Integrating Environmental Review into the Temporary Group Housing Site Selection Process Federal Emergency Management Agency The purpose of this brochure is to introduce to federal, state, and local officials to the scope, concepts, issues, timing, and key FEMA staff to be contacted for integrating environmental review into the temporary group housing site selection process. Addressing the Need Temporary group housing sites are sometimes necessary when disaster events render homes uninhabitable for long periods, and when the preferred response of placing travel trailers or manufactured homes on the victim's individual property is infeasible. Environmental review, in combination with other feasibility studies, permits FEMA to expeditiously select and build temporary group housing sites for victims in physically and environmentally safe conditions, while complying with applicable federal laws. It is imperative to recognize that environmental considerations are in place not only to protect sensitive resources in the community. FEMA wants to ensure that disaster victims sing temporary housing are kept out of harms way (i.e. - in floodplains or near hazardous materials). CHALLENGES Understanding the level of need. Because disaster victims often seek immediate shelter with friends or relatives instead of at emergency shelters, a preliminary count of displaced people can be deceptively low. Also, typical public communication channels may be disrupted or nonexistent during disaster recovery efforts, slowing or stopping the flow of valid information about temporary group housing opportunities. Dealing with a lack of housing resources. For some communities, housing and rental shortages are a fact of life even during normal times. After a disaster, any vacancies come at a premium. A lack of rental resources during disaster recovery efforts may require implementation of the Manufactured Housing Program, with temporary group housing sites selected to locate travel trailers or mobile homes. Seemingly Ideal sites may have hidden problems. Sites that appear suitable may prove problematic from a design, engineering, or environmental standpoint after an environmental review has been completed. For example, a seemingly ideal temporary group housing site may be located in floodplain, contain wetlands, impact historic properties, or have hazardous materials contamination. Environmental Review Process: 1. Temporary Group Housing Site locations are proposed. 2. Conduct feasibility and environmental review 3. Present preliminary findings 4. Discuss showstoppers with FEMA, other federal and state agencies 5. No significant issues, proceed-Or-Address significant issues 6. Issue draft environmental review, issue public notice, minimum 72- hour public comment period begins 7. Revise draft environmental review if needed and finalize 8. Issue Finding of No Significant Impact and Notice to Proceed CONSIDERATIONS Identify multiple sites. – This is a critical first step, because disaster victims cannot afford the time delay if the primary site selected is determined not to be feasible for locating temporary housing. Evaluating multiple sites simultaneously provides timely options. Start early and inform others of environmental requirements. – To reduce both perceived and real timing issues, it is important to integrate environmental review with other site feasibility evaluations early in the site selection process. Address expectations – The expectations of agencies and officials can be better addressed by providing all involved with a clear understanding of the purpose and need for environmental review, along with a plan that highlights implementation strategies and timelines. This approach should also identify roles and responsibilities, and ways regulatory and review agencies can assist with the efforts. Coordination is critical – There will be federal, state, and local agencies and officials involved in the temporary group housing site selection process. As a rule, temporary housing initiatives are high stress situations. The potential sites must be identified, and the owners contacted to determine site availability and to obtain access to the site for evaluation. Each site must be proven to be technically and environmentally feasible, and available for development within a very short time frame. The public must receive notification of FEMA's plans to develop a site, and have the opportunity to comment on the proposal. Additionally, no site development or construction can occur until the environmental review has been completed, and the process has determined that the implementation of temporary group housing would not result in harm to disaster victims or significant environmental impacts. Legal Requirements The purpose of environmental review for temporary group housing sites is to ensure that FEMA is in compliance with the National Environmental Policy Act (NEPA) of 1969, and all applicable environmental regulations and executive orders. NEPA serves as the primary charter for protecting the nation's human environment and resources by establishing policies and sets goals concerning the environment. NEPA charges each federal agency with the responsibility of not only complying with the Act, but also to take initiatives through their regulations, strategies, and actions to protect, restore, and enhance the human environment. These legal requirements are set forth in Title 44 of the Code of Federal Regulations (44 CFR) Part 10, and available on the Internet at http://www.access.gpo.gov/nara/cfr/waisidx_00/44cfr10_00.html. The environmental review is most typically evaluated through the NEPA documentation process known as an Environmental Assessment (EA). The EA examines proposed actions of placing temporary group housing at a given site and alternative site, the natural resources present in the surrounding environment, and potential impacts that could result from the implementation of temporary group housing. There may be other levels of NEPA documentation based on the scope and location of the project, including Categorical Exclusion or an Environmental Impact Statement. Frequently Asked Questions In an emergency situation, why do we have to worry about the environment? Aren't people more important? In a truly critical situation, the lives and safety of people take precedent over environmental concerns, and environmental laws and regulations that support this premise. When there is time, however, we are required to assess the situation and make informed decisions that address immediate need and the long-term health and needs of our environment and communities. Who coordinates this environmental review? The Regional Environmental Officer, located in FEMA's Disaster Field Office, coordinates the environmental review and should be consulted anytime a disaster results in displaced victims that will require travel trailers or manufactured homes, and any time a site is being considered for the placement of temporary group housing. The Regional Environmental Officer will help provide input on scope, integration, and timing of the environmental review process. Why is coordination the key to a successful temporary housing program? Determining a site's engineering and environmental feasibility depends on reviews, permits, and clearances from many federal, state, and local agencies. Close coordination of all parties involved in the review process is crucial for expediting the environmental review and development of a site. By working together on site visits and data collection, problematic sites can be quickly identified and eliminated, and critical assessments can be made for those sites that have greater promise. How long does a typical environmental review for temporary group housing take? If the site is eligible for a Categorical Exclusion, the review can usually be accomplished in a few days. A more detailed environmental review, such as an Environmental Assessment typically takes 7-14 days. This time period includes initial site selection, environmental field and research investigations, creating the environmental review documentation, and a public comment period. Why is public comment required and important? NEPA and other laws were designed to make public participation part of the environmental review process. Once a draft NEPA document is published, the public is given an expedited period (as short as 72 hours) to provide comments on the document. Substantive comments received from the public must be addressed in a final NEPA document. What would happen if an environmental review were not conducted? Non-compliance with environmental laws and regulations can result in delay in delivering temporary group housing, the loss of funding for temporary group housing efforts, unfavorable media coverage, or lawsuits. What issues will the environmental review focus on? The environmental review examines the existing conditions of the environment, and addresses potential environmental impacts of the placement of temporary group housing on that particular site. The review includes looking at impacts to: - Hazardous materials. - Physical resources such as soils, geologic features, or groundwater; - Natural resources such as flora and fauna (including threatened and endangered species); - Historic and Cultural resources, which include archaeological sites; historic districts, sites, buildings, or structures; traditional cultural properties; or objects in or eligible for listing in the National Register of Historic Properties. - Socioeconomic issues, which address environmental justice and other potential impacts to social and economic resources of the community. What are the key steps in the environmental review process? One key step for conducting an environmental review involves obtaining legal rights of entry to the property in order to conduct a field assessment. Other key steps include reviewing the site from an engineering standpoint for soil or slope stability, infrastructure, accessibility, or past contamination. Observations and research findings are incorporated into the draft environmental review document. A public notice informs the community of the availability of the draft document for their review and comment. How is the environmental review process concluded? If through the NEPA review process it can be determined that no significant impacts would result from implementation of temporary group housing at a given site, a Finding of No Significant Impact (FONSI) is issued. However, if it is determined through the review process that victims would be put at risk or there would be a significant impact to the environment from the proposed action that could be mitigated, than an Environmental Impact Statement (EIS) must be conducted. Due to the emergency nature of disaster recovery operations, lengthy EISs are not feasible, and another site should be selected as a replacement. Regional Environmental Officer Contacts The following list of the Regional Environmental Officers should be notified concerning temporary housing site selection and the environmental review process. William Kennedy, FEMA Region I: Maine, New Hampshire, Vermont, Rhode Island, Connecticut, Massachusetts. Phone:(617) 223-9528 Email: william.kennedy@dhs.gov Robert Tranter, FEMA Region II: New York, New Jersey, the Commonwealth of Puerto Rico, U.S. Virgin Islands Territory. Phone:(212) 680-3628 Email: robert.tranter@dhs.gov Gene Gruber, FEMA Region III: District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Phone:(215) 931-5610 Email: gene.gruber@dhs.gov William Straw, FEMA Region IV: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee Phone:(770) 220-5432 Email: william.straw@dhs.gov Jeanne Millin, FEMA Region V: Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin Phone:(312) 408-5540 Email: jeanne.millin@dhs.gov Kyle Mills, FEMA Region VI: Arkansas, Louisiana, New Mexico, Oklahoma, Texas Phone:(940) 898-5134 Email: kyle.mills@dhs.gov Ken Sessa, FEMA Region VII: Iowa, Kansas, Missouri, Nebraska Phone:(816) 283-7960 Email: kenneth.sessa@dhs.gov Bob Cox, FEMA Region VIII: Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming Phone: (303) 235-4714 Email: bob.cox@dhs.gov Allessandro Amaglio, FEMA Region IX: Arizona, California, Hawaii Nevada; American Samoa, Guam, the Northern Mariana Islands, the Marshall Islands, the Federated States of Micronesia, and Palau Phone: (510) 627-7284 Email: allessandro.amaglio@dhs.gov Mark Eberlein, FEMA Region X: Alaska, Idaho, Oregon, Washington Phone: (425) 487-4735 Email: mark.eberlein@dhs.gov Brent Paul, FEMA Headquarters Phone: (202) 646-3032 Email: brent.paul@dhs.gov For more information, please visit the FEMA National Environmental Website at: www.fema.gov/mit/ep/envhome.htm