NHPA 106 and its implementing regulations impose consultation procedures for federally funded projects with potential to affect historic properties. When an applicant initiates or completes work on a project before FEMA is able to conduct the necessary EHP compliance review; it jeopardizes Public Assistance (PA) funding for the project.The Applicant did not afford FEMA an opportunity to complete the EHP review prior to commencing the debris removal work; and FEMA could not ensure compliance with section 106 of the NHPA.

PAPPG; at 141-142.HeadnotesNHPA § 106 and its implementing regulations impose consultation procedures for federally funded projects with potential to affect historic properties. When an applicant initiates or completes work on a project before FEMA is able to conduct the necessary EHP compliance review; it jeopardizes Public Assistance (PA) funding for the project.The Applicant did not afford FEMA an opportunity to complete the EHP review prior to commencing the debris removal work; and FEMA could not ensure compliance with section 106 of the NHPA.Conclusion