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Environmental & Historic

Environmental and historic preservation review: NEPA, Section 106, ESA, floodplains and wetlands, permits and the documents EHP needs.

Every FEMA-funded project must clear environmental and historic preservation (EHP) review before work begins, unless it qualifies for an exception. This center covers how EHP review works, NEPA, Section 106 historic review, endangered species, floodplains and wetlands, permits, and what to do for emergency work and debris.

Start here: bring EHP into project planning early. Missing permits or starting work before review are common reasons FEMA deobligates funding.

Start with these guides and tools

The rules

What the PAPPG requires, in plain language.

Executive orders on floodplains, wetlands and invasive species
Executive Orders 11988 and 11990 require FEMA to avoid or minimize harm to floodplains and wetlands and to avoid supporting development there when there is a practicable alternative, using a documented 8-step process with public involvement under 44 CFR Part 9. Executive Order 13112 requires projects not to introduce or spread invasive species.
Air, land and waste laws
The Clean Air Act may require dust and emissions controls and state or local permits. Projects that could convert important farmland trigger consultation with USDA, and projects on protected rivers trigger review under the Wild and Scenic Rivers Act. RCRA governs disposal of solid and hazardous waste, including debris, and Superfund sites require consultation with EPA.
Wildlife and coastal laws
Projects on the coast or near wildlife can trigger the Coastal Barrier Resources Act, the Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act, fish habitat protections, the Marine Mammal Protection Act, the National Marine Sanctuaries Act and the Coastal Zone Management Act. FEMA consults the relevant wildlife, fisheries or state coastal agency before funding the work.
Water laws: Clean Water Act, Rivers and Harbors Act, Safe Drinking Water Act
The Clean Water Act requires Corps of Engineers or state permits before you discharge into, dredge or fill waters, which commonly includes bridge, stream crossing, dock, pier and marina repairs. The Rivers and Harbors Act requires Corps authorization for structures in or over navigable waters. The Safe Drinking Water Act requires FEMA to consult EPA for projects that could contaminate a sole source aquifer.
The greensheet and the core EHP laws (NEPA, Section 106, ESA)
The greensheet is FEMA’s disaster-specific EHP guide, prepared at the start of each declaration for your state and area. The three core reviews: NEPA requires FEMA to weigh environmental impacts and alternatives; Section 106 requires FEMA to consider effects on historic properties and consult the historic preservation officer; and the Endangered Species Act requires consultation with wildlife agencies to protect listed species and habitat.
Coordination with other agencies and cultural partners
When another federal agency is also funding, supporting or permitting work in the same area, FEMA coordinates early so you don’t face conflicting environmental standards. For example, FEMA works with HUD on public housing projects. The Unified Federal Review resolves disagreements between agencies, and the Heritage Emergency National Task Force helps museums, libraries and other cultural institutions.
Floodplains, wetlands, coastal barriers and water permits
FEMA must run its 8-step decision process for work in or affecting a floodplain or wetland, including whether there is a practicable alternative location. Work in a coastal barrier unit must meet a legal exception. And you, not FEMA, are responsible for any Clean Water Act permits, such as a Section 404 permit for dredge or fill work like culvert and bridge replacements.
NEPA, historic preservation and endangered species
NEPA decides the level of environmental review, from an exclusion up to a full environmental impact statement. Section 106 of the National Historic Preservation Act requires FEMA to check effects on historic properties and consult the State or Tribal Historic Preservation Officer. Section 7 of the Endangered Species Act requires review of effects on listed species and habitat, and consultation if there are effects.
Getting through EHP review faster
Give EHP a complete, clear scope of work with maps, photos and site plans; get permits before construction; share any permits you already hold, which can speed the review; keep and attach all agency correspondence; and follow permit conditions and best management practices, then document that you did.
EHP rules for permanent work and the original facility
Permanent work that changes a facility’s location, footprint, alignment or size, or affects natural or cultural resources, gets a deeper review, which is common for improved, alternate, relocation, code upgrade and mitigation projects. In alternate and alternative procedures projects, if you don’t repair or sell the old facility and it’s unsafe, you must secure it or demolish it, and coordinate with the historic and resource agencies.
EHP rules for emergency work and debris
Most emergency work is exempt from full NEPA review under Stafford Act Section 316, but other laws still apply, including the Endangered Species Act, the National Historic Preservation Act, solid waste and clean air and water laws, and the floodplain and invasive species executive orders. Debris must be staged at a safe distance from water, wetlands, wells and property lines, and you are responsible for the permits.
Streamlined vs. complex EHP review
It depends on the work. Like-for-like restoration, contents replacement and minor work on buildings under 45 years old usually qualify for streamlined review under existing programmatic agreements. Projects that change a facility’s size or location, touch older or historic properties, disturb soil, or are in or near floodplains, wetlands or water need longer reviews and often consultation with other agencies.
Information to give FEMA for EHP review
Exact locations (address and GPS) for every work site, staging area, disturbance and fill source; the size of any ground disturbance; materials and equipment; when the facility was built and renovated; debris disposal sites; when the work happens; maps, photos and plans; and any permits or agency correspondence. Missing items lead to a request for information and delay.
How EHP review works
Yes. Every PA project gets an environmental and historic preservation (EHP) review to check its effects on water, air, coasts, wildlife, land, historic buildings and cultural resources, and its compliance with federal laws and executive orders. FEMA records the result in a record of environmental consideration (REC), which lists any conditions you must meet.
Building code and floodplain administration (Category I)
Yes. Administering and enforcing building codes and floodplain ordinances for disaster-damaged structures, public, private and residential, is eligible from the start of the incident period through 180 days after the declaration is amended to authorize permanent work. There are no extensions.
Floodplains, wetlands and the 8-step process
FEMA must avoid floodplains and wetlands when practicable alternatives exist, using its 8-step decision process for projects over $18,000. New construction is barred in coastal high hazard areas and floodways, and critical facilities must consider the 500-year floodplain.
Historic facilities, construction methods and pre-existing conditions
Historic facilities can be restored as a code requires even if repair costs more than replacement. Changes in construction method or materials are approved when access, site conditions or tie-ins require them. Pre-existing damage must be fixed at your own cost before FEMA funds the repair.

Key takeaways

Short explainers with the points that matter most.

National Historic Preservation Act (NHPA)
National Historic Preservation Act (NHPA)
Floodplain Considerations for Temporary Critical Facilities
Executive Order 11988
FEMA Activities that May Trigger Environmental & Historic Review
National Environmental Policy Act (NEPA)
Environmental & Historic Laws
National Environmental Policy Act (NEPA)
Environmental Compliance
National Environmental Policy Act (NEPA)
Environmental and Historic Preservation Requirements
National Environmental Policy Act (NEPA)
Endangered Species Act (ESA)
Endangered Species Act (ESA)
EHP LAWS (Environmental and Historic Preservation Compliance)
National Environmental Policy Act (NEPA)
Determining if your project will affect "Waters of the U.S."
Clean Water Act (CWA)
Coastal Barrier Resources Act (CBRA)
Coastal Barrier Resources Act (CBRA)

Deep dives and briefings

Longer analysis, practitioner briefings and technical notes.

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EHP Compliance & Regulatory Laws Index
Federal environmental laws, C.F.R. regulations, and Executive Orders governing Public Assistance grants.
Environmental & Historic Preservation Compliance
NEPA review levels, NHPA Section 106 triggers, CWA Section 404 permits, and required REC documentation.

Questions people ask

Practitioner answers to common questions.

What types of projects qualify for streamlined EHP review?
environmental-compliance
What types of areas are considered environmentally sensitive?
environmental-compliance
What is the purpose of the Unified Federal Review (UFR) process?
environmental-compliance
What is the purpose of the National Environmental Policy Act (NEPA)?
environmental-compliance
What is the purpose of Categorical Exclusion (CATEX)?
environmental-compliance
What is the FEMA EHP Policy Guidance for FEMA Grant Applications
environmental-compliance
What is a Record of Environmental Consideration (REC)?
environmental-compliance
What information is required for EHP review?
environmental-compliance
What information do EHP Specialists need for project review?
environmental-compliance
What constitutes "Historic Properties" under FEMA PA EHP requirements:
environmental-compliance
What are the potential issues with a damaged facility located in a Coastal Barrier Resource System Unit?
environmental-compliance
What are some guidelines for EHP compliance?
environmental-compliance
What agencies require consultation for complex projects?
environmental-compliance
Under what conditions can FEMA assist projects in Protected Areas?
environmental-compliance
How can applicants facilitate the EHP project compliance review?
environmental-compliance

FEMA policies and guides

The official FEMA documents behind this subject.

Environmental and Historic Preservation (EHP) Fact Sheet: Debris Removal Activities
Explains environmental and historic preservation review for debris operations, including compliance obligations that remain despite statutory NEPA exclusions.

Laws and regulations

Stafford Act sections and federal regulations, summarized.

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Protection of Environment
Requires all disaster relief and restoration work to be conducted in accordance with federal environmental protection laws. Compliance Hint: Securing required Environmental Planning and Historic Preservation (EHP) clearances prior to project execution is vital to ensure full FEMA PA funding compliance. Click to read the complete environmental mandates.

Resource hubs and navigators

Curated paths through related material.

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Environmental & Historic Preservation
Identify FEMA Environmental and Historic Preservation requirements, including permits, floodplain issues, wetlands, historic resources, special conditions, and compliance documentation before work proceeds.

Related subject centers

GovStar is independent and not affiliated with FEMA. Summaries are educational, not legal advice; always confirm against the current PAPPG and your FEMA and state contacts.