Article 28: Hazardous Limbs, Trees, and Stumps
(Category: debris-removal)
Article Summary
Vegetative debris removal is eligible for Public Assistance if the hazard was directly caused by the disaster and is located on public property or rights-of-way (ROW). It is strictly ineligible in natural, unimproved areas unless it extends directly over improved public spaces like trails, sidewalks, or playgrounds. Routine landscaping, pruning, and trimming are completely excluded.
FEMA dictates precise eligibility metrics for three types of hazards:
- Broken Limbs/Branches: Must be 2 inches or larger in diameter at the point of the break and pose an immediate threat. Reimbursement is strictly limited to the "minimum cut" necessary to eliminate the hazard (e.g., cutting at the closest branch junction rather than removing the entire trunk).
- Hazardous Trees: Eligible for removal if the trunk diameter is 6 inches or greater (measured 4.5 feet above the ground) and exhibits a split trunk, broken canopy, or a lean greater than 30 degrees. If 50% or more of the root-ball is exposed, tree extraction and hole-filling are eligible. If less than 50% is exposed, the tree must be flush-cut at ground level; stump grinding is ineligible.
- Hazardous Stumps: Stumps 2 feet or larger in diameter (measured 2 feet above ground) with 50% or more of the root-ball exposed are eligible for extraction on a per-stump basis, which must include transport, disposal, and hole-filling. Smaller stumps are paid strictly by weight/volume.
Work must stop immediately if potential archaeological resources are uncovered during stump extraction.
Five Key Takeaways for CTA FEMA Compliance
- Adhere to the Minimum Cut Rule: Limit limb trimming claims strictly to the minimum cut necessary to remove the immediate overhead threat; full branch-to-trunk removals are disallowed if a junction cut suffices.
- Enforce Precise Physical Dimensions: Train monitoring teams to measure and document exact dimensions: limbs must be $\ge \text{2 inches}$, trees must be $\ge \text{6 inches}$ (measured 4.5 feet up), and stumps must be $\ge \text{2 feet}$ (measured 2 feet up) to qualify for per-unit pricing.
- Prohibit Dual-Unit Billing for Root-Balls: Ensure contract line items do not double-charge for a single hazard; FEMA will not reimburse separate unit costs for removing an eligible tree and its corresponding root-ball.
- Stop Work for Archaeological Discovered Sites: Mandate an immediate halt to all mechanical stump extractions if historical artifacts or archaeological soils are exposed, and notify FEMA immediately to initiate Section 106 consultation.
- Capture USNG Coordinates and Photo Evidence: Document every standing hazard claim with its exact U.S. National Grid (USNG) or GPS coordinates, paired with photographic or video proof confirming it sits on public property.
