According to 44 C.F.R. § 206.204 and the PA Guide, Category B emergency protective measures are those necessary to eliminate or reduce an immediate threat to life, public health, or safety, and are generally completed within 6 months of the date of declaration for a major disaster. Per the PA Guide and Fact Sheet 9580.100, Mold Remediation, mold remediation performed in the immediate aftermath of a disaster may be eligible as emergency work under Category B. The mold remediation activities in PW 588, as performed, were consistent with FEMA policy requirements for Category B mold remediation activities and within the required six-month timeline for emergency work; i.e., from September 4 to September 28, 2012. Thus, the mold remediation work in PW 588 is eligible as emergency work under Category B. 44 C.F.R. § 206.253(b)(2) provides that if a facility insured under a blanket insurance policy is damaged in a future similar other than flood disaster, eligible costs for permanent work in the future disaster will be reduced by the amount of eligible damage sustained in the previous disaster. The mold remediation work performed in PW 588 constitutes Category B emergency work, and is not subject to the prior loss reduction provision because it only applies to permanent work. Conclusion:

Stafford Act §§ 311, 403, and 406 44 C.F.R. §§ 206.204, 206.225, 206.250, and 206.253 FEMA Fact Sheet (FS) 9580.100, Mold Remediation PA Guide, at 32–33, 71, 74, and 83