Coronavirus (COVID-19) Pandemic: Environmental and Historic Preservation and Emergency Protective Measures

Release Date:
April 13, 2020

Environmental and Historic Preservation Compliance and Conditions

The Office of Environmental Planning and Historic Preservation is committed to facilitating timely and prompt compliance reviews for COVID-19 activities. This includes identifying activity types where the applicant will need to provide minimal information or documentation in order to conduct an environmental and historic preservation review.

Although certain emergency protective measures are statutorily exempted from review under the National Environmental Policy Act, these actions may still require review for compliance with other environmental and historic preservation laws, regulations, and executive orders. For activities where there is potential to adversely affect natural, historic, and/or archaeological resources, OEHP is working with other federal agency partners to streamline environmental and historic preservation compliance through a programmatic approach.

Applicants are responsible for completing activities in a manner that complies with all state and local guidelines and for obtaining all necessary permits. Work in violation of local, state, or federal laws, regulations, and executive orders may be ineligible for FEMA funding. Additionally, non-compliance with environmental and historic preservation conditions associated with individual projects may jeopardize receipt of federal funding.

COVID-19 EHP Considerations

The Public Assistance Program at FEMA will fund eligible emergency protective measures taken by a community to save lives, protect property and public health and safety, and lessen or avert the threat of a catastrophe. While the list of eligible activities includes actions that do not affect the environment (such as provision of personnel, supplies, and equipment), there are activities associated that do have the potential to adversely affect natural, historic, and/or archaeological resources. Examples are:

  • Repurposing, renovating, or reusing existing facilities as temporary medical or sheltering facilities
  • Placement of prefabricated facilities on a site
  • Construction of new temporary medical or sheltering facilities
  • Storage of human remains and mass mortuary services
  • Staging resources on an undeveloped site
  • Proper disposal of medical waste

Environmental and Historic Preservation Information Requirements

For projects that do have the potential to adversely affect natural, historic, and/or archaeological resources, Applicants should be prepared to provide the following:

  • Location of the work, including and latitude/longitude in decimal degrees (to the fifth decimal point) and site address. Maps or aerial imagery of the project area is also helpful.
  • Description of any ground-disturbing activities, including site preparation, laying new or expanding existing utilities, and expansion of existing footprints.
  • Dates of construction for facilities that are being reused, repurposed, or renovated.
  • Description of modifications made to existing facilities.
  • Photographs of the project site or facility.

Best Practices for Temporary Facilities

Responding to the COVID-19 pandemic may require repurposing, renovating, or reusing existing facilities, the placement of prefabricated facilities on a site, or the construction of new temporary facilities. In order to minimize potential impacts or effects to natural and cultural resources, minority populations, and low-income populations, states, tribes, communities, and applicants should consider the following:  

  • Avoid placement of temporary facilities in flood hazard areas and wetlands. While we recognize that the construction of temporary facilities may be necessary, the disruption of relocating these facilities in the future due to flooding—especially when occupants may not be sufficiently mobile—is too great of a risk.
  • Avoid placement of temporary facilities in brownfields and other use restricted sites. While we recognize that the construction of temporary medical facilities may be necessary, we also recognize the health risks of the occupants, medical providers, and construction workers and short- and long-term health risks associated with exposure to chemicals.
  • Ensure accessibility across the full range of clients and/or customers that need to utilize the services being provided by these facilities, including elements of the population with less capacity or mobility.
  • Select pre-disturbed sites or existing hardened surfaces, such as parking lots, concrete pads, or artificial playing fields, whenever possible. Previously disturbed areas typically have critical infrastructure such as electricity, water, sewer, and other amenities already onsite or easily accessible nearby, which will minimize ground disturbance.
  • Avoid new ground disturbance when possible. Should ground disturbance reveal archaeological resources, notify FEMA and State Historic Preservation Officer/Tribal Historic Preservation Officer immediately.
  • If renovation of a facility is required, consider the impacts of renovation (e.g. exposure to asbestos, lead-based paint, or other environmental contaminants associated with past use of the property) on the health of occupants, medical providers, and construction workers.
  • Document conditions by taking photographs before and after any work is carried out.

Best Practices for Disposal of Medical Waste

FEMA recognizes that the COVID-19 response may result in the need for the disposal of medical waste. FEMA advises States, Tribes, and communities, and Applicants to:

  • Follow state and local laws for disposal of medical waste.
  • If disposing of medical waste, indicate if an existing site will be used.
  • If a new disposal site is created, indicate if the waste will be landfilled or incinerated.

Best Practices for Decontamination Activities

FEMA recognizes that decontamination activities such as spraying down of facilities and the operation of decontamination stations may be necessary for public health and safety. FEMA advises states, tribes, communities and applicants to:

  • Avoid/minimize run-off/disposal that enters stormwater systems or open waters.

Additional Resources

For more information, visit the Office of Environmental Planning and Historic Preservation on    

For more information about FEMA’s Public Assistance Program and the COVID-19 response, contact your State Emergency Management Agency or tribal office or visit

Last updated March 17, 2021