If the applicant begins work associated with a change in scope of work before FEMA review and approval, it jeopardizes PA funding. EHP compliance reviews must be completed before FEMA approves funding and before work is started. The completed Phase I work was within the approved scope of work. FEMA must review each PA project to ensure that the work complies with applicable federal EHP laws, their implementing regulations, and applicable EOs. FEMA is responsible for reviewing connected actions associated with a proposed project, even if FEMA is not funding the connected action. The Applicant’s completed work complied with EHP requirements, and the third-party’s work was not a connected action requiring an additional EHP review.

The Applicant’s work is eligible for PA funding because it was completed within the approved scope of work, and the work complied with EHP requirements. Therefore, this appeal is granted for $1,435,834.75.

Stafford Act § 406(a). 2 C.F.R. § 200.308; 44 C.F.R. § 206.226. PAPPG, at 140-141,143, 168-169, 183-184, 221.