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.

PAPPG at 85; 108; 166.Metro. St. Louis Sewer Dist.; FEMA-4250-DR-MO; at 3.HeadnotesFEMA 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.Conclusion