FEMA must complete all necessary EHP reviews before an applicant starts work. When an applicant initiates or completes work on a project before FEMA is able to conduct the necessary EHP compliance review, the work generally is not eligible for PA funding. The Applicant disturbed archaeologically sensitive ground in the course of completing its repairs prior to consultation with the SHPO, as was required by the National Historic Preservation Act, preventing FEMA from completing its required EHP compliance review.

The Applicant did not afford FEMA an opportunity to complete its EHP review prior to starting work on its project. Accordingly, the appeal is denied.

Stafford Act § 316. National Historic Preservation Act § 106. 36 C.F.R. § 800.4. 44 C.F.R. § 206.220. PAPPG at 85, 108, 166. Metro. St. Louis Sewer Dist., FEMA-4250-DR-MO, at 3.