An applicant must obtain approval for an improved project from the recipient prior to the start of construction. If an improved project results in a significant change from the predisaster configuration, it must also be approved by FEMA prior to construction. The Applicant started construction of the improved project work without prior FEMA approval. NEPA requires federal agencies to consider the environmental impact of a proposed action, as well as whether any alternatives exist, prior to obligating funds and beginning work. The Applicant did not afford FEMA the opportunity to complete the required EHP review before work commenced in violation of FEMA policy.

The Applicant started construction of the improved project without prior FEMA approval, and thus, FEMA was unable to complete the required EHP review before work commenced, in violation of FEMA policy. Therefore, the appeal is denied.

Stafford Act §§ 406(a)(1)(A), (e)(1). 40 C.F.R. § 1508.25(a)(1). 44 C.F.R. § 10.8, 206.201(l), 206.226. PA Guide, at 79, 94-95, 107-108, 110-111, 117, 127, 128, 139-140, B-7. City of Ardmore, FEMA-DR-4222-OK, at 3; Town of Fairfield, FEMA-DR-4087-CT, at 4.