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f. Prior to procuring pharmaceuticals, Subrecipients must have in place an <br /> inventory management plan to avoid large periodic variations in supplies <br /> due to coinciding purchase and expiration dates. Subrecipients are <br /> encouraged to enter into rotational procurement agreements with vendors <br /> and distributors. Purchases of pharmaceuticals must include a budget for <br /> the disposal of expired drugs within each fiscal year's period of <br /> performance for 15HSGP. The cost of disposal cannot be carried over to <br /> another DHS/FEMA grant or grant period. <br /> g. As a subrecipient of federal funds, the Subrecipient must pass on <br /> equipment and supply management requirements that meet or exceed <br /> the requirements outlined above to any non-federal entity to which the <br /> Subrecipient makes a subaward of federal award funds under this <br /> Agreement. <br /> 4. ENVIRONMENTAL AND HISTORICAL PRESERVATION <br /> The Subrecipient shall ensure full compliance with the DHS/FEMA Environmental <br /> Planning and Historic Preservation (EHP) Program. Subrecipients are required <br /> to comply with DHS/FEMA EHP Policy Guidance which can be found at <br /> https://www.fema.gov/office-environmental-planning-and-historic-preservation; <br /> FP 108-023-1 Environmental Planning and Historic Preservation Policy Guidance <br /> at http://www.fema.gov/media-library/assets/documents/85376; and FP 108.24.4 <br /> Environmental Planning and Historical Preservation Policy at <br /> https://www.fema.gov/media-library/assets/documents/101537, all of which are <br /> incorporated in and made a part of this Agreement. <br /> a. Subrecipients proposing projects that have the potential to impact the <br /> environment, including, but not limited to, construction of communication <br /> towers, modification or renovation of existing buildings, structures and <br /> facilities, or new construction including replacement of facilities, must <br /> participate in the DHS/FEMA EHP review process prior to project <br /> initiation. Modification of existing buildings, including minimally invasive <br /> improvements such as attaching monitors to walls, and training or <br /> exercises occurring outside in areas not considered previously disturbed <br /> also require a DHS/FEMA EHP review before project initiation. <br /> b. The EHP review process involves the submission of a detailed project <br /> description that explains the goals and objectives of the proposed project <br /> along with supporting documentation so FEMA may determine whether <br /> the proposed project has the potential to impact environmental resources <br /> and/or historic properties. <br /> c. The Subrecipient agrees that to receive any federal preparedness <br /> funding, all EHP compliance requirements outlined in applicable guidance <br /> must be met. The EHP review process must be completed before funds <br /> are reimbursed. Expenditures for projects started before EHP process <br /> review completion approval is received will not be reimbursed. <br /> 5. PROCUREMENT <br /> a. The Subrecipient shall comply with all procurement requirements of 2 <br /> CFR Part 200.318 through 200.326 and as specified in the General <br /> Terms and Conditions, Exhibit B, A.28. <br /> b. For all sole source contracts expected to exceed $150,000, the <br /> Subrecipient must submit to the County for pre-procurement review and <br /> approval the procurement documents, such as requests for proposals, <br /> invitations for bids and independent cost estimates. This requirement <br /> must be passed on to any non-federal entity to which the Subrecipient <br /> makes a subaward, at which point the Subrecipient will be responsible for <br /> DHS-EMD—Snohomish Co. SHSP-15 Page 8 of 37 City of Everett, E16-053-1 <br />