Integrating Environmental Review into the Temporary Group Housing Site Selection Process

The purpose of this brochure is to introduce to
federal, state and local officials the scope,
concepts, issues, timing, and key FEMA staff to be
contacted for integrating environmental review into
the temporary group housing site selection process.

Addressing The Need

Temporary group housing sites are sometimes necessary when disaster events render homes uninhabitable for long periods, and when the preferred response of placing travel trailers or manufactured homes on the victim’s individual property is infeasible. Environmental review, in combination with other feasibility studies, permits FEMA to expeditiously select and build temporary group housing sites for disaster victims in physically and environmentally safe conditions, while complying with applicable federal laws. It is imperative to recognize that environmental considerations are in place not only to protect sensitive resources in the community, but also to ensure that the temporary residents are not placed in harms way (i.e., in floodplains or near hazardous materials.)

Challenges

Understanding the level of need.

Because disaster victims often seek immediate shelter with friends or relatives instead of at emergency shelters, a pre­liminary count of displaced people can be deceptively low. Also, typical public communication channels may be disrupted or nonexistent during disaster recovery efforts, slowing or stopping the flow of valid information about temporary group housing opportunities

Dealing with a lack of housing resources.

For some communities, housing and rental shortages are a fact of life even during normal times. After a disaster, any va­cancies come at a premium. A lack of rental resources during disaster recovery efforts may require the implementation of a Manufactured Housing Program, with temporary group housing sites selected to locate travel trailers or mobile homes.

Seemingly Ideal sites may have hidden problems.

Sites that appear suitable at first glance may prove problem­atic from a design, engineering, or environmental standpoint after an environmental review has been completed. For ex­ample, a seemingly ideal tem­porary group housing site may be located in the floodplain, contain wetlands, impact his­toric properties, or have hazard­ous materials contamination.

Key Environmental Issues to Examine:

·    Floodplains and Wetlands

·    Hazardous Materials

·    Historic and Cultural Resources

·   Threatened and Endangered Species

·   Socioeconomic Issues and Environmental Justice

·   Air, Water, and Soil Resources

·    Noise and Visual Resources

Considerations

Identify multiple sites.

This is a critical first step, because FEMA cannot afford the time delay if the primary site selected is determined not to be feasible for locating temporary housing. Evaluating mul­tiple sites simultaneously provides timely options.

Start early and inform others of environmental requirements.

To reduce both perceived and real timing issues, it is impor­tant to integrate environmental review with other site feasi­bility evaluations early in the temporary group housing site selection process.

Address expectations.

The expectations of agencies and officials can be better addressed by providing all involved with a clear understand­ing of the purpose and need for environmental review, along with a plan that highlights implementation strategies and timelines. This approach should also identify roles and re­sponsibilities, and ways regulatory and review agencies can assist with the efforts.

Coordination is critical.

There will be multiple federal, state, and local agencies and officials involved in the temporary group housing site selec­tion process. As a rule, temporary housing initiatives are high stress situations. The potential sites must be identified, and the owners contacted to determine site availability and to obtain access to the site for evaluation. Each site must be proven to be technically and environmentally feasible, and available for development within a very short time frame. The public must receive notification of FEMA’s plans to de­velop a site, and have the opportunity to comment on the proposal. Additionally, no site development or construction can occur until the environmental review has been com­pleted, and the process has determined that the implementa­tion of temporary group housing would not result in any significant environmental impacts.

Legal Requirements

The purpose of environmental review of temporary group housing sites is to ensure that FEMA is in compliance with its responsibilities under the National Environmental Policy Act (NEPA) of 1969, and all applicable environmental regulations and executive orders. NEPA serves as the primary charter for protecting the nation’s human environment and resources by establishing policies and sets goals concerning the environment. NEPA charges each federal agency with the responsibility of not only          complying with the Act, but also to take initiatives through their regulations, strategies, and actions to protect, restore, and enhance the human environment. These legal requirements are set forth in Title 44 of the Code of Federal Regulations (44 CFR) Part 10, and available on the Internet at www.access.gpo.gov/nara/cfr/waisidx_00/44cfr10_00.html.

The environmental review is most typically evaluated through the NEPA documentation process known as an Environmental Assessment (EA). The EA examines the proposed action of placing temporary group housing at a given site, the natural resources present in the surrounding environment, and potential impacts that could result from the implementation of temporary group housing. There may be other levels of NEPA documentation and related studies based on the scope and location of the project, including Categorical Exclusion or an Environmental Impact Statement.

Frequently Asked Questions

In an emergency situation, why do we have to worry about the environment? Aren’t people more

In a truly critical situation, the lives and safety of people take precedent over environmental concerns, and environmental laws and regulations support this premise. When there is time, however, we are required to assess the situation and make informed decisions that address the immediate need and the long term health and needs of our environment and communities.

Who coordinates this Environmental Review?

The Environmental Officer, located in FEMA’s Disaster Field Office, coordinates the environmental review and should be consulted anytime a disaster results in displaced victims that will require travel trailers or manufactured homes, and any time a site is being considered for the placement of tempo­rary group housing. The Environmental Officer will help pro­vide input on scope, integration, and timing of the environmental review process.

Why is coordination the key to a successful temporary housing program?

Determining a site’s engineering and environmental feasibil­ity depends on reviews, permits, and clearances from many federal, state, and local agencies. Close coordination of all parties involved in the review process is crucial for expedit­ing the environmental review and development of a site. FEMA’s Environmental Officer facilitates the coordination for environmental review. By working together on site visits and data collection, problematic sites can be quickly identified and eliminated, and critical assessments can be made in real time for those sites that have greater promise.

How long does a typical environmental review for temporary group housing take?

If the site is eligible for a Categorical Exclusion, the review can usually be accomplished in a few days. A more detailed environmental review, such as an Environmental Assess­ment, typically takes 7-14 days. This time includes initial site selection, environmental field and research investigations, creating the environmental review documentation, and a public comment period.

Why is public comment required and important?

NEPA regulations were designed to make public participation part of the environmental review process. Once a draft NEPA document is published, the public is given an expedited pe­riod of 72 hours to provide comments on the document. Substantive comments received from the public must be addressed in a final NEPA document.

What would happen if an environmental review were not conducted?

Non-compliance with FEMA’s NEPA regulations can result in delay in delivering temporary group housing, the loss of fund­ing for the temporary group housing efforts, unfavorable me­dia coverage, or lawsuits.

What issues will the environmental review focus on?

The environmental review examines the existing conditions of the environment, and addresses potential environmental im­pacts of the placement of temporary group housing on that particular site and its environs. The review includes looking at impacts to:

What are the key steps in the environmental review process?

One key step for conducting an environmental review involves obtaining legal rights of entry to the property in order to con­duct a field assessment. Other key steps include reviewing the site from an engineering standpoint for soil or slope stability, infrastructure, accessibility, or past contamination. Observa­tions and research findings are incorporated into the draft environmental review document. A public notice informs the community of the availability of the draft document for their review and comment.

How is the environmental review process concluded?

If through the NEPA review process it can be determined that no significant impacts would result from the implementation of temporary group housing at a given site, a Finding of No Significant Impact (FONSI) is issued. However, if it were deter­mined through the review process that there would be a sig­nificant impact to the environment from the proposed action that could not be mitigated, then an Environmental Impact Statement (EIS) must be conducted. Due to the emergency nature of disaster recovery operations, lengthy EISs are not feasible, and another site should be selected as a replace­ment.

Regional Environmental Officer Contacts

The following is a list of the Regional Environmental Officers that should be notified concerning temporary housing site selection and the environmental review process.

William Kennedy

FEMA Region I (ME, NH, VT, RI, CT, MA)

Phone: 617-223-9528

 

Robert Tranter

FEMA Region II (NY, NJ, Puerto Rico, Virgin Islands)

Phone: 212-680-3628

 

Gene Gruber

FEMA Region III (DC, DE, MD, PA, VA, WV)

Phone: 215-931-5610

 

William Straw

FEMA Region IV (AL, FL, GA, KY, MS, NC, SC, TN)

Phone: 770-220-5432

 

Jeanne Millin

FEMA Region V (IL, IN, MI, MN, OH, WI)

Phone: 312-408-5540

Kyle Mills

FEMA Region VI (AK, LA, NM, OK, TX)

Phone: 940-898-5134

 

Ken Sessa

FEMA Region VII (IA, KS, MO, NE)

Phone: 816-283-7960

 

Bob Cox

FEMA Region VIII (CO, MT, ND, SD, UT, WY)

Phone: 303-235-4714

 

Allessandro Amaglio

FEMA Region IX (AZ, CA, HI, NV, American Samoa, Guam, the Northern Mariana Islands, the Marshall Islands, the Federated States of Micronesia, Palau)

Phone: 415-923-7284

 

Mark Eberlein

FEMA Region X (AK, ID, OR, WA)

Phone: 425-487-4735

 

Brent Paul

FEMA Headquarters

Phone: 202-646-3032