FEMA must review each PA project to ensure that the work complies with applicable federal EHP laws; their implementing regulations; and applicable Executive Orders. If an applicant begins construction work on a project before FEMA is able to conduct its EHP review; the applicant will jeopardize PA funding for the project because FEMA generally cannot conduct consultation with resource agencies after the applicant initiates work on a project as those agencies lose the ability to consider alternatives that would avoid; minimize; or mitigate adverse effects to the environment or historic properties.The Applicant has completed or substantially completed work without presenting documentation to demonstrate EHP compliance and without providing FEMA an opportunity to conduct the necessary EHP compliance review.The Applicant did not afford FEMA an opportunity to complete its EHP review prior to starting work on the project; and the Applicant has not provided documentation demonstrating compliance with EHP requirements to prevent adverse consequences for activities within a floodplain. Therefore; this appeal is denied.

HeadnotesFEMA must review each PA project to ensure that the work complies with applicable federal EHP laws; their implementing regulations; and applicable Executive Orders. If an applicant begins construction work on a project before FEMA is able to conduct its EHP review; the applicant will jeopardize PA funding for the project because FEMA generally cannot conduct consultation with resource agencies after the applicant initiates work on a project as those agencies lose the ability to consider alternatives that would avoid; minimize; or mitigate adverse effects to the environment or historic properties.The Applicant has completed or substantially completed work without presenting documentation to demonstrate EHP compliance and without providing FEMA an opportunity to conduct the necessary EHP compliance review.ConclusionThe Applicant did not afford FEMA an opportunity to complete its EHP review prior to starting work on the project; and the Applicant has not provided documentation demonstrating compliance with EHP requirements to prevent adverse consequences for activities within a floodplain. Therefore; this appeal is denied.