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allowable. That is, an employee of a unit of government may not receive
compensation from their unit or agency of government AND from an award for a single period of
time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities.
• Travel. Travel costs (e.g., airfare, mileage, per diem, hotel) are allowable as expenses by
employees who are on travel status for official business related to approved training.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full- or part-time staff may be
hired to support direct training-related activities. Payment of salaries and fringe benefits must be
in accordance with the policies of the State or unit(s) of local government and have the approval
of the State or awarding agency, whichever is applicable.
• Certification/Recertification of Instructors. Costs associated with the certification and re-
certification of instructors are allowed. States are encouraged to follow the FEMA Instructor
Quality Assurance Program to ensure a minimum level of competency and corresponding levels
of evaluation of student learning. This is particularly important for those courses which involve
training of trainers.
D. Exercises
All EMPG Program funded personnel are REQUIRED to participate in no less than three
exercises in a 12 month period. One real world event can count towards meeting this
requirement. (see Attachment D, #2)
Allowable exercise-related costs include:
• Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs
related to planning, meeting space and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Grantees are encouraged to use free public
space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.
Exercises should provide the opportunity to demonstrate and validate skills learned, as well as to
identify any gaps in these skills. Any exercise or exercise gaps, including those for children and
individuals with disabilities or access and functional needs, should be identified in the AAR/IP and
addressed in the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full- or part – time staff may be
hired to support direct exercise activities. Payment of salaries and fringe benefits must be in
accordance with the policies of the State or unit(s) of local government and have the approval of
the State or the awarding agency, whichever is applicable. The services of
contractors/consultants may also be procured to support the design, development, conduct and
evaluation of exercises.
• Overtime and Backfill. The entire amount of overtime costs, including payments related to
backfilling personnel, which are the direct result of time spent on the design, development and
conduct of exercises are allowable expenses. These costs are allowed only to the extent the
payment for such services is in accordance with the policies of the State or unit(s) of local
government and has the approval of the State or the awarding agency, whichever is applicable. In
no case is dual compensation allowable. That is, an employee of a unit of government may not
receive compensation from their unit or agency of government AND from an award for a single
period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities.
• Travel. Travel costs (e.g., airfare, mileage, per diem, hotel) are allowable as expenses by
employees who are on travel status for official business related to the planning and conduct of the
exercise activities
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• Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise activities (e.g., gloves, non-sterile masks, and disposable protective
equipment)
• Implementation of HSEEP. This refers to costs related to developing and maintaining a self-
sustaining State HSEEP which is modeled after the national HSEEP
• Other Items. These costs are limited to items consumed in direct support of exercise activities
such as the rental of space/locations for planning and conducting an exercise, rental of
equipment, and the procurement of other essential nondurable goods. Grantees are encouraged
to use free public space/locations, whenever available, prior to the rental of space/locations.
Costs associated with inclusive practices and the provision of reasonable accommodations and
modifications that facilitate full access for children and adults with disabilities.
Unauthorized exercise-related costs include:
• Reimbursement for the maintenance and/or wear and tear costs of general use vehicles (e.g.,
construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances). The
only vehicle costs that are reimbursable are fuel/gasoline or mileage.
• Equipment that is purchased for permanent installation and/or use, beyond the scope of exercise
conduct (e.g., electronic messaging signs)
• Durable and non-durable goods purchased for installation and/or use beyond the scope of
exercise conduct
E. Equipment
Allowable equipment categories for the EMPG Program are listed on the web-based version of the
Authorized Equipment List (AEL) on the Responder Knowledge Base (RKB), which is sponsored by
FEMA at http://www.llis.dhs.gov/knowledgebase. Unless otherwise stated, equipment must meet all
mandatory regulatory and/or FEMA-adopted standards to be eligible for purchase using these funds.
In addition, counties will be responsible for obtaining and maintaining all necessary certifications and
licenses for the requested equipment.
The select allowable equipment includes equipment from the following AEL categories:
• Information Technology (Category 4)
• Cyber-Security Enhancement Equipment (Category 5)
• Interoperable Communications Equipment (Category 6)
• Detection Equipment (Category 7)
• Power Equipment (Category 10)
• Chemical, Biological, Radiological, Nuclear, and Explosive (CBRNE) Reference Materials
(Category 11)
• CBRNE Incident Response Vehicles (Category 12)
• Physical Security Enhancement Equipment (Category 14)
• CBRNE Logistical Support Equipment (Category 19)
• Other Authorized Equipment (Category 21)
In addition to the above, general purpose vehicles (such as sports utility vehicles) are allowed to be
procured in order to carry out the responsibilities of the EMPG Program. If State agencies and/or local
governments have questions concerning the eligibility of equipment not specifically addressed in the
AEL, they should contact their contract manager who will coordinate with the FEMA Regional
Program Analyst for clarification.
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F. Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of EMPG
Program funds, such as financial management and monitoring. It should be noted that salaries of
State and local emergency managers are not typically categorized as M&A, unless the State or local
EMA chooses to assign personnel to specific M&A activities.
II. EHP
Recipients must comply with all applicable EHP laws, regulations, and Executive Orders (EOs) in
order to draw down their FY 2014 EMPG Program grant funds. Any project with the potential to
impact natural resources or historic properties cannot be initiated until FEMA has completed the
required FEMA EHP review. Recipients that implement projects prior to receiving EHP approval from
FEMA risk de-obligation of funds. For these types of projects, Recipients must complete the FEMA
EHP Screening Form (OMB Number 1660-0115/FEMA Form 024-0-01) and submit it, with all
supporting documentation to their Contract Manager. Recipients should submit the FEMA EHP
Screening Form for each project as soon as possible upon receiving their grant award. The Screening
Form must be submitted prior to funds being expended. Refer to IBs 329, 345, and 356.
EHP Policy Guidance can be found in FP 108-023-1, Environmental Planning and Historic
Preservation Policy Guidance, at http://www.fema.gov/media-library/assets/documents/85376.
The following types of EMPG projects are to be submitted to FEMA for compliance review under EHP
laws and requirements prior to initiation of the project:
Any involvement with the installation of equipment,
Ground-disturbing activities,
New construction (installation and renovation), including communication towers, or
modification/renovation of existing buildings or structures
Proposed construction or renovation projects that are part of larger projects funded from a
non-FEMA source (such as an EOC that is part of a larger proposed public safety complex)
Renovation of and modification to buildings and structures that are 50 years old or older
Any other construction or renovation efforts that change or expand the footprint of a facility
or structure including security enhancements to improve perimeter security
Physical Security Enhancements, including but not limited to:
Lighting
Fencing
Closed-circuit television (CCTV) systems
Motion detection systems
Barriers, doors, gates and related security enhancements
Field based training and exercises including activities that involve ground disturbance, use
of explosives, toxic agents or otherwise have the potential to cause impact to the
environment or historical resources. This is only a requirement if the exercise or field
training is not being conducted by a certified professional or at an existing facility with
established procedures.
Communication tower projects
The following activities do not require the submission of the FEMA EHP Screening Form: planning
and development of policies or processes; management and administration; classroom-based
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training; table top exercises and functional exercises; and, acquisition of mobile and portable
equipment (no installation).
All recipients of financial assistance will comply with the requirements of the NEPA, as amended, 42
U.S.C. §4331 et seq., which establishes national policy goals and procedures to protect and enhance
the environment, including protection against natural disasters. To comply with NEPA for its grant-
supported activities, DHS requires the environmental aspects of construction grants (and certain non-
construction projects as specified by the component and awarding office) to be reviewed and
evaluated before final action on the application.
For more information on FEMA’s EHP requirements, see Informational Bulletins below”
Information Bulletin 329, Environmental Planning and Historic Preservation Requirements for
Grants, available at http://www.fema.gov/pdf/government/grant/bulletins/info329.pdf;
Information Bulletin 345, Programmatic Environmental Assessment, available at
http://www.fema.gov/pdf/government/grant/bulletins/info345.pdf; and
Information Bulletin 356, EHP Screening Form, available at
http://www.fema.gov/pdf/government/grant/bulletins/info356.pdf.
III. Construction and Renovation
Construction and renovation activities for a local government’s EOC as defined by the SAA are
