Local emergency responders spent four months and $5,000 to mitigate the environmental impacts of this communication tower by raising the equipment platform above the 100-year floodplain and not adding to the amount of infill within the floodplain. Photo: James Duncan
Local emergency responders spent four months and $5,000 to mitigate the environmental impacts of this communication tower by raising the equipment platform above the 100-year floodplain and not adding to the amount of infill within the floodplain. Photo: James Duncan

For almost a decade, the U.S. Department of Homeland Security and Federal Emergency Management Agency (FEMA) has funded efforts to coordinate local and regional emergency response. That goal came a step closer to realization in February, when a block of radio spectrum in the 700-megahertz frequency range, known as the D-Block, was opened to first responders.

As a result, police, fire, and public works departments and emergency management agencies are turning to advanced wireless networks to improve intra-agency communication in areas at high risk for natural disasters and threats of terrorism. However, Homeland Security Grant Program applicants must comply with all relevant federal legislation, including the National Environmental Policy Act. The law requires federal agencies to evaluate the consequences of a proposed project, such as developing and/ or improving a communication network, before funding it.

While protecting or enhancing the environment through well-informed decision-making is laudable, the required due diligence — called an environmental assessment — involves significant time and expense. Knowing what's involved in properly completing an application and anticipating and accounting for the timelines in your build schedule will help determine if a Homeland Security grant is a viable funding option.

Environmental assessments: what and why

The environmental assessment evaluates the potential consequences of both the project as well as construction alternatives on each of the following six resources:

  • Biological — endangered and threatened species
  • Coastal — barrier and coastal zones
  • Cultural and historic — archaeological and Native American properties
  • Physical — air quality
  • Socioeconomic — public health and safety, noise pollution, environmental justice
  • Water — floodplain and wetland quality.

Proper investigation usually requires in-depth research such as biological studies, stream evaluations, and historic structure eligibility surveys; consulting with and/or getting approval from state and federal agencies and Native American tribes; and informing the public via town meetings or published notices.

The funding agency (or agencies) uses this information to determine if the environment will be adversely affected or if further analysis is necessary, and:

  • When impacts are identified, request an environmental impact statement (EIS)
  • If impacts don't exist or can be mitigated, issue a finding of no significant impact (FONSI).

Identifying an acceptable alternative

The assessment process may reveal that a facility will be located within a 100-year floodplain or hinder the viewshed (the area visible from a fixed vantage point) of an adjacent historic district. When an impact is identified, the assessment should evaluate and determine the alternative that most minimizes or eliminates severity — including “No Action”; i.e., not constructing the project.

Developing appropriate mitigation strategies may require consulting with FEMA and DHS or the affected state or federal agency. In some cases, your department may have to sign a memorandum of agreement or memorandum of understanding with the agency. Typical strategies include:

  • Buying into a wetland bank
  • Constructing the project above the floodplain
  • Facilitating historic property preservation or eligibility studies
  • Recreating species habitat or constructing the project in a “species-friendly” manner.
Concern for the endangered Myotis sodalis (a.k.a. the Indiana Bat) has increased scrutiny of federally funded projects throughout the East Coast and into the Midwest. Photo: Ron Fields
Concern for the endangered Myotis sodalis (a.k.a. the Indiana Bat) has increased scrutiny of federally funded projects throughout the East Coast and into the Midwest. Photo: Ron Fields
ENVIRONMENTAL ASSESSMENTS: TIMELINES AND COSTS

What: Homeland Security Grant Program (HSGP)

Who: Department of Homeland Security and Federal Emergency Management Agency

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Click to expand

In some cases, HSGP funding can be used to offset the costs of an environmental assessment. The following estimates will vary depending on the project, federal requirements, and local regulations, but they provide a starting point for determining whether applying for a grant would be worth your time and effort.

EIS (environmental impact statement)

It's difficult to provide an estimate, but not uncommon for this arduous task to take 10 years and $100,000 to complete. That's why we recommend doing whatever's necessary to avoid one.

If the assessment addresses the impact properly and provides a solution that eliminates or satisfactorily minimizes the impact, FEMA and DHS will issue a FONSI and construction may proceed.

If, however, the impact cannot be properly or satisfactorily mitigated with the proposed action, the agencies may require an EIS or deny the project outright. If that happens, discuss alternatives directly with the agencies. At all costs, avoid the request for an EIS; they're inherently expensive and mind-numbingly long and arduous.

You can develop and complete an assessment on your own, but because of its complexity most applicants contract with a consultant that has the knowledge and resources to tackle the required environmental studies. Either way, take a look at the costs and time-lines in the table above when considering funding your emergency communication facility through a Homeland Security grant. If they conflict with your schedules or exceed your available budgets, you might be better off pursuing other sources such as state-funded programs, which in general don't require the detailed environmental studies necessary for federal funds.

— Duncan (jaduncan@terracon.com) is environmental department manager and a principal in the Nashville, Tenn., office of the engineering firm Terracon.