Chapter 10 › I.B–C Streamlined and Complex EHP Review

Will our project get a quick EHP review or a long one?

FEMA term

Streamlined EHP review; complex EHP review

Short answer

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.

What FEMA requires

All projects get an EHP review; timeframes vary by project type.
Streamlined reviews rely on programmatic agreements and consultations with predetermined compliance decisions for repeated, similar work.
Projects that may affect natural and cultural resources need more information and longer review, often with consultation or coordination with the U.S. Fish and Wildlife Service, EPA, National Marine Fisheries Service, U.S. Army Corps of Engineers, State or Tribal Historic Preservation Offices, and local, state or territorial agencies.
When consultation is needed, the regulatory agency sets the timeline.
Flood hazard area work includes the regulatory floodway and 1% annual chance floodplain, or for critical actions, the 0.2% annual chance floodplain.

<table class="pt-table"><thead><tr><th>Usually streamlined</th><th>Usually complex</th></tr></thead><tbody><tr><td>Restoring to pre-disaster condition with in-kind or like materials</td><td>New construction, or changes in location, footprint or size</td></tr><tr><td>Codes and standards upgrades</td><td>Larger or realigned roads, bridges or culverts</td></tr><tr><td>Replacing contents, supplies or equipment</td><td>Hazard mitigation and codes and standards upgrades</td></tr><tr><td>Minor work on buildings under 45 years old and not historic</td><td>Buildings or sites 45 years or older, historic landmarks, soil movement or footprint changes</td></tr><tr><td></td><td>Work in or near a flood hazard area, sensitive areas, or water bodies</td></tr><tr><td></td><td>Staging and disposal of debris</td></tr></tbody></table>

Documentation

For complex projects: the information above plus anything the regulatory agencies request during consultation, such as surveys, studies and permit applications.

Watch out · Govstar practitioner advice

The PAPPG lists codes and standards upgrades on both sides, so don’t assume an upgrade is quick. Anything involving a building 45 years or older, new ground disturbance or water should be planned for a longer review from the start.

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.