Article 14: Relocation, Temporary

(Category: costs-eligilbilty)

Article Summary

When buildings that house essential community services—such as school classrooms, police and fire department facilities, government offices, and certain private nonprofit functions like critical health facilities—are damaged extensively enough that they cannot be used until repairs are made, temporary relocation of the essential services may be necessary. Criticality of the service and safety of the facility are the primary factors used to determine the need for temporary relocation.

FEMA provides Public Assistance to cover the cost-effective leasing, purchasing, or construction of alternate temporary spaces. However, the final eligible funding is subject to cost-comparison evaluations across alternate methods of delivering the facilities. Crucially, while the structural procurement and setup costs of the temporary facility are eligible, the ongoing routine maintenance, utility bills, and standard daily operating costs of that temporary space are completely ineligible for reimbursement. Under 44 CFR 206.204(c), assistance for temporary relocation is normally limited to a strict regulatory timeframe of 6 months. Time extensions may be authorized by FEMA, but only if the applicant successfully documents severe extenuating circumstances alongside measurable, active progress toward repairing the primary, disaster-damaged facility back to its pre-disaster design.

Five Key Takeaways for CTA FEMA Compliance

1. Limit Relocation Requests to Essential Services: Only pursue temporary relocation funding for core, critical community functions—such as public safety, emergency communications, education, or specialized critical health services—that cannot be safely paused.
2. Omit Routine Operating, Utility, and Maintenance Costs: Exclude all daily utility billings, preventative maintenance charges, and standard operational costs of the temporary facility from your project worksheet, as these are strictly non-reimbursable.
3. Adhere to the 6-Month Regulatory Deadline: Align project schedules with the mandatory 6-month regulatory limit for temporary emergency relocation, ensuring that any necessary extension requests are submitted with proof of active restoration progress.
4. Provide Cost-Effectiveness Evaluations for Space Options: Document a formal market and cost-comparison study proving whether renting or purchasing temporary space and equipment represents the most fiscally sound option for the grant.
5. Tie Relocation Timelines to Pre-Disaster Repair Schedules: Limit the duration of all temporary facility expenses to the exact timeline estimated to restore the primary damaged asset back to its original pre-disaster design configuration.

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