Environmental and Historic Preservation (EHP) and Emergency Protective Measures for COVID-19


COVID-19 EHP Considerations

FEMA’s Public Assistance Program will fund eligible emergency protective measures taken by a community to save lives, protect property and public health and safety, and lessen or avert the threat of a catastrophe. While the list of eligible activities includes actions that do not affect the environment (such as provision of personnel, supplies, and equipment), there are activities associated that do have the potential to adversely affect natural, historic, and/or archaeological resources.

Examples are:
• Repurposing, renovating, or reusing existing facilities as temporary medical or sheltering facilities
• Placement of prefabricated facilities on a site
• Construction of new temporary medical or sheltering facilities
• Storage of human remains and mass mortuary services
• Staging resources on an undeveloped site
• Proper disposal of medical waste

EHP Information Requirements
For projects that do have the potential to adversely affect natural, historic, and/or archaeological resources, Applicants should be prepared to provide the following:

• Location of the work, including and latitude/longitude in decimal degrees (to the fifth decimal point) and site address. Maps or aerial imagery of the project area is also helpful.
• Description of any ground-disturbing activities, including site preparation, laying new or expanding existing utilities, and expansion of existing footprints.
• Dates of construction for facilities that are being reused, repurposed, or renovated.
• Description of modifications made to existing facilities.
• Photographs of the project site or facility.

EHP Best Practices for Temporary Facilities

Responding to the COVID-19 pandemic may require repurposing, renovating, or reusing existing facilities, the placement of prefabricated facilities on a site, or the construction of new temporary facilities. In order to minimize potential impacts or effects to natural and cultural resources, minority populations, and low-income populations, States, Tribes, communities, and Applicants should consider the following:

  • • Avoid placement of temporary facilities in flood hazard areas and wetlands. While we recognize that the construction of temporary facilities may be necessary, the disruption of relocating these facilities in the future due to flooding—especially when occupants may not be sufficiently mobile—is too great of a risk.
  • • Avoid placement of temporary facilities in brownfields and other use restricted sites. While we recognize that the construction of temporary medical facilities may be necessary, we also recognize the health risks of the occupants, medical providers, and construction workers and short- and long-term health risks associated with exposure to chemicals.
  • • Ensure accessibility across the full range of clients and/or customers that need to utilize the services being provided by these facilities, including elements of the population with less capacity or mobility.
  • • Select pre-disturbed sites or existing hardened surfaces, such as parking lots, concrete pads, or artificial playing fields, whenever possible. Previously disturbed areas typically have critical infrastructure such as electricity, water, sewer, and other amenities already onsite or easily accessible nearby, which will minimize ground disturbance.
  • • Avoid new ground disturbance when possible. Should ground disturbance reveal archaeological resources, notify FEMA and State Historic Preservation Officer/Tribal Historic Preservation Officer immediately.
  • • If renovation of a facility is required, consider the impacts of renovation (e.g. exposure to asbestos, lead-based paint, or other environmental contaminants associated with past use of the property) on the health of occupants, medical providers, and construction workers.
  • • Document conditions by taking photographs before and after any work is carried out.

Floodplain Considerations for Temporary Critical Facilities

Even a slight chance of flooding can pose too great a threat to the delivery of services provided by a critical facility (such as those that provide temporary medical services, including, but not limited to hospitals, medical sheltering, and mortuary facilities). Further, these critical facilities are likely to have occupants who may not be sufficiently mobile to evacuate in order to avoid injury or death during a flood. Site considerations for such facilities must include an evaluation of flood risk.

Review the second document for more details on floodplain guidance


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