMs) and requires communities to adopt
local floodplain ordinances that meet, at a minimum, FEMA’s floodplain
management criteria in 44 CFR 60 et seq.

Executive Order 11988 – Floodplain Management was issued in 1977 to
eliminate the long- and short-term adverse impacts associated with the
occupancy and modification of floodplains, and to avoid direct or
indirect support of floodplain development wherever there is a
practicable alternative for locating a project outside of the
floodplain.  EO 11988 applies to federally-funded projects and directs
agencies to consider alternatives to siting projects within a
floodplain.  FEMA’s regulations in 44 CFR Part 9 implement EO 11988
for the agency. These regulations require FEMA to engage in an 8-step
decisionmaking process before undertaking an action within the
floodplain or that would be affected by the floodplain. These steps
involve: (1) determination that the action is in the floodplain, would
affect the 100-year floodplain, or would indirectly support development
in the floodplain; (2) early public notice; (3) identification and
evaluation of alternatives to locating in the floodplain; (4)
identification of the impacts of the proposed action; (5) selection of
minimization, restoration and preservation measures; (6) reevaluation of
alternatives; (7) publication of findings and public explanation; and
(8) implementation of the action. For critical actions such as emergency
operation centers, communication towers, hazardous waste facilities,
hospitals, or utility plants FEMA must identify practicable alternatives
outside the 500-year floodplain.  If no practicable alternatives exist
to constructing a facility and/or supporting features, outside the
floodplain, then FEMA must minimize potential harm to or from the
floodplain. FEMA’s procedures contain particular restrictions and
minimization requirements for actions that will be located in the
coastal high hazard area (CHHA, typically depicted as V-zones in
FEMA’s FIRMs) or in the regulatory floodway.

Wetlands 

Wetlands are areas which are inundated or   HYPERLINK
"http://en.wikipedia.org/wiki/Saturated" \o "Saturated"  saturated  by
surface or ground water with a frequency sufficient to support, or that
under normal hydrological conditions does or would support, a prevalence
of vegetation or aquatic life typically adapted for these soil
conditions. Examples of wetlands include   HYPERLINK
"http://en.wikipedia.org/wiki/Swamp" \o "Swamp"  swamps ,   HYPERLINK
"http://en.wikipedia.org/wiki/Marsh" \o "Marsh"  marshes , estuaries,  
HYPERLINK "http://en.wikipedia.org/wiki/Bog" \o "Bog"  bogs , beaches,
wet meadows, sloughs, mud flats, among others.

Wetlands have important ecological functions and are biologically
diverse.  They assimilate nutrients in surrounding surface waters,
remove suspended solids and pollutants from stormwater, and protect
shorelines from wind and wave action and storm-generated forces. 
GPD-funded actions that would impact wetlands would require review under
several regulatory programs.  These programs are listed below.

Section 404 of the CWA: Formal legal protection of jurisdictional
wetlands is promulgated through Section 404 of the CWA.  A dredge and
fill permit for activities in waters of the United States including
wetlands from the USACE is required if an action has the potential to
adversely affect jurisdictional wetlands.  There are several Nationwide
Permits (NWP) for activities in waters of the United States that may
cover specific aspects of the development of the proposed activities. 
For example, NWP 3 (Maintenance) may apply to activities related to the
repair, rehabilitation, or replacement of an existing structure; NWP 12
(Utility Line Activities) or NWP 14 (Linear Transportation Projects) may
apply to the construction of utility lines and access roads for new
facilities; NWP 18 (Minor Discharges) or NWP 19 (Minor Dredging) may
apply to many sites where water impacts are minimal; NWP 28
(Modifications of Existing Marinas) may apply to activities near tidal
waters; and NWP 39 (Commercial and Institutional Developments) may apply
to actions involving the expansion or construction of security
facilities.  The NWP program has numerous guidelines and conditions that
must be met for an activity to qualify for a permit.  NWPs are subject
to review by the States under Section 401 of the CWA, as are all aspects
of the USACE permitting program.  Various USACE Districts also have
Regional General Permits that function similarly to NWPs; however,
Regional General Permits are typically more specific in the types of
actions that they cover and typically necessitate more stringent
conditions and reporting requirements. If none of the NWPs apply to the
proposed activity and no applicable Regional General Permit exists, then
the grantee or subgrantee must acquire an Individual Permit from the
USACE.

Section 401 of the CWA: Each State has an opportunity to establish
specific criteria for water quality protection under this section of
this Act.  These provisions must be satisfied prior to issuance of
permits under Sections 402 and 404 of the CWA.

Executive Order 11990 – Protection of Wetlands: This EO, issued in
1977, requires that all federally funded, permitted, or sponsored
projects affecting wetlands demonstrate that there are no practicable
alternatives, and that the proposed action includes all practicable
measures to minimize harm to wetlands that may result from such use.  

FEMA’s implementation of EO 11990 is described in 44 CFR Part 9 and
involves an 8-step decision-making process similar to that described for
EO 11988.  This process ensures that proposed activities are consistent
with EO 11990 and is also used to evaluate the potential effects of an
action on wetlands.  GPD-funded projects affecting wetland areas may
require site-specific evaluation and consultation to develop mitigation
measures.  

Biological Resources 

Biological resources include animals, plants, and their habitats. In
general, biological resources can include native and introduced plants
that comprise the various habitats, animals present in such habitats,
and natural areas that help support these plant and wildlife
populations. Protected or sensitive biological resources include plant
and animal species listed as threatened or endangered by FWS, National
Marine Fisheries Service (NMFS), or a State.

Vegetation

Vegetation can be characterized as tundra, forest (coniferous and
broadleaf/mixed), grasslands and savannas, and desert. The potential for
an area to provide and be used as wildlife habitat is based on several
factors, including topography, vegetative cover and type, water
availability, aerial extent, connectedness, and interferences
attributable to human activity. 

Terrestrial Wildlife and Aquatic Resources

Terrestrial wildlife species distribution and abundance are heavily
influenced by available habitat.  Available habitat and vegetative
communities vary significantly across the U.S. and its territories even
within short distances.  Site-specific information is needed to
determine project-specific impacts on wildlife species.  Therefore, the
focus of the baseline discussion is on compliance with existing laws and
EOs regarding terrestrial wildlife.

In general, aquatic resources that could be affected by project
activities are limited to water bodies located down gradient of a
project site.  Waterside structures also have potential to directly
affect a water body through the placement of pilings, docks, etc.  Both
the distribution and abundance of aquatic species can be influenced by
factors such as water quality (including temperature), land use
practices within the watershed, and the presence of other aquatic
species, especially non-native exotic species.  Again, because potential
project sites are located across the U.S. and its territories, providing
baseline information for all aquatic ecosystems that could be located
down gradient of project sites is beyond the scope of this PEA.  

Examples of laws and EOs governing terrestrial wildlife and aquatic
species are listed below.  

Endangered Species Act (ESA) of 1973 (16 U.S.C. § 1531 et seq.):  This
Act prohibits any actions that may harm or jeopardize the continued
existence of any threatened or endangered species, or critical habitat. 
This is discussed in greater detail below.  

Bald and Golden Eagle Protection Act (BGEPA) of 1940 (16 U.S.C. § 668
et seq.): This Act prohibits the taking or possession of and commerce in
bald eagle and golden eagles with limited exceptions.

Migratory Bird Treaty Act (MBTA ) of 1918 (16 U.S.C. §  703 et
seq.):The Migratory Bird Treaty Act makes it unlawful for any individual
to take, possess, buy, sell, purchase, or barter any migratory bird,
including feathers or other parts, nests, eggs, or products, except as
allowed by implementation regulations.  It has been extended to include
almost all birds that have the ability to seasonally relocate within
various part of the U.S. A list of migratory birds can be found in 50
CFR Part 10.13 and at   HYPERLINK
"http://www.fws.gov/migratorybirds/RegulationsPolicies/mbta/mbtandx.html
" 
http://www.fws.gov/migratorybirds/RegulationsPolicies/mbta/mbtandx.html
. 

Executive Order 12186 – Responsibilities of Federal Agencies to
Protect Migratory Birds: EO 13186 directs Federal agencies whose
activities have or are likely to have a measurable, negative effect on
migratory bird populations to develop and implement a Memorandum of
Understanding (MOU) with FWS that will promote the conservation of
migratory birds. Activities subject to the E.O. 12186 may include
implementation of agency programs.

Fish and Wildlife Coordination Act (FWCA) of 1934 (16 U.S.C. § 661 et
seq.): This Act was enacted to protect fish and wildlife when Federal
actions result in the impoundment of a natural stream or body of water. 
States also have biological resource protection regulations and
guidelines that must be considered in order to comply with the Act.

Marine Mammal Protection Act (MMPA) of 1972 (16 U.S.C. § 1361 et seq.):
This Act prohibits the taking or importing of marine mammals and marine
mammal products.  

Magnuson-Stevens Fishery Conservation and Management Act (MSA) of 1976
(16 U.S.C. § 1801 et seq.): The Amended Act, also known as the
Sustainable Fisheries Act, requires all Federal agencies to consult with
NMFS on activities or proposed activities authorized, funded, or
undertaken by that agency that may adversely affect Essential Fish
Habitat (EFH).  

EO 13089 – Coral Reef Protection: This EO tasks Federal agencies with
identifying actions that may affect coral reef ecosystems and ensuring
that actions that they authorize, fund, or conduct will not degrade the
conditions of coral reef ecosystems.

EO 13112 – Invasive Species: EO 13112 was created to prevent the
introduction of invasive species and to provide for their control. Under
this EO Federal agencies can not authorize, fund, or carry out actions
that are likely to cause or promote the introduction or spread of
invasive species in the U.S.

EO 13158 – Marine Protected Areas: This EO was created to help protect
the significant natural and cultural resources within the marine
environment. It requires Federal agencies whose actions affect the
resources protected by MPA’s to avoid harm to these resources.

The regulatory environment is an important consideration in reviewing
the potential adverse impacts of activities proposed for GPD funding. 
The applicability of these requirements changes based on site-specific
circumstances; project scope; Federal, State, and local government
programs; level of Federal involvement; proximity of the biological
resource(s) to a proposed project area; and land ownership. Developing
an accurate portrayal of the regulatory environment affecting each
proposed action is therefore essential in evaluating requirements for
biological resource protection.  Site-specific evaluation and a full
understanding of the Federal, State, and local requirements are
necessary.

Listed Species, Critical Habitat and Special-Status Species

Activities by humans, such as over-harvesting, spreading of invasive
exotic species, uncontrolled development resulting in the destruction of
habitat, and the release of contaminants into the air, water, and soil,
have resulted in significant reductions in the abundance and
distribution of native species with numerous species nearing extinction
or becoming extinct.  Regulatory programs, both Federal and State, have
been enacted in an attempt to prevent extinction of threatened and
endangered species.  Threatened and endangered species are broadly
distributed throughout the U.S. and its territories.  There are over
1,300 federally listed threatened and endangered species. Identifying
and discussing each, as well as their habitat requirements, is beyond
the scope of this PEA.

The ESA requires Federal agencies to conserve those plants and animal
species that have been listed as endangered and threatened species by
the FWS or NMFS and critical habitats designated by these agencies. It
defines an endangered species as any species in danger of extinction
throughout all or a significant area of its range and a threatened
species as any species likely to become endangered in the near future.
It also defines critical habitat as those geographical areas that
contain physical or biological features that are essential to the
conservation of the species. Under Section 7 of the ESA, Federal
agencies, in consultation with FWS or NMFS, must insure their actions
are not likely to jeopardize the continued existence of any endangered
or threatened species (i.e., a listed species) or result in the
destruction or adverse modification of critical habitat. 

FWS and NMFS are responsible for compiling the lists of threatened and
endangered species. If a Proposed Action is likely to adversely affect a
listed species or critical habitat, the Federal agency must prepare a
Biological Assessment (BA) and initiate a formal consultation with FWS
or NMFS. After reviewing the BA, FWS or NMFS prepares a Biological
Opinion stating whether the Proposed Action is likely to jeopardize the
continued existence of a listed species or cause the destruction or
adverse modification of critical habitat. If this is the case, the
Biological Opinion will provide the Federal agency with Reasonable
Prudent Alternatives that, if adopted, would avoid a jeopardy or adverse
modification determination. The purpose of the consultation process is
to ensure avoidance and minimization of potential adverse impacts on a
listed species or critical habitats. Formal consultation is not required
if the Federal agency determines that the action would have no effect on
endangered or threatened species or designated critical habitat. Formal
consultation is also not needed if the Federal agencies agree that the
Proposed Action is not likely to adversely affect listed species. In
addition, the ESA prohibits all persons subject to U.S. jurisdiction,
including Federal agencies, from, among other things, “taking”
endangered or threatened species. The “taking” prohibition includes
any harm or harassment and applies in the United States and on the high
seas.  

Many States have designated special status species and provide some
level of legal protection for these species.  The special status species
frequently overlap with those listed under the Federal ESA.  However,
species lists developed by the States frequently are more inclusive.  

Human Health and Safety

Hazardous substances are defined as any solid, liquid, contained gaseous
or semisolid waste, or any combination of wastes that pose a substantial
present or potential hazard to human health and the environment. 
Improper management and disposal of hazardous substances can lead to
contamination of groundwater and surface water, including drinking water
supplies, and soils.  The primary Federal laws for the management and
disposal of hazardous substances are the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980 (42 U.S.C. §
9601 et seq.), the Resource Conservation and Recovery Act (RCRA) of 1976
(42 U.S.C. § 6901 et seq.) and the Oil Pollution Act (OPA) of 1990 (33
U.S.C. § 2701 et seq.).

RCRA establishes national goals to protect human health and the
environment from the potential hazards of waste disposal, to conserve
energy and natural resources, to reduce the amount of waste generated,
and to ensure that wastes are managed in an environmentally sound
manner. RCRA outlines duties and responsibilities for hazardous waste
generators, transporters, storers, treaters, and disposers of hazardous
waste. RCRA requires the regulation of underground storage tanks (UST),
imposing structural integrity and management practice requirements. 

Waste management regulations by EPA are codified at 40 CFR Parts
239–282; regulations for management of hazardous waste begin at 40 CFR
Part 260. Nearly all developed areas in the continental U.S. have solid
waste management services or programs, with municipal solid waste
generally regulated and managed at the State and community level. States
have enacted laws and promulgated regulations that are at least as
stringent as the Federal regulations. In addition, States have the
authority to carry out many of the functions of RCRA through their own
hazardous waste programs (and State laws), if such programs have been
approved (authorized) by EPA.

Evaluations of hazardous substances and wastes must consider whether any
hazardous material will be generated by the proposed activity and
whether a hazardous material already exists at the site or in the
general vicinity of the site.  Existing hazardous materials and waste
concerns could impact future use of a site.  

The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986
(42 U.S.C. § 11001 et seq.) establishes requirements for Federal,
State, and local governments, Indian Tribes, and industry regarding
emergency planning and “community right-to-know” reporting on
hazardous and toxic chemicals.  States and communities, working with
facilities, can use the information to improve chemical safety and
protect public health and the environment.  Under EPCRA, local
governments are required to prepare chemical emergency response plans,
and to review plans at least annually.  State governments are required
to oversee and coordinate local planning efforts.  Facilities that
maintain Extremely Hazardous Substances (EHSs) on site in quantities
greater than corresponding Threshold Planning Quantities must cooperate
in emergency plan preparation.  

Additionally, facilities must immediately report accidental releases of
EHS chemicals and “hazardous substances” in quantities greater than
corresponding Reportable Quantities defined in CERCLA to State and local
officials.  This information must be made available to the public. 
Facilities manufacturing, processing, or storing designated hazardous
chemicals must make Material Safety Data Sheets (MSDSs) describing the
properties and health effects of these chemicals available to State and
local officials and local fire departments.  Facilities must also
report, to State and local officials and local fire departments,
inventories of all onsite chemicals for which MSDSs exist.  This
information must be made available to the public. 

Facilities must complete and submit a Toxic Chemical Release Inventory
Form annually for each of the more than 600 Toxic Release Inventory
chemicals that are manufactured or otherwise used above the applicable
threshold quantities.

The Small Business Liability Relief and Revitalization Act (the
Brownfield Amendments) clarified CERCLA liability provisions for
potential property owners. If the potential property owners meet the
specific provisions of the act, including an adequate inquiry on past
uses of the property, the landowner will be able to assert the innocent
landowner defense, contiguous property exemption, and bona fide
prospective purchaser exemption to CERCLA liability. The USEPA has
published the final “all appropriate inquiries” rule (40 C.F.R.
312.10) that establishes the criteria for conducting Environmental Site
Assessments on properties considered for acquisition.  

Section 550 of the Department of Homeland Security (DHS) Appropriations
Act of 2006 established an interim program requiring chemical facilities
to conduct vulnerability assessments and develop facility security plans
and required DHS to issue regulations for this program. In 2007 DHS
issued the Chemical Facility Anti-Terrorism Standard (CFATS) interim
final rule at 6 CFR Part 27. The purpose of this rule is to determine
where chemicals of interest (COI) exist and whether additional security
measures are required for facilities that store and manage these
chemicals. In this rule, DHS sets forth the list of COI and their
screening threshold quantities (STQs), which would trigger requirements
under CFATS. Any facility or institution that possesses COI in excess of
their listed thresholds was required to submit a detailed survey to DHS,
which in turn classified the facilities into one of four risk-based
tiers, ranging from the highest risk facilities in Tier 1 to lowest
facilities in Tier 4. DHS classified 7,002 facilities into these tiers
based on the information submitted in the surveys. These facilities were
required to submit Security Vulnerability Assessments and Site Security
Plans. DHS also issued Draft Risk-Based Performance Standards Guidance
associated with the CFATS regulations.  73 Fed. Reg. 63,719 (Oct. 27,
2008). These include standards for areas such as perimeter security,
access control, personnel surety, and cyber security. 

Minority and Low Income Populations

Executive Order 12898 – Federal Actions to Address Environmental
Justice in Minority and Low-Income Populations requires Federal agencies
to identify and correct its programs, policies, and activities that have
disproportionately high and adverse human health or environmental
effects on minority or low-income populations.  The EO also tasks
Federal agencies with ensuring that public notifications regarding
environmental issues are concise, understandable, and readily
accessible. The general purposes of EO 12898 are as follows:

To focus the attention of Federal agencies on human health and
environmental conditions in minority communities and low-income
communities with the goal of achieving environmental justice;

To foster nondiscrimination in Federal programs that substantially
affect human health or the environment;

To give minority communities and low-income communities greater
opportunities for public participation in, and access to, public
information on matters relating to human health and the environment.

Potential environmental justice impacts are evaluated by analyzing the
socioeconomic makeup of the community where a project is proposed to be
located. Some general category descriptions help define and weigh
Federal action impacts on socioeconomic resources and environmental
justice include economic characteristics such as low-income areas,
housing characteristics such as medium- to high-density residential
areas and rural areas, and demographic characteristics such as areas
with a high percentage of minorities. 

Low-income or poverty areas are defined using the statistical poverty
threshold from the U.S. Census Bureau (USCB), which is based on income
and family size. The USCB defines a poverty area as a census tract in
which 20 percent or more of its residents are below the poverty
threshold and an extreme poverty area as one in which 40 percent or more
are below the poverty level. The 2007 poverty threshold for a family of
four with two children under the age of 18 was $21,027 (USCB 2008). 

Minority populations include persons who identify themselves as Asian or
Pacific Islander, Native American or Alaskan Native, black (not of
Hispanic origin), or Hispanic. (CEQ 1997). A minority population exists
where the percentage of minorities in an affected area either exceeds 50
percent or is meaningfully greater than in the general population. In
addition, a minority population also exists if there is more than one
minority group present and the minority percentage, when calculated by
aggregating all minority persons, meets one of the above thresholds. 

If a proposed project will cause disproportionate high and adverse
impacts on low-income or minority populations, mitigation measures will
be required.

Historic Properties 

Historic properties are prehistoric or historic districts, sites,
buildings, structures, or objects listed in or eligible for listing in
the National Register of Historic Places (NRHP), maintained by the
Department of the Interior, National Park Service (NPS). More than
80,000 properties are listed in the NRHP. Almost every county in the
U.S. has at least one place listed in the NRHP.

Properties may be eligible for listing in the NRHP if they possess
significance at the national, tribal, state or territory, or local level
in American history, architecture, archeology, engineering, or culture.
In order for a property to be considered historic, it must meet basic
criteria and retain the historic integrity of those features necessary
to convey their significance.  To convey integrity, historic properties
will always possess several, and usually most, of the following seven
aspects of integrity: location, design, setting, materials, workmanship,
feeling, and association. The passage of time may require re-evaluation
of historic properties to reaffirm the original National Register
status. 

There are multiple Federal regulations that require consideration of
effects to historic properties, including Section 106 of the National
Historic Preservation Act (NHPA) of 1966 (16 U.S.C § 470 et seq.), the
Native American Graves Protection and Repatriation Act (NAGPRA) of 1990
(25 U.S.C. § 3001 et seq.), the American Indian Religious Freedom Act
(AIRFA) of 1978 (42 U.S.C. § 1992 et seq.), and the Archaeological
Resources Protection Act (ARPA) of 1979 (16 U.S.C. § 470aa et seq.). 

Section 106 of NHPA directs the Federal Government to consider the
effects of its undertakings on historic properties through a four-step
decision-making and compliance process. It is noteworthy that the law
does not mandate preservation of historic properties; rather, it
mandates that Federal agencies follow the decision-making process. The
four steps of the Section 106 compliance process are as follows:

Initiate the Section 106 Process. FEMA determines whether an undertaking
exists, engages the appropriate State Historic Preservation Office
(SHPO) or Tribal Historic Preservation Office (THPO), and identifies
potential consulting parties.

Identify historic properties. FEMA, in consultation with the SHPO/THPO,
determines the Area of Potential Effects (APE) for the undertaking and
reviews existing information on historic properties within the APE. The
APE is the geographic area or areas within which an undertaking may
directly or indirectly cause changes in the character or use of historic
properties, if any such properties exist.  The APE is determined by the
scope of the project, the characteristics of the project area (e.g.
topography, building density, land use), and the type of historic
property being considered, and may be different for different kinds of
effects caused by the undertaking. Also, the APE for historic properties
may be different from the area studied for other resource types under
NEPA. Once the APE is established, FEMA gathers information from the
SHPO/THPO, Indian tribes and Native Hawaiian organizations, consulting
parties, and other individuals or organizations likely to have knowledge
of historic properties in the area, and identifies issues relating to
the undertaking’s potential effects on historic properties. This step
also involves FEMA making a determination of whether a property is
eligible for listing on the NRHP. 

Assess adverse effects of undertaking on historic properties. If
FEMA’s assessment determines no historic properties or no adverse
effect to eligible historic properties, the SHPO/THPO and other
consulting parties are informed, and the compliance process ends at this
step. If the assessment determines actual or potential adverse effects
to eligible historic properties, the SHPO/THPO and other consulting
parties are notified through a letter and supporting documentation.
Federal agencies must consider possible direct, indirect, and cumulative
effects on historic properties.  Direct effects include physical
impacts, while indirect effects may include visual, atmospheric, and
audible impacts on historic properties.  

Resolve adverse effects to historic properties. As stipulated in 36 CFR
§ 800.6, the Federal agency must resolve adverse effects by seeking
ways to avoid, minimize, or mitigate the undertaking’s adverse effect
through consultation with the SHPO/THPO and Advisory Council on Historic
Preservation (ACHP). If avoiding or minimizing the adverse effect
through re-design or other alternative means is not possible, the
Federal agency, the SHPO/THPO, the ACHP, and other appropriate
consulting parties may enter into a Memorandum of Agreement that
outlines appropriate measures to mitigate adverse effects to historic
properties.  In cases where the Federal agency and the other consulting
parties fail to agree on appropriate mitigation measures, the Federal
agency or the other consulting parties may terminate consultation, in
which case the ACHP issues a final comment.  The Federal agency must
take these comments into consideration before notifying ACHP of its
final decision, after which the project may proceed.

Because of the broad scope and location of the proposed projects in this
PEA, the presence of historic properties within the APE of some of the
proposed projects is highly likely.  Once an APE is established for a
particular undertaking, background research with the SHPO/THPO, Indian
tribes, local libraries, government offices, historical societies, and
others as necessary, can provide information on previously-identified
historic properties. Research may also provide an understanding of the
historic context for a project area, which will further assist in
identifying resources and evaluating whether they may meet one or more
of the NRHP criteria.  Fieldwork could also be required to identify
historic properties. 

A higher standard is applicable to Federal agencies when their actions
may affect historic properties that are designated as National Historic
Landmarks (NHLs). Federal agencies must, to the maximum extent possible,
minimize harm to NHLs directly and adversely affected by their
undertakings prior to their approval. 16 U.S.C. § 470h-2(f). In
addition Federal agencies must notify and formally invite the Secretary
of Interior to the consultation process, and invite the ACHP to
participate in the consultation process to resolve adverse effects.
There are fewer than 2,500 NHLs but they include Critical Infrastructure
and Key Resources that may be the subject of GPD projects.

FEMA has entered into State-specific Programmatic Agreements (PAs) with
various State Historic Preservation Offices around the country. These
State-specific PAs provide streamlined procedures for FEMA undertakings
related to its disaster response and recovery missions. They also
include programmatic allowances that exclude certain FEMA undertakings
from the Section 106 consultation process. With the exception of
activities under the Assistance to Firefighters Grant Program (AFGP),
the GPD undertakings covered under this PEA are not covered by these
State-specific PAs. FEMA will be identifying opportunities to include
GPD-funded activities into these State-specific PAs as they are
developed or revised. 

In this PEA, FEMA divides historic properties into two broad categories:
archaeology and other historic properties. FEMA will always conduct the
Section 106 process described above to properly identify all historic
properties and address adverse effects of its undertakings to historic
properties. It is FEMA’s practice to complete this process before
completing the NEPA determination to ensure that impacts to historic
properties have been taken into account in the NEPA process.  

Infrastructure

Infrastructure consists of the systems and physical structures that
enable a population in a specified area to function. Infrastructure by
definition includes a broad array of facilities (e.g., utility systems,
streets, highways, railroads, airports, ports, bridges, buildings and
structures, and other man-made facilities). Individuals, businesses,
governmental entities, and virtually all relationships between these
groups depend upon this infrastructure for their most basic needs, as
well as for critical and advanced needs (e.g., emergency response and
health care). Section 5195c(e) of Title 42 of the U.S. Code defines
critical infrastructure (CI) as the assets, systems, and networks,
whether physical or virtual, so vital to the US that their
incapacitation or destruction would have a debilitating effect on
security, national economic security, public health or safety, or a
combination of these. Section 101(10) of Title 6 of the U.S. Code
defines key resources as publicly or privately controlled resources
essential to the minimal operations of the economy and government. 

Infrastructure is entirely man-made, with a high correlation between the
type and extent of infrastructure and the degree to which an area is
characterized as “developed.” An essential component of economic
growth to an area is the availability of infrastructure and its capacity
to support growth. Infrastructure components typically include utilities
(electricity and communications), solid waste, and the transportation
network.

Transportation

Potential sites addressed by this PEA can be located in any type of
area: urban, suburban, rural, or remote.  The transportation facilities
that serve these different types of locations can vary widely. Urban
areas are generally characterized by a complex and extensive system of
roads, including major interstate freeways and surface streets.  Urban
roads typically support high levels of traffic, which often result in
roadway segment and intersection congestion.  Rural environments can be
characterized by fewer roads and roads that are frequently graveled
instead of paved.  Generally, traffic levels on rural roads are
relatively low (i.e., little or no congestion).  Remote areas may have
no maintained roadways, but instead, only hiking or all-terrain vehicle
trails.  

Solid Waste

Solid waste, more commonly known as trash or garbage, consists of
everyday items such as product packaging, grass clippings, furniture,
clothing, bottles, food scraps, newspapers, appliances, paint, and
batteries.  Projects that have the potential to generate large amounts
of solid waste may impact a community’s ability to properly manage and
dispose of waste.  Projects proposed to take place in communities with
insufficient solid waste management capacity may need to create a plan
to address this issue.  

Communication Infrastructure

The use of the 700 MHz and 800 MHz frequency spectrum for communication
systems is regulated by the Federal Communications Commission (FCC).
Operators must obtain a FCC license to operate a communication tower
using these frequencies. The issuance of an FCC license is a Federal
action that triggers NEPA, Section 106 of NHPA, Section 7 of ESA and
other similar environmental laws. The FCC regulations at 47 CFR Part 17
prescribes procedures for antenna structure registration and requires
the Federal Aviation Administration (FAA) to conduct an aeronautical
study of the navigation air space to determine appropriate tower marking
and lighting requirements to achieve safe air space. Before the FCC
authorizes the construction of new antenna structures or alteration in
the height of existing antenna structures, an FAA determination of “no
hazard” is required if the structure will affect navigable air space
within a certain distance of an airport, heliport, or military base. FAA
notification is required for any new construction greater than 200 feet
AGL, and near an airport runway (taller than 100:1 for a horizontal
distance of 20,000 feet, 50:1 for a horizontal distance of 10,000 feet,
and 25:1 for a horizontal distance of 5,000 feet of a heliport). By
checking the heights of proposed antennae and their proximity to
airports, the FCC’s TOWAIR software system assists in determining if
FAA notification is required. The FAA can vary marking and lighting
recommendations when requested, provided that aviation safety is not
compromised. In all cases, safe aviation conditions around the tower are
the FCC’s primary concern, and safety concerns dictate the marking and
lighting requirements. Navigation air space, which starts at 200 feet
above the ground, decreases in elevation in close proximity to airports;
the minimum height for required marking or lighting would decrease in
these areas. 

The FCC has entered into two Nationwide Programmatic Agreements (PA)
that exclude some FCC undertaking associated with the licensing of these
structures from the Section 106 review process and streamlines the
Section 106 consultation process for those undertakings not excluded.
The PAs are titled Nationwide Programmatic Agreement for Review of
Effects on Historic Properties for Certain Undertakings Approved by the
Federal Communications Commission (September 2004), and Nationwide
Programmatic Agreement for the Co-location of Wireless Antennas (March
2001). On September 17, 209 the ACHP issued a Draft Program Comment to
the two FCC Nationwide PAs establishing that USDA’s Rural Utilities
Service and Department of Commerce’s National Telecommunications and
Information Administration (NTIA) would not need to comply with Section
106 for communication facilities construction or modification that have
undergone or would undergo Section 106 review, or that are exempt from
Section 106 review, by the FCC under the two Nationwide Programmatic
Agreements. The Federal Register notice (74 Fed. Reg. 47807, Sept. 17
2009) can be found in Appendix I of this PEA. FEMA provided comments to
the ACHP requesting FEMA to be included in the scope of the Program
Comment. See Appendix J. As a result, the ACHP included FEMA in the
Final Program Comment. See Appendix K. This Program Comment became
effective October 23, 2009 and will be available until September 30,
2015.  

The FCC has also developed a voluntary Tower Construction Notification
System (TCNS) that allows proponents of new towers to provide notice of
their proposal to participating Indian tribes and Native Hawaiian
Organizations (NHO). The TCNS facilitates the identification of, and
appropriate initial contact with, Indian tribes and NHOs that may attach
religious and cultural significance to historic properties within the
geographic area of the proposed undertaking. Once notified, Indian
tribes and NHOs have the option of responding to applicants through the
TCNS. The FCC retains the responsibility to engage in
government-to-government consultation with the interested tribe or NHO. 

FEMA recognizes that there are other Federal, State, Tribal and
Territory public safety interoperability-related activities such as the
FCC’s public safety initiatives, the NTIA’s Public Safety
Interoperable Communications Grant Program (PSIC), and the RUS programs.
These programs are part of a Nationwide effort to improve
interoperability within the emergency preparedness and response
community. Grantees and subgrantees have the ability to leverage these
different programs within their jurisdictions to achieve their overall
public safety interoperability goals. Thus, there is a potential for
some GPD-funded actions under this project type to be connected with
other Federal and non-Federal funded actions. 

Air Quality

The EPA has established primary and secondary National Ambient Air
Quality Standards (NAAQS) under the provisions of the Clean Air Act
(CAA) of 1970 (42 U.S.C. § 7401 et seq.).  The CAA not only established
the NAAQS, but also set emission limits for certain air pollutants from
specific sources, set new source performance standards based on best
demonstrated technologies, and established national emissions standards
for hazardous air pollutants. 

The EPA classifies the air quality within an air quality control region
(AQCR) according to whether the region meets or exceeds Federal primary
and secondary NAAQS.  Primary standards define levels of air quality
necessary to protect public health with an adequate margin of safety. 
Secondary standards define levels of air quality necessary to protect
public welfare (i.e., soils, vegetation, and wildlife) from any known or
anticipated adverse impacts of a pollutant.  Federal NAAQS are currently
established for the following seven pollutants (known as “criteria
pollutants”): carbon monoxide (CO), nitrogen dioxide (NO2), ozone
(O3), sulfur dioxide (SO2), lead (Pb), particulate matter equal to or
less than 10 micrometers in aerodynamic diameter (PM10), and particulate
matter equal to or less than 2.5 micrometers in aerodynamic diameter
(PM2.5).  Table 4-1 shows the NAAQS. 

Table 4-1:  National Ambient Air Quality Standards (NAAQS)

Pollutant	Primary Standards	Secondary Standards

	Level	Averaging Time	Level	Averaging Time

Carbon Monoxide (CO)	9 ppm

(10 milligrams/ m3 [mg/m3])	8 hours	None

	35 ppm 

(40 mg/m3)	1 hour

	Lead (Pb)	0.15 µg/m3	Rolling 3-month average	Same as primary

	1.5 µg/m3	Quarterly average	Same as primary

Nitrogen Dioxide (NO2)	0.053 ppm 

(100 µg/m3)	Annual 

(arithmetic mean)	Same as primary

Particulate Matter (PM10)	150 µg/m3	24 hours	Same as primary

Particulate Matter (PM2.5)	15.0 µg/m3	Annual 

(arithmetic mean)	Same as primary

	35 µg/m3	24 hours	Same as primary

Ozone (O3)	0.075 ppm (2008 std)	8 hours	Same as primary

	0.08 ppm (1997 std)	8 hours 	Same as primary

	0.12 ppm	1 hour (applies only in limited areas)	Same as primary

Sulfur Dioxide (SO2)	0.03 ppm	Annual 

(arithmetic mean)	0.5 ppm 

(1300 µg/m3)	3-hours

	0.14 ppm	24-hours



Source: EPA 2008a

Air quality is affected by both stationary sources (e.g., urban and
industrial developments) and mobile sources (e.g., automobiles and
trains).  In general, urban environments are characterized by elevated
levels of criteria pollutants, which can potentially reach unhealthy
levels.  Rural environments, in contrast, are typically characterized by
good air quality for most criteria pollutants due to the lack of
pollution- emitting sources.  However, due to the migratory nature of
air pollutants, emissions from urban areas can have a negative impact on
the air quality of a rural area.  Land use practices in rural areas can
affect air quality when wind erosion raises dust from tilled fields, and
when agricultural burning and fires caused by vegetation management
practices adversely affect air quality with smoke and wind blown ashes.

An AQCR or portion of an AQCR may be classified as attainment,
non-attainment, or unclassified for each of the seven criteria
pollutants.  Attainment describes a condition in which one or more of
the seven NAAQS are being met in an area.  The area is considered to be
attainment only for those criteria pollutants for which the NAAQS are
being met.  Non-attainment describes a condition in which one or more of
the seven NAAQS are not being met in an area.  Unclassified indicates
that air quality in the area has not been classified and is therefore
treated as attainment.  Areas that have been recently re-designated from
non-attainment to attainment are called maintenance areas (in reference
to how the area will maintain attainment).  An area may have all four
classifications for different criteria pollutants.  Air emission
regulations are more stringent in non-attainment areas and vary not only
from AQCR to AQCR, but also within an AQCR. States with air quality that
does not achieve the NAAQS are required to develop and maintain State
Implementation Plans (SIPs). In addition, the USEPA may develop a
Federal Implementation Plan (FIP) and Tribes may develop their own
Tribal Implementation Plans (TIP). These plans constitute a federally
enforceable definition of the applicable approach (or plan) and schedule
for the attainment of the NAAQS.

The General Conformity Rule (GCR), established under Section 176(c)(4)
of the CAA (42 U.S.C. § 7506(c)) requires Federal agencies to work with
State, Territory, Tribal, and local governments in a nonattainment or
maintenance area to ensure that Federal actions conform to the
initiatives established in the applicable SIP, FIP, or TIP.  Before a
Federal action is taken, it must be evaluated for conformity with the
applicable implementation plan.  

Noise

Noise is defined as unwanted sound that interferes with normal human
activities or wildlife behavior, or may otherwise diminish environmental
quality. Sound is most commonly measured in decibels (dB) on the
A-weighted scale, which is the scale most similar to the range of sounds
that the human ear can hear. The Day-Night Average sound Level (DNL) is
an average measure of sound. The DNL descriptor is accepted by federal
agencies as a standard for estimating sound impacts and establishing
guidelines for compatible land uses. In a typical day, most people are
exposed to sound levels of 50 to 55 dB or higher. 

Topographic features and structural barriers that absorb, reflect, or
scatter sound waves can decrease or increase noise levels. (HUD 2009).
In addition, atmospheric conditions, such as wind speed and direction,
and weather, can also affect the perception of the sound. (HUD 2009).
Animals use sounds for communication and navigation, to avoid danger,
and to find food. The same noise factors that affect humans may also
influence wildlife. In general, wildlife has a wider hearing range than
humans, both on the low and high frequency ends of the noise spectrum.
Noise studies, principally those on aircraft noise, have found varying
results, ranging from no identifiable effects in some species, to
noticeable behavioral and physiological effects in other species (e.g.,
birds) (EPA 1980).

For this PEA FEMA will adopt the U.S. Department of Transportation’s
Federal Highway Administration standards for noise abatement found in 23
CFR Part 772 – Table 1. These establish, for example, the need to
consider noise abatement measures for actions that produce sound levels
that 10 percent of the time exceed 70 dB in areas with sensitive
receptors (e.g. as playgrounds, parks, schools, libraries, residences,
and hospitals) and exceed 75 dB in developed lands. 

Visual Quality

Natural and man-made features give a particular setting or area its
aesthetic qualities.  These features define the landscape character of
an area and form the overall impression that an observer receives of
that area.  Evaluating the aesthetic qualities of an area is a
subjective process because the value an observer places on specific
landscape features varies depending upon the values and attitudes of the
observer.  Regardless of the subjective nature of assessing visual
aesthetics, landforms, water surfaces, vegetation, and man-made features
can generally be considered characteristic of an area if they are
inherent to the composition and function of the landscape.  

The aesthetic characteristics of a project area depend on whether the
area is a remote, rural, or urban setting.  In a remote or rural
setting, the visual aesthetics tend to be dominated by
naturally-occurring landforms and vegetation.  Examples include natural
landscapes, mountains, undulating land, valleys, cliffs, lakes, streams,
beaches, and natural vegetation.  Although naturally-occurring visual
resources dominate rural areas, some signs of human activity are likely
to be present and may also contribute to the visual aesthetics. 
Examples include farm houses, agricultural fields, fences, barns, silos,
scenic highways, and lighthouses.  Vegetation in rural areas is
primarily crops grown in tilled fields, grassland, and lawns around
farmhouses.  Remote areas may have no visible man-made structures.  

The natural features present in rural/remote settings may also be
present in an urban environment.  However, unlike the remote or rural
settings, man-made features are normally the dominant visual element in
an urban setting.  Examples of these features include houses, office
buildings, warehouses, rail yards, utility plants, historic buildings,
landmarks, parking areas, storage yards, billboards, and signage. 
Vegetation in an urban setting is primarily lawns, shrubs, and
ornamental trees.  

Air pollution can substantially reduce visibility in wilderness areas
and parks. The EPA issued the Regional Haze Rule, 40 CFR 51.300 et.
seq., to address the decrease in visibility in 156 of the Nation’s
National Parks and Wilderness areas (Class I Areas). The Regional Haze
Rule encourages States and Federal land management agencies to work
together to address regional haze in these areas. As a result of the
rule States with Class I Areas have adopted or may adopt plans and
regulations that restrict activities that contribute to regional haze. 

Climate Change

Climate change refers to long-term fluctuations in global surface
temperatures, precipitation, ice cover, sea levels, cloud cover, ocean
temperatures and currents, and other climatic conditions. Scientific
research has shown that in the past century, Earth’s surface
temperature has risen by an average of about 1.3 degrees Fahrenheit
(ºF) or 0.74 degrees Centigrade (ºC). (IPCC 2007). Sea levels have
risen 6.7 inches (0.17 meter) in the past century and Arctic sea ice has
shrunk by 2.7 percent per decade, with larger decreases of 7.4 percent
in summer. (IPCC 2007). Impacts of climate change include increase in
average surface temperatures, decrease in seasonal frozen ground,
extreme temperatures, extreme weather events such as heavy precipitation
events and intense and longer droughts, reduction in glaciers, ice caps
and snow cover, andincrease in cyclone activity. 

Most scientists agree that this climate change is largely a result of
green house gases (GHG) emissions from human activities. (IPCC 2007).
These GHG trap heat in the Earth’s troposphere and reradiate it back
to Earth causing warming. The Intergovernmental Panel on Climate Change
(IPCC) – the scientific body tasked by the United Nations to evaluate
the risk of human-induced climate change – has asserted that, “Most
of the observed increase in global average temperatures since the
mid-20th Century is very likely due to the observed increase in
anthropogenic greenhouse gas concentrations.” (IPCC 2007).

Most GHGs, including carbon dioxide (CO2), methane (CH4), nitrous oxide
(N2O), water vapor, and ozone occur by natural processes. However, human
activities such as the combustion of fossil fuels, production of
agricultural commodities and the harvesting of trees can contribute to
increased concentrations of these gases in the atmosphere. Atmospheric
concentrations of CO2, CH4 and N2O have increased approximately 35, 150,
and 18 percent, respectively, since the beginning of the Industrial
Revolution in the mid-1700 (IPCC 2007). The IPCC predicts that CO2
concentrations could rise to more than three times the pre-industrial
level by 2100 (Meehl et al. 2007). The IPCC also predicts a increase of
average global surface temperature of 2.0 to 11.5 ºF (1.1 to 6.4 ºC)
over the next century, accompanied by a sea level rise of approximately
0.6 to 1.9 ft. (0.18 to 0.59 m). (IPCC 2007).

Contributions to the increase of GHG in the atmosphere vary greatly from
country to country, and depend heavily on the level of industrial and
economic activity. The United States accounts for 19.6 percent of global
CO2 emissions. (WRI 2008). GHG emissions for the U.S. in 2006 were
estimated at 7,054 million metric tons of carbon dioxide (MMTCO2)
equivalent (EPA 2008b). CO2 is the primary GHG emitted in the U.S.,
represented close to 85 percent of all U.S. MMTCO2 equivalent emissions
in 2006. (EPA 2008b). 

On April 24, 2009 the USEPA issued a proposed endangerment finding and
proposed rule establishing that GHG endanger public health and welfare
of current and future generations. 78 Fed. Reg. 18886 (April 24, 2009).
This proposed finding was issued with respect to six GHG: carbon
dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons,
and sulfur hexafluoride. The USEPA Administrator also proposed to find
that the combined emissions of carbon dioxide, methane, nitrous oxide
and hydrofluorocarbons from new vehicles and new motor vehicles are
contributing to air pollution which is endangering public health and
welfare under Section 202(a) of the CAA. The adoption of this
endangerment finding will provide the USEPA with authority to regulate
the emission of these pollutants. 

 Environmental Consequences

This Section provides a programmatic analysis of the impacts of the No
Action Alternative and the Proposed Action. It describes the likely
effects of implementing the programs and project types eligible under
the various GPD grants and, to the extent possible, identifies
programmatic mitigation and best management practices (BMPs) that will
be used to reduce or avoid the impacts of particular activities. In
addition, this section identifies project activities that require
site-specific evaluation and may trigger the need for the preparation of
a Record of Environmental Consideration (REC) or a Supplemental
Environmental Assessment (SEA) to determine if the particular activities
would have significant impacts on the quality of the human environment
given their unique environmental context. 

Some of the proposed projects indentified in this PEA could be eligible
for one or more FEMA CATEX. GPD programs and grant-funded projects were
not the basis for FEMA’s list of CATEXs and extraordinary
circumstances at the time of their development in 1980 or the various
revisions in 1981, 1982, 1987, 1994, 1996 and 2001. For this reason the
PEA includes a discussion of the applicability of existing FEMA CATEX to
GPD actions. Appendix B provides a cross-walk of FEMA’s CATEX and how
they apply to GPD-funded activities.

For GPD project types to which FEMA CATEXs apply and do not have the
potential to trigger extraordinary circumstances, this PEA will serve as
the only NEPA documentation required. For those GPD project types to
which a FEMA CATEX applies, but which may trigger the need to evaluate
the presence or resolution of extraordinary circumstances based on the
unique environmental conditions present, FEMA will document the
applicability of the CATEX and extraordinary circumstances through a REC
on a case-by-case basis. If there are extraordinary circumstances
present that cannot be resolved, then FEMA will prepare a site-specific
SEA and determine whether a FONSI can be issued. See Figure 1-1. 

It is FEMA’s practice to review an action or project for its
compliance with other environmental planning and historic preservation
requirements such as ESA Section 7, NHPA Section 106, 44 CFR Part 9, and
others before making the final NEPA determination. This ensures that the
Agency integrates NEPA with other planning requirements and utilizes the
established review and consultation processes to inform the
determination of whether a CATEX applies, whether extraordinary
circumstances have been resolved, whether a PEA is applicable, whether a
finding of no significant impact (FONSI) could be reached, or the
appropriate timing for the issuance of a record of decision for an EIS.

The criteria for determining the level significance of environmental
impacts that is used in this PEA and for GPD actions in general is
established in Table 5-1 for easy reference.  

  Table 5-1. Criteria for determining significance in this PEA

Area of Evaluation	No Significant Effect	Significant Effect

Land Use	Impacts to land use would not be measurable or would be
measurable or perceptible, but would be limited to a relatively small
change in land use that is still consistent with surrounding or planned
land uses.  The proposed action and alternatives would be consistent
with respective State Coastal Zone Management plans, CBRA and FPPA.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance. 	The proposed action will significantly change
the surrounding land uses in the short- and long-term.  

or

The proposed action and alternatives would not be consistent with the
surrounding land use and the local land use agency requires a special
land use permit or waiver.

or

The proposed action and alternatives would not be consistent State
Coastal Zone Management plans or CBRA

or

The proposed action and alternatives would cause significant impacts to
prime and unique farmland.

Geology, Soils, and Seismicity	Impacts to geology, soils, and seismicity
as a result of the proposed action or alternatives would not be
detectable or detectable and steps are taken in order to minimize
adverse impacts.  Projects proposed in areas characterized by
susceptibility to seismic, volcanic, tsunamis, landslide or mudslide
activity, structural instability, excessive erodibility, or steep slopes
are mitigated.  

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Impacts on geology, soils, and seismicity as a
result of the proposed action or alternatives would be readily apparent
and result in a change to the character of the resource over a
relatively wide area.  

Or 

Projects proposed in areas characterized by susceptibility to seismic,
volcanic, tsunamis, landslide or mudslide activity, structural
instability, excessive erodibility, or steep slopes are not mitigated.  

Water Resources	Impacts (chemical, physical, or biological effects)
resulting from the proposed action or alternatives would be either not
detectable, or detectable, but at or below water quality standards or
criteria.  Alterations in water quality and hydrologic conditions
relative to historical baseline may occur, however, only on a localized
and short-term basis.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Impacts (chemical, physical, or biological
effects) resulting from the proposed action or alternatives would be
detectable and would be frequently altered from the historical baseline
or desired water quality conditions; and/or chemical, physical, or
biological water quality standards or criteria would be locally,
slightly and singularly, exceeded on either a short-term or prolonged
basis.

Floodplains	Activities are not in the floodplain.

Or

Adverse effects to or from the 100-year floodplain for non-critical
actions or adverse effects to or from the 500-year floodplain for
critical actions are present.  Adverse effects are minimized in
accordance with FEMA’s minimization standards in 44 CFR 9.11.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Adverse effects to or from the 100-year
floodplain for non-critical actions or adverse effects to or from the
500-year floodplain for critical actions are present.  Adverse effects
are not minimized in accordance with FEMA’s minimization standards in
44 CFR 9.11.

Wetlands	Actions are not taken in wetlands.

or

Adverse effects from the project to wetlands will occur but effects are
minimized in accordance with FEMA’s minimization standards in 44 CFR
9.11.  Water quality and hydrologic changes resulting from such
development would either be not detectable, or detectable, but at or
below water quality standards or criteria.  Alterations in water quality
and hydrologic conditions relative to historical baseline may occur as a
result of wetland loss.  For jurisdictional wetlands subgrantee will
notify the USACE and obtain any required permits prior to the initiation
of work.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Adverse effects from the project to wetlands will
occur.  Adverse effects are not minimized in accordance with FEMA’s
minimization standards in 44 CFR 9.11.  Impacts to water quality and
hydrology would be detectable and would be frequently altered from the
historical baseline or desired water quality conditions.  The USACE
determines that an EIS is required before an Individual Permit may be
issued for jurisdictional wetlands.

Biological Resources – Vegetation, Wildlife	Impacts to native species,
their habitats, or the natural processes sustaining them from the
proposed action or alternatives would be detectable, but would not be
expected to be outside the natural range of variability.  Occasional
responses to disturbance by some individuals could be expected, but
without interference to feeding, reproduction, or other factors
affecting population levels.  Sufficient habitat would remain functional
to maintain viability of all species.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Impacts from the proposed action or alternatives
on native species, their habitats, or the natural processes sustaining
them would be detectable, and would be expected to be outside the
natural range of variability for long periods of time or be permanent. 
Population numbers, population structure, genetic variability, and other
demographic factors for species might have large, short-term declines,
with long-term population numbers significantly depressed.  Frequent
responses to disturbance by some individuals would be expected, with
negative impacts to feeding, reproduction, or other factors resulting in
a long-term decrease in population levels.  Loss of habitat might affect
the viability of at least some native species.

Biological Resources – Listed Species, Critical Habitat, and Special
Status Species	Effects on listed species or designated critical habitat
are insignificant, discountable (i.e., extremely unlikely to occur and
not able to be meaningfully measured, detected, or evaluated) or
beneficial.  During consultation, FWS or NMFS provides written
concurrence of “not likely to adversely affect.”

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	A determination is issued that the action will
jeopardize the continued existence of a species or adversely modify
critical habitat and the agency will proceed with the action. 

Or

There will be take of a migratory bird without the appropriate permit by
FWS.

Human Health and Safety	Hazardous or toxic materials and/or wastes could
be safely and adequately managed in accordance with all applicable
regulations and policies, with limited exposures or risks.  There would
be no short- or long-term adverse impacts to public safety and homeland
security preparedness.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	A net increase in the amount of hazardous or
toxic materials and/or wastes to be handled, stored, used, or disposed
of, resulting in unacceptable risk, exceedence of available waste
disposal capacity, or probable regulatory violation(s).  Site
contamination conditions could preclude development of sites for the
proposed use.  Public safety and homeland security preparedness would be
compromised and vulnerabilities would increase.

Low-income and minority populations	There would be no disproportionately
high and adverse environmental or health effects to low-income and/or
minority populations, or any disproportionate effects would be
mitigated.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	There would be unmitigated disproportionately
high and adverse environmental and health impacts to low-income
populations, minority populations.  

Historic Properties 	No historic properties are affected.

or

The historic characteristics or setting of an NRHP eligible or listed
property are altered, or have the potential to be altered, but the
resource retains its integrity. 

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	The integrity of an NRHP eligible or listed
property would be diminished or destroyed and effects would not be
mitigated below the level of significance.  



Infrastructure 

*Significant impacts to utilities are not necessary and sufficient
criteria to prepare an EIS	No impacts to infrastructure.

Or

An impact to the human and/or natural environment would occur, but is
less than thresholds indicated below for “significant effect.”

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.

	Communications:  Effects would be considered potentially significant if
the proposed action or alternatives would require communication systems
to meet requirements that could not be provided without major
modifications to the existing systems.  

or

Solid Waste:  Effects would be considered potentially significant if the
proposed action or alternatives would require collection and/or disposal
that could not be provided in a reliable manner, which could cause waste
to accumulate or be disposed of in a manner that could adversely affect
human health or the environment.

or

Transportation - Additional demand placed on the existing transportation
network by the proposed action or alternatives would exceed the capacity
of the network, creating disruptions in service in roadways, rail, or
air transportation.



Air Quality	Emissions from the proposed action or alternatives for NAAQS
in nonattainment and maintenance areas would be less than excedence
levels as defined in Table 3.3.  Emissions in attainment areas would not
cause air quality to go out of attainment for any NAAQS.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.

	Emissions from the proposed action or alternatives for NAAQS would be
greater than the exceedance levels for nonattainment and maintenance
areas.  Emissions in attainment areas would cause an area to be out of
attainment for any NAAQS.

Noise	Noise levels resulting from the proposed action or alternatives
would exceed natural sounds, as described under no effect, but would not
exceed typical noise levels from construction equipment or generators. 
Noise generated by construction and operation of the facility would be
temporary or short-term in nature.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Noise levels would exceed typical noise levels
from construction equipment and generators on a permanent basis or for a
prolonged period of time.



Visual Quality	No permanent direct or indirect impacts to the viewsheds
of resources such as natural landscapes, Class I Areas, historic
properties and/or the aesthetic character of the surrounding area from
the proposed action or alternatives would be expected.  Any temporary
visual disturbances that alter the character of the viewshed and/or
aesthetic character of the surrounding area would be returned to its
original state following the action.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Significant direct or indirect impacts to the
viewsheds of any resources such as natural landscapes, Class I Areas,
historic properties and/or the aesthetic character of the surrounding
area from the proposed action or alternatives are anticipated, and these
effects would be greater in number, extent, and/or duration than
non-significant impacts.  Significant impacts could include disturbances
(such as the long-term alteration of the viewshed that would require
mitigation) that could alter the character of the viewshed of a
historical resource, and the viewshed might not resume its original
state following the action.

Climate Change	Emissions of  CO2 of proposed action or group of actions
are below the level of detection.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Emissions of  CO2 of proposed action or group of
actions are significant  and no mitigation is provided. 







Alternative 1: No Action Alternative

Implementing the No Action Alternative would have no impacts on areas of
concern such as land use, geology, soils, seismicity, noise, and visual
quality. 

The No Action Alternative may result in adverse impacts to areas of
concern such as water resources, floodplains, wetlands, biological
resources, historic properties, minority and low-income populations,
infrastructure, air quality, and human health and safety. Under the no
action alternative, facilities, including CI/KR, would remain vulnerable
to man-made disasters and the local communities, States, Territories,
and the Nation would not be fully prepared for these incidents. For
example, the release of hazardous substances from facilities that use,
store, process or dispose of such substances could have significant
impacts on the natural and physical environment and to human health and
safety. Properties of historic significance could be the target of a
man-made incident or could be damaged or destroyed as a result of the
incident.  CI/KR such as major transit facilities, transportation
corridors, ports, and emergency operations centers would remain
vulnerable. 

In addition to vulnerable facilities and infrastructure, the No Action
Alternative would result in a less prepared community of first
responders, local, State, Territory, and Tribal governments. An
unprepared response to a natural or man-made disaster could have
significant consequences to the natural and physical environment and/or
on human health and safety. Not only can environmental resources such as
soils, air and water be the medium or target of the incident, but the
response to such an incident itself could have irreversible adverse
consequences to areas such as water resources, floodplains, wetlands,
biological resources, historic properties, air quality, and human health
and safety. 

Alternative 2: Program Implementation

Under Alternative 2, FEMA would implement the GPD programs, including
the eligible activities and project types under each program.  

Programs

As provided in Section 3.2.1, the GPD grant programs are dynamic and may
change each year based on Congressional authorization, mandates and
priorities. Grant program implementation activities such as general
grant administration, development of program guidance, and policy and
regulations are not expected to have significant impacts on the quality
of the human environment. The particular project types allowed under the
various GPD grant programs that may have impacts on the environment are
discussed in Section 5.2.2 below. For any given year, programs that are
limited to planning, training, management and administration, exercises
within existing facilities, and mobile and portable equipment purchase
will not have significant impacts to the human environment. 

Each year, FEMA will evaluate the grant guidance for each GPD program to
determine if the eligible activities are covered under this PEA. For
activities not covered by this PEA, FEMA will develop Supplemental
Program EAs tiered from this analysis to take into account the impacts
of the activity type on the human environment. FEMA will ensure that the
grant guidance provides information on the particular environmental
planning and historic preservation requirements that must be met prior
to the initiation of the project.

In addition, FEMA and GPD will develop outreach and training tools such
as information bulletins, job aids, and classroom training to assist GPD
staff and grantees with environmental planning and historic preservation
compliance and to avoid, to the maximum extent possible, significant
impacts to the human environment from the implementation of these grant
programs. 

Project Types

The following project types may be allowable under various GPD grant
programs and may have the potential to affect the environment, including
historic properties: exercises outside of existing facilities,
communication towers, modification of existing structures and facilities
(including the installation of fixed equipment), and new
construction/replacement.   

The expected environmental impacts of many typical GPD-funded project
types are analyzed below.  Impacts are expected to vary substantially by
project type, and even within each project type according to certain
project parameters.

Planning

The activities associated with this project type are administrative in
nature, have no physical footprint, and use existing facilities,
established procedures, and land use designations. They do not involve
any changes in land use, ground disturbance, modification of facilities,
or release pollutants to environmental media (i.e. air, water, and
land). Therefore, this project type would have no effect on land use,
geology and soils, water resources, floodplains, wetlands, biological
resources, minority and low-income populations, historic properties, air
quality, noise, human health and safety, visual quality, or climate
change. This project type will have a beneficial effect on human health
and safety and infrastructure by improving local, State, Territory,
Tribal and National readiness.  

FEMA CATEX (iii) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA
documentation of activities under this project type will be needed.

Training

The activities associated with this project type are administrative in
nature, have no physical footprint, and use existing facilities,
established procedures, and land use designations. They do not involve
any changes in land use, ground disturbance, modification of structures
or facilities, or release of significant levels of pollutants to
environmental media (i.e. air, water, and land). Therefore, this project
type would have no effect on land use, geology and soils, water
resources, floodplains, wetlands, biological resources, minority and
low-income populations, historic properties, air quality, noise, visual
quality or climate change. This project type will have a beneficial
effect on human health and safety and infrastructure by improving local,
State, Territory, Tribal and National readiness.

FEMA CATEX (v) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA review or
documentation of activities under this project type will be needed. 

Management and Administration

The activities associated with this project type are administrative in
nature, have no physical footprint, and use existing facilities,
established procedures, and land use designations. They do not involve
any changes in land use, ground disturbance, modification of structures
or facilities, or release of significant levels of pollutants to
environmental media (i.e. air, water, and land). Therefore, this project
type would have no effect on land use, geology and soils, water
resources, floodplains, wetlands, biological resources, minority and
low-income populations, historic properties, air quality, noise, visual
quality or climate change. This project type will have a beneficial
effect on human health and safety and infrastructure by improving local,
State, Territory, Tribal and National readiness.

FEMA CATEX (i) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA review or
documentation of activities under this project type will be needed. 

Exercises

Exercises within existing facilities

Exercises that are conducted at existing facilities designed and
permitted to handle the specific type of exercise will not involve any
changes in land use, ground disturbance, modification of structures or
facilities, or release of significant levels of pollutants to
environmental media (i.e. air, water, and land). Therefore, this project
type would have no effects on land use, geology and soils, water
resources, floodplains, wetlands, biological resources, minority and
low-income populations, historic properties, air quality, noise, visual
quality, or climate change. This project type will have a beneficial
effect on human health and safety and infrastructure by improving local,
State, Territory, Tribal and National readiness.

FEMA CATEX (v) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA review or
documentation of activities under this project type will be needed.

Exercises outside existing facilities, with major logistic activity, or
that involve release of toxic, radioactive, or biological
material/agents

Other types of exercises such as those conducted outside existing
facilities, those with major logistic activity such as the creation of
base camps, construction of temporary facilities, development of staging
areas, significant redistribution of vehicles or people, or those
exercises that involve the release of toxic, radioactive, or biological
agents may have impacts on land use, geology and soils, water resources,
floodplains, wetlands, biological resources, minority and low-income
populations, historic properties, infrastructure, air quality, noise,
visual quality, and climate change. These impacts may vary depending on
the nature of the exercise, where it is located, and the resources
present that are likely to be affected.   

This project type will have beneficial impacts on human health and
safety by improving local, State, Territory, Tribal and National
readiness to terrorist attacks.  

FEMA CATEX (v) covers this project type and its applicability can be
extended to GPD activities. However, because of the potential
environmental impacts of this project type, FEMA will document the
applicability of the CATEX to the particular exercise thru an REC and
take into account any potential extraordinary circumstances and the
applicability of other environmental planning and historic preservation
requirements. If extraordinary circumstances exist and cannot be
adequately addressed, FEMA will require a site-specific SEA tiered from
this PEA to determine if the proposed project is likely to have
significant impacts on the quality of the human environment.

Mobile and Portable Equipment (No Installation)

The activities associated with this project type have no physical
footprint, and use existing facilities, established procedures, and land
use designations. They do not involve any changes in land use, ground
disturbance, modification of facilities, or release of significant
levels of pollutants to environmental media (i.e. air, water, and land).
Therefore, this project type would have no effects on land use, geology
and soils, floodplains, wetlands, minority and low-income populations,
historic properties, air quality, noise, visual quality, or climate
change. 

The AEL includes equipment that is used directly in water, such as
boats, sonar, and barriers.  Although this equipment is placed directly
in the water, it has no significant impact on water quality when used
properly and following industry Best Management Practices (BMPs) such as
regular maintenance and responsible handling, use, and storage of
materials that have the potential to affect water quality, such as fuels
and lubricants.  

FEMA CATEX (vi) covers this project type and its applicability can be
extended to GPD activities. Except for the purchase of mid-and
low-frequency active sonar equipment to be used in marine waters, no
further NEPA review or documentation of activities under this project
type will be needed because the project type is not likely to trigger
extraordinary circumstances.

Sonar

Under the MMPA, NMFS is responsible for the management and conservation
of cetaceans (whales, dolphins, and porpoises) and pinnipeds (seals and
sea lions).  NMFS is the primary government agency responsible for
enforcing the MMPA.  The MMPA established a moratorium on the taking
(harassment, injury, or killing) of marine mammals in U.S. waters and by
U.S. citizens on the high seas, and on the importing of marine mammals
and marine mammal products into the U.S. (NMFS, 2009a).  Along with
NMFS, FWS is also responsible for assessing the affects on marine
mammals under the MMPA.  Walruses, sirenians (manatees), sea otters, and
polar bears are under FWS jurisdiction (NMFS, 2009b).  Both NMFS and FWS
are responsible for reviewing and permitting sonar use activities that
may affect those marine mammals under their jurisdiction.

Marine mammals as a group have functional hearing ranges of 10 Hz to 200
kHz. (Navy 2008). Active sonars that operate within these frequency
ranges have the potential to harass marine mammals by affecting their
physiology (e.g. auditory system, organ tissue damage due to resonance)
and behavior (e.g. stress, orientation, breathing, social relationships,
flight response). They may also result in “masking” which is the
interference with the clear reception of signals that are of interest to
these marine mammals. Mid-frequency sonar (ranging from 1 to 10 kHz) and
low-frequency sonar (ranging from 1 Hz to 1 kHz) used in marine waters
has the potential to produce these effects on marine mammals. 
(Reynolds, 2008; Navy 2008).  Sonars that operate at frequencies higher
than 200 kHz do not have the potential to adversely affect marine
mammals because the source attenuates rapidly in the water and are
outside of the upper frequency limit of even the ultrasonic species of
marine mammals. (Navy 2008). High-frequency sonars operating between 10
kHz and 200 kHz may require coordination with NMFS or FWS. Site-specific
information on the geographic area where the equipment will be used,
predicted exposure levels (e.g., number, duration and sound pressure
level of received pings), and species density and distribution will be
needed to determine their potential for adverse effects on marine
mammals.  

FEMA will coordinate with NMFS and FWS on projects involving use of
active sonars that operate below the 200 kHz frequency. This
coordination may involve Section 7 consultation under the ESA. The
grantee or subgrantee is responsible for obtaining any permits that may
be required under the MMPA, ESA and CZMA and for complying with any
conditions that may be placed on the project as the result of
coordination with NFMS/FWS. 

This PEA will be the only NEPA documentation for passive sonars and
active sonars operating in frequencies higher than 200 kHz under this
project type. For all other sonars FEMA will document the applicability
of the CATEX (vi) thru an REC and take into account any potential
extraordinary circumstances as well as the results of the ESA Section 7
consultation process and applicability of other laws such as MMPA and
CZMA. If extraordinary circumstances exist and cannot be adequately
addressed, FEMA will require a site-specific SEA tiered from this PEA to
determine if the proposed project is likely to have significant impacts
on the quality of the human environment. 

Communication Towers 

As indicated in Section 4.10, FEMA recognizes that there are other
Federal, State, Tribal and Territory public safety
interoperability-related actions such as the FCC’s public safety
initiatives, NTIA’s PSIC Grant Program and USDA’s Rural Utility
Service’s programs. These programs are part of a Nationwide effort to
improve interoperability within the emergency preparedness and response
community. Grantees and subgrantees have the ability to leverage these
different programs within their jurisdictions to achieve their overall
public safety interoperability goals. Thus, there is a potential for
some GPD-funded actions under this project type to be connected with
other non-FEMA funded actions. FEMA will incorporate by reference into
this PEA the description of environmental conditions and environmental
consequences analysis of the NTIA PEA for the PSIC Grant Program and the
Generic Environmental Impact Statement New York State Statewide Wireless
Network to the extent that they are consistent with this document. FEMA
may issue separate SEAs or otherwise adopt other PEAs or Programmatic
EIS (PEIS) as they become final and available to ensure consistency of
NEPA reviews in the Nation’s public safety interoperability efforts.

Existing communication towers 

Modifications and/or upgrades of existing communication towers and
supporting facilities are covered by FEMA CATEX (ix). As explained
below, this project type may have the potential to impact the human
environment based on the site-specific conditions and resources present.
FEMA will always conduct site-specific evaluation and document the
applicability of the CATEX, including presence of extraordinary
circumstances and applicability of other environmental planning and
historic preservation requirements through a REC. For proposed projects
having extraordinary circumstances that cannot be resolved, a
site-specific SEA will be required to determine if the impacts are
likely to be significant. 

Land Use 

Modifications and/or upgrades of existing communication towers and
supporting facilities would not have significant impacts to land use
because they do not change existing land use patterns.  

Geology and Soils 

The co-location and upgrading of communication equipment on an existing
tower that is not located in areas characterized by susceptibility to
seismic, volcanic, tsunamis, landslide or mudslide activity, structural
instability, excessive erodibility, or steep slopes would not result
significant impacts from geology and soils to the project. The
construction of new equipment buildings or facilities that are not
located in areas characterized by these hazards will not result in
significant impacts from geology and soils to the project.

Some co-location and upgrading activities could occur in towers that are
in areas characterized by hazards characterized above. However, the
impacts from geology to these activities are not expected to be
significant.

Activities involving the expansion, placement, and construction of
supporting facilities in areas characterized by susceptibility to
seismic, volcanic, tsunamis, landslide or mudslide activity, structural
instability, excessive erodibility, or steep slopes may result in
impacts from geology to these actions. These activities may require the
use of certain engineering technologies or require consultation with
State or Federal agencies before the project may proceed. All structures
in areas of seismic risk that are covered by this PEA must be designed
and constructed in accordance with appropriate seismic design and
construction standards, which are promulgated through NEHRP.  Therefore,
the constructed buildings will represent a low seismic hazard to people
and equipment housed in the building during a seismic event.  

In addition, the expansion, placement, and construction of supporting
facilities may have adverse effects to soils. Inadequate stabilization
of the site may produce uncontrolled erosion that may result in the loss
of topsoil, reduction of infiltration capacity, alteration of natural
hydrology of the land, increase in flood risks, and adverse impacts to
nearby habitat. (EPA 2007).  Land disturbance associated with this
activity is expected to be less than one (1) acre. FEMA will require
grantees and subgrantees to follow the general mitigation measures for
ground disturbance activities in Section 7.2. Proposed projects that
implement these measures will not result in significant impacts to
geology and soils.  FEMA will require a site-specific SEA or stand-alone
EA for those projects under this project type that warrant more than one
(1) acre of ground disturbance or that would not implement applicable
mitigation measures in Section 7.2. 

Water Resources 

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on water resources.  These activities are
expected to occur within the existing previously disturbed area with
minimal or no ground disturbance. Therefore, there is no substantial
increase in runoff from the site.  Additionally, these types of projects
do not result in a substantial increase in groundwater or surface water
usage within the project area. 

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas may adversely
affect water resources and quality in the project area. Uncontrolled
stormwater pollution, erosion and sedimentation can result in the
pollution of waters of the U.S. (EPA 2007). Table 5-2 shows the most
common water pollutants associated with construction activities.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects implementing these measures will not
result in significant impacts to water resources and water quality. 
FEMA will require a site-specific SEA or stand-alone EA for those
projects under this project type that warrant more than one (1) acre of
ground disturbance or that would not implement applicable mitigation
measures in Section 7.2.

Floodplains 

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on floodplains but may be affected by the
floodplain. Impacts to the floodplain are not expected because these
activities would occur within the existing previously disturbed area and
minimal ground disturbance. Equipment installed on a tower located in
the floodplain may be exposed to flood hazards. 

Under 44 CFR Part 9, FEMA is required to avoid activities in a
floodplain unless it is the only practicable alternative. When a
proposed project is the only practicable alternative, FEMA is required
to minimize the impacts to the floodplain and the impacts from floods to
the facility. Minimization techniques apply to the location of
structures, equipment and building contents in floodplain areas. This
could include elevating supporting structures and equipment such as
equipment buildings and generators above the base flood elevation.
Minimization techniques may include floodproofing structures or
facilities. Public safety towers may be considered critical actions
under this analysis because the risk of flooding might be too great. In
such cases, the standard to be used for avoidance, elevation, or
floodproofing is the 500-year base flood elevation. In addition, if
supporting structures are flood-insurable structures and the upgrade
constitutes a substantial improvement, FEMA will require the grantee or
subgrantee to comply with the local floodplain ordinance and obtain, if
necessary, a local floodplain permit. 

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. They also prohibit substantial improvements
in the floodway. FEMA defines substantial improvements as any repair,
reconstruction or other improvement of a structure or facility the costs
of which equals or exceeds 50% of the market value of the structure.  

FEMA will document the 8-step decisionmaking process and minimization
measures for all proposed communication tower projects located in a
floodplain through either a REC or a site-specific SEA, depending on the
nature of the potential impacts to and from the floodplain. 

Wetlands 

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on wetlands.  These activities are
expected to occur within the existing previously disturbed area with
minimal ground disturbance.

Activities involving the expansion, placement, and/or construction of
supporting facilities beyond previously disturbed areas have the
potential to adversely impact wetlands. Potential indirect impacts
include uncontrolled stormwater pollution, erosion and sedimentation
from the project that may adversely affect nearby wetlands. In addition,
these activities may involve direct impacts such as conversion of nearby
wetlands as the result of the expansion of facilities. Under 44 CFR Part
9, FEMA is required to engage in an 8-step decisionmaking process for
proposed projects that may have adverse impacts on wetlands, which
includes the use of minimization techniques when the proposed project
affecting the wetland is the only practicable alternative. Minimization
measures include avoidance techniques such as establishing wetland
buffer zones, following the general mitigation measures for ground
disturbing activities as laid out in Section 7.2, and compensation
measures such as wetland mitigation and banking. In addition to FEMA’s
responsibility under 44 CFR Part 9, the grantee or subgrantee must
obtain the applicable CWA Section 404 permit prior to the initiation of
the project if it will affect wetlands that are considered waters of the
U.S. by the USACE.  The grantee or subgrantee must consult with USACE to
determine whether any of the NWPs or a Regional General Permit apply or
whether an Individual Permit is required.  Depending on the type of
permit and as part of the permitting process, the grantee or subgrantee
may need to prepare a CWA Section 404 (b)(1) alternatives analysis or a
wetland mitigation plan.

If the project cannot be designed to avoid impacts to the wetland, then
FEMA will document the 8-step decisionmaking process and minimization
measures in either a REC or a site-specific SEA, depending on the nature
and magnitude of the potential impacts to the wetlands. In addition,
FEMA will include a grant condition requiring the grantee or subgrantee
to secure applicable CWA permits /certifications before initiating any
work involving ground disturbance. 

Biological Resources - Vegetation 

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on vegetation.  These activities are
expected to occur within the existing previously disturbed area with
minimal ground disturbance. 

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas may adversely
impact vegetation. The removal of vegetation and the inadequate
stabilization of the site after construction may cause severe erosion
that could result in the loss of topsoil, reduction of infiltration
capacity, alteration of natural hydrology of the land, increase in flood
risks, and adverse impacts to nearby habitat. (EPA 2007).  

Ground disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects implementing these measures will not
result in significant impacts to vegetation. With the implementation of
these mitigation measures and the absence of any special status species,
modifications and/or upgrades to existing towers and supporting
facilities do not have a significant adverse impact on local vegetation
in the vicinity of a project site.  In addition, with the control of
invasive exotic plant species as discussed previously, compliance with
EO 13112 is also achieved.  FEMA will require a site-specific SEA or
stand-alone EA for those projects under this project type that warrant
more than one (1) acre of ground disturbance or that would not implement
applicable mitigation measures in Section 7.2.

In cases where the proposed project area is determined to contain or be
near a sensitive vegetation community, FEMA will document its impact
analysis through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts. 

Biological Resources - Terrestrial Wildlife 

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on terrestrial wildlife.  These
activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance; therefore, these
activities would not have significant impact on terrestrial wildlife.
One exception would be modifications of navigational safety nighttime
lighting in existing towers from white strobe lights (L-865) or red
flashing, incandescent lights (L-864) to steady-burning red lights
(L-810). Steady-burning red lighting has the potential to increase
migratory bird collisions with towers and guy wires supporting the
towers. (Gehring et al. 2009). FEMA will require a site-specific SEA for
those modifications that result in the change of tower lighting to
steady-burning red lights (L-810). 

The addition of communication equipment that results in the increase in
tower height exceeding 199 feet may adversely affect migratory birds.
The increase in tower height will trigger consultation with FAA and may
result in lighting requirements that could attract migratory birds and
result in avian collisions. FEMA will require a site-specific SEA if the
addition of communication equipment will result in an increase in tower
height exceeding 199 feet and will use steady burning red lights
(L-810). 

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect terrestrial wildlife. If an activity involves work
in a forested area or special status area such as a floodplain, wetland,
forest or wildlife refuge, the project may have adverse effects on
wildlife such as displacement or loss of foraging habitat for common
small mammals or birds or fragmentation of habitat. The grantee or
subgrantee will be required to coordinate with the appropriate Federal,
State, Territory, or Tribal agency and obtain any special land use
permits or licenses in these areas. Grantees and subgrantees will be
required to submit to FEMA any environmental or historic preservation
documentation or clearance obtained from that process. 

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that are less than one (1) acre and for
which these measures are implemented will not result in significant
impacts to terrestrial wildlife.  FEMA will require a site-specific SEA
or stand-alone EA for those projects under this project type that
warrant more than one (1) acre of ground disturbance or that would not
implement applicable mitigation measures in Section 7.2.

Biological Resources - Aquatic Wildlife 

The co-location and upgrading of communication equipment on an existing
tower would not have significant impacts on aquatic wildlife. These
activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance; therefore, these
activities would not have significant impact on these resources. One
exception is proposed projects that would result in new beachfront
lighting near sea turtle nesting grounds which may adversely affect
these resources. Beachfront lighting can disorient sea turtle
hatchlings. Hatchlings find their way to the sea by differentiating
between dark and bright areas and overhead artificial lights disrupts
this ability. (Salmon 2003). For proposed coastal projects that would
result in new lighting, FEMA will require grantees and subgrantees to
coordinate with the State natural resources or coastal resources agency
to determine if the project is likely to affect sea turtle nesting
patterns and, if it is, to design the project in a manner to reduce
these impacts. If the proposed project cannot be redesigned to reduce
these impacts, then a site-specific SEA will be required to evaluate the
potential impacts to the species.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect aquatic wildlife. Projects within floodplains or
affecting floodplains or wetlands may have adverse impacts to aquatic
wildlife and/or their habitat. FEMA would avoid taking actions within or
affecting floodplains or wetlands. If undertaking the project within the
floodplain or wetland is the only practicable alternative, then FEMA
will document the 8-step decisionmaking process and minimization
measures through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts. 

Biological Resources - Listed Species, Critical Habitat and Special
Status Species 

Except as provided above for migratory birds and sea turtles protected
under the ESA, the co-location and upgrading of communication equipment
on an existing tower would not have an impact on listed species,
critical habitat or special status species.  These activities are
expected to occur within the existing previously disturbed area with
minimal ground disturbance.

There may be situations where a special status species individual is
using the existing tower or nearby facility as a nesting area. FEMA will
require grantees and subgrantees to identify if the subject facility is
being used by a special status species individual or if a special status
species is nearby. FEMA will encourage grantees and subgrantees to
follow existing guidelines for the protection of such species. In
addition, FEMA will consult with FWS and/or appropriate State, Tribe, or
local government agency before the project is approved to discuss
measures needed to avoid impacts to these individuals. Projects that
incorporate measures to avoid impacts to these special status
individuals, such as avoiding disruption of nests and avoiding
construction activities within 660 feet of identified nests, would not
have significant impact on these resources. If the proposed project
cannot be designed to avoid impacts to these special status individuals,
then FEMA will document its impact analysis through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect listed species or special species habitat. These
activities may result in the displacement or fragmentation of habitat
for these species. Land disturbance associated with this activity is
expected to be less than one (1) acre and FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2. However, FEMA will not be able to
determine whether the impacts of the specific activity to the listed
species, critical habitat or special status species are significant
without an appropriate site-specific evaluation and consultation with
FWS or NMFS. If consultation results in a No Effect or Not Likely to
Adversely Affect (NLAA) determination, then the activity would not have
significant impacts on these resources and no additional NEPA review
would be required. If the consultation results in the initiation of
formal consultation, then FEMA will enter into the formal ESA Section 7
consultation and document the results in a site-specific SEA.	

Human Health and Safety

Activities in this project type are expected to have a beneficial impact
on human health and safety throughout the U.S. and its territories. 
Modifications and/or upgrades of communication towers and supporting
facilities will improve readiness and response to natural and man-made
disasters.  Updated equipment will allow a faster and more complete
transfer and sharing of information between agencies and first
responders at all levels of government and communities. 

Activities related to the modification and/or upgrade of communication
towers and supporting facilities may involve the use, handling, storage,
and disposal of hazardous substances such as fuel storage tanks and
flammable liquids.  Waste fuel and/or oil associated with the operation
of the emergency generator at tower sites must be disposed of according
to Federal and State regulations. Additionally, the above-ground fuel
storage tanks for the emergency generators would be located within berms
to limit runoff and infiltration should a spill or leak occur. FEMA will
encourage grantees and subgrantees to locate containers with a capacity
to store more than 100 gallons of hazardous substances of an explosive
or fire prone nature at an acceptable separation distance from
facilities or structures where people can congregate such as schools or
hospitals. Grantees and subgrantees may use the HUD’s guidance
“Siting of HUD-Assisted Projects near Hazardous Facilities (HUD
-1060-CPD, Sept. 1996), incorporated in this PEA by reference. The
grantee or subgrantee will be responsible for meeting the “all
appropriate inquiries” rule in 40 C.F.R. 312.10 before acquiring a new
property. Grantee and subgrantees must prepare, implement, and regularly
update spill prevention and control plan when needed and required by
law. The use, handling, storage and disposal will be disposed of
according to Federal, State or Territory, and local regulations. No
significant impacts are expected from these activities. 

Minority and Low-Income Populations

Activities in this project type would not have disproportionate high and
adverse impacts on low-income and/or minority populations. These
activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance and therefore have no
significant adverse effects on low-income or minority populations. These
activities will have a long-term beneficial impact on all segments of
the population, including minority and/or low-income populations, by
increasing public safety.

Historic Properties - Archeology

Modifications and/or upgrades of existing communication towers and
supporting facilities that do not involve ground disturbance would have
no potential to affect archeological resources.

Activities involving ground disturbance have the potential to affect
archeological resources, particularly if the activities would be located
on undisturbed land. Yet the presence of modern structures or facilities
does not mean that no archaeological resources exist or that they have
already been destroyed.  Examples of ground disturbing activities
include topsoil removal, hand excavation of trenches, excavation along
existing foundation walls (whether on an historic or modern building),
and/or enlargement of existing structures or facilities.  While existing
structures may have disturbed potential archaeological deposits at the
time of construction, intact resources may have been left undisturbed. 
In addition, existing historic structures may have archaeological
components and any landscaping or other activities that disturb the
ground could affect potential archaeological deposits.  Geographical
location and expected site types dictate whether a proposed project will
affect archaeological resources.  

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that are less than one (1) acre, for
which these measures are implemented, and that are located in areas with
low potential for presence of archeological resources are not likely to
result in significant impacts to archeological resources.  Proposed
projects located in areas with moderate to high potential for
archeological findings would trigger Section 106 consultation with the
SHPO/THPO and the resolution of adverse effects by avoidance,
minimization or mitigation. The Program Comment issued by the ACHP on
November 3rd, 2009 establishes that FEMA would not need to comply with
the Section 106 process for those tower-related projects that have
undergone or will undergo Section 106, or that are exempt from Section
106, by the FCC Nationwide PA and Collocation PA. FEMA will coordinate
with the FCC on the implementation of this Program Comment and FEMA’s
and its applicants role for tower-related projects covered by the
Program Comment. 

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Historic Properties - Other Historic Properties 

The co-location of equipment or modification of an existing tower is a
preferred alternative to the construction of a new tower, as this type
of activity minimizes ground disturbance and the introduction of new
visual elements on the landscape. Some existing towers may have not gone
through the Section 106 process prior to their license and construction.
Although FEMA Section 106 review responsibilities is limited to the FEMA
undertaking (i.e. the action being funded by FEMA) it is important to
point out that the Agency will take into account past actions and
impacts as part of the evaluation of cumulative effects and take these
into account in its determination of adverse effects of its
action/undertaking. 

In general, modifications of communication tower facilities –
including co-location of equipment and installation of additional
equipment within the fenced facility (e.g. equipment shelters,
additional fencing, generators, lighting, vehicle barriers) – that are
not considered historically significant, do not substantially increase
the height or size of the facility and are not located within or near an
historic district or landscape are not likely to adversely affect
historic properties or their viewshed.  

Proposed projects involving a substantial increase in height and size of
a communication tower may increase the radius of the APE because the
resultant structure would be visible from a greater distance.  FEMA must
identify the APE, identify historic properties within the APE, and
determine if the proposed increase adversely affects historic properties
in consultation with the SHPO or THPO and other interested parties. 
Likewise, should the communication tower be located within or in view of
an historic district or landscape, indirectly affected historic
properties must be considered.  Dense commercial areas, wilderness and
roadless areas, industrial areas, non-historic transportation corridors,
or new subdivisions are examples of areas where an increase in the
height or size of a communication tower will likely have no potential to
affect, result in a finding of no historic properties affected, or
result in a finding of no adverse effect on historic properties.  In the
latter two circumstances, FEMA must consult with the SHPO or THPO and
other interested parties.  In many cases, tower facilities blend into
industrial or commercial landscapes.  

To avoid adverse effects, equipment could be co-located on alternative
existing structures or in less historically sensitive areas, as long as
the needed radio coverage requirements would still be met.  Should
equipment need to be co-located on historic properties or within
historic districts, effects to historic properties can be minimized by
masking the equipment on or in existing structures within the required
location.  Landscape buffers surrounding the base of facilities may also
minimize visual effects on immediately adjacent historic properties. 

The Program Comment issued by the ACHP on November 3rd, 2009 establishes
that FEMA would not need to comply with the Section 106 process for
those tower-related projects that have undergone or will undergo Section
106, or that are exempt from Section 106, by the FCC Nationwide PA and
Collocation PA. FEMA will coordinate with the FCC on the implementation
of this Program Comment and FEMA’s and its applicants role for
tower-related projects covered by the Program Comment. 

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Infrastructure

Traffic impacts associated with modifications and/or upgrades to
existing communication towers and supporting facilities are limited to
the construction phase.  New construction would use existing
infrastructure or would require minimum infrastructure development. Once
construction activities have been completed, traffic levels and flow
return to original levels.  Grantees and subgrantees are responsible for
coordinating with the appropriate local agency to ensure adequate
measures are implemented during construction, including warning signage,
limitation of public right-of-ways for staging, use of flagpersons, lane
closures, and detours. Potential impacts of these activities on traffic
would not be significant. 

No significant adverse effect would occur on utilities or the collection
and disposal of solid waste as a result of these types of projects.
These proposed projects would enhance communications networks, providing
a beneficial impact.  

Air Quality

In general, the co-location and upgrading of communication equipment on
an existing tower would not have adverse impacts on air quality because
the activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance. Fugitive dust and
equipment exhaust emissions associated with these types of activities
are not expected to have any significant impact on air quality,
regardless of whether the project area is located in a pristine,
attainment, nonattainment, or maintenance area.  These projects
generally involve small structural changes or modifications to existing
structures or fences. However, even in nonattainment areas these
emissions are likely going to be below minimum regulatory thresholds for
these criteria pollutants.  

Some proposed projects could include the installation of a new or
upgraded emergency generator that operates during power outages. The
operation of generators may be regulated in the particular State or
region where the project will take place. A generator may qualify for
emergency generator provisions depending on its usage or it may be
exempt from permit requirements if they are below the State’s
established emission threshold.  Grantees and subgrantees must
coordinate with their State environmental quality agency to determine
the applicable requirements.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect air quality. Fugitive dust and air pollutants
associated with the operation of construction equipment may affect air
quality conditions at the project site. Off-road engines used in
construction-related vehicles such as backhoes, front end loaders,
bulldozers, tractors, graders, excavators, etc. are typically
diesel-based that produce nitrogen oxides (NOx), hydrocarbons (HC),
carbon monoxide (CO) and particulate matter (PM) emissions. (USEPA
2003). In FEMA’s experience, the air emissions associated with
individual site preparation and construction activities in sites less
than five (5) acres do not rise to the level of significance even in
non-attainment areas.  Table 5-3 and Appendix C shows, for example, an
estimate made by the agency on the air emissions associated with
equipment used for site preparation and construction activities for the
placement of alternative housing units in the Gulf Coast of the U.S.
(FEMA 2009). These estimates were based on US EPA’s NONROAD Model
(USEPA 2005). 

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to air quality.  FEMA will require a
site-specific SEA or stand-alone EA for those projects under this
project type that warrant more than one (1) acre of ground disturbance
or that would not implement applicable mitigation measures in Section
7.2.

Older structures often contain lead-based paint or asbestos containing
materials.  Any activities associated with the demolition of facilities
must be done in accordance with Federal and State laws and regulations
regarding the handling and disposal of hazardous materials, such as
lead-based paint and asbestos containing materials.

Noise

In general, the co-location and upgrading of communication equipment on
an existing tower does not have noise-related adverse effects. These
projects are generally small in scale and construction activities are
temporary in nature.  

Activity work involving the expansion, placement, and construction of
supporting facilities may have measurable noise-related impacts. Table
5-4 shows an estimate of the noise levels associated with typical
construction equipment and attenuation of noise at various distances. To
estimate the attenuation of the noise over a given distance the
following relationship was used:

	dBA2 = dBA1 – 20 log (d2/ d1)

Where:

	dBA2 = dBA at distance 2 from source (predicted);

	dBA1 = dBA at distance 1 from source (measured);

d1 = distance to location 2 from source;

	d2 = distance to location 1 from source (50 ft.);

Source: CDOT 1998.

Table 5-4. Estimated Sound Levels for Construction Equipment and
Attenuation at Various Distances

Equipment	Typical Noise Level (dBA) at 50 ft. from Source1	Estimate at
100 ft.	Estimate at 200 ft.	Estimate at 500 ft.	Estimate at 1,000 ft.

Air Compressor	81	75	69	61	55

Backhoe	80	74	68	60	54

Ballast Equalizer	82	76	70	62	56

Ballast Tamper	83	77	71	63	57

Compactor	82	76	70	62	56

Concrete Mixer	85	79	73	65	59

Concrete Pump	82	76	70	62	56

Concrete Vibrator	76	70	64	56	50

Crane Derrick	88	82	76	68	62

Crane Mobile	83	77	71	63	57

Dozer	85	79	73	65	59

Generator	81	75	69	61	55

Grader	85	79	73	65	59

Impact Wrench	85	79	73	65	59

Jack Hammer	88	82	76	68	62

Loader	85	79	73	65	59

Paver	89	83	77	69	63

Pneumatic Tool	85	79	73	65	59

Pump	76	70	64	56	50

Rock Drill	98	92	86	78	72

Roller	74	68	62	54	48

Saw	76	70	64	56	50

Scraper	89	83	77	69	63

Shovel	82	76	70	62	56

Truck	88	82	76	68	62

1Source: FHWA 2006.

The estimates provided in Table 5-4 indicate that most of the equipment
commonly associated with construction activities produces noise levels
that exceed 75 dBA. A distance of 200 feet or more is needed between
most of the construction equipment provided and a receptor to attenuate
the noise levels those that are acceptable. 

Land disturbance associated with this activity is expected to be less
than one (1) acre. This limits the type and time of use for each piece
of equipment. FEMA will adopt, or require grantees and subgrantees to
follow, the general mitigation measures for ground disturbance
activities in Section 7.2, which includes operation during business
hours (Monday thru Friday from 7am to 5pm) and the use equipment using
the manufacturer’s standard noise control devices (i.e. mufflers,
baffling, and/or engine enclosures). In addition, grantees and
subgrantees will be required to comply with any State, Territory, Tribal
or local noise control requirements. With these measures the activity
would not result in significant noise impacts.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Visual Quality

Short-term impacts are associated with the presence of construction
equipment and vehicles necessary to carry out the modification or
upgrades to existing towers. These impacts are considered insignificant
and limited to the construction phase.  Long-term impacts associated
with these actions are not considered significant because the existing
facilities are already a part of the viewshed and the changes would be
minor. 

FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2. 
Proposed projects that implement these measures will not result in
significant impacts to visual quality.  FEMA will require a
site-specific SEA or stand-alone EA for those projects under this
project type that warrant more than one (1) acre of ground disturbance
or that would not implement applicable mitigation measures in Section
7.2.

Climate Change

There would be no significant impact to climate change as a result of
modifications or upgrades to existing communication towers.  These
modifications would not result in any changes in land use, a significant
increase in the burning of fossil fuels, or any other activities known
to contribute to the increased emissions that cause climate change.  

Construction of new or replacement communication towers

The replacement of communication towers and supporting facilities are
covered by FEMA CATEX (ix) and (xv).  As explained below this project
type may have potential to impact the quality of the human environment
based on the site-specific conditions, and based on tower design (i.e.
use of guy wires versus a monopole or lattice design).  FEMA will
conduct site-specific evaluations and document the applicability of the
CATEX, including presence of extraordinary circumstances, and the
applicability of other environmental planning and historic preservation
requirements through a REC. For projects having extraordinary
circumstances that cannot be resolved, FEMA will develop a SEA to
determine if the impacts are significant.

Construction of new communication towers may be covered by FEMA CATEX
(ix).  FEMA will conduct site-specific evaluations and document the
applicability of the CATEX, including presence of extraordinary
circumstances, and the applicability of other environmental planning and
historic preservation requirements through a REC.  For projects having
extraordinary circumstances that cannot be resolved, FEMA will develop a
SEA to determine if the impacts are significant.

Construction of a new communication tower would trigger review by the
FCC under NEPA, Section 106 of NHPA, Section 7 of ESA, E.O. 11988 and
other federal environmental planning and historic preservation
compliance requirements.  In order to expedite this review and avoid the
duplication of reviews between FCC and FEMA, FEMA strongly recommends
that grantees and subgrantees complete the FCC’s required
environmental and historic preservation compliance review and include
documentation prepared for that process or any clearance obtained from
the FCC as part of the request for FEMA funding for the communication
tower.  Appendix E provides FEMA’s procedures for the adoption of
other Agency’s reviews such as the FCC environmental planning and
historic preservation review. FEMA will continue to work with the FCC
and resource agencies to seek ways to eliminate the duplication of
reviews for this project type and may memorialize these approaches as
they are established. 

Figure 5-  SEQ FEMA's_NEPA_Process_for_Towers \* ARABIC  1 . FEMA NEPA
Process for New Communication Towers

 

Land Use

Replacement of towers would not have significant impacts on land use
because the new and previous land use would be the same. 

Construction of a new tower and supporting facilities in a new location
may require land use changes at the local level.  However, substantial
changes to land use are unlikely given the relatively small footprint of
this project type (less than 1 acre).  

Depending on the extent of changes proposed for the tower and the
required construction and demolition activities, a construction permit
from local authorities may be required prior to construction. 
Conditions of the permit normally specify that the proposed facility be
constructed and operated in compliance with local zoning ordinances, or
that a zoning variance be obtained.  The grantee or subgrantee is
responsible for obtaining the necessary construction permits.

FEMA is prohibited from providing assistance for new construction
activities in CBRS units. FEMA will require the grantee or subgrantee to
coordinate with the State Coastal Management Agency to obtain a
consistency determination when the propose project occurs within a
State’s designated coastal zone. 

If the proposed project will affect prime and unique farmland, FEMA will
complete the required Form AD-1006 and consult with NRCS. If the Form
AD-1006 indicates that the proposed project will score more than 160
points, then FEMA will document this finding in either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Geology and Soils

Construction of new towers and the replacement of towers in areas that
are not characterized by susceptibility to seismic or volcanic activity,
tsunamis, landslides, mudslides, structural instability, excessive
erodibility, or steep slopes will not result in significant impacts from
geology and soils to the project.

New construction activities in areas characterized by susceptibility to
seismic or volcanic activity, tsunamis, landslides, mudslides,
structural instability, excessive erodibility, or steep slopes will
require the use of certain engineering technologies or require
consultation with State or Federal agencies before the proposed project
may proceed. All structures, such as equipment and storage buildings, in
areas of seismic risk that are covered by this PEA must be designed and
constructed in accordance with appropriate seismic design and
construction standards, which are promulgated through NEHRP.  

Replacement towers would not have any impact on soil because soils in
the project area have already been compacted under the original tower. 
However, construction of new towers and supporting facilities may have
adverse impacts to soils. Inadequate stabilization of the site may
produce uncontrolled erosion that may result in the loss of topsoil,
reduction of infiltration capacity, alteration of natural hydrology of
the land, increase in flood risks, and adverse impacts to nearby habitat
(EPA 2007). Land disturbance associated with this activity is expected
to be less than one (1) acre. FEMA will require grantees and subgrantees
to follow the general mitigation measures for ground disturbance
activities in Section 7.2. Proposed projects that implement these
measures will not result in significant impacts to geology and soils. 
FEMA will require a site-specific SEA or stand-alone EA for those
projects under this project type that warrant more than one (1) acre of
ground disturbance or that would not implement applicable mitigation
measures in Section 7.2.

Water Resources

Replacement towers would not have significant impacts to water resources
or water quality. This activity would not increase the amount of
impervious surfaces at a given location.  However, areas that have been
disturbed by the removal of the existing vegetation are much more
susceptible to water erosion during major precipitation events and to
wind erosion during dry and windy weather conditions.  Uncontrolled
stormwater pollution, erosion and sedimentation can result in the
pollution of waters of the U.S. (EPA 2007). 

Construction of new towers and supporting facilities may adversely
affect water resources and quality in the project area. Uncontrolled
stormwater pollution, erosion and sedimentation can result in the
pollution of waters of the U.S. (EPA 2007). Table 5-2 shows the most
common water pollutants associated with construction activities.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects implementing these measures will not
result in significant impacts to water resources and water quality. FEMA
will require a site-specific SEA or stand-alone EA for those projects
under this project type that warrant more than one (1) acre of ground
disturbance or that would not implement applicable mitigation measures
in Section 7.2.

FEMA will coordinate with the appropriate agency if any of the
construction activities occur in the vicinity of a wild or scenic river.
 If the project affects a wild or scenic river, then FEMA will engage in
a site-specific SEA to appropriately evaluate the potential for
significant impacts to this resource. 

If construction activities involve the filling of navigable waters of
the U.S., FEMA will require the grantee or subgrantee to coordinate with
the USACE to obtain the applicable Federal permit. Proposed projects
that would require Individual Permit will require close coordination
among the grantee or subgrantee, FEMA and USACE. This process may
include the development of a site-specific SEA under this PEA or the
start of the EIS process.

Construction activities that comply with the required NPDES permits,
comply with applicable Nationwide or General permits under Section 404
and Section 10, and do not affect wild or scenic rivers will not result
in significant impacts to water resources and water quality. 

Floodplains 

Public safety interoperable communication towers may be considered
critical actions because the risk of flooding that could damage or
destroy the tower is too great. Therefore, proposed tower projects
require evaluation under the 500-year BFE standard. Under 44 CFR Part 9,
FEMA is required to avoid activities in a floodplain unless it is the
only practicable alternative. If locating a project in the floodplain is
the only practicable alternative, FEMA must minimize the impacts to the
floodplain and the impacts from floods to the facility. Minimization
techniques apply to the location of structures, equipment and building
contents in floodplain areas. This could include elevating facilities or
structures above the base flood elevation. Minimization techniques may
include floodproofing structures or facilities. In addition, if
structures are flood-insurable structures and the upgrade constitutes a
substantial improvement, FEMA will require the grantee to comply with
the local floodplain ordinance and obtain, if necessary, a local
floodplain permit. 

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. Communication towers are not functionally
dependent uses. The regulations also prohibit substantial improvements
in the floodway. 

If undertaking the project in the 500-year floodplain is the only
practicable alternative, then FEMA will document the 8-step
decisionmaking process and minimization measures through either a REC or
a site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Wetlands

The replacement of a communication tower at an existing site is not
expected to have a significant impact on wetlands because the activities
would occur within the previously disturbed area. Construction of new
towers and supporting facilities that are not within or affect wetlands
will not have significant impacts on wetlands. 

Some construction activities related with the placement of new towers
and supporting facilities may adversely affect wetlands. Activities
outside of wetland areas but near wetlands may result in uncontrolled
stormwater pollution, erosion and sedimentation that may adversely
affect these nearby wetlands. Minimization measures include avoidance
techniques such as establishing wetland buffer zones and complying with
the mitigation measures in Section 7.2 would reduce the potential
adverse impacts of these activities to nearby wetlands.

Some construction activities related with the placement of new towers
and supporting facilities may take place within wetland areas. Under 44
CFR Part 9, FEMA is required to engage in an 8-step decisionmaking
process for proposed projects that may have adverse impacts on wetlands,
which includes the use of minimization techniques when the project
affecting the wetland is the only practicable alternative. Minimization
measures include avoidance techniques such as establishing wetland
buffer zones to avoid converting or filling wetlands. Compensation
measures include such wetland mitigation and wetlands banking. In
addition to FEMA’s responsibility under 44 CFR Part 9, the grantee or
subgrantee must obtain the applicable Federal permit prior to the
initiation of the project if it will affect wetlands that are considered
waters of the U.S. by the USACE.  The grantee or subgrantee must
coordinate with USACE to determine whether any of the NWPs or a Regional
General Permit apply or whether an Individual Permit is required.
Proposed projects that would require Individual Permit will require
close coordination among the grantee or subgrantee, FEMA and USACE. This
process may include the development of a site-specific SEA under this
PEA or the start of the EIS process.

If the project cannot be designed to avoid impacts to the wetland, then
FEMA will document the 8-step decisionmaking process and minimization
measures through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts. 

Biological Resources - Vegetation 

The replacement of a communication tower at the existing site is not
expected to have no or minimal impact on vegetation.  The activities are
expected to occur within the existing previously disturbed area.
However, there may be disturbance or removal of vegetation that has
grown up around the base of the existing tower and supporting facilities
since their original placement on the site. 

The construction of new communication towers and supporting facilities
may adversely impact vegetation. The removal of vegetation and the
inadequate stabilization of the site after construction may cause severe
erosion that could result in the loss of topsoil, reduction of
infiltration capacity, alteration of natural hydrology of the land,
increase in flood risks, and adverse impacts to nearby habitat. (EPA
2007).  

Ground disturbance for the construction of a new tower, associated
equipment building, generator and security fencing to enclose these
facilities is expected to be less than one (1) acre. However, depending
on the location of the proposed project and the need to construct an
access road and utility easements, the amount of ground disturbance
associated with these supporting activities could increase the potential
for impacts to vegetation, particularly in remote or undeveloped areas.
FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2.
Proposed projects implementing these measures will not result in
significant impacts to vegetation. With the implementation of these
mitigation measures and the absence of any special status species,
construction of new communication towers are not expected to have a
significant adverse impact on local vegetation in the vicinity of a
project site.  In addition, with the control of invasive exotic plant
species as discussed previously, compliance with EO 13112 is also
achieved.   FEMA will require a site-specific SEA or stand-alone EA for
those projects under this project type that warrant more than one (1)
acre of ground disturbance or that would not implement these mitigation
measures.

If the project area is determined to be located within or near a
sensitive vegetation community, a FEMA will document its impact analysis
through either a REC or a site-specific SEA, depending on the nature and
magnitude of the potential impacts. 

Biological Resources - Terrestrial Wildlife 

The replacement of a communications tower at the existing site that
follow FWS guidelines explained below would have no or minimal impact on
terrestrial wildlife. The activities are expected to occur within the
previously disturbed area. 

The construction of new communication towers and supporting facilities
has potential to affect terrestrial wildlife. If an activity involves
work in a forest area or special status area such as a wildlife refuge,
wetlands, or floodplains, the proposed project may have adverse impacts
on wildlife such as displacement or loss of foraging habitat for common
small mammals or birds or fragmentation of habitat. These impacts,
however, are not likely to be significant due to the small size and
scope of a typical communication tower project. The grantee or
subgrantee will be required to coordinate with the appropriate Federal,
State, Territory, or Tribal agency and obtain any special land use
permits or licenses in these areas. Grantees and subgrantees will be
required to submit to FEMA any environmental or historic preservation
compliance documentation or clearance obtained from that process.

Ground disturbance for the construction of a new tower, associated
equipment building, generator and security fencing to enclose these
facilities is expected to be less than one (1) acre. However, depending
on the location of the proposed project and the need to construct an
access road and utility easements, the amount of ground disturbance
associated with these supporting activities could increase the potential
for impacts to terrestrial wildlife. FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2. Proposed projects that implement
these measures will not result in significant impacts to terrestrial
wildlife.  FEMA will require a site-specific SEA for projects that would
result in more than one (1) acre of ground disturbance or do not
implement applicable mitigation measures in Section 7.2.

Migratory Birds

The long-term impacts on migratory birds from communication towers are
potentially significant.  The FWS Division of Migratory Bird Management
has issued interim guidelines for reducing impacts from towers on
migratory birds (FWS 2000). The Division also submitted comments to the
FCC’s Notice of Proposed Rulemaking, “Effects of Communication
Towers on Migratory Birds” in February 2007 that update the guidance
provided in 2000. These comments are incorporated in Appendix F of this
PEA.  FEMA is currently coordinating with FWS in the development of an
MOU under Executive Order 13186 – Responsibilities of Federal Agencies
to Protect Migratory Birds that would take into account actions
involving communication tower constructions, including the programs
discussed in this PEA. A Draft MOU can be found in Appendix G. The MOU
incorporates the following FWS guidelines for the siting, construction,
and operation of communication towers:

Co-location of communication equipment on existing towers or other tall
structures (e.g. water tower) is preferred over construction of a new
tower. 

Communication towers, where practicable, should be less than 200 feet
AGL in height, be of monopole or lattice design, contain no guy wires,
and contain no lights, except where required along major highway travel
corridors and within 3.8 statute miles of approach and departure airport
runways (i.e. towers should be unlighted if Federal Aviation
Administration (FAA) regulations allow). This recommendation is the
environmentally-preferred industry standard for tower placement,
construction, and operation. This includes all new communication towers,
the repair or re-construction of outdated or damaged towers, and the
upgrade and modification of existing towers.  

All new towers must be fitted in decreasing order of priority with white
strobes, red strobes, or blinking incandescent lighting, and no L-810
side lights should be used.  

Where tower height and guy wires are a concern regarding impacts to
migratory birds, shorter, un-guyed towers should be constructed, even if
a larger number of towers are needed to provide equivalent service. In
other words, a larger overall footprint is preferable to the use of guy
wires.   

Towers exceeding 199 feet AGL in height, even those that are several
hundred feet AGL in height, do not necessarily need to be guyed.
However, it is recognized that towers may need to be guyed in areas
susceptible to hurricanes, tornadoes, and other types of hazards. 

Through the implementation of these guidelines, replacement and
construction of new communication towers will comply with the Bald and
Golden Eagle Protection Act, the Migratory Bird Treaty Act, the Fish and
Wildlife Coordination Act. FEMA programs would be in compliance with
E.O. 13186.  

For tower projects that fully meet the FWS guidelines, no consultation
between FEMA and FWS shall be necessary. For projects that do not meet
the FWS guidelines, FEMA will not be able to determine whether the
impacts of the specific activity to migratory birds are significant
without an appropriate site-specific evaluation and consultation with
FWS. If FWS determines that the proposed tower project will not have
adverse impacts to migratory birds, FEMA will document the results in an
REC. If, however, FWS determines that the proposed tower project will
have adverse impacts to migratory birds and those impacts cannot be
adequately mitigated, a site-specific SEA will be required to determine
the level of significance of the impacts. 

Biological Resources – Aquatic Wildlife

The replacement or new construction of towers and supporting facilities
activities in areas that are not located within or affect the 100-year
floodplain, wetlands, or coastal areas would not have significant
impacts on aquatic life.

Proposed projects within floodplains or affecting floodplains, wetlands,
or coastal areas may have adverse impacts to aquatic wildlife and/or
their habitat. Conversion of floodplain or wetlands to other uses would
reduce important habitat that is critical for aquatic species. (NMFS
2008). FEMA will avoid taking actions within or affecting floodplains or
wetlands. If locating the project within the floodplain or wetland is
the only practicable alternative, FEMA will document the 8-step
decisionmaking process and minimization measures through a site-specific
SEA. 

Coastal projects that would result in new beachfront lighting near
nesting grounds for sea turtles may adversely affect these resources.
Beachfront lighting can disorient sea turtle hatchlings. Hatchlings find
their way to the sea by differentiating between dark and bright areas
and overhead artificial lights disrupts this ability (Salmon 2003). For
proposed coastal projects that would result in new lighting, FEMA will
require grantees and subgrantees to coordinate with the State natural
resources or coastal resources agency to determine if the coastal
project is likely to affect sea turtle nesting patterns and, if it is,
to design the project in a manner to reduce these impacts. If the
project cannot be redesigned to reduce these impacts, then FEMA will
document its impact analysis through either a REC or a site-specific
SEA, depending on the nature and magnitude of the potential impacts.

Biological Resources - Listed Species, Critical Habitat and Special
Status Species 

In general, the replacement of a communication tower at the existing
site is expected to have minimal or no impact on listed species,
critical habitat or special status species.  These activities are
expected to occur within the previously disturbed area. However, there
may be situations where a special status species individual is using the
existing tower or is nesting nearby. FEMA will require grantees and
subgrantees to identify if a special status species is nearby and, when
it is nearby, will encourage grantees and subgrantees to design their
projects following existing guidelines for the protection of such
species. In addition, FEMA will consult with FWS and/or appropriate
State, Tribe, or local government agency before the project is approved
to discuss measures needed to avoid impacts to these individuals.
Proposed projects that incorporate measures to avoid impacts to these
special status individuals would not have significant impact on these
resources. 

Construction of new towers and supporting facilities has the potential
to affect listed species, critical habitat or special status species.
Ground disturbance for the construction of a new tower, associated
equipment building, generator and security fencing to enclose these
facilities is expected to be less than one (1) acre. However, depending
on the location and design of the proposed project and the need to
construct an access road and/or utility easements, the amount of ground
disturbance associated with these supporting activities could increase
the potential for impacts to listed species, critical habitat or special
status species. FEMA will require grantees and subgrantees to follow the
general mitigation measures for ground disturbance activities in Section
7.2. 

FEMA will consult with FWS or NMFS under Section 7 of ESA. If
consultation under Section 7 results in a No Effect or Not Likely to
Adversely Affect (NLAA) determination, then the activity would not have
significant impacts on these resources and no additional NEPA review
would be required. If the consultation results in the initiation of
formal consultation, then FEMA will enter into the formal ESA Section 7
consultation and document the results in a site-specific SEA.

Human Health and Safety

Replacement or construction of new communication towers and supporting
facilities are expected to have a beneficial impact on human health and
safety throughout the US and its territories.  These activities will
improve readiness and response to natural and man-made disasters and
will allow a faster and more complete transfer and sharing of
information between agencies and first responders at all levels of
government and communities. 

The replacement or construction of new communication towers may involve
the use, handling, storage, and disposal of hazardous substances such as
fuel storage tanks and flammable liquids.  Waste fuel and/or oil
associated with the operation of the emergency generator at tower sites
must be disposed of according to Federal and State regulations.
Additionally, the above-ground fuel storage tanks for the emergency
generators would be located within berms to limit runoff and
infiltration should a spill or leak occur.  FEMA will require grantees
and subgrantees to locate containers with a capacity to store more than
100 gallons of hazardous substances of an explosive or fire prone nature
at an acceptable separation distance from facilities or structures where
people can congregate such as schools or hospitals. Grantees and
subgrantees may use the HUD’s guidance “Siting of HUD-Assisted
Projects near Hazardous Facilities (HUD -1060-CPD, Sept. 1996)”,
incorporated in this PEA by reference. FEMA will require grantees and
subgrantees to prepare, implement, and regularly update spill prevention
and control plan when needed.  The use, handling, storage and disposal
will be disposed of according to Federal, State or Territory, and local
regulations. No significant impacts are expected from these activities. 

Minority and Low-Income Populations

Impacts related to replacement projects are similar to those discussed
for existing tower sites because the structure being replaced already
exists in the environment.  Potential impacts are those associated with
ground disturbance (e.g. localized air quality, stormwater pollution),
traffic, and noise. However, these impacts would affect all populations
and would not be disproportionally directed to minority or low-income
populations. FEMA will require grantees and subgrantees to follow the
general mitigation measures for ground disturbance activities in Section
7.2 which include practices to control these impacts.

There is a potential for new communication towers to be
disproportionately located near minority or low-income populations.
Grantees and subgrantees are responsible for adequate planning of these
activities to avoid this result. Grantees and subgrantees are also
responsible for engaging in adequate community outreach before the
project is proposed to FEMA. For these projects FEMA will require
evidence from grantees and subgrantees of their community outreach
efforts.

With appropriate planning, community outreach, and implementation of the
mitigation measures, these proposed projects are not anticipated to have
a significant impact on minority or low-income populations.  If FEMA
finds disproportionate high and adverse impacts to minority and/or
low-income populations, then a site-specific SEA will be required.

Historic Properties - Archeology

The replacement or construction of new communication towers will not
have an adverse effect on archeological resources if the projects are
located on sites that have low probability for the presence of
archeological deposits or that have been previously surveyed and found
not to have archeological deposits.

The replacement of communication towers in sites that have moderate to
high probability for the presence of archeological deposits may have
adverse effects on these resources. The presence of modern structures or
facilities does not mean that no archaeological resources exist or that
they have already been destroyed. While existing structures may have
disturbed potential archaeological deposits at the time of construction,
intact resources may have been left undisturbed.  In addition, any
landscaping or other activities that disturb the ground could affect
potential archaeological deposits. Geographical location and physical
characteristics of the site dictate whether an undertaking will affect
archaeological resources.  If such activities are anticipated, then
Section 106 consultation is necessary to determine whether potential
archaeological resources exist and whether they would be adversely
affected. If the project will have an adverse effect, FEMA must develop
ways to avoid, minimize, or mitigate adverse effects to the
archaeological resources in consultation with the SHPO or THPO and other
interested parties.

The construction of new communication towers and supporting facilities
on sites that have moderate to high probability for the presence of
archeological deposits may have adverse effects on these resources.
Geographical location and physical characteristics of the site dictate
whether an undertaking will affect archaeological resources.  

The Program Comment issued by the ACHP on November 3rd, 2009 establishes
that FEMA would not need to comply with the Section 106 process for
those tower-related projects that have undergone or will undergo Section
106, or that are exempt from Section 106, by the FCC Nationwide PA and
Collocation PA. FEMA will coordinate with the FCC on the implementation
of this Program Comment and FEMA’s and its applicants role for
tower-related projects covered by the Program Comment. 

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Historic Properties - Other Historic Properties

The replacement or construction of new communication towers that do not
affect historic properties will not have significant impacts on these
resources. Locating new towers in areas where historic properties are
not likely present helps reduce or avoid adverse impacts to historic
properties. Examples include industrial parks or commercial strip malls
and transportation right-of-way corridors that are not within boundaries
of historic districts. The construction of a new tower outside the
limits of an historic district or designated historic landscape and with
no or limited visibility from historic properties will not likely have
an adverse effect on historic properties.  

Some proposed projects involving the replacement or construction of new
towers and supporting facilities may have adverse effects to historic
properties. The replacement of a communication tower with a tower that
is substantially increased in height, footprint, or of different type
(i.e. lattice vs. guy wire) may result in adverse affects of historic
properties within the identified historic property’s APE. Conversely,
the construction of new towers within historic districts or designated
historic landscapes or within the viewshed of historic properties is
likely to introduce characteristics that diminish the historic integrity
of these properties and, therefore, have adverse effects on historic
properties.  Activities to be considered in the undertaking include any
construction and/or demolition activities associated with the project
and/or activities that may not be eligible under the GPD programs but
are connected to the tower construction such as the construction of
access roads, installation of utilities, and removal of vegetation among
others.  

Avoidance of adverse effects can be achieved by siting towers in less
historically sensitive areas or co-locating equipment on existing
structures to avoid construction of a new tower. For new communication
towers constructed within an historic district or within the viewshed of
historic properties, examples of measures to minimize the impacts could
include using a design and color so that the tower blends into the
surrounding area and placing landscape buffers. 

The Program Comment issued by the ACHP on November 3rd, 2009 establishes
that FEMA would not need to comply with the Section 106 process for
those tower-related projects that have undergone or will undergo Section
106, or that are exempt from Section 106, by the FCC Nationwide PA and
Collocation PA. FEMA will coordinate with the FCC on the implementation
of this Program Comment and FEMA’s and its applicants role for
tower-related projects covered by the Program Comment. 

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Infrastructure

Traffic impacts associated with replacement or construction of new
communication towers and supporting facilities are limited to the
construction phase. Except for routine maintenance and inspection
visits, tower sites are unmanned. Once construction activities have been
completed, traffic levels and flow return to original levels. Grantees
and subgrantees are responsible for coordinating with the appropriate
local agency to ensure adequate measures are implemented during
construction, including warning signage, limitation of public
right-of-ways for staging, use of flagpersons, lane closures, and
detours. Impacts of these activities on traffic would not be
significant. 

No significant adverse effect would occur on utilities or the collection
and disposal of solid waste as a result of these types of projects.
These projects would enhance communications networks, providing a
beneficial impact to communities during emergency events.  

Air Quality 

Impacts to air quality for replacement or construction of new
communication towers and supporting facilities are similar to those
described for modification/upgrades to existing towers.
Construction-related activities that could result in an adverse impact
on air quality are generally associated with short-term emissions,
principally from site clearing activities and the use of construction
equipment and related vehicles.  The construction activities are not
likely to result in a violation of the GCR or cause PSD deterioration.
Operation of the new facilities would not have significant impact on the
local or regional air quality.  In general, operation of new or replaced
facilities would not result in a new major source and would not likely
result in a violation of the GCR or cause PSD deterioration.  

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to air quality.  FEMA will require a
site-specific SEA or stand-alone EA for those projects under this
project type that warrant more than one (1) acre of ground disturbance
or that would not implement applicable mitigation measures in Section
7.2.

Noise 

Noise impacts associated with the replacement or construction of new
communication towers and supporting facilities are similar to those
described for upgrades to existing towers, although impacts from
construction equipment may be greater in magnitude and duration. Impacts
would be limited to the construction period and would not be
significant. 

FEMA will require grantees and subgrantees to follow, the general
mitigation measures for ground disturbance activities in Section 7.2,
which includes operation during business hours (Monday thru Friday from
7am to 5pm) and the use equipment using the manufacturer’s standard
noise control devices (i.e. mufflers, baffling, and/or engine
enclosures). In addition, grantees and subgrantees will be required to
comply with any State, Tribal or local noise control requirements. With
these measures, proposed projects would not result in significant noise
impacts.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Visual Quality

The replacement of an existing tower of similar height and design would
not have long-term  impacts on visual quality, as a tower previously
existed on the landscape.  However, construction activities would result
in minor, short-term impacts to visual quality.

The visual impacts of a new tower, access road, power lines, and
supporting equipment and buildings may be more noticeable in a rural or
remote area where man-made features sharply contrast with the natural
setting. These impacts are typically less noticeable in an urban area
where other towers, high-rise buildings, etc. are present.  

Communication towers constructed in rural, remote, roadless areas, near
natural landscapes, or Class I areas have the greatest potential for
impacts to visual quality.  To minimize impacts, the following
mitigation measures would be implemented when appropriate:

Selecting tower sites from areas already served by a road

Consolidating communication facilities when possible (e.g. “tower
farm”)

Selecting new site locations where the features of the communication
tower site are consistent with the topography of the area

Minimizing the footprint of the affected area 

Painting concrete foundations with an earth-tone paint to reduce
contrast

Painting communication towers to make them less visible and distinct
from the surrounding features

Restoring and landscaping disturbed areas after construction activities
have been completed

Take into account other measures to buffer visual effects and
alterations to natural landscapes

In addition FEMA will require grantees and subgrantees to follow the
general mitigation measures for ground disturbance activities in Section
7.2. These measures will reduce the particulate matter emissions of
ground disturbance actions. Proposed projects implementing these
measures will not result in significant impacts to visual quality. If
these measures are not followed, then FEMA will document its impacts
analysis through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts. 

Climate Change

The replacement of existing towers would have no effect on climate
change, because the land use and function of the facility would remain
the same.  

The construction of new communication towers would not have a
significant impact on climate change.  Increased emissions from
construction activities would be of short duration and a limited scale. 
While land use would be altered at the site and there would be an
increase in energy usage to provide power to the tower, the scale at
which these changes would occur would not be significant.  

Modification of Existing Structures and Facilities

Modification, including renovation, retrofits and expansions, of
existing structures and facilities are covered by FEMA CATEX (xvi) and
(xvii). As explained below, this project type may have the potential to
impact the quality of the human environment based on the site-specific
conditions and resources present. FEMA will conduct a site-specific
evaluation and document the applicability of the CATEX, including
presence of extraordinary circumstances, and applicability of other
environmental planning and historic preservation requirements through a
REC. For projects having extraordinary circumstances that cannot be
resolved, a site-specific SEA will be required. 

Land Use 

Proposed modification of existing structures and facilities would not
have significant impacts on land use. Some activities under this project
type involving structural changes to the existing facility may require a
construction permit from local authorities prior to construction. 
Conditions of the permit normally specify that the proposed facility be
constructed and operated in compliance with local zoning ordinances, or
that a zoning variance be obtained. The grantee or subgrantee is
responsible for obtaining the necessary construction permits.

Geology and Soils 

Proposed modification of existing structures and facilities in areas
that are not characterized by susceptibility to seismic or volcanic
activity, tsunamis, landslides, mudslides, structural instability,
excessive erodibility, or steep slopes will not result in significant
impacts from geology and soils to the project. 

Some proposed modifications for structures or facilities located in
areas characterized by susceptibility to seismic or volcanic acitivity,
tsunamis, landslides, mudslides, structural instability, excessive
erodibility, or steep slopes may be adversely affected by these hazard
conditions. However, the impacts would not be significant given the type
of activities under this project type (e.g. installing blast-proof doors
and/or windows, security lighting and fencing, CCTVs, and other similar
physical security enhancements). Expansion of existing facilities is
also included in this project type.  As these proposed projects do not
involve construction of new buildings, EO 12699 does not apply.  

Some proposed projects could involve more extensive renovation
activities, including the removal and/or construction of walls,
installation of bollards, or installation of tire puncture treadles. 
All such activities must be completed in accordance with building codes
of the local area, including seismic requirements, as appropriate. 
Thus, the intent of EO 12699 is satisfied.

Areas that have been disturbed by the removal of the existing vegetation
are much more susceptible to water erosion during major precipitation
events and to wind erosion during dry and windy weather conditions. FEMA
will require grantees and subgrantees to follow the general mitigation
measures for ground disturbance activities in Section 7.2 which include
practices to reduce soil erosion.  Proposed projects implementing these
measures will not have significant impacts on geology and soils.  FEMA
will require a site-specific SEA or stand-alone EA for those projects
under this project type that warrant more than one (1) acre of ground
disturbance or that would not implement applicable mitigation measures
in Section 7.2.

Water Resources 

Proposed projects that would involve modification of the interior of
existing structures and facilities would have no significant impact on
water resources. These activities are expected to occur within the
existing previously disturbed area with minimal or no ground
disturbance. Therefore, there is no substantial increase in runoff from
the site.  Additionally, these types of activities do not result in a
substantial increase in groundwater or surface water usage within the
project area. 

Activities involving the expansion of facilities beyond previously
disturbed areas or construction may adversely affect water resources and
quality in the project area. Uncontrolled stormwater pollution, erosion
and sedimentation can result in the pollution of waters of the U.S. (EPA
2007). Table 5-2 shows the most common water pollutants associated with
construction activities.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to water resources and water quality. 
FEMA will require a site-specific SEA or stand-alone EA for those
projects under this project type that warrant more than one (1) acre of
ground disturbance or that would not implement applicable mitigation
measures in Section 7.2.

Activities associated with buildings and structures located waterside
have the potential to directly impact aquatic resources, through erosion
and runoff and pollutants. Proposed activities involving docks, piers,
boathouses, and other facilities or structures dependent on water would
be carried out in a manner that minimizes the potential for any
hazardous materials (e.g., oil or gasoline) to enter the water,
emphasizing BMPs for the handling, use, storage, and disposal of
hazardous substances.  Grantees or subgrantees are responsible for
complying with required and applicable permits for these actions
including the drafting of a spill prevention and contingency plan when
required.  Therefore, these activities do not have a significant impact
on water resources.  

Construction activities located in or near a water body may require a
RHA Section 10 or a CWA Section 404 permit from the USACE. The permits
would identify measures that must be implemented to minimize erosion and
runoff, such as the use of silt fencing, rip-rap, and other
erosion-prevention methods.  The grantee or subgrantee is responsible
for acquiring all necessary permits and complying with all mitigation
measures identified to ensure no significant impacts.  

Floodplains 

Proposed modification of existing structures and facilities that are not
located within the 100-year floodplain (500-year floodplain for critical
actions) would not have significant impacts on floodplains.

Proposed modification of existing structures and facilities that are
located in the floodplain would not have impacts on floodplains but may
be affected by the floodplain. Impacts to the floodplain are not
expected because these activities would occur within the existing
previously disturbed area and minimal ground disturbance. However, any
components added to existing facilities located in the floodplain may be
exposed to flood hazards. 

Under 44 CFR Part 9, FEMA is required to avoid activities in a
floodplain unless it is the only practicable alternative. If locating a
project in the floodplain is the only practicable alternative, FEMA must
minimize the impacts to the floodplain and the impacts from floods to
the facility. Minimization techniques apply to the location of
structures, equipment and building contents in floodplain areas. This
could include elevating facilities or structures above the base flood
elevation. Minimization techniques may include floodproofing structures
or facilities. Some of these facilities may be considered critical
actions under this analysis because the risk of flooding might be too
great. In such cases, the base flood elevation or standard for
floodproofing is the 500-year flood event. In addition, if structures
are flood-insurable structures and the upgrade constitutes a substantial
improvement, FEMA may require the grantee to comply with the local
floodplain ordinance and obtain, if necessary, a local floodplain
permit. 

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. Boat houses, docks, piers are examples of
functionally dependent uses. They also prohibit substantial improvements
in the floodway. 

If undertaking the proposed project in the floodplain is the only
practicable alternative, then FEMA will document the 8-step
decisionmaking process and minimization measures through a REC or
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Wetlands 

Modification of existing structures and facilities would not typically
involve the installation or construction of any new fixed structures or
buildings within a wetland, and therefore would have no significant
effect on wetlands and comply with EO 11990 and Section 404 of the CWA. 

Activities outside of wetland areas but near wetlands may result in
uncontrolled stormwater pollution, erosion and sedimentation that may
adversely affect these nearby wetlands. Minimization measures include
avoidance techniques such as establishing wetland buffer zones and
obtaining and complying with NPDES permits and SWPPP measures would
reduce the potential adverse effects of these activities to nearby
wetlands.

Enlargement of a facility or construction within wetland areas would
affect wetlands. Under 44 CFR Part 9, FEMA is required to engage in an
8-step decisionmaking process for projects that may have adverse impacts
on wetlands, which includes the use of minimization techniques when the
project affecting the wetland is the only practicable alternative.
Minimization measures include avoidance techniques such as establishing
wetland buffer zones to avoid converting or filling wetlands.
Compensation measures include such wetland mitigation and wetlands
banking. In addition to FEMA’s responsibility under 44 CFR Part 9, the
grantee or subgrantee must obtain the applicable CWA Section 404 permit
prior to the initiation of the project if it will affect wetlands that
are considered waters of the U.S. by the USACE. The grantee or
subgrantee must coordinate with USACE to determine whether any of the
NWPs or a Regional General Permit apply or whether an Individual Permit
is required. Proposed projects that require an Individual Permit will
require close coordination between the grantee or subgrantee, FEMA and
USACE. This process may include the development of a site-specific SEA
or the start of the EIS process.

If the proposed project cannot be designed to avoid impacts to the
wetland, then FEMA will document the 8-step decisionmaking process and
minimization measures through REC or site-specific SEA, depending on the
nature and magnitude of the potential impacts.. 

Biological Resources-Vegetation 

Proposed projects that would involve modifications to the interior of
existing structures or facilities would not have significant impacts on
vegetation.

Enlargement of a facility or construction activities beyond previously
disturbed areas may adversely impact vegetation. The removal of
vegetation and the inadequate stabilization of the site after
construction may cause severe erosion that could result in the loss of
topsoil, reduction of infiltration capacity, alteration of natural
hydrology of the land, increase in flood risks, and adverse impacts to
nearby habitat. (EPA 2007).  

Ground disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that are less than one (1) acre and for
which these measure are implemented will not result in significant
impacts to vegetation. With the implementation of these mitigation
measures and the absence of any special status species, modifications to
existing structures or facilities will not have a significant adverse
impact on local vegetation in the vicinity of a project site.  In
addition, with the control of invasive exotic plant species as discussed
previously, compliance with EO 13112 is also achieved.  FEMA will
require a site-specific SEA or stand-alone EA for those projects under
this project type that warrant more than one (1) acre of ground
disturbance or that would not implement applicable mitigation measures
in Section 7.2.

If the project area is determined to contain or be located near a
sensitive vegetation community, then FEMA will document its impacts
analysis through a REC or site-specific SEA, depending on the nature and
magnitude of the potential impacts. .

Biological Resources -Terrestrial Wildlife 

Proposed modification of existing structures and facilities would not
have significant impacts on terrestrial wildlife.

The construction phase of outdoor activities under this project type may
have the potential to disturb terrestrial wildlife and their habitat,
but most impacts are not expected to be significant or long-term.  The
incremental loss of habitat from an expansion project would not be
significant, as expansion is not expected to significantly alter the
building footprint.  Operational impacts include long-term loss of
habitat and direct impacts on terrestrial wildlife species which may
alter feeding, mating, or foraging behaviors, construction-related noise
and other disturbance can affect wildlife population usage in areas
surrounding the project site.  This is especially true during sensitive
periods of the species life cycle.

Biological Resources - Aquatic Wildlife 

Proposed modification of existing structures and facilities that are not
located within or do not affect the 100-year floodplain, wetlands or
coastal areas would not have significant impacts on aquatic life.

Proposed projects within floodplains or affecting floodplains, wetlands
or coastal areas may have adverse impacts to aquatic wildlife and/or
their habitat. FEMA would avoid taking actions within or affecting
floodplains or wetlands. If undertaking the proposed project within the
floodplain or wetland is the only practicable alternative, FEMA will
document the 8-step decisionmaking process and minimization measures
through a site-specific SEA. 

Propose coastal projects that would result in new beachfront lighting
near nesting grounds for sea turtles may adversely affect these
resources. Beachfront lighting can disorient sea turtle hatchlings.
Hatchlings find their way to the sea by differentiating between dark and
bright areas and overhead artificial lights disrupts this ability
(Salmon 2003). For coastal projects that would result in new lighting,
FEMA will require grantees and subgrantees to coordinate with the State
natural resources or coastal resources agency to determine if the
coastal project is likely to affect sea turtle nesting patterns and, if
it is, to design the project in a manner to reduce these impacts. If the
proposed project cannot be redesigned to reduce these impacts, then FEMA
will document the impacts analysis with a REC or site-specific SEA,
depending on the nature and magnitude of the potential impacts.

Biological Resources - Listed Species, Critical Habitat and Special
Status Species 

Proposed projects that would involve modification of the interior of
existing structures and facilities would not have significant impacts on
listed species, critical habitat, or special status species. Enlargement
of a facility or construction activities beyond previously disturbed
areas in areas that do not have presence or likelihood of listed
species, critical habitat or special status species would not have
significant impacts on these resources. 

Enlargement of a facility or construction activities beyond previously
disturbed areas in areas where listed species, critical habitat or
special status species are present may adversely affect these resources.
Activities that have the potential to adversely affect threatened and
endangered species would include the installation of security fencing,
in-ground vehicle barriers, small building additions, noise from
construction activities, and lighting. These activities may result in
the displacement or fragmentation of species habitat, disorientation of
species due to lighting, and abandonment of nests due to noise
disruptions. 

Land disturbance associated with this activity is expected to be less
than one (1) acre and FEMA will require grantees and subgrantees to
follow the general mitigation measures for ground disturbance activities
in Section 7.2. However, FEMA will not be able to determine whether the
impacts of the specific activity to the listed species, critical habitat
or special status species are significant without an appropriate
site-specific evaluation and consultation with FWS or NMFS. If
consultation results in a No Effect or Not Likely to Adversely Affect
(NLAA) determination, then the activity would not have significant
impacts on these resources and no additional NEPA review would be
required. If the consultation results in the initiation of formal
consultation, then FEMA will enter into the formal ESA Section 7
consultation and document the results in a site-specific SEA.

There may be situations where a special status species individual is
living near the site of a proposed project. FEMA will require grantees
and subgrantees to identify if a special status species is nearby and,
when it is nearby, will encourage grantees and subgrantees to design
their projects following existing guidelines for the protection of such
species.  In addition, FEMA will consult with FWS and/or appropriate
State, Tribe, or local government agency before the project is approved
to discuss measures needed to avoid impacts to these individuals.
Projects that incorporate measures to avoid impacts to these special
status individuals would not have significant impact on these resources.
If the proposed project cannot be designed to avoid impacts to these
special status individuals, then FEMA will document its impacts analysis
through REC or site-specific SEA, depending on the nature and magnitude
of the potential impacts. 

Human Health and Safety 

These types of projects are expected to have a beneficial impact on
human health and safety throughout the U.S. and its territories. 
Modifications of existing structures and facilities such as security
guard buildings, EOCs, stadiums, etc. reduces the risk of attacks and
assists agencies and communities in their response should an attack or
national disaster occur.  Updated equipment, especially first responder
medical and firefighting equipment, allows responding agencies to ensure
better care for victims and better protection for themselves.  Updated
security provides greater protection to personnel working in these
facilities, helping to minimize loss of life and facilitating continued
performance of personnel duties during an emergency event.  

The grantee or subgrantee is responsible for checking and complying with
the EPCRA and CFATS regulations.  Waste fuel and/or oil associated with
the new facilities must be disposed of according to Federal and State
regulations. Additionally, the above-ground fuel storage tanks for the
emergency generators would be located within berms to limit runoff and
infiltration should a spill or leak occur. FEMA will require grantees
and subgrantees to locate containers with a capacity to store more than
100 gallons of hazardous substances of an explosive or fire prone nature
at an acceptable separation distance from facilities or structures where
people can congregate such as schools or hospitals. Grantees and
subgrantees may use the HUD’s guidance “Siting of HUD-Assisted
Projects near Hazardous Facilities (HUD -1060-CPD, Sept. 1996),
incorporated in this PEA by reference. The grantee or subgrantee will be
responsible for meeting the “all appropriate inquiries” rule in 40
C.F.R. 312.10 before acquiring a new property. FEMA will require
grantees and subgrantees to prepare, implement, and regularly update
spill prevention and control plan when needed. The use, handling,
storage and disposal will be disposed of according to Federal, State or
Territory, and local regulations. Therefore, no significant long-term
impacts associated with hazardous waste/materials are anticipated from
the renovation, retrofitting, or operation of these facilities.         

Minority and Low Income Populations

Proposed projects that would involve modification of the interior of
existing structures and facilities are not likely to have
disproportionate high and adverse impacts on minority or low-income
populations. 

The impacts on minority or low-income populations for proposed projects
that involve the enlargement of a facility or construction activities
beyond previously disturbed areas would be those associated with ground
disturbance (e.g. localized air quality, stormwater pollution), traffic,
and noise. However, these impacts would affect all populations and would
not be disproportionally directed to minority or low-income populations.
FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2
which include practices to control these impacts. Proposed projects
implementing these measures would minimize impacts to all populations
and would not result in disproportionate high and adverse environmental
or health effects on minority or low-income populations. 

Historic Properties - Archeology

Proposed modification of existing structures and facilities would have
no effect on archeological resources because there would be no ground
disturbing activities.  

Expansion and other external construction-related activities, such as
trenching, in sites that have low probability for the presence of
archeological deposits or that have been previously surveyed and found
not to have archeological deposits would not have significant impacts on
these resources.

Expansion and other external construction-related activities in sites,
such as trenching, that have moderate to high probability for the
presence of archeological deposits may have adverse effects on these
resources. The presence of modern structures or facilities does not mean
that no archaeological resources exist or that they have been destroyed.
While existing structures may have disturbed potential archaeological
deposits at the time of construction, intact resources may have been
left undisturbed.  In addition, existing historic structures may also
have archaeological components and any landscaping or other activities
that disturb the ground could affect potential archaeological deposits.
Geographical location and physical characteristics of the site dictate
whether a proposed project will affect archaeological resources.  If
such activities are anticipated, then Section 106 consultation is
necessary to determine whether potential archaeological resources exist
and whether they would be adversely affected by the proposed project. If
the proposed project will have an adverse effect, FEMA must develop ways
to avoid, minimize, or mitigate adverse effects to the archaeological
resources in consultation with the SHPO or THPO and other interested
parties.

FEMA will consult with the SHPO/THPO, tribes and other sources to
determine the probability for the presence of archeological resources.
If the proposed project does not have the potential to adversely affect
archaeological resources, then there is no significant impact to this
resource and no further NEPA review would be required. If the proposed
project has the potential to adversely affect these resources, FEMA will
engage in the Section 106 process and document this process and the
resolution of adverse effects with a REC or site-specific SEA, depending
on the nature and magnitude of the potential impacts. . 

Historic Properties - Other Historic Properties

Proposed modification of existing structures and facilities that are not
considered historic properties would not have significant impacts on
these resources. 

Proposed modification of existing structures and facilities that are
considered historic properties or exterior work on structures and
facilities in the APE of an historic property may have adverse effects
on these resources. The critical infrastructure or key resources that
are the subject of GPD-funded projects may be objects, structures,
building, sites, or districts that are included in or eligible for
inclusion in the NRHP. A number of these historic properties may also be
NHLs. 

Activities under this project type that could have adverse effects on
historic properties include demolition, modification of historic
buildings and structures, ground disturbance, and activities with in the
APE of an identified historic property. Types of adverse effects may
include the loss of the historic property, abandonment of the historic
property, alteration of historic-defining features or components, and
viewshed impacts. 

FEMA will consult with the SHPO/THPO, tribes and other sources to
determine if the proposed project has the potential to adversely affect
historic properties. If the proposed project does not have the potential
to adversely affect historic properties, then there is no significant
impact to this resource and no further NEPA review would be required. If
the proposed project has the potential to adversely affect these
resources, FEMA will engage in the Section 106 process and document this
process and the resolution of adverse effects through a REC or
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Infrastructure 

Proposed modification of existing structures and facilities would not
have significant adverse impacts to infrastructure. These activities
would use existing infrastructure or would require minimum
infrastructure development. Expansion of facilities could result in
long-term changes in traffic flow in the area near the project site due
to the ingress and egress of workers.  However, these changes are not
considered a significant impact as roadway construction and traffic flow
patterns are completed according to Federal Highway Administration
(FHWA) and State Department of Transportation (DOT) protocols.
Construction may lead to a temporary increase in solid waste generation,
but this increase would be short-term and would not be expected to be
significant.

Air Quality 

Proposed modification of existing structures and facilities would not
have significant adverse impacts on air quality. Expansion and
construction-related actions, such as trenching and removal of
vegetation, that could result in an adverse impact on air quality are
generally associated with short-term emissions, principally from site
clearing activities and the use of construction equipment and related
vehicles.  FEMA does not expect that the construction nor demolition
activities would result in a violation of the GCR or cause PSD
deterioration. 

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to air quality.  FEMA will require a
site-specific SEA for those projects under this project type that are
more than one (1) acre or that would not implement applicable mitigation
measures in Section 7.2.

Older structures often contain lead-based paint or asbestos containing
materials.  Any activities associated with the demolition of facilities
must be done in accordance with Federal and State laws and regulations
regarding the handling and disposal of hazardous materials, such as
lead-based paint and asbestos containing materials.

Noise 

Proposed modification of existing structures and facilities will not
have significant adverse impacts on noise. FEMA will require grantees
and subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2, which includes equipment
operation during business hours (Monday through Friday from 7am to 5pm)
and using equipment with the manufacturer’s standard noise control
devices (e.g. mufflers, baffling, engine enclosures). In addition,
grantees and subgrantees will be required to comply with any State,
Territory, Tribal, or local noise control requirements. With these
measures the activity would not result in significant noise impacts.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Visual Quality 

Proposed modification of existing structures and facilities will not
have significant adverse aesthetic impacts. Any impacts that do occur
would be limited to the immediate vicinity of the project. Short-term
impacts would be expected due to the presence of heavy equipment, the
presence of debris and construction materials, and the disruption of the
site during construction. However, FEMA will require grantees and
subgrantees to implement the general mitigation measures for ground
disturbance activities in Section 7.2 and conduct site cleanup and
restoration following the completion of construction, which would limit
these impacts.

Climate Change

Proposed modification of existing structures and facilities would have
no significant impacts to climate change.  Increased emissions from
construction activities would be of a short duration and small scale. 
These project types would not result in changes in land use or
significant increases, if any, in energy requirements and fossil
fuel-burning activities.  

New Construction

Currently FEMA does not have a CATEX that covers new construction. As
described in Section 3.2.2.8, the activities covered under this project
type are new construction projects, including replacement of facilities,
of up to five (5) acres in previously undisturbed, disturbed, or
developed sites.  Examples of new construction include security guard
buildings, EOCs, and fire stations. FEMA will conduct site-specific
evaluation and document the applicability of this PEA and the
applicability of other environmental planning and historic preservation
requirements to the proposed project through a REC. A site-specific SEA
will be required for proposed projects with impacts that are not
adequately addressed in this PEA. 

New construction, including replacement, on previously developed or
disturbed sites

Land Use 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not result
in land use changes and would not have significant impacts on land use.
The grantee or subgrantee will be required to obtain all necessary
permits, including applicable construction permits, before initiating
work. Construction permits may include requirements for the construction
and operation of the facility to be in compliance with local zoning
ordinances or in compliance with any zoning variance granted. Any
changes in zoning must be coordinated at the local government level
before work begins and may require site-specific evaluation. 

FEMA is prohibited from providing assistance for new construction
activities, including replacements, in CBRS units. FEMA will require the
grantee or subgrantee to coordinate with the State Coastal Management
Agency to obtain a consistency determination when the proposed project
occurs within a State’s designated coastal zone. New construction in
previously developed areas or replacements of facilities are exempt from
the FPPA requirements. 

Geology and Soils 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas that are not in
areas characterized by susceptibility to seismic or volcanic activity,
tsunamis, landslides, mudslides, structural instability, excessive
erodibility, or steep slopes would not result in significant impacts
from geology and soils to the project.

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed sites in areas
characterized by the hazards described above will require the use of
certain engineering technologies or require consultation with State or
Federal agencies before the project may proceed. All structures in areas
of seismic risk that are covered by this PEA must be designed and
constructed in accordance with appropriate seismic design and
construction standards, which are promulgated through NEHRP.  Therefore,
the constructed buildings will represent a low seismic hazard to people
and equipment housed in the building during a seismic event.  

Land disturbance associated with this activity is expected to be less
than five (5) acres. FEMA will require grantees and subgrantees to
follow the general mitigation measures for ground disturbance activities
in Section 7.2.  Proposed projects implementing these measures will not
have significant impacts on geology and soils. FEMA will require a
site-specific SEA for those projects that would result in more than five
(5) acres of ground disturbance or that do not implement applicable
mitigation measures in Section 7.2.

Water Resources 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas are not expected
to have significant impacts to water resources or water quality. This
activity would not increase the amount of impervious surfaces at a given
location.  However, areas that have been disturbed by the removal of the
existing vegetation are much more susceptible to water erosion during
major precipitation events and to wind erosion during dry and windy
weather conditions.  Uncontrolled stormwater pollution, erosion and
sedimentation can result in the pollution of waters of the US (EPA
2007).  

Land disturbance associated with this activity is expected to be less
than five (5) acres. FEMA will require grantees and subgrantees to
follow the general mitigation measures for ground disturbance activities
in Section 7.2. Grantees and subgrantees are responsible for securing
any applicable NPDES permits and meeting permit conditions, which may
include developing a SWPPP for the construction activity. Proposed
projects that obtain and comply with the required NPDES permits and
SWPPP will not result in significant impacts to water resources or water
quality.  FEMA will require site-specific SEAs for projects that would
result in more than five (5) acres of ground disturbance or that do not
implement applicable mitigation measures in Section 7.2.

Floodplains 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas that are not
located within the 100-year floodplain (500-year floodplain for critical
actions) would not have significant impacts on floodplains.

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
impacts on floodplains but may be affected by the floodplain. Impacts to
the floodplain are not expected because these activities would occur
within the existing previously disturbed area. However, any new
facilities located in the floodplain may be exposed to flood hazards. 

Under 44 CFR Part 9, FEMA is required to avoid activities in a
floodplain unless it is the only practicable alternative. If undertaking
a proposed project in the floodplain is the only practicable
alternative, then FEMA must minimize the impacts to the floodplain and
the impacts from floods to the facility. Minimization techniques apply
to the location of structures, equipment and building contents in
floodplain areas. This could include elevating facilities or structures
above the base flood elevation. Minimization techniques may include
floodproofing structures or facilities. Some of these facilities may be
considered critical actions under this analysis because the risk of
flooding might be too great. In such cases, the base flood elevation or
standard for floodproofing is the 500-year flood event. In addition, if
structures are flood-insurable structures and the upgrade constitutes a
substantial improvement, FEMA will require the grantee to comply with
the local floodplain ordinance and obtain, if necessary, a local
floodplain permit. 

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. They also prohibit substantial improvements
in the floodway. 

If undertaking the proposed project in the floodplain is the only
practicable alternative, FEMA will document the 8-step decisionmaking
process and minimization measures through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Wetlands 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant impacts on wetlands. However, areas that have been disturbed
by the removal of the existing vegetation are much more susceptible to
water erosion during major precipitation events and to wind erosion
during dry and windy weather conditions.  Both types of erosion can
cause adverse impacts on wetlands located down gradient or down wind.
Grantees and subgrantees are responsible for securing any applicable
NPDES permits and meeting permit conditions, which may include
developing a SWPPP for the construction activity.  The SWPPP would
include practices to control soil erosion, sedimentation and water
pollution that may affect wetlands. Projects that obtain and comply with
the required NPDES permits and SWPPP will not result in significant
impacts to wetlands.

Biological Resources - Vegetation 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant impacts on vegetation. Areas that have been disturbed by the
removal of the existing vegetation are much more susceptible to water
erosion during major precipitation events and to wind erosion during dry
and windy weather conditions.  Both types of erosion can cause adverse
impacts on vegetation located down gradient or down wind, and on fish
and wildlife resources located in off-site areas.  FEMA will require
grantees and subgrantees to secure any applicable NPDES permits, which
may include developing a SWPPP for the construction activity. FEMA will
also require applicants to follow the mitigation measures in Section
7.2.  Projects that obtain and comply with the required NPDES permits
and SWPPP and follow these measures will not result in significant
impacts to vegetation.

With the implementation of these mitigation measures and the absence of
any special status species, new construction or replacement of a
structure or facility will not have a significant adverse impact on
local vegetation.  

If the project area is determined to contain or be located near a
sensitive vegetation community, FEMA will document its impact analysis
through an REC or site-specific SEA, depending on the nature and
magnitude of the potential impacts. 

Biological Resources - Terrestrial Wildlife 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant impacts on terrestrial wildlife. These areas have been
previously disturbed and the presence of terrestrial wildlife is not
likely. 

Biological Resources - Aquatic Wildlife 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant impacts on aquatic wildlife. These areas have been
previously disturbed and the presence of terrestrial wildlife is not
likely. An exception is coastal projects that would result in new
beachfront lighting near nesting grounds for sea turtles. Beachfront
lighting can disorient sea turtle hatchlings. Hatchlings find their way
to the sea by differentiating between dark and bright areas and overhead
artificial lights disrupts this ability (Salmon 2003). For proposed
coastal projects that would result in new lighting, FEMA will require
grantees and subgrantees to coordinate with the State natural resources
or coastal resources agency to determine if the project is likely to
affect sea turtle nesting patterns and, if it is, to design the project
in a manner to reduce these impacts. If the proposed project cannot be
redesigned to reduce these impacts, then FEMA will document the impacts
analysis through a REC or site-specific SEA, depending on the nature and
magnitude of the potential impacts.

Biological Resources - Listed Species, Critical Habitat, and Special
Status Species 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant impacts on threatened, endangered and special status species
or Federally designated critical habitat. These areas have been
previously disturbed and the presence of these resources is not likely. 

However, there may be situations where a special status species
individual is living in the vicinity of the proposed project site. FEMA
will require grantees and subgrantees to identify if a special status
species is nearby and, when it is nearby, will encourage grantees and
subgrantees to design their projects following existing guidelines for
the protection of such species. In addition, FEMA will consult with FWS
and/or appropriate State, Tribe, or local government agency before the
project is approved to discuss measures needed to avoid impacts to these
individuals. Proposed projects that incorporate measures to avoid
impacts to these special status individuals would not have a significant
impact on these resources. If the proposed project cannot be designed to
avoid impacts to these special status individuals, then FEMA will
document the impacts analysis through a REC or a site-specific SEA,
depending on the nature and magnitude of the potential impacts. 

Human Health and Safety 

These types of proposed projects are expected to have a beneficial
impact on human health and safety throughout the United States and its
territories.  The construction of new first responder and emergency
response facilities, as well as other structures to house homeland
security and emergency preparedness functions, reduces the risk of
attacks and assists agencies and communities in their response should a
disaster occur.  Updated security and response capacity provides greater
protection, helping to minimize loss of life and facilitating continued
performance of first responder personnel duties during an attack or
national disaster.  

Grantees and subgrantees are responsible for checking and complying with
the EPCRA and CFATS regulations, as appropriate, is the responsibility
of the grantee or subgrantee.  Waste fuel and/or oil associated with the
new facilities must be disposed of according to Federal and State
regulations. Additionally, the above-ground fuel storage tanks for the
emergency generators would be located within berms to limit runoff and
infiltration should a spill or leak occur. FEMA will require grantees
and subgrantees to locate containers with a capacity to store more than
100 gallons of hazardous substances of an explosive or fire prone nature
at an acceptable separation distance from facilities or structures where
people can congregate such as schools or hospitals. Grantees and
subgrantees may use the HUD’s guidance “Siting of HUD-Assisted
Projects near Hazardous Facilities (HUD -1060-CPD, Sept. 1996),
incorporated in this PEA by reference. The grantee or subgrantee will be
responsible for meeting the “all appropriate inquiries” rule in 40
C.F.R. 312.10 before acquiring a new property. Grantees and subgrantees
are responsible for preparing, implementing, and regularly updating
spill prevention and control plan when needed. The use, handling,
storage and disposal will be disposed of according to Federal, State or
Territory, and local regulations. Therefore, no significant long-term
impacts associated with hazardous waste/materials are anticipated from
the renovation, retrofitting, or operation of these facilities.         

Minority and Low-income Populations

The impacts on minority or low-income populations for proposed new
construction projects in previously developed or disturbed areas include
those associated with ground disturbance (e.g. localized air quality,
stormwater pollution), traffic, and noise. However, these impacts would
affect all populations and would not be disproportionally directed to
minority or low-income populations. FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2 which include practices to control
these impacts. 

Some proposed new construction projects may involve the placement of
facilities that may be of concern (e.g. hazardous materials storage
sites) near minority or low-income populations. Grantees are responsible
for adequate planning and community outreach for these projects before
they are submitted to FEMA. For proposed projects of concern, FEMA will
require evidence from grantees and subgrantees of community outreach
efforts. 

The replacement or relocation of fire stations and other operation
centers may result in the indirect effect of abandonment of a station or
operation center that served an area with predominant low-income or
minority populations. Grantees or subgrantees are responsible for
adequate planning of these activities to ensure that service times and
areas are not affected in a manner that results in a high
disproportionate and adverse indirect impacts on these populations. For
these proposed projects, FEMA will require evidence from grantees and
subgrantees of community outreach efforts.

With appropriate planning, community outreach, and implementation of the
mitigation measures, these projects are not anticipated to have a
significant impact on minority or low-income populations.  FEMA will
require a site-specific SEA if it finds that there are disproportionate
high and adverse impacts to minority and/or low-income populations from
the particular project.

Historic Properties - Archeology 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant impact on these resources if those sites have low
probability for the presence of archeological deposits or have been
previously surveyed and found not to have archeological deposits.

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas that have moderate
to high probability for the presence of archeological deposits may have
adverse effects on these resources. The presence of modern structures or
facilities does not mean that no archeological resources exist or that
they have already been destroyed. While existing structures may have
disturbed potential archeological deposits at the time of construction,
intact resources may have been left undisturbed.  In addition, existing
historic structures may also have archeological components and any
landscaping or other activities that disturb the ground could affect
potential archeological deposits. Geographical location and physical
characteristics of the site dictate whether a proposed project will
affect archeological resources.  If such activities are anticipated,
Section 106 consultation is necessary to determine whether potential
archeological resources exist and whether they would be adversely
affected by the proposed project. If the proposed project will have an
adverse effect, FEMA must develop ways to avoid, minimize, or mitigate
adverse effects to the archeological resources in consultation with the
SHPO or THPO and other interested parties.

FEMA will consult with the SHPO/THPO, tribes and other sources to
determine the probability for the presence of archeological resources.
If the proposed project does not have the potential to adversely affect
these resources, then there is no significant impact to this resource
and no further NEPA review would be required. If the proposed project
has the potential to adversely affect these resources, FEMA will engage
in the Section 106 process and document this process and the resolution
of adverse effects through a REC or a site-specific SEA, depending on
the nature and magnitude of the potential impacts.

Historic Properties - Other Historic Properties 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas that do not affect
historic properties would not have significant impacts on these
resources. 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas that affect
historic properties may have significant impacts these resources. The
critical infrastructure or key resources that are the subject of these
proposed projects may be objects, structures, building, sites, or
districts that are included in or eligible for inclusion in the NRHP. A
number of these historic properties may also be NHLs. 

Proposed activities under this project type that could have adverse
effects on historic properties include the demolition, facilities’
modifications, ground disturbance, and the placement of new facilities
or structures within the APE of an identified historic property. Types
of adverse effects may include the loss the historic property,
abandonment of the historic property, alteration of historic defining
features or components, displacement or relocation of a historic
property, and viewshed impacts. 

FEMA will consult with the SHPO/THPO, tribes and other sources to
determine if the proposed project has the potential to adversely affect
historic properties. If the proposed project does not have the potential
to adversely affect historic properties, then there is no significant
impact to this resource and no further NEPA review would be required. If
the proposed undertaking has the potential to adversely affect these
resources, FEMA will engage in the Section 106 process and document this
process and the resolution of adverse effects through a REC or
site-specific REC, depending on the nature and magnitude of the
potential impacts. 

Infrastructure 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant adverse impacts on infrastructure. New construction would
use existing infrastructure or would require minimum infrastructure
development. Construction of new facilities could result in long-term
changes in traffic flow in the area near the site due to the ingress and
egress of workers, regardless of whether the site was previously
developed.  However, these changes are not considered a significant
impact as roadway construction and traffic flow patterns are completed
according to FHWA and local Department of Transportation (DOT)
protocols. Construction may lead to a temporary increase in solid waste
generation, but this increase would be short-term and would not be
expected to be significant.

The construction of new facilities will enhance the protection of CI/KR
at the local, State, Territory, Tribal, and national level, resulting in
a beneficial impacts to infrastructure.  

Air Quality 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant adverse impacts on air quality. Construction-related
activities that could result in an adverse impact on air quality are
generally associated with short-term emissions, principally from site
clearing activities and the use of construction equipment and vehicles. 
FEMA does not expect construction or demolition activities to result in
a violation of the GCR or cause PSD deterioration. Operation of the new
facilities would not have significant impact on the local or regional
air quality.  In general, operation of new or replaced facilities would
not result in a new major source and does not result in a violation of
the GCR or cause PSD deterioration.  

Land disturbance associated with this activity is expected to be less
than five (5) acres. FEMA will require grantees and subgrantees to
follow the general mitigation measures for ground disturbance activities
in Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to air quality.   FEMA will require
site-specific SEA for projects under this project type of more than five
(5) acres of ground disturbance or that do not implement applicable
measures in Section 7.2.

Older structures often contain lead-based paint or asbestos containing
materials.  Any activities associated with the demolition of facilities
must be done in accordance with Federal and State laws and regulations
regarding the handling and disposal of hazardous materials, such as
lead-based paint and asbestos containing materials.

Noise 

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have
significant adverse impacts from noise. FEMA will require grantees and
subgrantees to follow, the general mitigation measures for ground
disturbance activities in Section 7.2, which includes operation during
business hours (Monday thru Friday from 7am to 5pm) and the use
equipment using the manufacturer’s standard noise control devices
(i.e. mufflers, baffling, and/or engine enclosures). In addition,
grantees and subgrantees will be required to comply with any State,
Territory, Tribal, or local noise control requirements. With these
measures the proposed project would not result in significant noise
impacts.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Visual Quality

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas may have adverse
aesthetic impacts both short-term during the construction period and
long-term during operation of the new facility. Short-term impacts would
be expected due to the presence of heavy equipment, the presence of
debris and construction materials, and the disruption of the site during
construction. However, FEMA will require grantees and subgrantees to
implement the general mitigation measures for ground disturbance
activities in Section 7.2 which would limit these impacts. Long-term
aesthetic impacts would be limited to the immediate vicinity of the
project. FEMA will require grantees and subgrantees to take prudent
measures, such as maintaining existing stands of trees and revegetating
with native plants where possible, to minimize long-term impacts. In
addition, the design and building materials used for new structures and
facilities may be selected to be compatible with the surrounding
existing architecture, which would help minimize impacts.

Climate Change

Proposed new construction, including replacements, of structures or
facilities in previously developed or disturbed areas would not have a
significant impact on climate change.  Increased emissions from
construction activities would be of short duration and a limited scale. 
While land use would be altered at the site and there would be an
increase in energy usage to provide power to the facility, the scale at
which these changes would occur would not be significant.  

New construction on undeveloped or undisturbed sites

Land Use 

Proposed new construction projects on undeveloped or undisturbed sites
that are consistent with existing land use/ zoning designations, are not
in CBRS units, are consistent with a State’s coastal management plan,
and do not affect important farmlands would not have significant impacts
on land use. 

Some proposed new construction projects on undeveloped or undisturbed
sites may involve land use/zoning changes. Construction of a new
facility may require a change in land use or zoning, depending on the
location chosen for construction. Any proposed projects involving
structural changes to the existing facility require a construction
permit from local authorities prior to construction.  Conditions of the
permit normally specify that the proposed facility be constructed and
operated in compliance with local zoning ordinances, or that a zoning
variance be obtained. The grantee or subgrantee is responsible for
obtaining the necessary construction permits.

FEMA is prohibited from providing assistance for new construction
activities in CBRS units. FEMA will require the grantee or subgrantee to
coordinate with the State Coastal Management Agency to obtain a
consistency determination when the propose project occurs within a
State’s designated coastal zone. 

If a proposed new construction project will convert prime and unique
farmland to non-agricultural use, FEMA will conduct the required
assessment (Form AD-1006) and consult with NRCS when necessary. If the
Form AD-1006 indicates that the proposed project will score more than
160 points, then FEMA will document this finding in either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Geology and Soils

Proposed new construction projects on undeveloped or undisturbed sites
that are not in areas characterized by susceptibility to seismic or
volcanic activity, tsunamis, landslides, mudslides, structural
instability, excessive erodibility, or steep slopes would not result
significant impacts from geology and soils to the project.

Proposed new construction projects on undeveloped or undisturbed sites
that are in areas characterized by the hazards identified above will
require the use of certain engineering technologies or require
consultation with State or Federal agencies before the project may
proceed. All structures in areas of seismic risk that are covered by
this PEA must be designed and constructed in accordance with appropriate
seismic design and construction standards, which are promulgated through
NEHRP.  Therefore, the constructed buildings will represent a low
seismic hazard to people and equipment housed in the building during a
seismic event.  

In addition, proposed new construction projects on undeveloped or
undisturbed sites may have adverse effects to soils. Inadequate
stabilization of the site may produce uncontrolled erosion that may
result in the loss of topsoil, reduction of infiltration capacity,
alteration of natural hydrology of the land, increase in flood risks,
and adverse impacts to nearby habitat (EPA 2007). Land disturbance
associated with this activity is expected to be less than five (5)
acres. FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2.
Proposed projects that implement these measures will not result in
significant impacts to geology and soils.  FEMA will require a
site-specific SEA for projects under this project type that would result
in more than five (5) acres of ground disturbance or that do not
implement applicable measures in Section 7.2.

Water Resources

Proposed new construction projects on undeveloped or undisturbed sites
may adversely affect water resources and quality in the project area.
Uncontrolled stormwater pollution, erosion and sedimentation can result
in the pollution of waters of the U.S. (EPA 2007). Table 5-2 shows the
most common water pollutants associated with construction activities.

Land disturbance associated with this activity is expected to be less
than five (5) acres. Grantees and subgrantees are responsible for
securing any applicable NPDES permits and meeting permit conditions,
which may include developing a SWPP for the proposed construction
project.

If proposed new construction projects involve the filling of waters of
the U.S., FEMA will require the grantee or subgrantee to coordinate with
the USACE to obtain a Section 10 permit if the water is navigable or a
Section 404 Nationwide, Regional General, or Individual permit for
non-navigable waters before the project starts. Proposed projects that
would require an Individual Permit will require close coordination
between the grantee or subgrantee, FEMA and USACE. This process may
include the development of a site-specific SEA or the start of the EIS
process.

If a proposed new construction project occurs in the vicinity of a wild
or scenic river, FEMA will coordinate with the appropriate agency.  If
the project affects a wild or scenic river, then FEMA will engage in a
site-specific SEA to appropriately evaluate the potential for
significant impacts to this resource.

Proposed new construction projects that comply with the required NPDES
permits, comply with applicable Nationwide or General permits under
Section 404 and Section 10, and do not affect wild or scenic rivers will
not result in significant impacts to water resources and water quality. 

Floodplains

Proposed new construction projects on undeveloped or undisturbed sites
that are not located within the 100-year floodplain (500-year floodplain
for critical actions) would not have significant impacts on floodplains.

Under 44 CFR Part 9, FEMA is required to avoid activities in a
floodplain unless it is the only practicable alternative. If undertaking
a project in the floodplain is the only practicable alternative, FEMA
must minimize the impacts to the floodplain and the impacts from floods
to the new structure or facility. Minimization techniques apply to the
location of structures, equipment and building contents in floodplain
areas. This could include elevating facilities or structures above the
base flood elevation. Minimization techniques may include floodproofing
structures or facilities. Some of these facilities may be considered
critical actions under this analysis because the risk of flooding might
be too great. In such cases, the base flood elevation or standard for
floodproofing is the 500-year flood event. In addition, if structures
are flood-insurable structures and the upgrade constitutes a substantial
improvement, FEMA will require the grantee to comply with the local
floodplain ordinance and obtain, if necessary, a local floodplain
permit. 

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. They also prohibit substantial improvements
in the floodway. 

If undertaking the proposed project in the floodplain is the only
practicable alternative, FEMA will document the 8-step decisionmaking
process and minimization measures through a REC or a site-specific SEA,
depending on the nature and magnitude of the potential impacts to or
from the floodplain. 

Wetlands

Proposed new construction projects on undeveloped or undisturbed sites
that are not located within or would otherwise affect wetlands would not
have significant impacts on wetlands.

Some proposed new construction projects on undeveloped or undisturbed
sites may have adverse impacts to wetlands. Activities outside of
wetland areas but near wetlands may result in uncontrolled stormwater
pollution, erosion and sedimentation that may adversely affect these
nearby wetlands. Minimization measures include avoidance techniques such
as establishing wetland buffer zones and obtaining and complying with
NPDES permits and SWPPP measures would reduce the potential adverse
impacts of these proposed projects to nearby wetlands.

Some proposed new construction projects may take place within wetland
areas. Under 44 CFR Part 9, FEMA is required to engage in an 8-step
decisionmaking process for projects that may have adverse impacts on
wetlands, which includes the use of minimization techniques when the
project affecting the wetland is the only practicable alternative.
Minimization measures include avoidance techniques such as establishing
wetland buffer zones to avoid converting or filling wetlands.
Compensation measures include such wetland mitigation and wetlands
banking. In addition to FEMA’s responsibility under 44 CFR Part 9, the
grantee or subgrantee must obtain the applicable CWA Section 404 permit
prior to the initiation of the project if it will affect wetlands that
are considered waters of the U.S. by the USACE. The grantee or
subgrantee must coordinate with USACE to determine whether any of the
NWPs or a Regional General Permit apply or whether an Individual Permit
is required. Proposed projects that would require an Individual Permit
will require close coordination between the grantee or subgrantee, FEMA
and USACE.  This process may include the development of a site-specific
SEA or the start of the EIS process.

If the proposed project cannot be designed to avoid impacts to the
wetland, FEMA will document the 8-step decisionmaking process and
minimization measures in a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts to the wetlands. 

Biological Resources - Vegetation 

Proposed new construction projects on undeveloped or undisturbed sites
may have adverse impacts to vegetation. Areas that have been disturbed
by the removal of the existing vegetation are much more susceptible to
water erosion during major precipitation events and to wind erosion
during dry and windy weather conditions.  Both types of erosion can
cause adverse impacts on vegetation located down gradient or down wind,
and on fish and wildlife resources located in off-site areas.  Grantees
and subgrantees are responsible for securing any applicable NPDES
permits, which may include developing a SWPPP for the construction
activity. FEMA will also require grantees and subgrantees to follow the
mitigation measures in Section 7.2. Proposed projects that obtain and
comply with the required NPDES permits and SWPPP and implement these
mitigation measures will not result in significant impacts to
vegetation.   

With the implementation of these mitigation measures and the absence of
any special status species, new construction or replacement of a
structure or facility would not have a significant adverse impact on
local vegetation.  FEMA will require a site-specific SEA for projects
under this project type that would result in more than five (5) acres of
ground disturbance or that do not implement applicable measures in
Section 7.2.

If the project area is determined to contain or be located near a
sensitive vegetation community, FEMA will document the impact analysis
through an REC or site-specific SEA, depending on the nature and
magnitude of the potential impacts.

Biological Resources - Terrestrial Wildlife 

Proposed new construction projects on undeveloped or undisturbed sites
may have adverse impacts to terrestrial wildlife and/or their habitat.
Operational impacts include long-term loss of habitat and direct impacts
on terrestrial wildlife species.

Impacts on habitat are generally limited to new construction within an
undisturbed area. Construction-related noise and other disturbance can
affect wildlife population usage in areas surrounding the project site. 
This is especially true during sensitive periods of the species’ life
cycle.

FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2.
Projects that implement these measures will not result in significant
impacts to terrestrial wildlife.  FEMA will require site-specific SEA
for projects under this project type that would result in more than five
(5) acres of ground disturbance or would not implement applicable
measures in Section 7.2.

Biological Resources - Aquatic Wildlife 

New construction projects on undeveloped or undisturbed sites that are
not located within or affect the 100-year floodplain, wetlands, or
coastal areas would not have significant impacts on aquatic life.

Proposed projects within floodplains or affecting floodplains, wetlands,
or coastal areas may have adverse impacts to aquatic wildlife and/or
their habitat. FEMA would avoid taking actions within or affecting
floodplains or wetlands. If undertaking the project within the
floodplain or wetland is the only practicable alternative, FEMA will
document the 8-step decisionmaking process and minimization measures
through a REC or a site-specific SEA, depending on the nature and
magnitude of the potential impacts. 

Proposed coastal projects that would result in new beachfront lighting
near nesting grounds for sea turtles may adversely affect these
resources. Beachfront lighting can disorient sea turtle hatchlings.
Hatchlings find their way to the sea by differentiating between dark and
bright areas and overhead artificial lights disrupts this ability
(Salmon 2003). For proposed coastal projects that would result in new
lighting, FEMA will require grantees and subgrantees to coordinate with
the State natural resources or coastal resources agency to determine if
the project is likely to affect sea turtle nesting patterns and, if it
is, to design the project in a manner to reduce these impacts. If the
project cannot be redesigned to reduce these impacts, then FEMA will
document the impact analysis through a REC or a site-specific SEA,
depending on the nature and magnitude of the potential impacts
identified. 

Biological Resources – Listed Species, Critical Habitat, and Special
Status Species 

Proposed new construction projects on undeveloped or undisturbed sites
would affect threatened, endangered, and special status species in the
same manner that vegetation and wildlife would be affected.  The
threatened and endangered species that could be affected would depend on
the physiographic region in which the proposed project is located and
the nature and extent of the habitats present at the project site and
surrounding areas. Construction-related activities may adversely affect
threatened and endangered species by potentially reducing, altering, or
fragmenting available habitat; introducing invasive species; causing
injury or mortality to wildlife; noise; and behavioral impacts.

Land disturbance associated with this activity is expected to be less
than five (5) acres and FEMA will require grantees and subgrantees to
follow the general mitigation measures for ground disturbance activities
in Section 7.2. However, FEMA will not be able to determine whether the
impacts of the specific activity to the listed species, critical habitat
or special status species are significant without an appropriate
site-specific evaluation and consultation with FWS or NMFS. If
consultation results in a No Effect or Not Likely to Adversely Affect
(NLAA) determination, the activity would not have significant impacts on
these resources and no additional NEPA review would be required. If the
consultation results in the initiation of formal consultation, FEMA will
enter into the formal ESA Section 7 consultation and document the
results in a site-specific SEA.

In addition, there may be situations where a special status species
individual is living in the vicinity of a proposed project. FEMA will
require grantees and subgrantees to identify if a special status species
is nearby and, when it is nearby, will encourage grantees and
subgrantees to design their projects following existing guidelines for
the protection of such species. In addition, FEMA will consult with FWS
and/or appropriate State, Tribe, or local government agency before the
project is approved to discuss measures needed to avoid impacts to these
individuals. Projects that incorporate measures to avoid impacts to
these special status individuals would not have significant impact on
these resources. If the project cannot be designed to avoid impacts to
these special status individuals, then FEMA will document the impact
analysis through a REC or a site-specific SEA, depending on the nature
and magnitude of the potential impacts identified..

Human Health and Safety 

Proposed new construction projects are expected to have a beneficial
impact on human health and safety throughout the U.S. and its
territories.  The construction of new first responder and emergency
response facilities, as well as other structures to house homeland
security functions, reduces the risk of attacks and assists agencies and
communities in their response should a disaster occur.  Updated security
and response capacity provides greater protection, helping to minimize
loss of life and facilitating continued performance of first responder
personnel duties during an attack or national disaster.  

Grantees and subgrantees are responsible for checking and complying with
the EPCRA and CFATS regulations, as appropriate. Waste fuel and/or oil
associated with the new facilities must be disposed of according to
Federal and State regulations. Additionally, the above-ground fuel
storage tanks for the emergency generators would be located within berms
to limit runoff and infiltration should a spill or leak occur. FEMA will
require grantees and subgrantees to locate containers with a capacity to
store more than 100 gallons of hazardous substances of an explosive or
fire prone nature at an acceptable separation distance from facilities
or structures where people may congregate such as schools or hospitals.
Grantees and subgrantees may use the HUD’s guidance “Siting of
HUD-Assisted Projects near Hazardous Facilities (HUD -1060-CPD, Sept.
1996), incorporated in this PEA by reference. The grantee or subgrantee
will be responsible for meeting the “all appropriate inquiries” rule
in 40 C.F.R. 312.10 before acquiring a new property. Grantees and
subgrantees are responsible for preparing, implementing, and regularly
updating spill prevention and control plan for proposed projects when
needed. The use, handling, storage and disposal will be disposed of
according to Federal, State or Territory, and local regulations. 

Minority and Low-income Populations

The impacts on minority or low-income populations of proposed new
construction projects on undeveloped or undisturbed sites would be those
associated with ground disturbance (e.g. localized air quality,
stormwater pollution), traffic, and noise. However, these impacts would
affect all populations and would not be disproportionally directed to
minority or low-income populations. FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2 which include practices to control
these impacts. 

Some proposed new construction projects may involve the placement of
facilities that may be of concern (e.g. hazardous materials storage
sites) near minority or low-income populations. Grantees and subgrantees
are responsible for adequate planning and community outreach for these
projects before they are submitted to FEMA. For projects of concern,
FEMA will require evidence from grantees and subgrantees of community
outreach efforts.

The replacement or relocation of fire stations and other operation
centers may result in the indirect effect of abandonment of a station or
operation center that served an area with predominant low-income or
minority populations. Grantees and subgrantees are responsible for
adequate planning of these activities to ensure that service times and
areas are not affected in a manner that results in a high
disproportionate and adverse indirect impacts on these populations. For
these proposed projects, FEMA will require evidence from grantees and
subgrantees of community outreach efforts.

With appropriate planning, community outreach, and implementation of the
mitigation measures, these proposed projects are not anticipated to have
a significant impact on minority or low-income populations.  If FEMA
finds disproportionate high and adverse impacts to minority and/or
low-income populations, a site-specific SEA will be required.

Historic Properties - Archeology

Proposed new construction projects on undeveloped or undisturbed sites
would not have significant impact on archeological resources if those
sites have low probability for the presence of archeological deposits or
have been previously surveyed and found not to have archeological
deposits.

Proposed new construction projects on undeveloped or undisturbed sites
that have moderate to high probability for the presence of archeological
deposits may have adverse effects on these resources. Geographical
location and physical characteristics of the site dictate whether an
undertaking will affect archeological resources.  If such activities are
anticipated, Section 106 consultation is necessary to determine whether
potential archeological resources exist and whether they would be
adversely affected by the proposed project. If the proposed project will
have an adverse effect, FEMA must develop ways to avoid, minimize, or
mitigate adverse effects to the archeological resources in consultation
with the SHPO or THPO and other interested parties.

FEMA will consult with the SHPO/THPO, tribes and other sources to
determine the probability for the presence of archeological resources.
If the proposed project does not have the potential to adversely affect
these resources, then there is no significant impact to this resource
and no further NEPA review would be required. If the proposed project
has the potential to adversely affect these resources, FEMA will engage
in the Section 106 process and document this process and the resolution
of adverse effects through a REC or a site-specific SEA, depending on
the nature and magnitude of the potential impacts. 

Historic Properties - Other Historic Properties 

Proposed new construction projects on undeveloped or undisturbed sites
that do not affect historic properties would not have significant
impacts on these resources. 

Some proposed new construction projects may adversely affect historic
properties, such as through the placement of new facilities or
structures within the APE of an identified historic property or historic
district. 

FEMA will consult with the SHPO/THPO, tribes and other sources to
determine if the proposed project has the potential to adversely affect
historic properties. If the proposed project does not have the potential
to adversely affect historic properties, then there is no significant
impact to this resource and no further NEPA review will be required. If
the proposed project has the potential to adversely affect these
resources, FEMA will engage in the Section 106 process and document this
process and the resolution of adverse effects through a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Infrastructure 

Proposed new construction projects on undeveloped or undisturbed sites
may have an adverse impact on infrastructure. New construction projects
could result in long-term changes in traffic flow in the area near the
site due to the ingress and egress of workers.. However, these changes
are not considered a significant impact as roadway construction and
traffic flow patterns are completed according to FHWA and State DOT
protocols. Construction activities may lead to a temporary increase in
solid waste generation, but this increase would be short-term and would
not be expected to be significant.  Proposed projects may increase
demand on local utilities, such as electricity, sewer, and water
service, but that increase is not expected to be significant.  

The construction of new facilities will enhance the protection of CI/KR
at the local, State, Territory, Tribal, and national level, resulting in
a beneficial impacts to infrastructure.

Air Quality 

Proposed new construction projects may have adverse impacts on air
quality. Construction-related activities that could result in an adverse
impact on air quality are generally associated with short-term
emissions, principally from site clearing activities and the use of
construction equipment and vehicles.  FEMA does not expect that the
construction nor demolition activities would result in a violation of
the GCR or cause PSD deterioration. Operation of the new facilities
would not have significant impact on the local or regional air quality. 
In general, operation of new or replaced facilities would not result in
a new major source and does not result in a violation of the GCR or
cause PSD deterioration.  

Land disturbance associated with this activity is expected to be less
than five (5) acres. FEMA will require grantees and subgrantees to
follow the general mitigation measures for ground disturbance activities
in Section 7.2. Projects that implement these measures will not result
in significant impacts to air quality.  FEMA will require a
site-specific SEA for projects under this project type that would result
in more than five (5) acres of ground disturbance or do not implement
applicable measures in Section 7.2.

Noise 

Proposed new construction projects on undeveloped or undisturbed sites
may have noise-related adverse impacts. FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2, which includes operation of
equipment during business hours (Monday through Friday from 7am to 5pm)
and the use of manufacturers’ standard noise control devices (e.g.
mufflers, baffling, engine enclosures). In addition, grantees and
subgrantees will be required to comply with any State, Territory, Tribal
or local noise control requirements. With these measures the activity
would not result in significant impacts from noise.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts. 

Visual Quality

Proposed new construction projects on undeveloped or undisturbed sites
may have adverse aesthetic impacts, both short-term during the
construction period and long-term during operation of the new facility.
Short-term impacts would be expected due to the presence of heavy
equipment, the presence of debris and construction materials, and the
disruption of the site during construction. However, FEMA will require
grantees and subgrantees to implement the general mitigation measures
for ground disturbance activities in Section 7.2, which would limit
these impacts. Long-term aesthetic impacts would be limited to the
immediate vicinity of the project. FEMA will require grantees and
subgrantees to take prudent measures, such as maintaining existing
stands of trees and revegetating with native plants where possible, to
minimize long-term impacts.

Climate Change

Proposed new construction projects on previously undisturbed sites would
not have a significant impact on climate change.  Increased emissions
from construction activities would be of short duration and a limited
scale.  While land use would be altered at the site and there would be
an increase in energy usage to provide power to the facility, the scale
at which these changes would occur would not be significant due to the
typical nature of the types of projects that GPD funds.  



Cumulative Impacts 

The CEQ regulations implementing NEPA define cumulative impacts as the
“impact on the environment which results from the incremental impact
of the action when added to other past, present, and reasonably
foreseeable future actions, regardless of what agency (Federal or
non-Federal) or person undertakes such other actions.  Cumulative
impacts can result from individually minor but collectively significant
actions taking place over a period of time” (40 CFR 1508.7).

Alternative 1: No Action

Under the No Action Alternative, cumulative impacts would result in
persistent vulnerabilities and the continued compromised ability of
first responders as well as local, State, Territory, and National
governments to prepare for and respond to national security emergencies.
 

Alternative 2: Program Implementation

Programs

Implementation of GPD programs would result in beneficial cumulative
impacts on human health and safety. Financial assistance being provided
by GPD to State, Territory, local, and Tribal governments and
private-sector and non-governmental first responders may be used to
implement projects throughout the United States, its six territories,
and two Pacific island countries (FSM and RMI).  This assistance is
provided to enhance the capabilities of grantees and subgrantees to
prevent and respond to national emergencies, including acts of
terrorism.  The cumulative effect of the enhanced capability resulting
from the grant programs coupled with existing and on-going security
activities will greatly elevate the level of local, State, and national
security within the United States, its six territories, FSM, and RMI. 
These cumulative beneficial impacts on the human health and
safety/security of our country are associated with:

Increase in staff of affected governmental agencies

Accelerated training of existing and new personnel

Purchase of new and/or improved security and communication equipment

Improvement of communication of first responders within and between all
levels (Federal, State, and local) of governmental agencies

Improved security at major public gathering areas

Improved safety of security and law enforcement personnel

Expanded medical resources (facilities, equipment, and supplies) for
responding to emergency conditions that could have large numbers of
victims.

Projects

FEMA’s experience with similar types of projects addressed in this PEA
is that they would have minimal adverse cumulative impacts given the
relatively small amount of land that will be physically affected by the
proposed projects. However, project-specific information will be needed
for the following projects to appropriately take into consideration the
potential for cumulative impacts:

Construction of new communication towers and supporting facilities,

Modification of existing structures and facilities,

New construction.

FEMA will take cumulative impacts into account when evaluating whether
the particular action fits within this PEA. If the potential for
cumulative impacts is present FEMA, will document this in a REC or a
site-specific SEA.

Two particular areas deserve further discussion given their potential
for nationwide cumulative impacts: impacts of communication towers to
migratory birds and impacts of construction activities on climate
change.  

Migratory Birds and Communication Towers

FEMA recognizes that there are other Federal, State, Tribal and
Territory public safety interoperability-related actions such as the
FCC’s public safety initiatives, NTIA’s PSIC Grant Program, and the
USDA Rural Development’s Rural Utilities Service programs. These
programs are part of a nationwide effort to improve interoperability
within the emergency preparedness and response community. Grantees and
subgrantees have the ability to leverage these different programs within
their jurisdictions to achieve their overall public safety
interoperability goals. 

The combination of new public safety communication towers that do not
follow the FWS guidelines with other communication towers, such as
private cell towers, that do not follow these guidelines could have
measurable impacts on migratory birds. However, information on the level
of significance of these cumulative impacts on migratory birds, such as
number of migratory bird collisions and deaths caused by towers and the
percentage of these that are associated with public safety towers, is
currently unavailable. To address this unavailable information FEMA will
collect information regarding migratory bird fatalities in towers funded
by the agency. FEMA will require grantees and subgrantees to report for
up to five (5) years the number of bird collisions and deaths caused by
the towers. In turn FEMA will report to FWS on this information. 

Construction Actions and Climate Change

A recent study by the EPA indicates that the construction sector, which
is engaged in the preparation of land and the construction, alteration,
and repair of facilities and structures, is a substantial contributor of
the nation’s GHG emissions. The study established that the
construction industry produces approximately 1.7% of the total GHG
emissions in the U.S. and roughly 6% of the U.S. industrial-related GHG
emissions (EPA 2009). The reason for this proportion is due to the sheer
number of construction activities occurring in the U.S. simultaneously. 

The number of GPD-funded construction-related projects in a given year
is expected to be limited. The majority of GPD funds are used for
planning activities, management and administration activities, purchase
of portable or mobile equipment, training, and exercises. However, FEMA
will require grantees and subgrantess to observe the following practices
to reduce the amount of potential GHG emissions in the construction
related activities associated with communication towers and supporting
facilities, facilities modifications, and new construction:

Reduce construction equipment idling to the maximum extent practicable;

Ensure adequate maintenance of equipment, including proper engine
maintenance, adequate tire inflation, and proper maintenance of
pollution control devices;

To the extent possible, adopt other feasible measures under the EPA
guidance Potential for Reducing Greenhouse Gas Emissions in the
Construction Sector.

Mitigation

FEMA will encourage grantees and subgrantees to take the following
measures into account to the extent practicable and applicable to avoid
or minimize impacts to the quality of the human environment. If grantees
or subgrantees cannot avoid or minimize the impacts, an SEA may be
required. The general mitigation measures outlined in this section may
be superseded by higher or more stringent standards required by the
particular Federal, State or Territory, Tribe, or local government
agency issuing a permit, license, or approval for the project.
Additional project-specific mitigation measures may be imposed as a
condition of project approval/grant award for those projects covered by
a CATEX that trigger extraordinary circumstances or those projects for
which a site-specific SEA will be prepared. 

Measures to avoid impacts to the human environment

Avoid taking actions that modify existing land use patterns;

Avoid undertaking projects in areas characterized by susceptibility to
seismic or volcanic activity, tsunamis, landslides, mudslides,
structural instability, excessive erodibility, or steep slopes;

Avoid undertaking projects in the floodplain;

Avoid undertaking projects on important farmlands;

Avoid undertaking projects on or near TCPs;

Avoid undertaking projects in wetlands;

Avoid undertaking projects that adversely affect historic properties;

Avoid undertaking projects that adversely affect threatened and
endangered or special status species or critical habitat. 

Minimization Measures for ground disturbing/ construction activities of
up to five (5) acres

Follow applicable State, Territory, Tribal, and local permitting
requirements for construction; 

Water down construction site two to three times per day if dust
emissions become a problem;

Enclose or water down exposed dirt storage piles;  

Minimize the disturbed area and preserve vegetation to the maximum
extent possible;

Maintain topsoil whenever possible;

Phase construction activities to the extent possible;

Control stormwater flowing to and through the project site;

Protect slopes by using measures such as erosion control blankets,
bonded fiber matrices, turf reinforcement mats, silt fences (for
moderate slopes), etc.;

Temporarily protect storm drain inlets until site is stabilized;

Retain sediment on-site and control dewatering practices by using
sediment traps or basins for large areas (> 1 acre) when appropriate;

Establish stabilized construction entrances/exits (e.g. large crushed
rocks, stone pads, steel wash racks, hose-down systems, pads);

Limit construction activities, including operation of heavy machinery,
to normal business hours (M-F 7am-5pm);

Avoid engaging in construction activities within 200 feet of
noise-sensitive receptors such as schools, hospitals, residential areas,
nursing homes, etc. 

Ensure adequate maintenance of equipment, including proper engine
maintenance, adequate tire inflation, and proper maintenance of
pollution control devices; 

Ensure equipment at the project site uses the manufacturer’s standard
noise control devices (i.e., mufflers, baffling, and/or engine
enclosures);

Reduce construction equipment idling to the maximum extent practicable;

Implement plans to eliminate and minimize oil or fuel spills from
construction equipment;

Minimize the impacts of equipment staging areas;

Stabilize slopes promptly through temporary and permanent cover best
management practices (BMPs). Following construction all remaining
disturbed areas must be revegetated with locally acquired sources of
native seeds and plants in a manner that returns the site to its
pre-construction condition or better.  Plantings are done during the
optimum season for the species being planted.  Any seeding carried out
during the revegetation program is completed with commercially available
seeds certified to be free of noxious weed seeds and other invasive
species.  If necessary, an irrigation system is installed to ensure
establishment of the planted vegetation.  The target for new plantings
is an 80 percent survival rate at the end of 3 years.  Invasive exotic
plant species are controlled to the maximum extent practical to
accomplish the revegetation effort.  If the application of a chemical is
required to control an invasive exotic plant species, the chemical is
applied by a certified pesticide or herbicide applicator per labeled
directions and in compliance with all Federal, State, and local laws and
regulations.

When applicable adopt measures to minimize traffic impacts during
construction such as providing warning signage, limit the use of public
right-of-ways for staging of equipment or materials, use of flagpersons
when needed, and coordinate detours if traffic access points will be
obstructed.

Avoid engaging in construction activities within 660 feet of a bald or
golden eagle nest during nesting and fledging, as nesting eagles are
quite sensitive to human activities during these times.  

Establish an inspection and maintenance approach to ensure these
measures are working adequately.

To the extent possible, adopt other feasible measures under the EPA
Guidance Potential for Reducing Greenhouse Gas Emissions in the
Construction Sector.

Avoid archeological sites by shifting ground disturbance in a particular
area, when possible. 

Minimization/ Mitigation measures for communication towers 

Avoid engaging in construction activities within 660 feet of a bald or
golden eagle nest during nesting and fledging, as nesting eagles are
quite sensitive to human activities during these times.  

Avoid initiating construction during the nesting/fledging period in an
area that contains potential nesting habitat for migratory birds.  If
such disturbance is required, a nest survey is conducted of the area to
be disturbed and if no nests are found, construction can proceed. 
However, if nests are found, construction must be delayed until any eggs
have hatched and the young birds have fledged.

Limit construction within or in the vicinity of habitat utilized by
wildlife during sensitive periods (i.e., calving or fawning periods).

Reduce the speed of vehicles traveling through project areas with
concentrations of wildlife such that potential impacts on wildlife are
minimized.

Co-locate communication systems or equipment in already existing towers,
whenever possible;

Avoid increasing the height of towers to taller than 199 feet above
ground level (AGL), using construction techniques that do not require
guy wires (i.e., use a lattice structure, monopole, etc.).  Such towers
should be unlighted if Federal Aviation Administration (FAA) regulations
allow. 

If taller (>199 feet AGL) towers requiring lights for aviation safety
must be constructed, the minimum amount of pilot warning and obstruction
avoidance lighting required by the FAA should be used.  Unless otherwise
required by the FAA, only white (preferable) or red strobe lights should
be used at night with the minimum number, minimum intensity, and minimum
number of flashes per minute (longest duration between flashes)
allowable by the FAA. The use of solid red or pulsating red warning
lights at night should be avoided. 

Down-shield security lighting for on-ground facilities and equipment to
keep light within the boundaries of the site. 

Place daytime visual markers on the guy wires of those towers proposed
to be located in known raptor or waterbird concentration areas or daily
movement routes, or in major diurnal migratory bird movement routes or
stopover sites. 

Towers and appendant facilities should be sited, designed, and
constructed to avoid or minimize habitat loss within and adjacent to the
tower “footprint.”  

Minimize road access and fencing to reduce or prevent habitat
fragmentation and disturbance, and to reduce above ground obstacles to
birds in flight. 

Take into account the potential to buffer visual effects and alterations
to natural landscapes in the siting of towers.

Documents Incorporated by Reference

U.S. Department of Housing and Urban Development (HUD) 1996. Siting of
HUD-Assisted Projects near Hazardous Facilities (HUD -1060-CPD).
September 1996.
http://www.hud.gov/offices/cpd/environment/training/guidebooks/hazfacili
ties/

U.S. Fish and Wildlife Service (FWS). 2004. The Bald Eagle: Other
Protection following

	Delisting under the Endangered Species Act of 1973. 

	http://www.fws.gov/migratorybirds/issues/BaldEagle/FactSheetJan1806.pdf
. 

FWS 2007. National Bald Eagle Management Guidelines. May 2007. 

	http://www.fws.gov/migratorybirds/issues/BaldEagle/NationalBaldEagleMan
agementGui

	delines.pdf. 

USEPA (U.S. Environmental Protection Agency) 2007. Developing Your
Stormwater Pollution Prevention Plan: A Guide for Construction Sites. 
http://www.rpi.edu/~kilduff/Stormwater/EPA%20swppp%20guide.pdf

USEPA 2009. Potential for Reducing Greenhouse Gas Emissions in the
Construction Sector.
http://www.epa.gov/sectors/pdf/construction-sector-report.pdf

Navy 2008. Final Atlantic Fleet Active Sonar Training EIS/OEIS. December
2008. http://afasteis.gcsaic.com/docs.aspx

NEHRP (National Earthquake Hazard Reduction Program) 2000.  Recommended
Provisions for New Buildings and Other Structures.  March 2000.
http://www.bssconline.org/NEHRP2000/comments/provisions/front.pdf

NMFS (National Marine Fisheries Service) 2008. Biological Opinion for
the Implementation of the National Flood Insurance Program in the State
of Washington, Phase One Document – Puget Sound Region, September
2008.

NPS (National Park Service) 1998.   HYPERLINK
"http://www.nps.gov/history/nr/publications/bulletins/nrb38/nrb38.pdf"
\t "_blank"  Guidelines for Evaluating and Documenting Traditional
Cultural Properties . 1990, revised 1992, 1998. Available at:
http://www.nps.gov/history/nr/publications/bulletins/nrb38/. 

Glossary of Terms

Supporting facilities – Subsidiary or auxiliary buildings, equipment,
infrastructure, or services such as roads, utilities, storage buildings,
fuel tanks, generators, etc. that support the successful operation of a
parent facility.

Ground disturbance - any work or activity that results in a disturbance
of the earth, including excavating, digging, trenching, plowing,
drilling, tunneling, backfilling, blasting, topsoil stripping, land
leveling, peat removing, quarrying, clearing and grating

Best Management Practices (BMPs) – Effective, practical, structural or
nonstructural methods, schedules of activities, or prohibitions of
practices which prevent or reduce the movement of sediment, nutrients,
pesticides and other pollutants from the land to surface or ground
water, or which otherwise protect water quality. 

Critical Infrastructure - Assets, systems, and networks, whether
physical or virtual, that are so vital to a population that their
incapacitation or destruction would have a debilitating effect on public
health or safety, national security, economic vitality, or a combination
of these. Critical infrastructure includes facilities that are
especially important during and after a natural or man-made hazard
event, including but not limited to, hospitals, fire and police
stations, shelters, and facilities that store important records.

Key resources - Publicly or privately controlled resources essential to
the minimal operations of the economy and government. 

Historic property – Any prehistoric or historic district, site,
building, structure, or object included in, or eligible for inclusion on
the National Register of Historic Places, including artifacts, records,
and material remains related to such a property or resource. Historic
properties are significant at the national, tribal, regional, state,
territory, or local level in American history, architecture,
archaeology, engineering, or culture.

Infrastructure - Those systems necessary to provide electric power,
natural gas, water, and wastewater services.

Modification – Changes to an existing building or structure resulting
from the addition or removal of architectural elements, equipment,
utilities, etc.

New construction – The preparation of previously disturbed or
undisturbed land and the building or assembly of new buildings,
structures, infrastructure and other real property on that land. The
preparation of land includes removal of vegetation; site clearing,
grading, and grubbing; excavation, etc. This definition does not include
activities prior to construction, such as design, siting of buildings,
or specification of materials, nor does it include the operation of a
facility following construction. 

Physical security enhancements and access controls – Equipment or
devices installed at existing facilities to improve security and
restrict access of unauthorized personnel. Examples include lighting,
jersey barriers, vehicle bollards, fencing, gates, tire puncture
treadles, surveillance cameras.

Retrofitting – Making changes to an existing building, structure or
utility system to protect it against a natural or man-made hazard, such
as an earthquake or explosion.

References

Avian Power Line Interaction Committee (APLIC) 1994. Mitigating Bird
Collisions with Power Lines: The State of the Art in 1994. Edison
Electric Institute, Washington, D.C. 

Avian Power Line Interaction Committee (APLIC) 1996. Suggested Practices
for Raptor Protection on Power Lines. Edison Electric Institute/Raptor
Research Foundation, Washington, D.C. 

California Department of Transportation (CDOT) 1998. Technical Noise
Supplement by the California Department of Transportation Environmental
Program Environmental Engineering - Noise, Air Quality, and Hazardous
Waste Management Office. October 1998, pp. 24-28.

CEQ (President’s Council on Environmental Quality) 1997. Environmental
Justice: Guidance Under the National Environmental Policy Act. December
1997.

FEMA (Federal Emergency Management Agency) 2009. Programmatic
Environmental Assessment for the Alternative Housing Pilot Program’s
Permanent Housing in Calcasieu Parish, Louisiana. March 2009.

FHWA (Federal Highway Administration) 2006. Highway Construction Noise
Handbook, August 2006. FHWA-HEP-06-015, DOT-VNTSC-FHWA-06-02, NTIS No.
PB2006-109102. Available at:
http://www.fhwa.dot.gov/environment/noise/handbook/index.htm. 

Gehring J., Kerlinger P., Manville A.M. 2009. Communication towers,
lights, and birds: successful methods of reducing the frequency of avian
collisions. Ecological Applications: Vol. 19, No. 2, pp. 505-514.

HUD (US Housing and Urban Development) 2009. The Noise Guidebook.
Available at:
http://www.hud.gov/offices/cpd/environment/training/guidebooks/noise/ind
ex.cfm.

IPCC (Intergovernmental Panel on Climate Change) 2007. Summary for
Policymakers. In: IPCC, 2007. Climate Change 2007: The Physical Science
Basis. Contribution of Working Group I to the Fourth Assessment Report
of the Intergovernmental Panel on Climate Change [Solomon, S. D.Qin, M.
Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller
(eds.)] 

NEHRP (National Earthquake Hazard Reduction Program) 2000.  Recommended
Provisions for New Buildings and Other Structures.  March 1.

NMFS (National Marine Fisheries Service) 2008. Biological Opinion for
the Implementation of the National Flood Insurance Program in the State
of Washington, Phase One Document – Puget Sound Region, September
2008.

NMFS, 2009a. Marine Mammal Protection Act of 1972.  Available at:  
HYPERLINK "http://www.nmfs.noaa.gov/pr/laws/mmpa/" 
http://www.nmfs.noaa.gov/pr/laws/mmpa/ 

NMFS, 2009b.  Marine Mammals.  Available at:   HYPERLINK
"http://www.nmfs.noaa.gov/pr/species/mammals/" 
http://www.nmfs.noaa.gov/pr/species/mammals/ 

NPS (National Park Service), 1998.   HYPERLINK
"http://www.nps.gov/history/nr/publications/bulletins/nrb38/nrb38.pdf"
\t "_blank"  Guidelines for Evaluating and Documenting Traditional
Cultural Properties . 1990, revised 1992, 1998. Available at:
http://www.nps.gov/history/nr/publications/bulletins/nrb38/. Accessed 8
January 2009.

Meehl, G.A., T.F. Stocker, W.D. Collins, P. Friedlingstein, A.T. Gaye,
J.M. Gregory, A. Kitoh, R. Knutti, J.M. Murphy, A. Noda, S.C.B. Raper,
I.G. Watterson, A.J. Weaver and Z.-C. Zhao 2007. Global Climate
Projections. In: Climate Change 2007: The Physical Science Basis.
Contribution of Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change, [Solomon, S.D. Qin, M.
Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller
(eds.)]. Cambridge University Press, Cambridge, United Kingdom and New
York, NY, USA, pp. 747–846.

Reynolds, J.R.  2008.  Submarines, sonar, and the death of whales: 
Enforcing the delicate balance of environmental compliance and national
security in military training.  Wm. & Mary Envtl. L. & Pol’y Rev.
32:759-802.

USCB (United States Census Bureau) 2008. Poverty Thresholds for 2007 by
Size of Family and Number of Related Children Under 18 Years. 2008.
Available at:
http://www.census.gov/hhes/www/poverty/threshld/thresh07.html. Accessed
8 January 2009.

USEPA (U.S. Environmental Protection Agency) 1980. Effects of Noise on
Wildlife and Other Animals. EPA 550/9-80-100. TIC 242667. December 1980.

USEPA 1995.  Compilation of Air Pollutant Factors, Volume 1: Stationary
Point and Area Sources (AP-42), 5th edition, United Stated
Environmental Protection Agency, Ann Arbor.  January.

USEPA 2007. Developing Your Stormwater Pollution Prevention Plan: A
Guide for Construction Sites. 
http://www.rpi.edu/~kilduff/Stormwater/EPA%20swppp%20guide.pdf

USEPA. 2008a. Air and Radiation Division, Office of Air Quality Planning
and Standards. National Ambient Air Quality Standards.  
http://www.epa.gov/air/criteria.html

USEPA 2008b. Inventory of U.S. Greenhouse Gas Emissions and Sinks:
1990–2006. Washington, DC: U.S. Environmental Protection Agency. EPA
430-R-08-005. April.   HYPERLINK
"http://www.epa.gov/climatechange/emissions/usinventoryreport.html" 
http://www.epa.gov/climatechange/emissions/usinventoryreport.html .

USEPA 2009. Potential for Reducing Greenhouse Gas Emissions in the
Construction Sector. 
http://www.epa.gov/sectors/pdf/construction-sector-report.pdf

FWS (U.S. Fish and Wildlife Service) 2000. Division of Migratory Bird
Management, “Service Guidance on the Siting, Construction, Operation
and Decommissioning of Communications Towers,” Sept. 14.

FWS 2007. National Bald Eagle Management Guidelines. May 2007. 

	http://www.fws.gov/migratorybirds/issues/BaldEagle/NationalBaldEagleMan
agementGui

	delines.pdf. 

Salmon, M. 2003. Artificial night lighting and sea turtles. Biologist
50(4) pp. 163-168.

Western Regional Air Partnership (WRAP).  2004. WRAP Fugitive Dust
Handbook.  November 15. 

WRI (World Resources Institute). 2008. Climate Analysis Indicators Tool
(CAIT) Version 5.0. Washington, DC: World Resources Institute.
http://cait.wri.org.List of Preparers

FEMA

Jomar Maldonado, Acting Environmental Officer

Laura Shick, Environmental Program Specialist

Adria Martínez, Program Manager

Booz Allen Hamilton

John Thomas Fitch, Senior Environmental Manager

William McGovern, Senior Environmental Specialist

Amanda Pereira, Environmental Specialist

Emily Lux, Environmental Specialist

URS Corp.

Kathryn St. Clair-Barrett, Senior Architectural Historian

Carrie Albee, Senior Architectural Historian

Kathleen Furgerson, RPA, Principal Archeologist

Mark Edwards, Principal Architectural Historian

Susan Volkmer, Senior Environmental Scientist

Quentin Bliss, Principal Environmental Scientist

Morgan Griffin, Project Manager

 PAGE   

 PAGE   iii 

	  

	  STYLEREF “HEADING1Title”  

 PAGE   4 

	  

	  STYLEREF “HEADING1Title”  Environmental Consequences 

 PAGE   

 PAGE   44 

	  STYLEREF “HEADING1Title”  Mitigation 

 PAGE   96 

	Incorporation by Reference

	Glossary

	References

	List of Preparers

Would compliance with another EHP requirement (NHPA, ESA, EO 11988,
etc.) resolve effects not addressed in the PEA?

Yes

No

Yes

Is documentation necessary to address extraordinary circumstances?

EIS required. Issue Notice of Intent to Prepare EIS.

Scope of the project  is described within in the PEA

No

Can a FONSI be made?

Prepare SEA that tiers off PEA. Focus on issues specific to the action. 

Yes

No

No

No

Yes

Prepare Record of Environmental Consideration (REC)

Is the project scope, impacts, and mitigation adequately addressed in
the PEA? 

Can a FONSI be made?

No additional NEPA documentation required.

Is the project covered by  a CATEX?

No

Supplement documentation and complete any required agency coordination. 

Does the submitted EHP documentation and analysis support FEMA’s
adoption of  NEPA document?

Return to applicant for needed information.

Does the project require FCC license or review?

Did applicant submit all necessary EHP documentation?

Did the applicant submit EHP documentation prepared for FCC license?

Table 5-2: Water pollutants from construction practices

Source: FEMA 2009, prepared by Gulf South Research Corp.

Table 5-3: Estimate of Criteria Pollutant Emissions from Equipment Used
in Site Preparation and Construction Activities for Alternative Housing
Pilot Program (AHPP) in Calcasieu, Louisiana

Source: USEPA, Developing Your Stormwater Pollution Prevention Plan: A
Guide for Construction Sites (2007)

No

Yes

Yes

Issue 

FONSI

Prepare stand-alone Environmental Assessment.

Review project in accordance with Figure 1-1 of PEA.

No

Yes

No

Yes

Develop REC. Determine need for circulation/ public involvement. Issue
FONSI or ROD 

No

Yes

Yes

No

Yes

No

