Article 24: Category A: Eligibility Overview

(Category: debris-removal)

Article Summary

Category A (Debris Removal) activities are eligible for Public Assistance funding if the clearance, removal, and disposal work is in the public interest. Work meets this threshold if it eliminates immediate threats to human life, public health, and safety; removes immediate threats of significant damage to improved public or private property; or ensures the rapid economic recovery of the affected community at large. Eligible debris types include vegetative matter, construction/demolition waste, sand, mud, silt, gravel, vehicle/vessel wreckage, and household hazardous waste.

For Private Nonprofit (PNP) organizations, eligible debris operations are strictly limited to debris located directly on the property of an eligible, critical, or essential social service facility. Generally, debris removal is strictly ineligible if it takes place on federally maintained navigable channels, agricultural land, or natural unimproved land (such as heavily wooded interior areas). Furthermore, local jurisdictions cannot claim reimbursement for removing debris generated by commercial properties that has been placed on public rights-of-way (ROW), nor can they claim materials derived from commercial construction, repair, or renovation activities.

Five Key Takeaways for CTA FEMA Compliance

1. Document the Three Facets of Public Interest: Ensure every debris removal log or contract task order explicitly states whether the clear-and-remove action eliminates a threat to life, protects improved property, or drives community-wide economic recovery.
2. Restrict PNP Operations to Facility Footprints: Limit Private Nonprofit debris claims strictly to the immediate physical boundaries of the eligible service facility property.
3. Audit ROW Debris for Commercial Omissions: Instruct field spotters to monitor rights-of-way and exclude any debris piles rolled out from commercial business entities or derived from private structural renovations.
4. Enforce Geographic Ineligibility Boundaries: Do not clear or claim debris located on agricultural acreage, natural forests, or channels under the legal maintenance authority of other federal bodies like the USACE or NRCS.
5. Deploy a Specialized Debris Task Force: For widespread, catastrophic debris events, coordinate with FEMA to form a dedicated debris task force to review complex material stratifications (like silt, wreckage, and hazardous waste) prior to hauling.

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