NSGP environmental and historic preservation review

What EHP review covers

Environmental planning and historic preservation (EHP) review is FEMA's check that a funded project complies with environmental and historic-preservation law. Those authorities include the National Environmental Policy Act, the Endangered Species Act, the National Historic Preservation Act, and federal floodplain and wetland rules (FY2026 FEMA Standard Terms and Conditions). The FY2026 NSGP NOFO says federal law requires the review to finish before FEMA releases funds for the project.

The nonprofit supplies the project description, site details and photos. Its State Administrative Agency (SAA) checks the package and submits it to FEMA, which makes the decision and may consult other agencies or the public. FEMA's policy says the review begins after award and work may not start until EHP requirements are met (FEMA Policy 108-023-1, Revision 2). See after an NSGP award for the rest of the post-award sequence.

Which NSGP projects need screening

FEMA's form identifies "physical security enhancements to existing structures" as a project type. Cameras, fencing, access control, bollards, alarms, security doors, lighting and similar equipment need screening when installation attaches them to a building or structure (FEMA EHP Screening Form).

FEMA policy exempts planning, management and administration, classroom training, discussion-based exercises, and portable equipment with no fixed installation. Drills and full-scale exercises need a form unless held at a facility designed for them (FEMA Policy 108-023-1, Revision 2). The policy doesn't address contracted security services, so ask the SAA whether it requires a form for a guard contract.

The policy also offers a narrow shortcut for repeat interior work. After FEMA approves a screening form for interior construction in a building less than 43 years old, later interior construction projects at that location can be considered "previously approved" for the approval year plus two more calendar years. FEMA applies this case by case. Any project with exterior changes or ground disturbance still needs a form (Policy 108-023-1, Revision 2, section C.2.b).

Check the National Park Service's National Register database for listed properties and districts and FEMA's Flood Map Service Center for the site's flood zone. An equipment installation that counts as construction or renovation also needs FEMA's prior written approval (NOFO, Construction and Renovation). Ask the SAA to consult FEMA's Preparedness Officer if the classification is unclear. The allowable costs guide addresses whether the equipment itself is fundable.

What to submit

FEMA posts its current form on the EHP grant preparation resources page. The posted form, FF-207-FY-21-100, shows an OMB expiration date of 3/31/2026. A February 11, 2026 Federal Register notice proposed extending the collection without change and listed the form as FF-119-FY-21-105. Use the version and instructions the SAA gives you. State procedures differ: New York's SAA, for example, pre-fills part of the form and sets an internal due date (New York DHSES, EHP requirements, November 2025).

• Describe what will be done, where, how, and why, with a separate project summary for each site.
• List equipment and quantities, attachment points, electrical work, and every ground-disturbing activity.
• Give the age of buildings on or near the site and identify any National Register or historic-district status.
• Provide the required labeled color photos, including each attachment point and marked aerial views. Buildings more than 45 years old require photos of every exterior side.
• Include earlier environmental studies or agency correspondence for the site.

FEMA asks for photos that identify the facility and location and mark proposed equipment or digging. Its form says the images provide pre-project documentation, so take them before the site changes. Before-and-after photos also support reimbursement; Florida's hardening milestones require them (Florida security grants).

Plan for review time

FEMA's policy estimates 30 to 45 working days for work with little potential to affect environmental or historic resources. A project with potential for significant effects can take a year or more, and incomplete documentation can extend the review (FEMA Policy 108-023-1, Revision 2). Those estimates begin after the SAA checks the package, and federal delays can add time.

Leave room for that process in the project schedule. FEMA's Investment Justification criteria direct applicants to account for EHP review in their milestones (NOFO, Appendix D). A late clearance can otherwise push installation against the end of the period of performance.

While review is pending

You can prepare or run a procurement without authorizing installation, but follow the rules in NSGP procurement requirements. Confirm that proposed mounting points and trench routes match the EHP submission, identify local permits, and answer FEMA questions through the SAA. EHP clearance doesn't replace other federal, state, or local approvals (FY2026 FEMA Standard Terms and Conditions).

A nonprofit should not sign an installation contract, pay a deposit, or place an order that commits grant funds before written clearance. If a vendor needs a signature to hold a price, ask the SAA whether it will accept a contract conditioned on EHP approval.

Follow the clearance conditions

The SAA forwards FEMA's decision to the nonprofit. Approval may include mitigation measures or other conditions that change how the work must be done (NOFO, EHP Compliance). Give those conditions to the installer before work starts.

If digging uncovers potential archaeological resources, the FY2026 standard terms require work in that area to stop immediately and require notice to the SAA and FEMA (FY2026 FEMA Standard Terms and Conditions). FEMA may also check EHP compliance at closeout, so retain the approval with the award records.

If work started before clearance

FEMA may not fund it. Its policy says a project started or finished before or during review "may not be funded," depending on the work and the environmental rules that apply (FEMA Policy 108-023-1, Revision 2). Any amount FEMA declines remains the nonprofit's cost.

Stop further work and tell the SAA in writing what was done and when. Keep the invoices, dates and photos, describe completed work accurately in the screening form and leave the cost out of a claim until the SAA explains FEMA's decision.

Changes after clearance

The decision covers the project FEMA reviewed. A different camera location, new light pole, rerouted trench, or installer-proposed upgrade may change that project. New York's SAA tells subrecipients with significant changes to ask about an "EHP Rescope" and submit a new form with photos of the changed locations (New York DHSES, EHP requirements).

Ask the SAA in writing whether a proposed change needs another review before work proceeds. A scope change also requires FEMA's prior written approval through a separate process, covered under budget and scope changes.