properties have been taken into account in the NEPA process.

Infrastructure

Infrastructure consists of the systems and physical structures that
enable a population in a specified area to function. Infrastructure by
definition includes a broad array of facilities (e.g., utility systems,
streets, highways, railroads, airports, ports, bridges, buildings and
structures, and other man-made facilities). Individuals, businesses,
governmental entities, and virtually all relationships between these
groups depend upon this infrastructure for their most basic needs, as
well as for critical and advanced needs (e.g., emergency response and
health care). Section 5195c(e) of Title 42 of the U.S. Code defines
critical infrastructure (CI) as the assets, systems, and networks,
whether physical or virtual, so vital to the US that their
incapacitation or destruction would have a debilitating effect on
security, national economic security, public health or safety, or a
combination of these. Section 101(10) of Title 6 of the U.S. Code
defines key resources as publicly or privately controlled resources
essential to the minimal operations of the economy and government.

Infrastructure is entirely man-made, with a high correlation between the
type and extent of infrastructure and the degree to which an area is
characterized as “developed.” An essential component of economic
growth to an area is the availability of infrastructure and its capacity
to support growth. Infrastructure components typically include utilities
(electricity and communications), solid waste, and the transportation
network.

Transportation

Potential sites addressed by this PEA can be located in any type of
area: urban, suburban, rural, or remote.  The transportation facilities
that serve these different types of locations can vary widely. Urban
areas are generally characterized by a complex and extensive system of
roads, including major interstate freeways and surface streets.  Urban
roads typically support high levels of traffic, which often result in
roadway segment and intersection congestion.  Rural environments can be
characterized by fewer roads and roads that are frequently graveled
instead of paved.  Generally, traffic levels on rural roads are
relatively low (i.e., little or no congestion).  Remote areas may have
no maintained roadways, but instead, only hiking or all-terrain vehicle
trails.

Solid Waste

Solid waste, more commonly known as trash or garbage, consists of
everyday items such as product packaging, grass clippings, furniture,
clothing, bottles, food scraps, newspapers, appliances, paint, and
batteries.  Projects that have the potential to generate large amounts
of solid waste may impact a community’s ability to properly manage and
dispose of waste.  Projects proposed to take place in communities with
insufficient solid waste management capacity may need to create a plan
to address this issue.

Communication Infrastructure

The use of the 700 MHz and 800 MHz frequency spectrum for communication
systems is regulated by the Federal Communications Commission (FCC).
Operators must obtain a FCC license to operate a communication tower
using these frequencies. The issuance of an FCC license is a Federal
action that triggers NEPA, Section 106 of NHPA, Section 7 of ESA and
other similar environmental laws. The FCC regulations at 47 CFR Part 17
prescribes procedures for antenna structure registration and requires
the Federal Aviation Administration (FAA) to conduct an aeronautical
study of the navigation air space to determine appropriate tower marking
and lighting requirements to achieve safe air space. Before the FCC
authorizes the construction of new antenna structures or alteration in
the height of existing antenna structures, an FAA determination of “no
hazard” is required if the structure will affect navigable air space
within a certain distance of an airport, heliport, or military base. FAA
notification is required for any new construction greater than 200 feet
AGL, and near an airport runway (taller than 100:1 for a horizontal
distance of 20,000 feet, 50:1 for a horizontal distance of 10,000 feet,
and 25:1 for a horizontal distance of 5,000 feet of a heliport). By
checking the heights of proposed antennae and their proximity to
airports, the FCC’s TOWAIR software system assists in determining if
FAA notification is required. The FAA can vary marking and lighting
recommendations when requested, provided that aviation safety is not
compromised. In all cases, safe aviation conditions around the tower are
the FCC’s primary concern, and safety concerns dictate the marking and
lighting requirements. Navigation air space, which starts at 200 feet
above the ground, decreases in elevation in close proximity to airports;
the minimum height for required marking or lighting would decrease in
these areas.

The FCC has entered into two Nationwide Programmatic Agreements (PA)
that exclude some FCC undertaking associated with the licensing of these
structures from the Section 106 review process and streamlines the
Section 106 consultation process for those undertakings not excluded.
The PAs are titled Nationwide Programmatic Agreement for Review of
Effects on Historic Properties for Certain Undertakings Approved by the
Federal Communications Commission (September 2004), and Nationwide
Programmatic Agreement for the Co-location of Wireless Antennas (March
2001). On September 17, 209 the ACHP issued a Draft Program Comment to
the two FCC Nationwide PAs establishing that USDA’s Rural Utilities
Service and Department of Commerce’s National Telecommunications and
Information Administration (NTIA) would not need to comply with Section
106 for communication facilities construction or modification that have
undergone or would undergo Section 106 review, or that are exempt from
Section 106 review, by the FCC under the two Nationwide Programmatic
Agreements. The Federal Register notice (74 Fed. Reg. 47807, Sept. 17
2009) can be found in Appendix I of this PEA. FEMA provided comments to
the ACHP requesting FEMA to be included in the scope of the Program
Comment. See Appendix J. As a result, the ACHP included FEMA in the
Final Program Comment. See Appendix K. This Program Comment became
effective October 23, 2009 and will be available until September 30,
2015.

The FCC has also developed a voluntary Tower Construction Notification
System (TCNS) that allows proponents of new towers to provide notice of
their proposal to participating Indian tribes and Native Hawaiian
Organizations (NHO). The TCNS facilitates the identification of, and
appropriate initial contact with, Indian tribes and NHOs that may attach
religious and cultural significance to historic properties within the
geographic area of the proposed undertaking. Once notified, Indian
tribes and NHOs have the option of responding to applicants through the
TCNS. The FCC retains the responsibility to engage in
government-to-government consultation with the interested tribe or NHO.

FEMA recognizes that there are other Federal, State, Tribal and
Territory public safety interoperability-related activities such as the
FCC’s public safety initiatives, the NTIA’s Public Safety
Interoperable Communications Grant Program (PSIC), and the RUS programs.
These programs are part of a Nationwide effort to improve
interoperability within the emergency preparedness and response
community. Grantees and subgrantees have the ability to leverage these
different programs within their jurisdictions to achieve their overall
public safety interoperability goals. Thus, there is a potential for
some GPD-funded actions under this project type to be connected with
other Federal and non-Federal funded actions.

Air Quality

The EPA has established primary and secondary National Ambient Air
Quality Standards (NAAQS) under the provisions of the Clean Air Act
(CAA) of 1970 (42 U.S.C. § 7401 et seq.).  The CAA not only established
the NAAQS, but also set emission limits for certain air pollutants from
specific sources, set new source performance standards based on best
demonstrated technologies, and established national emissions standards
for hazardous air pollutants.

The EPA classifies the air quality within an air quality control region
(AQCR) according to whether the region meets or exceeds Federal primary
and secondary NAAQS.  Primary standards define levels of air quality
necessary to protect public health with an adequate margin of safety.
Secondary standards define levels of air quality necessary to protect
public welfare (i.e., soils, vegetation, and wildlife) from any known or
anticipated adverse impacts of a pollutant.  Federal NAAQS are currently
established for the following seven pollutants (known as “criteria
pollutants”): carbon monoxide (CO), nitrogen dioxide (NO2), ozone
(O3), sulfur dioxide (SO2), lead (Pb), particulate matter equal to or
less than 10 micrometers in aerodynamic diameter (PM10), and particulate
matter equal to or less than 2.5 micrometers in aerodynamic diameter
(PM2.5).  Table 4-1 shows the NAAQS.

Table 4-1:  National Ambient Air Quality Standards (NAAQS)

Pollutant	Primary Standards	Secondary Standards

	Level	Averaging Time	Level	Averaging Time

Carbon Monoxide (CO)	9 ppm

(10 milligrams/ m3 [mg/m3])	8 hours	None

	35 ppm

(40 mg/m3)	1 hour

	Lead (Pb)	0.15 µg/m3	Rolling 3-month average	Same as primary

	1.5 µg/m3	Quarterly average	Same as primary

Nitrogen Dioxide (NO2)	0.053 ppm

(100 µg/m3)	Annual

(arithmetic mean)	Same as primary

Particulate Matter (PM10)	150 µg/m3	24 hours	Same as primary

Particulate Matter (PM2.5)	15.0 µg/m3	Annual

(arithmetic mean)	Same as primary

	35 µg/m3	24 hours	Same as primary

Ozone (O3)	0.075 ppm (2008 std)	8 hours	Same as primary

	0.08 ppm (1997 std)	8 hours 	Same as primary

	0.12 ppm	1 hour (applies only in limited areas)	Same as primary

Sulfur Dioxide (SO2)	0.03 ppm	Annual

(arithmetic mean)	0.5 ppm

(1300 µg/m3)	3-hours

	0.14 ppm	24-hours

Source: EPA 2008a

Air quality is affected by both stationary sources (e.g., urban and
industrial developments) and mobile sources (e.g., automobiles and
trains).  In general, urban environments are characterized by elevated
levels of criteria pollutants, which can potentially reach unhealthy
levels.  Rural environments, in contrast, are typically characterized by
good air quality for most criteria pollutants due to the lack of
pollution- emitting sources.  However, due to the migratory nature of
air pollutants, emissions from urban areas can have a negative impact on
the air quality of a rural area.  Land use practices in rural areas can
affect air quality when wind erosion raises dust from tilled fields, and
when agricultural burning and fires caused by vegetation management
practices adversely affect air quality with smoke and wind blown ashes.

An AQCR or portion of an AQCR may be classified as attainment,
non-attainment, or unclassified for each of the seven criteria
pollutants.  Attainment describes a condition in which one or more of
the seven NAAQS are being met in an area.  The area is considered to be
attainment only for those criteria pollutants for which the NAAQS are
being met.  Non-attainment describes a condition in which one or more of
the seven NAAQS are not being met in an area.  Unclassified indicates
that air quality in the area has not been classified and is therefore
treated as attainment.  Areas that have been recently re-designated from
non-attainment to attainment are called maintenance areas (in reference
to how the area will maintain attainment).  An area may have all four
classifications for different criteria pollutants.  Air emission
regulations are more stringent in non-attainment areas and vary not only
from AQCR to AQCR, but also within an AQCR. States with air quality that
does not achieve the NAAQS are required to develop and maintain State
Implementation Plans (SIPs). In addition, the USEPA may develop a
Federal Implementation Plan (FIP) and Tribes may develop their own
Tribal Implementation Plans (TIP). These plans constitute a federally
enforceable definition of the applicable approach (or plan) and schedule
for the attainment of the NAAQS.

The General Conformity Rule (GCR), established under Section 176(c)(4)
of the CAA (42 U.S.C. § 7506(c)) requires Federal agencies to work with
State, Territory, Tribal, and local governments in a nonattainment or
maintenance area to ensure that Federal actions conform to the
initiatives established in the applicable SIP, FIP, or TIP.  Before a
Federal action is taken, it must be evaluated for conformity with the
applicable implementation plan.

Noise

Noise is defined as unwanted sound that interferes with normal human
activities or wildlife behavior, or may otherwise diminish environmental
quality. Sound is most commonly measured in decibels (dB) on the
A-weighted scale, which is the scale most similar to the range of sounds
that the human ear can hear. The Day-Night Average sound Level (DNL) is
an average measure of sound. The DNL descriptor is accepted by federal
agencies as a standard for estimating sound impacts and establishing
guidelines for compatible land uses. In a typical day, most people are
exposed to sound levels of 50 to 55 dB or higher.

Topographic features and structural barriers that absorb, reflect, or
scatter sound waves can decrease or increase noise levels. (HUD 2009).
In addition, atmospheric conditions, such as wind speed and direction,
and weather, can also affect the perception of the sound. (HUD 2009).
Animals use sounds for communication and navigation, to avoid danger,
and to find food. The same noise factors that affect humans may also
influence wildlife. In general, wildlife has a wider hearing range than
humans, both on the low and high frequency ends of the noise spectrum.
Noise studies, principally those on aircraft noise, have found varying
results, ranging from no identifiable effects in some species, to
noticeable behavioral and physiological effects in other species (e.g.,
birds) (EPA 1980).

For this PEA FEMA will adopt the U.S. Department of Transportation’s
Federal Highway Administration standards for noise abatement found in 23
CFR Part 772 – Table 1. These establish, for example, the need to
consider noise abatement measures for actions that produce sound levels
that 10 percent of the time exceed 70 dB in areas with sensitive
receptors (e.g. as playgrounds, parks, schools, libraries, residences,
and hospitals) and exceed 75 dB in developed lands.

Visual Quality

Natural and man-made features give a particular setting or area its
aesthetic qualities.  These features define the landscape character of
an area and form the overall impression that an observer receives of
that area.  Evaluating the aesthetic qualities of an area is a
subjective process because the value an observer places on specific
landscape features varies depending upon the values and attitudes of the
observer.  Regardless of the subjective nature of assessing visual
aesthetics, landforms, water surfaces, vegetation, and man-made features
can generally be considered characteristic of an area if they are
inherent to the composition and function of the landscape.

The aesthetic characteristics of a project area depend on whether the
area is a remote, rural, or urban setting.  In a remote or rural
setting, the visual aesthetics tend to be dominated by
naturally-occurring landforms and vegetation.  Examples include natural
landscapes, mountains, undulating land, valleys, cliffs, lakes, streams,
beaches, and natural vegetation.  Although naturally-occurring visual
resources dominate rural areas, some signs of human activity are likely
to be present and may also contribute to the visual aesthetics.
Examples include farm houses, agricultural fields, fences, barns, silos,
scenic highways, and lighthouses.  Vegetation in rural areas is
primarily crops grown in tilled fields, grassland, and lawns around
farmhouses.  Remote areas may have no visible man-made structures.

The natural features present in rural/remote settings may also be
present in an urban environment.  However, unlike the remote or rural
settings, man-made features are normally the dominant visual element in
an urban setting.  Examples of these features include houses, office
buildings, warehouses, rail yards, utility plants, historic buildings,
landmarks, parking areas, storage yards, billboards, and signage.
Vegetation in an urban setting is primarily lawns, shrubs, and
ornamental trees.

Air pollution can substantially reduce visibility in wilderness areas
and parks. The EPA issued the Regional Haze Rule, 40 CFR 51.300 et.
seq., to address the decrease in visibility in 156 of the Nation’s
National Parks and Wilderness areas (Class I Areas). The Regional Haze
Rule encourages States and Federal land management agencies to work
together to address regional haze in these areas. As a result of the
rule States with Class I Areas have adopted or may adopt plans and
regulations that restrict activities that contribute to regional haze.

Climate Change

Climate change refers to long-term fluctuations in global surface
temperatures, precipitation, ice cover, sea levels, cloud cover, ocean
temperatures and currents, and other climatic conditions. Scientific
research has shown that in the past century, Earth’s surface
temperature has risen by an average of about 1.3 degrees Fahrenheit
(ºF) or 0.74 degrees Centigrade (ºC). (IPCC 2007). Sea levels have
risen 6.7 inches (0.17 meter) in the past century and Arctic sea ice has
shrunk by 2.7 percent per decade, with larger decreases of 7.4 percent
in summer. (IPCC 2007). Impacts of climate change include increase in
average surface temperatures, decrease in seasonal frozen ground,
extreme temperatures, extreme weather events such as heavy precipitation
events and intense and longer droughts, reduction in glaciers, ice caps
and snow cover, andincrease in cyclone activity.

Most scientists agree that this climate change is largely a result of
green house gases (GHG) emissions from human activities. (IPCC 2007).
These GHG trap heat in the Earth’s troposphere and reradiate it back
to Earth causing warming. The Intergovernmental Panel on Climate Change
(IPCC) – the scientific body tasked by the United Nations to evaluate
the risk of human-induced climate change – has asserted that, “Most
of the observed increase in global average temperatures since the
mid-20th Century is very likely due to the observed increase in
anthropogenic greenhouse gas concentrations.” (IPCC 2007).

Most GHGs, including carbon dioxide (CO2), methane (CH4), nitrous oxide
(N2O), water vapor, and ozone occur by natural processes. However, human
activities such as the combustion of fossil fuels, production of
agricultural commodities and the harvesting of trees can contribute to
increased concentrations of these gases in the atmosphere. Atmospheric
concentrations of CO2, CH4 and N2O have increased approximately 35, 150,
and 18 percent, respectively, since the beginning of the Industrial
Revolution in the mid-1700 (IPCC 2007). The IPCC predicts that CO2
concentrations could rise to more than three times the pre-industrial
level by 2100 (Meehl et al. 2007). The IPCC also predicts a increase of
average global surface temperature of 2.0 to 11.5 ºF (1.1 to 6.4 ºC)
over the next century, accompanied by a sea level rise of approximately
0.6 to 1.9 ft. (0.18 to 0.59 m). (IPCC 2007).

Contributions to the increase of GHG in the atmosphere vary greatly from
country to country, and depend heavily on the level of industrial and
economic activity. The United States accounts for 19.6 percent of global
CO2 emissions. (WRI 2008). GHG emissions for the U.S. in 2006 were
estimated at 7,054 million metric tons of carbon dioxide (MMTCO2)
equivalent (EPA 2008b). CO2 is the primary GHG emitted in the U.S.,
represented close to 85 percent of all U.S. MMTCO2 equivalent emissions
in 2006. (EPA 2008b).

On April 24, 2009 the USEPA issued a proposed endangerment finding and
proposed rule establishing that GHG endanger public health and welfare
of current and future generations. 78 Fed. Reg. 18886 (April 24, 2009).
This proposed finding was issued with respect to six GHG: carbon
dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons,
and sulfur hexafluoride. The USEPA Administrator also proposed to find
that the combined emissions of carbon dioxide, methane, nitrous oxide
and hydrofluorocarbons from new vehicles and new motor vehicles are
contributing to air pollution which is endangering public health and
welfare under Section 202(a) of the CAA. The adoption of this
endangerment finding will provide the USEPA with authority to regulate
the emission of these pollutants.

 Environmental Consequences

This Section provides a programmatic analysis of the impacts of the No
Action Alternative and the Proposed Action. It describes the likely
effects of implementing the programs and project types eligible under
the various GPD grants and, to the extent possible, identifies
programmatic mitigation and best management practices (BMPs) that will
be used to reduce or avoid the impacts of particular activities. In
addition, this section identifies project activities that require
site-specific evaluation and may trigger the need for the preparation of
a Record of Environmental Consideration (REC) or a Supplemental
Environmental Assessment (SEA) to determine if the particular activities
would have significant impacts on the quality of the human environment
given their unique environmental context.

Some of the proposed projects indentified in this PEA could be eligible
for one or more FEMA CATEX. GPD programs and grant-funded projects were
not the basis for FEMA’s list of CATEXs and extraordinary
circumstances at the time of their development in 1980 or the various
revisions in 1981, 1982, 1987, 1994, 1996 and 2001. For this reason the
PEA includes a discussion of the applicability of existing FEMA CATEX to
GPD actions. Appendix B provides a cross-walk of FEMA’s CATEX and how
they apply to GPD-funded activities.

For GPD project types to which FEMA CATEXs apply and do not have the
potential to trigger extraordinary circumstances, this PEA will serve as
the only NEPA documentation required. For those GPD project types to
which a FEMA CATEX applies, but which may trigger the need to evaluate
the presence or resolution of extraordinary circumstances based on the
unique environmental conditions present, FEMA will document the
applicability of the CATEX and extraordinary circumstances through a REC
on a case-by-case basis. If there are extraordinary circumstances
present that cannot be resolved, then FEMA will prepare a site-specific
SEA and determine whether a FONSI can be issued. See Figure 1-1.

It is FEMA’s practice to review an action or project for its
compliance with other environmental planning and historic preservation
requirements such as ESA Section 7, NHPA Section 106, 44 CFR Part 9, and
others before making the final NEPA determination. This ensures that the
Agency integrates NEPA with other planning requirements and utilizes the
established review and consultation processes to inform the
determination of whether a CATEX applies, whether extraordinary
circumstances have been resolved, whether a PEA is applicable, whether a
finding of no significant impact (FONSI) could be reached, or the
appropriate timing for the issuance of a record of decision for an EIS.

The criteria for determining the level significance of environmental
impacts that is used in this PEA and for GPD actions in general is
established in Table 5-1 for easy reference.

  Table 5-1. Criteria for determining significance in this PEA

Area of Evaluation	No Significant Effect	Significant Effect

Land Use	Impacts to land use would not be measurable or would be
measurable or perceptible, but would be limited to a relatively small
change in land use that is still consistent with surrounding or planned
land uses.  The proposed action and alternatives would be consistent
with respective State Coastal Zone Management plans, CBRA and FPPA.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance. 	The proposed action will significantly change
the surrounding land uses in the short- and long-term.

or

The proposed action and alternatives would not be consistent with the
surrounding land use and the local land use agency requires a special
land use permit or waiver.

or

The proposed action and alternatives would not be consistent State
Coastal Zone Management plans or CBRA

or

The proposed action and alternatives would cause significant impacts to
prime and unique farmland.

Geology, Soils, and Seismicity	Impacts to geology, soils, and seismicity
as a result of the proposed action or alternatives would not be
detectable or detectable and steps are taken in order to minimize
adverse impacts.  Projects proposed in areas characterized by
susceptibility to seismic, volcanic, tsunamis, landslide or mudslide
activity, structural instability, excessive erodibility, or steep slopes
are mitigated.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Impacts on geology, soils, and seismicity as a
result of the proposed action or alternatives would be readily apparent
and result in a change to the character of the resource over a
relatively wide area.

Or

Projects proposed in areas characterized by susceptibility to seismic,
volcanic, tsunamis, landslide or mudslide activity, structural
instability, excessive erodibility, or steep slopes are not mitigated.

Water Resources	Impacts (chemical, physical, or biological effects)
resulting from the proposed action or alternatives would be either not
detectable, or detectable, but at or below water quality standards or
criteria.  Alterations in water quality and hydrologic conditions
relative to historical baseline may occur, however, only on a localized
and short-term basis.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Impacts (chemical, physical, or biological
effects) resulting from the proposed action or alternatives would be
detectable and would be frequently altered from the historical baseline
or desired water quality conditions; and/or chemical, physical, or
biological water quality standards or criteria would be locally,
slightly and singularly, exceeded on either a short-term or prolonged
basis.

Floodplains	Activities are not in the floodplain.

Or

Adverse effects to or from the 100-year floodplain for non-critical
actions or adverse effects to or from the 500-year floodplain for
critical actions are present.  Adverse effects are minimized in
accordance with FEMA’s minimization standards in 44 CFR 9.11.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Adverse effects to or from the 100-year
floodplain for non-critical actions or adverse effects to or from the
500-year floodplain for critical actions are present.  Adverse effects
are not minimized in accordance with FEMA’s minimization standards in
44 CFR 9.11.

Wetlands	Actions are not taken in wetlands.

or

Adverse effects from the project to wetlands will occur but effects are
minimized in accordance with FEMA’s minimization standards in 44 CFR
9.11.  Water quality and hydrologic changes resulting from such
development would either be not detectable, or detectable, but at or
below water quality standards or criteria.  Alterations in water quality
and hydrologic conditions relative to historical baseline may occur as a
result of wetland loss.  For jurisdictional wetlands subgrantee will
notify the USACE and obtain any required permits prior to the initiation
of work.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Adverse effects from the project to wetlands will
occur.  Adverse effects are not minimized in accordance with FEMA’s
minimization standards in 44 CFR 9.11.  Impacts to water quality and
hydrology would be detectable and would be frequently altered from the
historical baseline or desired water quality conditions.  The USACE
determines that an EIS is required before an Individual Permit may be
issued for jurisdictional wetlands.

Biological Resources – Vegetation, Wildlife	Impacts to native species,
their habitats, or the natural processes sustaining them from the
proposed action or alternatives would be detectable, but would not be
expected to be outside the natural range of variability.  Occasional
responses to disturbance by some individuals could be expected, but
without interference to feeding, reproduction, or other factors
affecting population levels.  Sufficient habitat would remain functional
to maintain viability of all species.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Impacts from the proposed action or alternatives
on native species, their habitats, or the natural processes sustaining
them would be detectable, and would be expected to be outside the
natural range of variability for long periods of time or be permanent.
Population numbers, population structure, genetic variability, and other
demographic factors for species might have large, short-term declines,
with long-term population numbers significantly depressed.  Frequent
responses to disturbance by some individuals would be expected, with
negative impacts to feeding, reproduction, or other factors resulting in
a long-term decrease in population levels.  Loss of habitat might affect
the viability of at least some native species.

Biological Resources – Listed Species, Critical Habitat, and Special
Status Species	Effects on listed species or designated critical habitat
are insignificant, discountable (i.e., extremely unlikely to occur and
not able to be meaningfully measured, detected, or evaluated) or
beneficial.  During consultation, FWS or NMFS provides written
concurrence of “not likely to adversely affect.”

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	A determination is issued that the action will
jeopardize the continued existence of a species or adversely modify
critical habitat and the agency will proceed with the action.

Or

There will be take of a migratory bird without the appropriate permit by
FWS.

Human Health and Safety	Hazardous or toxic materials and/or wastes could
be safely and adequately managed in accordance with all applicable
regulations and policies, with limited exposures or risks.  There would
be no short- or long-term adverse impacts to public safety and homeland
security preparedness.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	A net increase in the amount of hazardous or
toxic materials and/or wastes to be handled, stored, used, or disposed
of, resulting in unacceptable risk, exceedence of available waste
disposal capacity, or probable regulatory violation(s).  Site
contamination conditions could preclude development of sites for the
proposed use.  Public safety and homeland security preparedness would be
compromised and vulnerabilities would increase.

Low-income and minority populations	There would be no disproportionately
high and adverse environmental or health effects to low-income and/or
minority populations, or any disproportionate effects would be
mitigated.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	There would be unmitigated disproportionately
high and adverse environmental and health impacts to low-income
populations, minority populations.

Historic Properties 	No historic properties are affected.

or

The historic characteristics or setting of an NRHP eligible or listed
property are altered, or have the potential to be altered, but the
resource retains its integrity.

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	The integrity of an NRHP eligible or listed
property would be diminished or destroyed and effects would not be
mitigated below the level of significance.

Infrastructure

*Significant impacts to utilities are not necessary and sufficient
criteria to prepare an EIS	No impacts to infrastructure.

Or

An impact to the human and/or natural environment would occur, but is
less than thresholds indicated below for “significant effect.”

or

Mitigation measures are used to reduce the level of impacts below the
level of significance.

	Communications:  Effects would be considered potentially significant if
the proposed action or alternatives would require communication systems
to meet requirements that could not be provided without major
modifications to the existing systems.

or

Solid Waste:  Effects would be considered potentially significant if the
proposed action or alternatives would require collection and/or disposal
that could not be provided in a reliable manner, which could cause waste
to accumulate or be disposed of in a manner that could adversely affect
human health or the environment.

or

Transportation - Additional demand placed on the existing transportation
network by the proposed action or alternatives would exceed the capacity
of the network, creating disruptions in service in roadways, rail, or
air transportation.

Air Quality	Emissions from the proposed action or alternatives for NAAQS
in nonattainment and maintenance areas would be less than excedence
levels as defined in Table 3.3.  Emissions in attainment areas would not
cause air quality to go out of attainment for any NAAQS.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.

	Emissions from the proposed action or alternatives for NAAQS would be
greater than the exceedance levels for nonattainment and maintenance
areas.  Emissions in attainment areas would cause an area to be out of
attainment for any NAAQS.

Noise	Noise levels resulting from the proposed action or alternatives
would exceed natural sounds, as described under no effect, but would not
exceed typical noise levels from construction equipment or generators.
Noise generated by construction and operation of the facility would be
temporary or short-term in nature.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Noise levels would exceed typical noise levels
from construction equipment and generators on a permanent basis or for a
prolonged period of time.

Visual Quality	No permanent direct or indirect impacts to the viewsheds
of resources such as natural landscapes, Class I Areas, historic
properties and/or the aesthetic character of the surrounding area from
the proposed action or alternatives would be expected.  Any temporary
visual disturbances that alter the character of the viewshed and/or
aesthetic character of the surrounding area would be returned to its
original state following the action.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Significant direct or indirect impacts to the
viewsheds of any resources such as natural landscapes, Class I Areas,
historic properties and/or the aesthetic character of the surrounding
area from the proposed action or alternatives are anticipated, and these
effects would be greater in number, extent, and/or duration than
non-significant impacts.  Significant impacts could include disturbances
(such as the long-term alteration of the viewshed that would require
mitigation) that could alter the character of the viewshed of a
historical resource, and the viewshed might not resume its original
state following the action.

Climate Change	Emissions of  CO2 of proposed action or group of actions
are below the level of detection.

Or

Mitigation measures are used to reduce the level of impacts below the
level of significance.	Emissions of  CO2 of proposed action or group of
actions are significant  and no mitigation is provided.

Alternative 1: No Action Alternative

Implementing the No Action Alternative would have no impacts on areas of
concern such as land use, geology, soils, seismicity, noise, and visual
quality.

The No Action Alternative may result in adverse impacts to areas of
concern such as water resources, floodplains, wetlands, biological
resources, historic properties, minority and low-income populations,
infrastructure, air quality, and human health and safety. Under the no
action alternative, facilities, including CI/KR, would remain vulnerable
to man-made disasters and the local communities, States, Territories,
and the Nation would not be fully prepared for these incidents. For
example, the release of hazardous substances from facilities that use,
store, process or dispose of such substances could have significant
impacts on the natural and physical environment and to human health and
safety. Properties of historic significance could be the target of a
man-made incident or could be damaged or destroyed as a result of the
incident.  CI/KR such as major transit facilities, transportation
corridors, ports, and emergency operations centers would remain
vulnerable.

In addition to vulnerable facilities and infrastructure, the No Action
Alternative would result in a less prepared community of first
responders, local, State, Territory, and Tribal governments. An
unprepared response to a natural or man-made disaster could have
significant consequences to the natural and physical environment and/or
on human health and safety. Not only can environmental resources such as
soils, air and water be the medium or target of the incident, but the
response to such an incident itself could have irreversible adverse
consequences to areas such as water resources, floodplains, wetlands,
biological resources, historic properties, air quality, and human health
and safety.

Alternative 2: Program Implementation

Under Alternative 2, FEMA would implement the GPD programs, including
the eligible activities and project types under each program.

Programs

As provided in Section 3.2.1, the GPD grant programs are dynamic and may
change each year based on Congressional authorization, mandates and
priorities. Grant program implementation activities such as general
grant administration, development of program guidance, and policy and
regulations are not expected to have significant impacts on the quality
of the human environment. The particular project types allowed under the
various GPD grant programs that may have impacts on the environment are
discussed in Section 5.2.2 below. For any given year, programs that are
limited to planning, training, management and administration, exercises
within existing facilities, and mobile and portable equipment purchase
will not have significant impacts to the human environment.

Each year, FEMA will evaluate the grant guidance for each GPD program to
determine if the eligible activities are covered under this PEA. For
activities not covered by this PEA, FEMA will develop Supplemental
Program EAs tiered from this analysis to take into account the impacts
of the activity type on the human environment. FEMA will ensure that the
grant guidance provides information on the particular environmental
planning and historic preservation requirements that must be met prior
to the initiation of the project.

In addition, FEMA and GPD will develop outreach and training tools such
as information bulletins, job aids, and classroom training to assist GPD
staff and grantees with environmental planning and historic preservation
compliance and to avoid, to the maximum extent possible, significant
impacts to the human environment from the implementation of these grant
programs.

Project Types

The following project types may be allowable under various GPD grant
programs and may have the potential to affect the environment, including
historic properties: exercises outside of existing facilities,
communication towers, modification of existing structures and facilities
(including the installation of fixed equipment), and new
construction/replacement.

The expected environmental impacts of many typical GPD-funded project
types are analyzed below.  Impacts are expected to vary substantially by
project type, and even within each project type according to certain
project parameters.

Planning

The activities associated with this project type are administrative in
nature, have no physical footprint, and use existing facilities,
established procedures, and land use designations. They do not involve
any changes in land use, ground disturbance, modification of facilities,
or release pollutants to environmental media (i.e. air, water, and
land). Therefore, this project type would have no effect on land use,
geology and soils, water resources, floodplains, wetlands, biological
resources, minority and low-income populations, historic properties, air
quality, noise, human health and safety, visual quality, or climate
change. This project type will have a beneficial effect on human health
and safety and infrastructure by improving local, State, Territory,
Tribal and National readiness.

FEMA CATEX (iii) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA
documentation of activities under this project type will be needed.

Training

The activities associated with this project type are administrative in
nature, have no physical footprint, and use existing facilities,
established procedures, and land use designations. They do not involve
any changes in land use, ground disturbance, modification of structures
or facilities, or release of significant levels of pollutants to
environmental media (i.e. air, water, and land). Therefore, this project
type would have no effect on land use, geology and soils, water
resources, floodplains, wetlands, biological resources, minority and
low-income populations, historic properties, air quality, noise, visual
quality or climate change. This project type will have a beneficial
effect on human health and safety and infrastructure by improving local,
State, Territory, Tribal and National readiness.

FEMA CATEX (v) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA review or
documentation of activities under this project type will be needed.

Management and Administration

The activities associated with this project type are administrative in
nature, have no physical footprint, and use existing facilities,
established procedures, and land use designations. They do not involve
any changes in land use, ground disturbance, modification of structures
or facilities, or release of significant levels of pollutants to
environmental media (i.e. air, water, and land). Therefore, this project
type would have no effect on land use, geology and soils, water
resources, floodplains, wetlands, biological resources, minority and
low-income populations, historic properties, air quality, noise, visual
quality or climate change. This project type will have a beneficial
effect on human health and safety and infrastructure by improving local,
State, Territory, Tribal and National readiness.

FEMA CATEX (i) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA review or
documentation of activities under this project type will be needed.

Exercises

Exercises within existing facilities

Exercises that are conducted at existing facilities designed and
permitted to handle the specific type of exercise will not involve any
changes in land use, ground disturbance, modification of structures or
facilities, or release of significant levels of pollutants to
environmental media (i.e. air, water, and land). Therefore, this project
type would have no effects on land use, geology and soils, water
resources, floodplains, wetlands, biological resources, minority and
low-income populations, historic properties, air quality, noise, visual
quality, or climate change. This project type will have a beneficial
effect on human health and safety and infrastructure by improving local,
State, Territory, Tribal and National readiness.

FEMA CATEX (v) covers this project type and its applicability can be
extended to GPD activities. This project type is not likely to trigger
extraordinary circumstances and, therefore, no further NEPA review or
documentation of activities under this project type will be needed.

Exercises outside existing facilities, with major logistic activity, or
that involve release of toxic, radioactive, or biological
material/agents

Other types of exercises such as those conducted outside existing
facilities, those with major logistic activity such as the creation of
base camps, construction of temporary facilities, development of staging
areas, significant redistribution of vehicles or people, or those
exercises that involve the release of toxic, radioactive, or biological
agents may have impacts on land use, geology and soils, water resources,
floodplains, wetlands, biological resources, minority and low-income
populations, historic properties, infrastructure, air quality, noise,
visual quality, and climate change. These impacts may vary depending on
the nature of the exercise, where it is located, and the resources
present that are likely to be affected.

This project type will have beneficial impacts on human health and
safety by improving local, State, Territory, Tribal and National
readiness to terrorist attacks.

FEMA CATEX (v) covers this project type and its applicability can be
extended to GPD activities. However, because of the potential
environmental impacts of this project type, FEMA will document the
applicability of the CATEX to the particular exercise thru an REC and
take into account any potential extraordinary circumstances and the
applicability of other environmental planning and historic preservation
requirements. If extraordinary circumstances exist and cannot be
adequately addressed, FEMA will require a site-specific SEA tiered from
this PEA to determine if the proposed project is likely to have
significant impacts on the quality of the human environment.

Mobile and Portable Equipment (No Installation)

The activities associated with this project type have no physical
footprint, and use existing facilities, established procedures, and land
use designations. They do not involve any changes in land use, ground
disturbance, modification of facilities, or release of significant
levels of pollutants to environmental media (i.e. air, water, and land).
Therefore, this project type would have no effects on land use, geology
and soils, floodplains, wetlands, minority and low-income populations,
historic properties, air quality, noise, visual quality, or climate
change.

The AEL includes equipment that is used directly in water, such as
boats, sonar, and barriers.  Although this equipment is placed directly
in the water, it has no significant impact on water quality when used
properly and following industry Best Management Practices (BMPs) such as
regular maintenance and responsible handling, use, and storage of
materials that have the potential to affect water quality, such as fuels
and lubricants.

FEMA CATEX (vi) covers this project type and its applicability can be
extended to GPD activities. Except for the purchase of mid-and
low-frequency active sonar equipment to be used in marine waters, no
further NEPA review or documentation of activities under this project
type will be needed because the project type is not likely to trigger
extraordinary circumstances.

Sonar

Under the MMPA, NMFS is responsible for the management and conservation
of cetaceans (whales, dolphins, and porpoises) and pinnipeds (seals and
sea lions).  NMFS is the primary government agency responsible for
enforcing the MMPA.  The MMPA established a moratorium on the taking
(harassment, injury, or killing) of marine mammals in U.S. waters and by
U.S. citizens on the high seas, and on the importing of marine mammals
and marine mammal products into the U.S. (NMFS, 2009a).  Along with
NMFS, FWS is also responsible for assessing the affects on marine
mammals under the MMPA.  Walruses, sirenians (manatees), sea otters, and
polar bears are under FWS jurisdiction (NMFS, 2009b).  Both NMFS and FWS
are responsible for reviewing and permitting sonar use activities that
may affect those marine mammals under their jurisdiction.

Marine mammals as a group have functional hearing ranges of 10 Hz to 200
kHz. (Navy 2008). Active sonars that operate within these frequency
ranges have the potential to harass marine mammals by affecting their
physiology (e.g. auditory system, organ tissue damage due to resonance)
and behavior (e.g. stress, orientation, breathing, social relationships,
flight response). They may also result in “masking” which is the
interference with the clear reception of signals that are of interest to
these marine mammals. Mid-frequency sonar (ranging from 1 to 10 kHz) and
low-frequency sonar (ranging from 1 Hz to 1 kHz) used in marine waters
has the potential to produce these effects on marine mammals.
(Reynolds, 2008; Navy 2008).  Sonars that operate at frequencies higher
than 200 kHz do not have the potential to adversely affect marine
mammals because the source attenuates rapidly in the water and are
outside of the upper frequency limit of even the ultrasonic species of
marine mammals. (Navy 2008). High-frequency sonars operating between 10
kHz and 200 kHz may require coordination with NMFS or FWS. Site-specific
information on the geographic area where the equipment will be used,
predicted exposure levels (e.g., number, duration and sound pressure
level of received pings), and species density and distribution will be
needed to determine their potential for adverse effects on marine
mammals.

FEMA will coordinate with NMFS and FWS on projects involving use of
active sonars that operate below the 200 kHz frequency. This
coordination may involve Section 7 consultation under the ESA. The
grantee or subgrantee is responsible for obtaining any permits that may
be required under the MMPA, ESA and CZMA and for complying with any
conditions that may be placed on the project as the result of
coordination with NFMS/FWS.

This PEA will be the only NEPA documentation for passive sonars and
active sonars operating in frequencies higher than 200 kHz under this
project type. For all other sonars FEMA will document the applicability
of the CATEX (vi) thru an REC and take into account any potential
extraordinary circumstances as well as the results of the ESA Section 7
consultation process and applicability of other laws such as MMPA and
CZMA. If extraordinary circumstances exist and cannot be adequately
addressed, FEMA will require a site-specific SEA tiered from this PEA to
determine if the proposed project is likely to have significant impacts
on the quality of the human environment.

Communication Towers

As indicated in Section 4.10, FEMA recognizes that there are other
Federal, State, Tribal and Territory public safety
interoperability-related actions such as the FCC’s public safety
initiatives, NTIA’s PSIC Grant Program and USDA’s Rural Utility
Service’s programs. These programs are part of a Nationwide effort to
improve interoperability within the emergency preparedness and response
community. Grantees and subgrantees have the ability to leverage these
different programs within their jurisdictions to achieve their overall
public safety interoperability goals. Thus, there is a potential for
some GPD-funded actions under this project type to be connected with
other non-FEMA funded actions. FEMA will incorporate by reference into
this PEA the description of environmental conditions and environmental
consequences analysis of the NTIA PEA for the PSIC Grant Program and the
Generic Environmental Impact Statement New York State Statewide Wireless
Network to the extent that they are consistent with this document. FEMA
may issue separate SEAs or otherwise adopt other PEAs or Programmatic
EIS (PEIS) as they become final and available to ensure consistency of
NEPA reviews in the Nation’s public safety interoperability efforts.

Existing communication towers

Modifications and/or upgrades of existing communication towers and
supporting facilities are covered by FEMA CATEX (ix). As explained
below, this project type may have the potential to impact the human
environment based on the site-specific conditions and resources present.
FEMA will always conduct site-specific evaluation and document the
applicability of the CATEX, including presence of extraordinary
circumstances and applicability of other environmental planning and
historic preservation requirements through a REC. For proposed projects
having extraordinary circumstances that cannot be resolved, a
site-specific SEA will be required to determine if the impacts are
likely to be significant.

Land Use

Modifications and/or upgrades of existing communication towers and
supporting facilities would not have significant impacts to land use
because they do not change existing land use patterns.

Geology and Soils

The co-location and upgrading of communication equipment on an existing
tower that is not located in areas characterized by susceptibility to
seismic, volcanic, tsunamis, landslide or mudslide activity, structural
instability, excessive erodibility, or steep slopes would not result
significant impacts from geology and soils to the project. The
construction of new equipment buildings or facilities that are not
located in areas characterized by these hazards will not result in
significant impacts from geology and soils to the project.

Some co-location and upgrading activities could occur in towers that are
in areas characterized by hazards characterized above. However, the
impacts from geology to these activities are not expected to be
significant.

Activities involving the expansion, placement, and construction of
supporting facilities in areas characterized by susceptibility to
seismic, volcanic, tsunamis, landslide or mudslide activity, structural
instability, excessive erodibility, or steep slopes may result in
impacts from geology to these actions. These activities may require the
use of certain engineering technologies or require consultation with
State or Federal agencies before the project may proceed. All structures
in areas of seismic risk that are covered by this PEA must be designed
and constructed in accordance with appropriate seismic design and
construction standards, which are promulgated through NEHRP.  Therefore,
the constructed buildings will represent a low seismic hazard to people
and equipment housed in the building during a seismic event.

In addition, the expansion, placement, and construction of supporting
facilities may have adverse effects to soils. Inadequate stabilization
of the site may produce uncontrolled erosion that may result in the loss
of topsoil, reduction of infiltration capacity, alteration of natural
hydrology of the land, increase in flood risks, and adverse impacts to
nearby habitat. (EPA 2007).  Land disturbance associated with this
activity is expected to be less than one (1) acre. FEMA will require
grantees and subgrantees to follow the general mitigation measures for
ground disturbance activities in Section 7.2. Proposed projects that
implement these measures will not result in significant impacts to
geology and soils.  FEMA will require a site-specific SEA or stand-alone
EA for those projects under this project type that warrant more than one
(1) acre of ground disturbance or that would not implement applicable
mitigation measures in Section 7.2.

Water Resources

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on water resources.  These activities are
expected to occur within the existing previously disturbed area with
minimal or no ground disturbance. Therefore, there is no substantial
increase in runoff from the site.  Additionally, these types of projects
do not result in a substantial increase in groundwater or surface water
usage within the project area.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas may adversely
affect water resources and quality in the project area. Uncontrolled
stormwater pollution, erosion and sedimentation can result in the
pollution of waters of the U.S. (EPA 2007). Table 5-2 shows the most
common water pollutants associated with construction activities.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects implementing these measures will not
result in significant impacts to water resources and water quality.
FEMA will require a site-specific SEA or stand-alone EA for those
projects under this project type that warrant more than one (1) acre of
ground disturbance or that would not implement applicable mitigation
measures in Section 7.2.

Floodplains

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on floodplains but may be affected by the
floodplain. Impacts to the floodplain are not expected because these
activities would occur within the existing previously disturbed area and
minimal ground disturbance. Equipment installed on a tower located in
the floodplain may be exposed to flood hazards.

Under 44 CFR Part 9, FEMA is required to avoid activities in a
floodplain unless it is the only practicable alternative. When a
proposed project is the only practicable alternative, FEMA is required
to minimize the impacts to the floodplain and the impacts from floods to
the facility. Minimization techniques apply to the location of
structures, equipment and building contents in floodplain areas. This
could include elevating supporting structures and equipment such as
equipment buildings and generators above the base flood elevation.
Minimization techniques may include floodproofing structures or
facilities. Public safety towers may be considered critical actions
under this analysis because the risk of flooding might be too great. In
such cases, the standard to be used for avoidance, elevation, or
floodproofing is the 500-year base flood elevation. In addition, if
supporting structures are flood-insurable structures and the upgrade
constitutes a substantial improvement, FEMA will require the grantee or
subgrantee to comply with the local floodplain ordinance and obtain, if
necessary, a local floodplain permit.

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. They also prohibit substantial improvements
in the floodway. FEMA defines substantial improvements as any repair,
reconstruction or other improvement of a structure or facility the costs
of which equals or exceeds 50% of the market value of the structure.

FEMA will document the 8-step decisionmaking process and minimization
measures for all proposed communication tower projects located in a
floodplain through either a REC or a site-specific SEA, depending on the
nature of the potential impacts to and from the floodplain.

Wetlands

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on wetlands.  These activities are
expected to occur within the existing previously disturbed area with
minimal ground disturbance.

Activities involving the expansion, placement, and/or construction of
supporting facilities beyond previously disturbed areas have the
potential to adversely impact wetlands. Potential indirect impacts
include uncontrolled stormwater pollution, erosion and sedimentation
from the project that may adversely affect nearby wetlands. In addition,
these activities may involve direct impacts such as conversion of nearby
wetlands as the result of the expansion of facilities. Under 44 CFR Part
9, FEMA is required to engage in an 8-step decisionmaking process for
proposed projects that may have adverse impacts on wetlands, which
includes the use of minimization techniques when the proposed project
affecting the wetland is the only practicable alternative. Minimization
measures include avoidance techniques such as establishing wetland
buffer zones, following the general mitigation measures for ground
disturbing activities as laid out in Section 7.2, and compensation
measures such as wetland mitigation and banking. In addition to FEMA’s
responsibility under 44 CFR Part 9, the grantee or subgrantee must
obtain the applicable CWA Section 404 permit prior to the initiation of
the project if it will affect wetlands that are considered waters of the
U.S. by the USACE.  The grantee or subgrantee must consult with USACE to
determine whether any of the NWPs or a Regional General Permit apply or
whether an Individual Permit is required.  Depending on the type of
permit and as part of the permitting process, the grantee or subgrantee
may need to prepare a CWA Section 404 (b)(1) alternatives analysis or a
wetland mitigation plan.

If the project cannot be designed to avoid impacts to the wetland, then
FEMA will document the 8-step decisionmaking process and minimization
measures in either a REC or a site-specific SEA, depending on the nature
and magnitude of the potential impacts to the wetlands. In addition,
FEMA will include a grant condition requiring the grantee or subgrantee
to secure applicable CWA permits /certifications before initiating any
work involving ground disturbance.

Biological Resources - Vegetation

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on vegetation.  These activities are
expected to occur within the existing previously disturbed area with
minimal ground disturbance.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas may adversely
impact vegetation. The removal of vegetation and the inadequate
stabilization of the site after construction may cause severe erosion
that could result in the loss of topsoil, reduction of infiltration
capacity, alteration of natural hydrology of the land, increase in flood
risks, and adverse impacts to nearby habitat. (EPA 2007).

Ground disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects implementing these measures will not
result in significant impacts to vegetation. With the implementation of
these mitigation measures and the absence of any special status species,
modifications and/or upgrades to existing towers and supporting
facilities do not have a significant adverse impact on local vegetation
in the vicinity of a project site.  In addition, with the control of
invasive exotic plant species as discussed previously, compliance with
EO 13112 is also achieved.  FEMA will require a site-specific SEA or
stand-alone EA for those projects under this project type that warrant
more than one (1) acre of ground disturbance or that would not implement
applicable mitigation measures in Section 7.2.

In cases where the proposed project area is determined to contain or be
near a sensitive vegetation community, FEMA will document its impact
analysis through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts.

Biological Resources - Terrestrial Wildlife

The co-location and upgrading of communication equipment on an existing
tower would not have an impact on terrestrial wildlife.  These
activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance; therefore, these
activities would not have significant impact on terrestrial wildlife.
One exception would be modifications of navigational safety nighttime
lighting in existing towers from white strobe lights (L-865) or red
flashing, incandescent lights (L-864) to steady-burning red lights
(L-810). Steady-burning red lighting has the potential to increase
migratory bird collisions with towers and guy wires supporting the
towers. (Gehring et al. 2009). FEMA will require a site-specific SEA for
those modifications that result in the change of tower lighting to
steady-burning red lights (L-810).

The addition of communication equipment that results in the increase in
tower height exceeding 199 feet may adversely affect migratory birds.
The increase in tower height will trigger consultation with FAA and may
result in lighting requirements that could attract migratory birds and
result in avian collisions. FEMA will require a site-specific SEA if the
addition of communication equipment will result in an increase in tower
height exceeding 199 feet and will use steady burning red lights
(L-810).

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect terrestrial wildlife. If an activity involves work
in a forested area or special status area such as a floodplain, wetland,
forest or wildlife refuge, the project may have adverse effects on
wildlife such as displacement or loss of foraging habitat for common
small mammals or birds or fragmentation of habitat. The grantee or
subgrantee will be required to coordinate with the appropriate Federal,
State, Territory, or Tribal agency and obtain any special land use
permits or licenses in these areas. Grantees and subgrantees will be
required to submit to FEMA any environmental or historic preservation
documentation or clearance obtained from that process.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that are less than one (1) acre and for
which these measures are implemented will not result in significant
impacts to terrestrial wildlife.  FEMA will require a site-specific SEA
or stand-alone EA for those projects under this project type that
warrant more than one (1) acre of ground disturbance or that would not
implement applicable mitigation measures in Section 7.2.

Biological Resources - Aquatic Wildlife

The co-location and upgrading of communication equipment on an existing
tower would not have significant impacts on aquatic wildlife. These
activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance; therefore, these
activities would not have significant impact on these resources. One
exception is proposed projects that would result in new beachfront
lighting near sea turtle nesting grounds which may adversely affect
these resources. Beachfront lighting can disorient sea turtle
hatchlings. Hatchlings find their way to the sea by differentiating
between dark and bright areas and overhead artificial lights disrupts
this ability. (Salmon 2003). For proposed coastal projects that would
result in new lighting, FEMA will require grantees and subgrantees to
coordinate with the State natural resources or coastal resources agency
to determine if the project is likely to affect sea turtle nesting
patterns and, if it is, to design the project in a manner to reduce
these impacts. If the proposed project cannot be redesigned to reduce
these impacts, then a site-specific SEA will be required to evaluate the
potential impacts to the species.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect aquatic wildlife. Projects within floodplains or
affecting floodplains or wetlands may have adverse impacts to aquatic
wildlife and/or their habitat. FEMA would avoid taking actions within or
affecting floodplains or wetlands. If undertaking the project within the
floodplain or wetland is the only practicable alternative, then FEMA
will document the 8-step decisionmaking process and minimization
measures through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts.

Biological Resources - Listed Species, Critical Habitat and Special
Status Species

Except as provided above for migratory birds and sea turtles protected
under the ESA, the co-location and upgrading of communication equipment
on an existing tower would not have an impact on listed species,
critical habitat or special status species.  These activities are
expected to occur within the existing previously disturbed area with
minimal ground disturbance.

There may be situations where a special status species individual is
using the existing tower or nearby facility as a nesting area. FEMA will
require grantees and subgrantees to identify if the subject facility is
being used by a special status species individual or if a special status
species is nearby. FEMA will encourage grantees and subgrantees to
follow existing guidelines for the protection of such species. In
addition, FEMA will consult with FWS and/or appropriate State, Tribe, or
local government agency before the project is approved to discuss
measures needed to avoid impacts to these individuals. Projects that
incorporate measures to avoid impacts to these special status
individuals, such as avoiding disruption of nests and avoiding
construction activities within 660 feet of identified nests, would not
have significant impact on these resources. If the proposed project
cannot be designed to avoid impacts to these special status individuals,
then FEMA will document its impact analysis through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect listed species or special species habitat. These
activities may result in the displacement or fragmentation of habitat
for these species. Land disturbance associated with this activity is
expected to be less than one (1) acre and FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2. However, FEMA will not be able to
determine whether the impacts of the specific activity to the listed
species, critical habitat or special status species are significant
without an appropriate site-specific evaluation and consultation with
FWS or NMFS. If consultation results in a No Effect or Not Likely to
Adversely Affect (NLAA) determination, then the activity would not have
significant impacts on these resources and no additional NEPA review
would be required. If the consultation results in the initiation of
formal consultation, then FEMA will enter into the formal ESA Section 7
consultation and document the results in a site-specific SEA.

Human Health and Safety

Activities in this project type are expected to have a beneficial impact
on human health and safety throughout the U.S. and its territories.
Modifications and/or upgrades of communication towers and supporting
facilities will improve readiness and response to natural and man-made
disasters.  Updated equipment will allow a faster and more complete
transfer and sharing of information between agencies and first
responders at all levels of government and communities.

Activities related to the modification and/or upgrade of communication
towers and supporting facilities may involve the use, handling, storage,
and disposal of hazardous substances such as fuel storage tanks and
flammable liquids.  Waste fuel and/or oil associated with the operation
of the emergency generator at tower sites must be disposed of according
to Federal and State regulations. Additionally, the above-ground fuel
storage tanks for the emergency generators would be located within berms
to limit runoff and infiltration should a spill or leak occur. FEMA will
encourage grantees and subgrantees to locate containers with a capacity
to store more than 100 gallons of hazardous substances of an explosive
or fire prone nature at an acceptable separation distance from
facilities or structures where people can congregate such as schools or
hospitals. Grantees and subgrantees may use the HUD’s guidance
“Siting of HUD-Assisted Projects near Hazardous Facilities (HUD
-1060-CPD, Sept. 1996), incorporated in this PEA by reference. The
grantee or subgrantee will be responsible for meeting the “all
appropriate inquiries” rule in 40 C.F.R. 312.10 before acquiring a new
property. Grantee and subgrantees must prepare, implement, and regularly
update spill prevention and control plan when needed and required by
law. The use, handling, storage and disposal will be disposed of
according to Federal, State or Territory, and local regulations. No
significant impacts are expected from these activities.

Minority and Low-Income Populations

Activities in this project type would not have disproportionate high and
adverse impacts on low-income and/or minority populations. These
activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance and therefore have no
significant adverse effects on low-income or minority populations. These
activities will have a long-term beneficial impact on all segments of
the population, including minority and/or low-income populations, by
increasing public safety.

Historic Properties - Archeology

Modifications and/or upgrades of existing communication towers and
supporting facilities that do not involve ground disturbance would have
no potential to affect archeological resources.

Activities involving ground disturbance have the potential to affect
archeological resources, particularly if the activities would be located
on undisturbed land. Yet the presence of modern structures or facilities
does not mean that no archaeological resources exist or that they have
already been destroyed.  Examples of ground disturbing activities
include topsoil removal, hand excavation of trenches, excavation along
existing foundation walls (whether on an historic or modern building),
and/or enlargement of existing structures or facilities.  While existing
structures may have disturbed potential archaeological deposits at the
time of construction, intact resources may have been left undisturbed.
In addition, existing historic structures may have archaeological
components and any landscaping or other activities that disturb the
ground could affect potential archaeological deposits.  Geographical
location and expected site types dictate whether a proposed project will
affect archaeological resources.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that are less than one (1) acre, for
which these measures are implemented, and that are located in areas with
low potential for presence of archeological resources are not likely to
result in significant impacts to archeological resources.  Proposed
projects located in areas with moderate to high potential for
archeological findings would trigger Section 106 consultation with the
SHPO/THPO and the resolution of adverse effects by avoidance,
minimization or mitigation. The Program Comment issued by the ACHP on
November 3rd, 2009 establishes that FEMA would not need to comply with
the Section 106 process for those tower-related projects that have
undergone or will undergo Section 106, or that are exempt from Section
106, by the FCC Nationwide PA and Collocation PA. FEMA will coordinate
with the FCC on the implementation of this Program Comment and FEMA’s
and its applicants role for tower-related projects covered by the
Program Comment.

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Historic Properties - Other Historic Properties

The co-location of equipment or modification of an existing tower is a
preferred alternative to the construction of a new tower, as this type
of activity minimizes ground disturbance and the introduction of new
visual elements on the landscape. Some existing towers may have not gone
through the Section 106 process prior to their license and construction.
Although FEMA Section 106 review responsibilities is limited to the FEMA
undertaking (i.e. the action being funded by FEMA) it is important to
point out that the Agency will take into account past actions and
impacts as part of the evaluation of cumulative effects and take these
into account in its determination of adverse effects of its
action/undertaking.

In general, modifications of communication tower facilities –
including co-location of equipment and installation of additional
equipment within the fenced facility (e.g. equipment shelters,
additional fencing, generators, lighting, vehicle barriers) – that are
not considered historically significant, do not substantially increase
the height or size of the facility and are not located within or near an
historic district or landscape are not likely to adversely affect
historic properties or their viewshed.

Proposed projects involving a substantial increase in height and size of
a communication tower may increase the radius of the APE because the
resultant structure would be visible from a greater distance.  FEMA must
identify the APE, identify historic properties within the APE, and
determine if the proposed increase adversely affects historic properties
in consultation with the SHPO or THPO and other interested parties.
Likewise, should the communication tower be located within or in view of
an historic district or landscape, indirectly affected historic
properties must be considered.  Dense commercial areas, wilderness and
roadless areas, industrial areas, non-historic transportation corridors,
or new subdivisions are examples of areas where an increase in the
height or size of a communication tower will likely have no potential to
affect, result in a finding of no historic properties affected, or
result in a finding of no adverse effect on historic properties.  In the
latter two circumstances, FEMA must consult with the SHPO or THPO and
other interested parties.  In many cases, tower facilities blend into
industrial or commercial landscapes.

To avoid adverse effects, equipment could be co-located on alternative
existing structures or in less historically sensitive areas, as long as
the needed radio coverage requirements would still be met.  Should
equipment need to be co-located on historic properties or within
historic districts, effects to historic properties can be minimized by
masking the equipment on or in existing structures within the required
location.  Landscape buffers surrounding the base of facilities may also
minimize visual effects on immediately adjacent historic properties.

The Program Comment issued by the ACHP on November 3rd, 2009 establishes
that FEMA would not need to comply with the Section 106 process for
those tower-related projects that have undergone or will undergo Section
106, or that are exempt from Section 106, by the FCC Nationwide PA and
Collocation PA. FEMA will coordinate with the FCC on the implementation
of this Program Comment and FEMA’s and its applicants role for
tower-related projects covered by the Program Comment.

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Infrastructure

Traffic impacts associated with modifications and/or upgrades to
existing communication towers and supporting facilities are limited to
the construction phase.  New construction would use existing
infrastructure or would require minimum infrastructure development. Once
construction activities have been completed, traffic levels and flow
return to original levels.  Grantees and subgrantees are responsible for
coordinating with the appropriate local agency to ensure adequate
measures are implemented during construction, including warning signage,
limitation of public right-of-ways for staging, use of flagpersons, lane
closures, and detours. Potential impacts of these activities on traffic
would not be significant.

No significant adverse effect would occur on utilities or the collection
and disposal of solid waste as a result of these types of projects.
These proposed projects would enhance communications networks, providing
a beneficial impact.

Air Quality

In general, the co-location and upgrading of communication equipment on
an existing tower would not have adverse impacts on air quality because
the activities are expected to occur within the existing previously
disturbed area with minimal ground disturbance. Fugitive dust and
equipment exhaust emissions associated with these types of activities
are not expected to have any significant impact on air quality,
regardless of whether the project area is located in a pristine,
attainment, nonattainment, or maintenance area.  These projects
generally involve small structural changes or modifications to existing
structures or fences. However, even in nonattainment areas these
emissions are likely going to be below minimum regulatory thresholds for
these criteria pollutants.

Some proposed projects could include the installation of a new or
upgraded emergency generator that operates during power outages. The
operation of generators may be regulated in the particular State or
region where the project will take place. A generator may qualify for
emergency generator provisions depending on its usage or it may be
exempt from permit requirements if they are below the State’s
established emission threshold.  Grantees and subgrantees must
coordinate with their State environmental quality agency to determine
the applicable requirements.

Activities involving the expansion, placement, and construction of
supporting facilities beyond previously disturbed areas have the
potential to affect air quality. Fugitive dust and air pollutants
associated with the operation of construction equipment may affect air
quality conditions at the project site. Off-road engines used in
construction-related vehicles such as backhoes, front end loaders,
bulldozers, tractors, graders, excavators, etc. are typically
diesel-based that produce nitrogen oxides (NOx), hydrocarbons (HC),
carbon monoxide (CO) and particulate matter (PM) emissions. (USEPA
2003). In FEMA’s experience, the air emissions associated with
individual site preparation and construction activities in sites less
than five (5) acres do not rise to the level of significance even in
non-attainment areas.  Table 5-3 and Appendix C shows, for example, an
estimate made by the agency on the air emissions associated with
equipment used for site preparation and construction activities for the
placement of alternative housing units in the Gulf Coast of the U.S.
(FEMA 2009). These estimates were based on US EPA’s NONROAD Model
(USEPA 2005).

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to air quality.  FEMA will require a
site-specific SEA or stand-alone EA for those projects under this
project type that warrant more than one (1) acre of ground disturbance
or that would not implement applicable mitigation measures in Section
7.2.

Older structures often contain lead-based paint or asbestos containing
materials.  Any activities associated with the demolition of facilities
must be done in accordance with Federal and State laws and regulations
regarding the handling and disposal of hazardous materials, such as
lead-based paint and asbestos containing materials.

Noise

In general, the co-location and upgrading of communication equipment on
an existing tower does not have noise-related adverse effects. These
projects are generally small in scale and construction activities are
temporary in nature.

Activity work involving the expansion, placement, and construction of
supporting facilities may have measurable noise-related impacts. Table
5-4 shows an estimate of the noise levels associated with typical
construction equipment and attenuation of noise at various distances. To
estimate the attenuation of the noise over a given distance the
following relationship was used:

	dBA2 = dBA1 – 20 log (d2/ d1)

Where:

	dBA2 = dBA at distance 2 from source (predicted);

	dBA1 = dBA at distance 1 from source (measured);

d1 = distance to location 2 from source;

	d2 = distance to location 1 from source (50 ft.);

Source: CDOT 1998.

Table 5-4. Estimated Sound Levels for Construction Equipment and
Attenuation at Various Distances

Equipment	Typical Noise Level (dBA) at 50 ft. from Source1	Estimate at
100 ft.	Estimate at 200 ft.	Estimate at 500 ft.	Estimate at 1,000 ft.

Air Compressor	81	75	69	61	55

Backhoe	80	74	68	60	54

Ballast Equalizer	82	76	70	62	56

Ballast Tamper	83	77	71	63	57

Compactor	82	76	70	62	56

Concrete Mixer	85	79	73	65	59

Concrete Pump	82	76	70	62	56

Concrete Vibrator	76	70	64	56	50

Crane Derrick	88	82	76	68	62

Crane Mobile	83	77	71	63	57

Dozer	85	79	73	65	59

Generator	81	75	69	61	55

Grader	85	79	73	65	59

Impact Wrench	85	79	73	65	59

Jack Hammer	88	82	76	68	62

Loader	85	79	73	65	59

Paver	89	83	77	69	63

Pneumatic Tool	85	79	73	65	59

Pump	76	70	64	56	50

Rock Drill	98	92	86	78	72

Roller	74	68	62	54	48

Saw	76	70	64	56	50

Scraper	89	83	77	69	63

Shovel	82	76	70	62	56

Truck	88	82	76	68	62

1Source: FHWA 2006.

The estimates provided in Table 5-4 indicate that most of the equipment
commonly associated with construction activities produces noise levels
that exceed 75 dBA. A distance of 200 feet or more is needed between
most of the construction equipment provided and a receptor to attenuate
the noise levels those that are acceptable.

Land disturbance associated with this activity is expected to be less
than one (1) acre. This limits the type and time of use for each piece
of equipment. FEMA will adopt, or require grantees and subgrantees to
follow, the general mitigation measures for ground disturbance
activities in Section 7.2, which includes operation during business
hours (Monday thru Friday from 7am to 5pm) and the use equipment using
the manufacturer’s standard noise control devices (i.e. mufflers,
baffling, and/or engine enclosures). In addition, grantees and
subgrantees will be required to comply with any State, Territory, Tribal
or local noise control requirements. With these measures the activity
would not result in significant noise impacts.

FEMA will document those actions that would result in noise levels
exceeding 70 dBA for more than 10 percent of the time and will take
place less than 200 feet from sensitive receptors (e.g. schools,
hospitals, and residential areas) through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Visual Quality

Short-term impacts are associated with the presence of construction
equipment and vehicles necessary to carry out the modification or
upgrades to existing towers. These impacts are considered insignificant
and limited to the construction phase.  Long-term impacts associated
with these actions are not considered significant because the existing
facilities are already a part of the viewshed and the changes would be
minor.

FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2.
Proposed projects that implement these measures will not result in
significant impacts to visual quality.  FEMA will require a
site-specific SEA or stand-alone EA for those projects under this
project type that warrant more than one (1) acre of ground disturbance
or that would not implement applicable mitigation measures in Section
7.2.

Climate Change

There would be no significant impact to climate change as a result of
modifications or upgrades to existing communication towers.  These
modifications would not result in any changes in land use, a significant
increase in the burning of fossil fuels, or any other activities known
to contribute to the increased emissions that cause climate change.

Construction of new or replacement communication towers

The replacement of communication towers and supporting facilities are
covered by FEMA CATEX (ix) and (xv).  As explained below this project
type may have potential to impact the quality of the human environment
based on the site-specific conditions, and based on tower design (i.e.
use of guy wires versus a monopole or lattice design).  FEMA will
conduct site-specific evaluations and document the applicability of the
CATEX, including presence of extraordinary circumstances, and the
applicability of other environmental planning and historic preservation
requirements through a REC. For projects having extraordinary
circumstances that cannot be resolved, FEMA will develop a SEA to
determine if the impacts are significant.

Construction of new communication towers may be covered by FEMA CATEX
(ix).  FEMA will conduct site-specific evaluations and document the
applicability of the CATEX, including presence of extraordinary
circumstances, and the applicability of other environmental planning and
historic preservation requirements through a REC.  For projects having
extraordinary circumstances that cannot be resolved, FEMA will develop a
SEA to determine if the impacts are significant.

Construction of a new communication tower would trigger review by the
FCC under NEPA, Section 106 of NHPA, Section 7 of ESA, E.O. 11988 and
other federal environmental planning and historic preservation
compliance requirements.  In order to expedite this review and avoid the
duplication of reviews between FCC and FEMA, FEMA strongly recommends
that grantees and subgrantees complete the FCC’s required
environmental and historic preservation compliance review and include
documentation prepared for that process or any clearance obtained from
the FCC as part of the request for FEMA funding for the communication
tower.  Appendix E provides FEMA’s procedures for the adoption of
other Agency’s reviews such as the FCC environmental planning and
historic preservation review. FEMA will continue to work with the FCC
and resource agencies to seek ways to eliminate the duplication of
reviews for this project type and may memorialize these approaches as
they are established.

Figure 5-  SEQ FEMA's_NEPA_Process_for_Towers \* ARABIC  1 . FEMA NEPA
Process for New Communication Towers

Land Use

Replacement of towers would not have significant impacts on land use
because the new and previous land use would be the same.

Construction of a new tower and supporting facilities in a new location
may require land use changes at the local level.  However, substantial
changes to land use are unlikely given the relatively small footprint of
this project type (less than 1 acre).

Depending on the extent of changes proposed for the tower and the
required construction and demolition activities, a construction permit
from local authorities may be required prior to construction.
Conditions of the permit normally specify that the proposed facility be
constructed and operated in compliance with local zoning ordinances, or
that a zoning variance be obtained.  The grantee or subgrantee is
responsible for obtaining the necessary construction permits.

FEMA is prohibited from providing assistance for new construction
activities in CBRS units. FEMA will require the grantee or subgrantee to
coordinate with the State Coastal Management Agency to obtain a
consistency determination when the propose project occurs within a
State’s designated coastal zone.

If the proposed project will affect prime and unique farmland, FEMA will
complete the required Form AD-1006 and consult with NRCS. If the Form
AD-1006 indicates that the proposed project will score more than 160
points, then FEMA will document this finding in either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Geology and Soils

Construction of new towers and the replacement of towers in areas that
are not characterized by susceptibility to seismic or volcanic activity,
tsunamis, landslides, mudslides, structural instability, excessive
erodibility, or steep slopes will not result in significant impacts from
geology and soils to the project.

New construction activities in areas characterized by susceptibility to
seismic or volcanic activity, tsunamis, landslides, mudslides,
structural instability, excessive erodibility, or steep slopes will
require the use of certain engineering technologies or require
consultation with State or Federal agencies before the proposed project
may proceed. All structures, such as equipment and storage buildings, in
areas of seismic risk that are covered by this PEA must be designed and
constructed in accordance with appropriate seismic design and
construction standards, which are promulgated through NEHRP.

Replacement towers would not have any impact on soil because soils in
the project area have already been compacted under the original tower.
However, construction of new towers and supporting facilities may have
adverse impacts to soils. Inadequate stabilization of the site may
produce uncontrolled erosion that may result in the loss of topsoil,
reduction of infiltration capacity, alteration of natural hydrology of
the land, increase in flood risks, and adverse impacts to nearby habitat
(EPA 2007). Land disturbance associated with this activity is expected
to be less than one (1) acre. FEMA will require grantees and subgrantees
to follow the general mitigation measures for ground disturbance
activities in Section 7.2. Proposed projects that implement these
measures will not result in significant impacts to geology and soils.
FEMA will require a site-specific SEA or stand-alone EA for those
projects under this project type that warrant more than one (1) acre of
ground disturbance or that would not implement applicable mitigation
measures in Section 7.2.

Water Resources

Replacement towers would not have significant impacts to water resources
or water quality. This activity would not increase the amount of
impervious surfaces at a given location.  However, areas that have been
disturbed by the removal of the existing vegetation are much more
susceptible to water erosion during major precipitation events and to
wind erosion during dry and windy weather conditions.  Uncontrolled
stormwater pollution, erosion and sedimentation can result in the
pollution of waters of the U.S. (EPA 2007).

Construction of new towers and supporting facilities may adversely
affect water resources and quality in the project area. Uncontrolled
stormwater pollution, erosion and sedimentation can result in the
pollution of waters of the U.S. (EPA 2007). Table 5-2 shows the most
common water pollutants associated with construction activities.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects implementing these measures will not
result in significant impacts to water resources and water quality. FEMA
will require a site-specific SEA or stand-alone EA for those projects
under this project type that warrant more than one (1) acre of ground
disturbance or that would not implement applicable mitigation measures
in Section 7.2.

FEMA will coordinate with the appropriate agency if any of the
construction activities occur in the vicinity of a wild or scenic river.
 If the project affects a wild or scenic river, then FEMA will engage in
a site-specific SEA to appropriately evaluate the potential for
significant impacts to this resource.

If construction activities involve the filling of navigable waters of
the U.S., FEMA will require the grantee or subgrantee to coordinate with
the USACE to obtain the applicable Federal permit. Proposed projects
that would require Individual Permit will require close coordination
among the grantee or subgrantee, FEMA and USACE. This process may
include the development of a site-specific SEA under this PEA or the
start of the EIS process.

Construction activities that comply with the required NPDES permits,
comply with applicable Nationwide or General permits under Section 404
and Section 10, and do not affect wild or scenic rivers will not result
in significant impacts to water resources and water quality.

Floodplains

Public safety interoperable communication towers may be considered
critical actions because the risk of flooding that could damage or
destroy the tower is too great. Therefore, proposed tower projects
require evaluation under the 500-year BFE standard. Under 44 CFR Part 9,
FEMA is required to avoid activities in a floodplain unless it is the
only practicable alternative. If locating a project in the floodplain is
the only practicable alternative, FEMA must minimize the impacts to the
floodplain and the impacts from floods to the facility. Minimization
techniques apply to the location of structures, equipment and building
contents in floodplain areas. This could include elevating facilities or
structures above the base flood elevation. Minimization techniques may
include floodproofing structures or facilities. In addition, if
structures are flood-insurable structures and the upgrade constitutes a
substantial improvement, FEMA will require the grantee to comply with
the local floodplain ordinance and obtain, if necessary, a local
floodplain permit.

FEMA regulations at 44 CFR 9.11(d) prohibit the agency from funding new
construction, including replacement, in coastal high hazard areas (CHHA)
or in floodways unless they are functionally dependent uses or
facilitate open space use. Communication towers are not functionally
dependent uses. The regulations also prohibit substantial improvements
in the floodway.

If undertaking the project in the 500-year floodplain is the only
practicable alternative, then FEMA will document the 8-step
decisionmaking process and minimization measures through either a REC or
a site-specific SEA, depending on the nature and magnitude of the
potential impacts.

Wetlands

The replacement of a communication tower at an existing site is not
expected to have a significant impact on wetlands because the activities
would occur within the previously disturbed area. Construction of new
towers and supporting facilities that are not within or affect wetlands
will not have significant impacts on wetlands.

Some construction activities related with the placement of new towers
and supporting facilities may adversely affect wetlands. Activities
outside of wetland areas but near wetlands may result in uncontrolled
stormwater pollution, erosion and sedimentation that may adversely
affect these nearby wetlands. Minimization measures include avoidance
techniques such as establishing wetland buffer zones and complying with
the mitigation measures in Section 7.2 would reduce the potential
adverse impacts of these activities to nearby wetlands.

Some construction activities related with the placement of new towers
and supporting facilities may take place within wetland areas. Under 44
CFR Part 9, FEMA is required to engage in an 8-step decisionmaking
process for proposed projects that may have adverse impacts on wetlands,
which includes the use of minimization techniques when the project
affecting the wetland is the only practicable alternative. Minimization
measures include avoidance techniques such as establishing wetland
buffer zones to avoid converting or filling wetlands. Compensation
measures include such wetland mitigation and wetlands banking. In
addition to FEMA’s responsibility under 44 CFR Part 9, the grantee or
subgrantee must obtain the applicable Federal permit prior to the
initiation of the project if it will affect wetlands that are considered
waters of the U.S. by the USACE.  The grantee or subgrantee must
coordinate with USACE to determine whether any of the NWPs or a Regional
General Permit apply or whether an Individual Permit is required.
Proposed projects that would require Individual Permit will require
close coordination among the grantee or subgrantee, FEMA and USACE. This
process may include the development of a site-specific SEA under this
PEA or the start of the EIS process.

If the project cannot be designed to avoid impacts to the wetland, then
FEMA will document the 8-step decisionmaking process and minimization
measures through either a REC or a site-specific SEA, depending on the
nature and magnitude of the potential impacts.

Biological Resources - Vegetation

The replacement of a communication tower at the existing site is not
expected to have no or minimal impact on vegetation.  The activities are
expected to occur within the existing previously disturbed area.
However, there may be disturbance or removal of vegetation that has
grown up around the base of the existing tower and supporting facilities
since their original placement on the site.

The construction of new communication towers and supporting facilities
may adversely impact vegetation. The removal of vegetation and the
inadequate stabilization of the site after construction may cause severe
erosion that could result in the loss of topsoil, reduction of
infiltration capacity, alteration of natural hydrology of the land,
increase in flood risks, and adverse impacts to nearby habitat. (EPA
2007).

Ground disturbance for the construction of a new tower, associated
equipment building, generator and security fencing to enclose these
facilities is expected to be less than one (1) acre. However, depending
on the location of the proposed project and the need to construct an
access road and utility easements, the amount of ground disturbance
associated with these supporting activities could increase the potential
for impacts to vegetation, particularly in remote or undeveloped areas.
FEMA will require grantees and subgrantees to follow the general
mitigation measures for ground disturbance activities in Section 7.2.
Proposed projects implementing these measures will not result in
significant impacts to vegetation. With the implementation of these
mitigation measures and the absence of any special status species,
construction of new communication towers are not expected to have a
significant adverse impact on local vegetation in the vicinity of a
project site.  In addition, with the control of invasive exotic plant
species as discussed previously, compliance with EO 13112 is also
achieved.   FEMA will require a site-specific SEA or stand-alone EA for
those projects under this project type that warrant more than one (1)
acre of ground disturbance or that would not implement these mitigation
measures.

If the project area is determined to be located within or near a
sensitive vegetation community, a FEMA will document its impact analysis
through either a REC or a site-specific SEA, depending on the nature and
magnitude of the potential impacts.

Biological Resources - Terrestrial Wildlife

The replacement of a communications tower at the existing site that
follow FWS guidelines explained below would have no or minimal impact on
terrestrial wildlife. The activities are expected to occur within the
previously disturbed area.

The construction of new communication towers and supporting facilities
has potential to affect terrestrial wildlife. If an activity involves
work in a forest area or special status area such as a wildlife refuge,
wetlands, or floodplains, the proposed project may have adverse impacts
on wildlife such as displacement or loss of foraging habitat for common
small mammals or birds or fragmentation of habitat. These impacts,
however, are not likely to be significant due to the small size and
scope of a typical communication tower project. The grantee or
subgrantee will be required to coordinate with the appropriate Federal,
State, Territory, or Tribal agency and obtain any special land use
permits or licenses in these areas. Grantees and subgrantees will be
required to submit to FEMA any environmental or historic preservation
compliance documentation or clearance obtained from that process.

Ground disturbance for the construction of a new tower, associated
equipment building, generator and security fencing to enclose these
facilities is expected to be less than one (1) acre. However, depending
on the location of the proposed project and the need to construct an
access road and utility easements, the amount of ground disturbance
associated with these supporting activities could increase the potential
for impacts to terrestrial wildlife. FEMA will require grantees and
subgrantees to follow the general mitigation measures for ground
disturbance activities in Section 7.2. Proposed projects that implement
these measures will not result in significant impacts to terrestrial
wildlife.  FEMA will require a site-specific SEA for projects that would
result in more than one (1) acre of ground disturbance or do not
implement applicable mitigation measures in Section 7.2.

Migratory Birds

The long-term impacts on migratory birds from communication towers are
potentially significant.  The FWS Division of Migratory Bird Management
has issued interim guidelines for reducing impacts from towers on
migratory birds (FWS 2000). The Division also submitted comments to the
FCC’s Notice of Proposed Rulemaking, “Effects of Communication
Towers on Migratory Birds” in February 2007 that update the guidance
provided in 2000. These comments are incorporated in Appendix F of this
PEA.  FEMA is currently coordinating with FWS in the development of an
MOU under Executive Order 13186 – Responsibilities of Federal Agencies
to Protect Migratory Birds that would take into account actions
involving communication tower constructions, including the programs
discussed in this PEA. A Draft MOU can be found in Appendix G. The MOU
incorporates the following FWS guidelines for the siting, construction,
and operation of communication towers:

Co-location of communication equipment on existing towers or other tall
structures (e.g. water tower) is preferred over construction of a new
tower.

Communication towers, where practicable, should be less than 200 feet
AGL in height, be of monopole or lattice design, contain no guy wires,
and contain no lights, except where required along major highway travel
corridors and within 3.8 statute miles of approach and departure airport
runways (i.e. towers should be unlighted if Federal Aviation
Administration (FAA) regulations allow). This recommendation is the
environmentally-preferred industry standard for tower placement,
construction, and operation. This includes all new communication towers,
the repair or re-construction of outdated or damaged towers, and the
upgrade and modification of existing towers.

All new towers must be fitted in decreasing order of priority with white
strobes, red strobes, or blinking incandescent lighting, and no L-810
side lights should be used.

Where tower height and guy wires are a concern regarding impacts to
migratory birds, shorter, un-guyed towers should be constructed, even if
a larger number of towers are needed to provide equivalent service. In
other words, a larger overall footprint is preferable to the use of guy
wires.

Towers exceeding 199 feet AGL in height, even those that are several
hundred feet AGL in height, do not necessarily need to be guyed.
However, it is recognized that towers may need to be guyed in areas
susceptible to hurricanes, tornadoes, and other types of hazards.

Through the implementation of these guidelines, replacement and
construction of new communication towers will comply with the Bald and
Golden Eagle Protection Act, the Migratory Bird Treaty Act, the Fish and
Wildlife Coordination Act. FEMA programs would be in compliance with
E.O. 13186.

For tower projects that fully meet the FWS guidelines, no consultation
between FEMA and FWS shall be necessary. For projects that do not meet
the FWS guidelines, FEMA will not be able to determine whether the
impacts of the specific activity to migratory birds are significant
without an appropriate site-specific evaluation and consultation with
FWS. If FWS determines that the proposed tower project will not have
adverse impacts to migratory birds, FEMA will document the results in an
REC. If, however, FWS determines that the proposed tower project will
have adverse impacts to migratory birds and those impacts cannot be
adequately mitigated, a site-specific SEA will be required to determine
the level of significance of the impacts.

Biological Resources – Aquatic Wildlife

The replacement or new construction of towers and supporting facilities
activities in areas that are not located within or affect the 100-year
floodplain, wetlands, or coastal areas would not have significant
impacts on aquatic life.

Proposed projects within floodplains or affecting floodplains, wetlands,
or coastal areas may have adverse impacts to aquatic wildlife and/or
their habitat. Conversion of floodplain or wetlands to other uses would
reduce important habitat that is critical for aquatic species. (NMFS
2008). FEMA will avoid taking actions within or affecting floodplains or
wetlands. If locating the project within the floodplain or wetland is
the only practicable alternative, FEMA will document the 8-step
decisionmaking process and minimization measures through a site-specific
SEA.

Coastal projects that would result in new beachfront lighting near
nesting grounds for sea turtles may adversely affect these resources.
Beachfront lighting can disorient sea turtle hatchlings. Hatchlings find
their way to the sea by differentiating between dark and bright areas
and overhead artificial lights disrupts this ability (Salmon 2003). For
proposed coastal projects that would result in new lighting, FEMA will
require grantees and subgrantees to coordinate with the State natural
resources or coastal resources agency to determine if the coastal
project is likely to affect sea turtle nesting patterns and, if it is,
to design the project in a manner to reduce these impacts. If the
project cannot be redesigned to reduce these impacts, then FEMA will
document its impact analysis through either a REC or a site-specific
SEA, depending on the nature and magnitude of the potential impacts.

Biological Resources - Listed Species, Critical Habitat and Special
Status Species

In general, the replacement of a communication tower at the existing
site is expected to have minimal or no impact on listed species,
critical habitat or special status species.  These activities are
expected to occur within the previously disturbed area. However, there
may be situations where a special status species individual is using the
existing tower or is nesting nearby. FEMA will require grantees and
subgrantees to identify if a special status species is nearby and, when
it is nearby, will encourage grantees and subgrantees to design their
projects following existing guidelines for the protection of such
species. In addition, FEMA will consult with FWS and/or appropriate
State, Tribe, or local government agency before the project is approved
to discuss measures needed to avoid impacts to these individuals.
Proposed projects that incorporate measures to avoid impacts to these
special status individuals would not have significant impact on these
resources.

Construction of new towers and supporting facilities has the potential
to affect listed species, critical habitat or special status species.
Ground disturbance for the construction of a new tower, associated
equipment building, generator and security fencing to enclose these
facilities is expected to be less than one (1) acre. However, depending
on the location and design of the proposed project and the need to
construct an access road and/or utility easements, the amount of ground
disturbance associated with these supporting activities could increase
the potential for impacts to listed species, critical habitat or special
status species. FEMA will require grantees and subgrantees to follow the
general mitigation measures for ground disturbance activities in Section
7.2.

FEMA will consult with FWS or NMFS under Section 7 of ESA. If
consultation under Section 7 results in a No Effect or Not Likely to
Adversely Affect (NLAA) determination, then the activity would not have
significant impacts on these resources and no additional NEPA review
would be required. If the consultation results in the initiation of
formal consultation, then FEMA will enter into the formal ESA Section 7
consultation and document the results in a site-specific SEA.

Human Health and Safety

Replacement or construction of new communication towers and supporting
facilities are expected to have a beneficial impact on human health and
safety throughout the US and its territories.  These activities will
improve readiness and response to natural and man-made disasters and
will allow a faster and more complete transfer and sharing of
information between agencies and first responders at all levels of
government and communities.

The replacement or construction of new communication towers may involve
the use, handling, storage, and disposal of hazardous substances such as
fuel storage tanks and flammable liquids.  Waste fuel and/or oil
associated with the operation of the emergency generator at tower sites
must be disposed of according to Federal and State regulations.
Additionally, the above-ground fuel storage tanks for the emergency
generators would be located within berms to limit runoff and
infiltration should a spill or leak occur.  FEMA will require grantees
and subgrantees to locate containers with a capacity to store more than
100 gallons of hazardous substances of an explosive or fire prone nature
at an acceptable separation distance from facilities or structures where
people can congregate such as schools or hospitals. Grantees and
subgrantees may use the HUD’s guidance “Siting of HUD-Assisted
Projects near Hazardous Facilities (HUD -1060-CPD, Sept. 1996)”,
incorporated in this PEA by reference. FEMA will require grantees and
subgrantees to prepare, implement, and regularly update spill prevention
and control plan when needed.  The use, handling, storage and disposal
will be disposed of according to Federal, State or Territory, and local
regulations. No significant impacts are expected from these activities.

Minority and Low-Income Populations

Impacts related to replacement projects are similar to those discussed
for existing tower sites because the structure being replaced already
exists in the environment.  Potential impacts are those associated with
ground disturbance (e.g. localized air quality, stormwater pollution),
traffic, and noise. However, these impacts would affect all populations
and would not be disproportionally directed to minority or low-income
populations. FEMA will require grantees and subgrantees to follow the
general mitigation measures for ground disturbance activities in Section
7.2 which include practices to control these impacts.

There is a potential for new communication towers to be
disproportionately located near minority or low-income populations.
Grantees and subgrantees are responsible for adequate planning of these
activities to avoid this result. Grantees and subgrantees are also
responsible for engaging in adequate community outreach before the
project is proposed to FEMA. For these projects FEMA will require
evidence from grantees and subgrantees of their community outreach
efforts.

With appropriate planning, community outreach, and implementation of the
mitigation measures, these proposed projects are not anticipated to have
a significant impact on minority or low-income populations.  If FEMA
finds disproportionate high and adverse impacts to minority and/or
low-income populations, then a site-specific SEA will be required.

Historic Properties - Archeology

The replacement or construction of new communication towers will not
have an adverse effect on archeological resources if the projects are
located on sites that have low probability for the presence of
archeological deposits or that have been previously surveyed and found
not to have archeological deposits.

The replacement of communication towers in sites that have moderate to
high probability for the presence of archeological deposits may have
adverse effects on these resources. The presence of modern structures or
facilities does not mean that no archaeological resources exist or that
they have already been destroyed. While existing structures may have
disturbed potential archaeological deposits at the time of construction,
intact resources may have been left undisturbed.  In addition, any
landscaping or other activities that disturb the ground could affect
potential archaeological deposits. Geographical location and physical
characteristics of the site dictate whether an undertaking will affect
archaeological resources.  If such activities are anticipated, then
Section 106 consultation is necessary to determine whether potential
archaeological resources exist and whether they would be adversely
affected. If the project will have an adverse effect, FEMA must develop
ways to avoid, minimize, or mitigate adverse effects to the
archaeological resources in consultation with the SHPO or THPO and other
interested parties.

The construction of new communication towers and supporting facilities
on sites that have moderate to high probability for the presence of
archeological deposits may have adverse effects on these resources.
Geographical location and physical characteristics of the site dictate
whether an undertaking will affect archaeological resources.

The Program Comment issued by the ACHP on November 3rd, 2009 establishes
that FEMA would not need to comply with the Section 106 process for
those tower-related projects that have undergone or will undergo Section
106, or that are exempt from Section 106, by the FCC Nationwide PA and
Collocation PA. FEMA will coordinate with the FCC on the implementation
of this Program Comment and FEMA’s and its applicants role for
tower-related projects covered by the Program Comment.

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Historic Properties - Other Historic Properties

The replacement or construction of new communication towers that do not
affect historic properties will not have significant impacts on these
resources. Locating new towers in areas where historic properties are
not likely present helps reduce or avoid adverse impacts to historic
properties. Examples include industrial parks or commercial strip malls
and transportation right-of-way corridors that are not within boundaries
of historic districts. The construction of a new tower outside the
limits of an historic district or designated historic landscape and with
no or limited visibility from historic properties will not likely have
an adverse effect on historic properties.

Some proposed projects involving the replacement or construction of new
towers and supporting facilities may have adverse effects to historic
properties. The replacement of a communication tower with a tower that
is substantially increased in height, footprint, or of different type
(i.e. lattice vs. guy wire) may result in adverse affects of historic
properties within the identified historic property’s APE. Conversely,
the construction of new towers within historic districts or designated
historic landscapes or within the viewshed of historic properties is
likely to introduce characteristics that diminish the historic integrity
of these properties and, therefore, have adverse effects on historic
properties.  Activities to be considered in the undertaking include any
construction and/or demolition activities associated with the project
and/or activities that may not be eligible under the GPD programs but
are connected to the tower construction such as the construction of
access roads, installation of utilities, and removal of vegetation among
others.

Avoidance of adverse effects can be achieved by siting towers in less
historically sensitive areas or co-locating equipment on existing
structures to avoid construction of a new tower. For new communication
towers constructed within an historic district or within the viewshed of
historic properties, examples of measures to minimize the impacts could
include using a design and color so that the tower blends into the
surrounding area and placing landscape buffers.

The Program Comment issued by the ACHP on November 3rd, 2009 establishes
that FEMA would not need to comply with the Section 106 process for
those tower-related projects that have undergone or will undergo Section
106, or that are exempt from Section 106, by the FCC Nationwide PA and
Collocation PA. FEMA will coordinate with the FCC on the implementation
of this Program Comment and FEMA’s and its applicants role for
tower-related projects covered by the Program Comment.

FEMA will engage in the Section 106 consultation process for projects
not covered by the Program Comment to determine whether historic
properties would be adversely affected and to resolve those adverse
effects. FEMA will consult with the SHPO/THPO, tribes and other sources
to determine if the proposed project has the potential to adversely
affect historic properties. If the proposed project does not have the
potential to adversely affect historic properties, then there is no
adverse effect to this resource and no further NEPA review would be
required. FEMA will document this process through either a REC or a
site-specific SEA, depending on the nature and magnitude of the
potential adverse effects.

Infrastructure

Traffic impacts associated with replacement or construction of new
communication towers and supporting facilities are limited to the
construction phase. Except for routine maintenance and inspection
visits, tower sites are unmanned. Once construction activities have been
completed, traffic levels and flow return to original levels. Grantees
and subgrantees are responsible for coordinating with the appropriate
local agency to ensure adequate measures are implemented during
construction, including warning signage, limitation of public
right-of-ways for staging, use of flagpersons, lane closures, and
detours. Impacts of these activities on traffic would not be
significant.

No significant adverse effect would occur on utilities or the collection
and disposal of solid waste as a result of these types of projects.
These projects would enhance communications networks, providing a
beneficial impact to communities during emergency events.

Air Quality

Impacts to air quality for replacement or construction of new
communication towers and supporting facilities are similar to those
described for modification/upgrades to existing towers.
Construction-related activities that could result in an adverse impact
on air quality are generally associated with short-term emissions,
principally from site clearing activities and the use of construction
equipment and related vehicles.  The construction activities are not
likely to result in a violation of the GCR or cause PSD deterioration.
Operation of the new facilities would not have significant impact on the
local or regional air quality.  In general, operation of new or replaced
facilities would not result in a new major source and would not likely
result in a violation of the GCR or cause PSD deterioration.

Land disturbance associated with this activity is expected to be less
than one (1) acre. FEMA will require grantees and subgrantees to follow
the general mitigation measures for ground disturbance activities in
Section 7.2. Proposed projects that implement these measures will not
result in significant impacts to air quality.  FEMA will require a
site-specific SEA or stand-alone EA for those projects under this
project type that warrant more than one (1) acre of ground disturbance
or that would not implement applicable mitigation measures in Section
7.2.

Noise

Noise impacts associated with the replacement or construction of new
communication towers and supporting facilities are similar to those
described for upgrades to existing towers, although impacts from
construction equipment may be greater in magnitude and duration. Impacts
would be limited to the construction period and would not be
significant.

FEMA will require grantees and subgrantees to follow, the general
mitigation measures for ground disturbance activities in Section 7.2,
which includes operation during business hours (Monday thru Friday from
7am to 5pm) and the use equipment using the manufacturer’s standard