Chapter 10 › I.A EHP Compliance Review

What is an EHP review, and does every project need one?

FEMA term

EHP compliance review; record of environmental consideration (REC)

Short answer

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.

What FEMA requires

PA projects must comply with FEMA Directive 108-1 and all applicable EHP laws, regulations and executive orders, and address adverse impacts by avoiding, minimizing or compensating for them.
EHP specialists review your scope of work and supporting documents to understand the work, its locations (including staging areas) and what natural or cultural resources may be affected.
Findings go in a REC included in every project. The REC records the categorical or statutory exclusion that applies, the compliance determinations, and any project conditions.
For completed or partly completed work, you must document compliance with project-specific conditions, for example permits, certifications and post-construction surveys.
At the start of each declaration, EHP prepares a “greensheet” with EHP information for the designated areas.
Review timeframes vary with the scope, resources affected, public notice and consultations with regulatory agencies.

Documentation

A complete scope of work with locations (including equipment and material staging), plus the record of environmental consideration (REC) for each project and proof you met every condition it lists.

Watch out · Govstar practitioner advice

Read the conditions in each project’s REC as carefully as the scope. Unmet REC conditions, such as a missing permit or a required survey that was never done, are a common reason for costs being pulled back at closeout.

Govstar summarizes FEMA’s Public Assistance Program and Policy Guide in plain language and links to the official text. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.