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FEMA EHP review: environmental and historic preservation review for FEMA grants

FEMA EHP review is FEMA's environmental planning and historic preservation review of the projects it funds, such as Public Assistance and Hazard Mitigation grants[1][2][3]. Each project gets a statutory exclusion, a categorical exclusion, an EA or an EIS, and the review must finish before funds are released[4][1].

By Ilya Volodarsky. 16 sources, last read on . This page explains the law; it is not legal advice.

Draft an EHP Review Narrative for Flood Repair

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    • A first draft of your EHP Review Narrative, from a project description or the files you already have
    • Precedent research: analog projects and their documents, found for you
    • Every fact ePlan can't confirm, marked for your team to fill in
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    Describe the project and ePlan drafts the EHP review narrative with the scope of work, locations and resource findings; every fact it can't confirm is marked for you.

    ePlan vs. by hand

    How ePlan compares to drafting an EHP Review Narrative by hand

    The same document, two ways to a first draft.

    ComparedePlan.aiBy hand
    Agency toolsePlan.aiReads the IPaC species lists, maps and survey reports you upload; it does not run IPaC or submit anything to FEMABy handCopying tool results into the narrative by hand
    Starting pointePlan.aiA narrative that follows a reference document you upload or one it finds, with your scope of work filled in and gaps markedBy handA blank scope of work and FEMA's EHP checklist
    Precedent researchePlan.aiA research agent searches agency project pages, CEQAnet, the Federal Register, eCFR and EPA's EIS database for your project and up to two analog projectsBy handSearching each agency site and PDF library by hand
    Missing factsePlan.aiEvery fact ePlan can't confirm stays a highlighted [INSERT] placeholder until someone fills itBy handGaps surface in review, or not at all
    Cost to startePlan.aiScoping letters are free. EAs, EIRs and decision memos are on Max at $199 a monthBy handStaff or consultant hours for every draft

    ePlan.ai as of October 2026. “By hand” means a Word template, past documents and agency PDFs. Your team reviews, edits and signs every draft.

    When is a FEMA environmental review required, and under which laws?

    Every Public Assistance project gets an EHP review, documented in a record of environmental consideration (REC)[2]; Hazard Mitigation reviews finish before the award[3]. FEMA keeps responsibility for tribal and agency consultation, even when the applicant prepares the studies[4].

    Besides NEPA, the usual triggers are NHPA section 106, ESA section 7 and the floodplain and wetland orders in 44 CFR part 9[4], plus Clean Water Act permits, coastal laws and NAGPRA[6].

    Statutory exclusions under Stafford Act section 316

    Stafford Act section 316 says aid that restores a facility substantially to its pre-disaster condition is not a major Federal action under NEPA[7]. FEMA applies this statutory exclusion (STATEX) to emergency work under sections 403 and 407 and to same-site section 406 repairs; improved or relocated projects need NEPA review[8]. Other laws, such as the NHPA and ESA, still apply[4].

    FEMA categorical exclusions (CATEXs) and the REC

    If no STATEX applies, FEMA checks the CATEXs in Appendix A of DHS Instruction Manual 023-01-001-01. If one fits and no extraordinary circumstance exists, such as possible significant effects on listed species or historic properties, a REC completes NEPA[4][9][10].

    DHS has also adopted other agencies' CATEXs, such as post-wildfire stream bank stabilization[11][12][13]. Common grant CATEXs[9]:

    • N2: repairs keeping the existing design, function, location and use, away from streams
    • N3: buyouts from willing sellers, with the land deed-restricted to open space forever
    • N7: reconstruction, elevation, retrofits and code upgrades in already disturbed areas
    • N8: new construction under one acre, outside undisturbed floodplains and wetlands

    When does FEMA prepare an EA or EIS?

    FEMA prepares an EA when impacts are unknown or unlikely to be significant, and an EIS when they are likely. A capable applicant may write either; FEMA reviews it, issues the FONSI or ROD, and may adopt other agencies' EAs[4].

    FEMA posts its EAs online[14]. In Quincy, Massachusetts, after a 2012 disaster declaration, the city sought Hazard Mitigation funds for a pump station, new drainage and about 900 feet of restored brook. FEMA weighed five alternatives and no action, noticed the draft EA on October 10, 2020, got no comments, and signed the FONSI October 26[15].

    Outline

    What an EHP review narrative covers

    FEMA has no form for it; this combines what FEMA asks Public Assistance and Hazard Mitigation applicants for[2][3].

    1. Project description

      What, where, how and why, for each site[16][4].

    2. Locations

      Addresses and GPS points for work, staging and fill sites, with maps and photos[2][3].

    3. Alternatives

      Options that avoid or reduce impacts, including no action[3][4].

    4. Historic resources

      Construction dates, and at least two color photos of anything 45 years or older[3][2].

    5. Natural resources

      Listed species, critical habitat, vegetation removal, surface waters, floodplains, wetlands and coastal zones[3][2].

    6. Hazardous materials and debris

      Known contamination, and debris staging and disposal sites[3][2].

    7. Connected actions, permits and mitigation

      Connected actions, other federal funding, permits and agency letters, and mitigation costs[3][4][2].

    Sources

    Where each statement comes from

    Show all 16 sources
    1. [1]Environmental & Historic Preservation Guidance for FEMA Grant Applications. Federal Emergency Management Agency, March 25, 2025. Read October 2, 2026.
    2. [2]Public Assistance Program and Policy Guide, Version 5.0 Amended (FP 104-009-2), Chapter 10: Environmental and Historic Preservation. Federal Emergency Management Agency, January 6, 2025. Read October 2, 2026.
    3. [3]Hazard Mitigation Assistance Program and Policy Guide, Version 2.1. Federal Emergency Management Agency, January 20, 2025. Read October 2, 2026.
    4. [4]FEMA Instruction 108-1-1: Implementation of the Environmental Planning and Historic Preservation Responsibilities and Program Requirements. Federal Emergency Management Agency, August 2025. Read October 2, 2026.
    5. [5]FEMA Directive 108-1: Environmental Planning and Historic Preservation Responsibilities and Program Requirements. Federal Emergency Management Agency, August 7, 2025. Read October 2, 2026.
    6. [6]Descriptions of All Policies (environmental planning and historic preservation laws and executive orders). Federal Emergency Management Agency, September 10, 2026. Read October 2, 2026.
    7. [7]42 U.S.C. 5159 - Protection of environment (Stafford Act section 316). United States Code, 2023 edition (GovInfo). Read October 2, 2026.
    8. [8]FEMA Statutory Exclusions. Federal Emergency Management Agency, June 20, 2020. Read October 2, 2026.
    9. [9]DHS Instruction Manual 023-01-001-01, Revision 01: Implementation of the National Environmental Policy Act (NEPA). U.S. Department of Homeland Security (hosted by FEMA). Read October 2, 2026.
    10. [10]FEMA Categorical Exclusions. Federal Emergency Management Agency, July 28, 2020. Read October 2, 2026.
    11. [11]42 U.S.C. 4336c - Adoption of categorical exclusions. United States Code, 2023 edition (GovInfo). Read October 2, 2026.
    12. [12]Notice of Adoption of Categorical Exclusions Under Section 109 of the National Environmental Policy Act, 90 FR 25350. Department of Homeland Security, Federal Register, June 16, 2025. Read October 2, 2026.
    13. [13]Notice of Adoption of Categorical Exclusions Under Section 109 of the National Environmental Policy Act, 91 FR 55104. Department of Homeland Security, Federal Register, August 26, 2026. Read October 2, 2026.
    14. [14]National Environmental Policy Act Repository. Federal Emergency Management Agency. Read October 2, 2026.
    15. [15]Finding of No Significant Impact: Miller St., Cross St., and Furnace Ave. Area Flood Control and Furnace Brook Restoration Project, Quincy, MA (DR-4051-MA-51). Federal Emergency Management Agency, October 26, 2020. Read October 3, 2026.
    16. [16]Environmental and Historic Preservation Screening Form (FEMA Form FF-207-FY-21-100). Federal Emergency Management Agency. Read October 2, 2026.

    Written by

    Ilya Volodarsky

    Ilya Volodarsky founded ePlan.ai. He co-founded Segment and is co-founder and CEO of Wildfires.org.

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    • It depends on scope, resources and consultations. In-kind repairs can move quickly under programmatic agreements; an EA or EIS adds public comment.

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