Lesson 4 Overview and Objectives

This lesson discusses key stakeholders and resources for environmental and historic preservation coordination. The lesson also covers FEMA/Recipient Disaster Greensheets, Greensheet content, and examples of stakeholder contact information that appears on the Disaster Greensheet.

At the end of this lesson, participants will be able to:

  • Identify key stakeholders and resources at the Recipient and Federal level
  • Describe the coordinating activities with partner agencies to ensure environmental and historic preservation compliance
  • Explain the function, purpose, and information contained in FEMA/Recipient Greensheets
Key Stakeholders and Resources for Environmental and Historic Preservation Coordination (1 of 2)

To maintain seamless communication and coordination on grant projects, Applicants will coordinate with the Recipient and a FEMA Program Delivery Manager throughout all phases of the Public Assistance grant development process. The FEMA Program Delivery Manager will coordinate with FEMA Environmental and Historic Preservation staff to ensure that environmental and historic preservation compliance requirements are met.

When necessary or upon request of the Applicant, the FEMA Program Delivery Manager will also coordinate FEMA Environmental and Historic Preservation Staff to communicate with and support Applicants during meetings and site visits to support the Applicant.

Two women shaking hands at a business meeting
Key Stakeholders and Resources for Environmental and Historic Preservation Coordination (2 of 2)

During the Recovery Scoping Meeting, the Applicant will receive a Greensheet from the FEMA Joint Field Office's Environmental and Historic Preservation Staff. The Greensheet is published by FEMA upon declaration of a national disaster in close coordination with the Recipient.

The Greensheet briefs the Applicant regarding potential environmental and historic preservation considerations within the declared area and compliance requirements tied to these considerations. The Greensheet also identifies Federal and Recipient stakeholders relevant to the specific disaster.

Federal Stakeholders

The Applicant will coordinate with all regulatory agencies to obtain appropriate permits or letters for compliance concerns. FEMA will coordinate with regulatory and management agencies, including Tribal groups to consider consequences of the actions.

The Applicant should utilize the Greensheet to support the recovery operation while communicating with the applicable Recipient/Federal stakeholders identified on the Greensheet and maintaining continuous coordination and communication with FEMA Program Delivery Managers, who will engage the FEMA Environmental and Historic Preservation staff to support needs. Continuous communication and coordination ensures environmental and historic preservation compliance throughout the Public Assistance grants process.

U.S. Fish and Wildlife Service logo, Department of the Interior
Examples of Federal Agency Stakeholder Coordination

Stakeholder coordination will be necessary to receive Public Assistance funding for any project and will also be needed throughout the entire grant program lifecycle. Stakeholder coordination for environmental and historic preservation compliance will include the following types of tasks:

  • Monitoring and tracking compliance
  • Determining project-specific conditions
  • Supporting written documentation
  • Consulting with interested parties
The Applicant is responsible for obtaining clearance to proceed with the scope of work from respective regulatory agencies in the form of a permit or letter/email. FEMA’s coordination with partner agencies is to consider the consequences resulting from scope of work on protected resources. FEMA stipulates conditions on grants because of concerns for protected resources as present by the partner agencies.
A person's hand signing a document with a pen
Example of Federal Agency Stakeholder Coordination: Monitoring and Tracking Compliance (1 of 2)

Here is an example of the stakeholder coordination involved with monitoring and tracking compliance:

A major disaster has occurred within a community. The event has generated an extensive quantity of debris. The Applicant is executing their Debris Management Plan and has a properly procured contractor to remove the debris. The Applicant is also opening a temporary staging and reduction site area where debris will be managed. Vegetative debris will be burned as the method of reduction.

The Applicant will need to do the following as a program monitoring and tracking requirement and to show environmental and historic preservation compliance:

  1. Debris trucks will need to be monitored to ensure the debris collected is in the public right of way or in public spaces with no additional impact to the environment or historical interests.
  2. Debris will be hauled to the established Temporary Debris Staging Site.
  3. The Applicant must obtain a permit from the Recipient's Department of Environmental Protection or Department of Natural Resources prior to opening the site to demonstrate no environmental impact.
Example of Federal Agency Stakeholder Coordination: Monitoring and Tracking Compliance (2 of 2)
  1. Debris will need to be measured by weight or estimated cubic yardage entering the Temporary Debris Staging Site where it will then be reduced.
  2. For reduction, additional considerations apply, and the Applicant should consult with their respective Recipient agencies and obtain appropriate permits.
    • For this example: The Applicant has selected to burn vegetative debris at the site and haul away the ash
    • The Applicant must obtain from a State environmental regulatory agency for waste management a burn permit
  3. The Applicant will need to close the temporary staging in compliance with the regulatory agency and obtain documentation from agency that staging area was appropriately closed.
    • The Applicant is responsible for providing documentation that the debris went to a permitted landfill site
    • Debris operations stipulate that the Applicant will be responsible for demonstrating compliance and disclosing records of compliance, including the removal efforts used from beginning to end of the project through monitored, tracked, and permitted work
Example of Federal Agency Stakeholder Coordination: Determining Hazard Mitigation Incident-Specific Conditions

A community has had an issue with a 36-inch diameter culvert pipe, which continues to wash out and destroy the road during every significant rainfall event. The road accesses a community with several dozen homes. The residents are continuously frustrated with their loss of access out of the neighborhood. The Applicant's road department is continuously frustrated with the constant repair and expense.

The latest round of storms has resulted in a FEMA Public Assistance major disaster declaration. As a method of repair, the Applicant plans to request a hazard mitigation proposal to elevate the roadway and install a 72-inch diameter culvert pipe to handle more water and prevent future washout.

The new culvert is double the size of the existing one and to complete the work, a hydrologic and hydraulic study needs to be completed. The purpose of the hydrologic and hydraulic study is to identify any potential impacts to the overall drainage and hydrology at the site or in the surrounding areas upstream and downstream. If the hydrologic and hydraulic study shows there are impacts to other areas upstream or downstream, then hazard mitigation proposal would need to be revised to ensure that there are no impacts.

Visit Independent Study Course IS-1014 Integrating 406 Mitigation Considerations into Your Public Assistance Grant course which provides additional information and guidance related to the 406 Hazard Mitigation Program.

Example of Federal Agency Stakeholder Coordination: Supporting Written Documentation

A recent flash flood event had county wide impacts to include the rural areas. The rural areas are comprised of miles of gravel roads and many roadways were completely washed out. As a result, a significant amount of gravel will need to be applied to the roads to restore to pre-disaster condition.

The Applicant proceeds to do the work and supplies invoices for the repairs during Public Assistance grant development. A review of the invoices show that the material purchased was washed river rock. The invoice indicates that the material may have been excavated from a body of water. The Applicant will need to demonstrate the location of the quarry and for materials excavated from a water source, disclose permits to excavate the rock.

Example of Federal Agency Stakeholder Coordination: Consulting with Interested Parties (1 of 2)

An example of statutory exclusion pursuant to the National Historic Preservation act for protection of life and property – emergency situation.

During the recent severe weather outbreak, an EF4 rated tornado moved directly through the center of town. Prior to the disaster, the Applicant had purchased the old Coca-Cola bottling plant (built in 1909) and converted it into a functioning community and event center. The impact of the tornado destroyed the roof and collapsed two of the four exterior walls.

A county engineer has assessed the site and determined the remaining two walls are imminent collapse hazards. The remaining two walls parallel a public sidewalk and the Applicant initially considers sending the public works crew to the site to knock down the remaining two walls to render the site safe. Prior to doing so, the Applicant representative contacts the Program Delivery Manager. The Program Delivery Manager arranges a site visit with the Environmental and Historic Preservation staff, who document the site and initiate coordination with the State Historic Preservation Office.

Example of Federal Agency Stakeholder Coordination: Consulting with Interested Parties (2 of 2)

The State Historic Preservation Office, along with FEMA environmental and historic preservation staff provides the Applicant with the following guidance during that call:

  1. The Applicant must postpone demolition for the building and its damage to be properly photographed and documented for the State historical archives
  2. To render the site safe, the State Historic Preservation Office advises the Applicant to fence off the area a safe distance from the collapse hazard to eliminate the threat
  3. Guidance is provided for the salvage of any usable materials or components of the destroyed building for possible repurposing or reuse.
In addition, during the design and reconstruction of the building, the Applicant works with the State Historic Preservation Office in constructing a new building that is similar in appearance and re-integrates salvaged items from the destroyed building.
FEMA/Recipient Disaster Greensheets

As discussed previously, FEMA will prepare a Greensheet specific to every Presidentially-declared emergency or disaster. The Greensheets state that projects must be reviewed for compliance with all applicable environmental laws, regulations, and Executive Orders as a condition of FEMA funding.

The Greensheet provides the Applicant with guidance on FEMA's environmental and historic preservation review processes to help the Applicant understand their obligations for ensuring that all Federal and State compliance requirements are met and how compliance may impact project funding.

The Greensheet is one of the key resources an Applicant can use, along with coordinating with the FEMA Public Assistance Program Delivery Manager, to engage FEMA Environmental and Historic Preservation staff support, answer questions and direct Applicants to other resources as needed.

Select this link to view an example of a Greensheet: https://www.fema.gov/media-library-data/1454431073752-f9235b8f1fd990025dfdcd6afc8d7399/Greensheet4222-DR-OK508.pdf

The first page of a FEMA Greensheet. Select the link on the screen for full image description.
Greensheet Example (1 of 3)

Each page of the Greensheet will be reviewed in detail. Note that each Greensheet is disaster specific and will identify different stakeholders. The Greensheet will also contain different sections based on the specific area of the disaster.

The first page of the Greensheet may look similar to this one. The first section of the Greensheet explains that the purpose of the document is to provide Applicants with guidance on FEMA's environmental and historic preservation review process.

The first page of a FEMA Greensheet, with highlighting around the Environmental and Historic Preservation Guidance section. The highlighted section is written out within the screen text.
Greensheet Example (2 of 3)

Greensheets will include a section describing the Federal laws and Executive Orders affecting the area, such as the one shown here.

The laws and orders applicable to this Greensheet include:

  • National Environmental Policy Act
  • National Historic Preservation Act
  • Clean Water Act
  • Endangered Species Act
  • Coastal Zone Management Act
  • Coastal Barrier Resources Act
  • Executive Order 11988 Floodplain Management
  • Executive Order 11990 Wetlands Protection
  • Federal Funding
The first page of a FEMA Greensheet, with highlighting around the Federal Laws and Executive Orders section. The highlighted section is written out within the screen text.
Greensheet Example (3 of 3)

The Environmental Compliance and Federal Funding section of this Greensheet states that:

The National Environmental Policy Act requires Federal Agencies to assess the environmental effects of their actions, such as funding disaster recovery projects, prior to making funding decisions. The National Environmental Policy Act incorporates the other environmental and historic preservation laws into the final consideration of the proposed project or its potential alternatives.

A clear scope of work is needed to determine the level of review required under the National Environmental Policy Act, which can impact project timelines. Some projects may require additional regulatory permitting or consultation with State, Federal, or Tribal entities. FEMA Environmental and Historical Preservations staff will advise Applicants on what to expect during the review process.

This guidance includes information regarding many, but not all, of the laws routinely addressed during disaster recovery project review. Applicant has several compliance responsibilities which may be required before funding can be approved or work can proceed. Failure to comply with applicable Federal, State, and local environmental and historic preservation laws could delay or jeopardize potential funding.

The first page of a FEMA Greensheet, with highlighting around the Environmental Compliance and Federal Funding section. The highlighted section is written out within the screen text.
Lesson 4 Summary

In this lesson, you learned how to:

  • Identify key stakeholders and resources at the Recipient and Federal level
  • Describe the coordinating activities with partner agencies to ensure environmental and historic preservation compliance
  • Explain the function, purpose, and information contained in FEMA/Recipient Greensheets

The next lesson will provide a review of course objectives from each lesson.