Appendix D › Introduction; I–III NEPA, NHPA, ESA

What is the greensheet, and what do NEPA, Section 106 and the Endangered Species Act require?

FEMA term

EHP laws: greensheet; NEPA; NHPA Section 106; Endangered Species Act

Short answer

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.

What FEMA requires

FEMA reviews every PA project for compliance with applicable federal EHP laws, regulations and executive orders. Compliance with all federal, state, local, tribal and territorial laws is a requirement of every FEMA award; local laws such as hazardous materials rules vary and aren’t listed in Appendix D.
Greensheet: FEMA’s disaster-specific EHP guidance, prepared at the start of each declaration, covering relevant laws, triggering project types, and federal and local laws to follow.
NEPA: FEMA must consider environmental impacts and reasonable alternatives, with public involvement, under DHS procedures. The PAPPG notes that, effective April 11, 2025, an interim final rule removed the Council on Environmental Quality’s NEPA implementing regulations.
NHPA Section 106: FEMA consults the SHPO or THPO and other consulting parties, often through programmatic agreements, and resolves adverse effects through avoidance, minimization or compensation.
Endangered Species Act: FEMA consults the U.S. Fish and Wildlife Service and NOAA Fisheries so projects don’t jeopardize listed species or destroy or adversely modify critical habitat.

<table class="pt-table"><thead><tr><th>Law</th><th>What it requires</th><th>Who FEMA consults</th></tr></thead><tbody><tr><td>NEPA</td><td>Consider environmental impacts of the project and reasonable alternatives before deciding, with public involvement</td><td>Follows DHS procedures</td></tr><tr><td>NHPA Section 106</td><td>Consider effects on historic properties (on or eligible for the National Register) and resolve adverse effects</td><td>SHPO or THPO, other consulting parties, Advisory Council on Historic Preservation</td></tr><tr><td>Endangered Species Act</td><td>Ensure projects don’t jeopardize listed species or harm critical habitat</td><td>U.S. Fish and Wildlife Service, NOAA Fisheries</td></tr></tbody></table>

Documentation

The greensheet for your declaration, information on historic properties affected (age, renovations, register listings), and any species or habitat information for the work sites.

Watch out · Govstar practitioner advice

Ask for your declaration’s greensheet early. It tells you which laws and project types are likely to trigger review in your area, and it is the fastest way to spot permit needs before work starts.

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.