An NSGP EHP Review is one of the most overlooked steps in the entire grant lifecycle. An NSGP award covers more than equipment and installation — certain projects also have to clear this federal environmental and historic preservation review before any of the funded work can begin. Organizations that don’t plan for their NSGP EHP Review often lose months of their three-year window without realizing why.
The short answer: if your project involves construction, renovation, or changes to a building or the ground around it, it likely needs to clear an NSGP EHP Review first. Federal funds cannot be used for that scope until FEMA has completed it. This guide explains what the review is, the rule that most often catches awardees off guard, and why the NSGP EHP Review deserves attention early rather than late.
What an NSGP EHP Review Is, and Who It Comes From
Environmental and Historic Preservation (EHP) review is a federal compliance step FEMA runs on grant-funded projects. It exists because federal money comes with federal obligations — drawn from statutes like the National Environmental Policy Act and the National Historic Preservation Act — that require agencies to consider a project’s effect on the environment and on historic properties before funding it.
FEMA is not the source of these obligations. It is the agency responsible for confirming a project complies with them. For NSGP awardees, that means a defined set of project types has to be documented and reviewed under the FEMA EHP program before the affected work moves forward.
The Rule That Catches Awardees Off Guard
Here is the part that matters most about the NSGP EHP Review: federal law requires it to be completed before federal funds are released to carry out the project. This is not a formality that runs alongside procurement. It comes first.
An organization that signs a vendor contract or places a purchase order for EHP-affected scope before clearance is not simply early. It has put that portion of the award at risk, because funds cannot be used for work that has not cleared review.
This is the mistake SGA sees most often. An organization gets its award notice, is eager to move, and treats the EHP review as paperwork to handle once the real work starts. By the time it surfaces as a blocker, a contract may already be signed or a vendor already scheduled.
What FEMA Has Published About EHP Review Scope and Timing
FEMA’s guidance on the Nonprofit Security Grant Program is clear on a few points every awardee should know going in.
Construction and renovation always require it. Any project of this type triggers EHP review, without exception.
The clock starts early for larger projects. If your project might need a more involved environmental assessment, FEMA has to be notified within six months of the award, and the completed review materials are due no later than twelve months before your period of performance ends. That is a meaningful chunk of a three-year window reserved for this step alone.
Scope and complexity vary the timeline. What triggers review, what documentation FEMA wants, and how long a determination takes depend on the specifics of the project: what is being built or installed, where, and whether the property has any historic designation. There is no single timeline that applies to every NSGP EHP Review, which is exactly why this step benefits from experienced hands rather than a generic checklist.
Why the NSGP EHP Review Is Easy to Underestimate
Most organizations preparing an NSGP application are focused on winning the award. Few spend much time thinking about what happens in the months after. EHP sits in that gap. It is not part of the application scoring, it does not show up until after the award is made, and by the time an organization learns its project needs an EHP review, the clock is already running against a fixed three-year deadline.
The organizations that avoid losing time here are the ones that treat the EHP review as a first post-award task rather than a later one, and that get the right information into FEMA’s hands the first time instead of waiting on a request for more documentation to restart the process.
What an NSGP EHP Review Means for Your Organization
If your award includes construction, renovation, or any physical change to your facility or grounds, assume EHP review applies to that portion of the project until you have confirmed otherwise. Don’t sign contracts or place orders for that scope before you know where the review stands.
This is exactly the kind of post-award step SGA manages for awardees. We know what FEMA is looking for, how to get a project through EHP review without unnecessary delay, and how to keep this workstream from eating into the time your organization needs for installation and reimbursement. Organizations that bring us in early for their NSGP EHP Review protect their full three-year window instead of losing months to a step they didn’t see coming.
Still have questions about what your award requires? We’re happy to walk through it with you. Book a free consultation with SGA here.
How SGA Supports Your NSGP EHP Review
Our work covers the project description and scope-of-work narrative, the site photography brief, the site sketch or plan view, the floodplain documentation, the building age and historic-status determination, the EHP screening forms, and the response to any FEMA request for additional information. Where Section 106 consultation is needed, we coordinate directly with the State Historic Preservation Office in the awardee’s state.
For awardees who have already received a request for additional information or a cleared-with-conditions determination, we run a remediation engagement focused on the specific gaps FEMA identified.
Official Sources
Every claim in this guide traces back to a primary federal source. Confirm current requirements at the URLs below before submission.
- FEMA Environmental and Historic Preservation (EHP) for grants
- FEMA Nonprofit Security Grant Program (NSGP)
- FEMA EHP guidance for emergency managers and practitioners
- U.S. Environmental Protection Agency, NEPA program
- Advisory Council on Historic Preservation (Section 106 oversight)
- FEMA Map Service Center (Flood Insurance Rate Maps)
- 2 CFR Part 200 (Uniform Guidance for federal awards)
State Historic Preservation Offices publish state-specific consultation procedures and timelines. Confirm the current SHPO contact for your state through the National Conference of State Historic Preservation Officers or your FEMA regional EHP team.
