Article 22: Surveys to Assess or Locate Damage or Debris Impacts

(Category: damage-impact)

Article Summary

Public Assistance applicants are solely responsible for identifying and documenting all locations of incident-related damage and debris. Costs associated with general, macro-level assessments—including initial field surveys, mapping general debris impact zones, and participating in joint Preliminary Damage Assessments (PDAs)—are legally classified as indirect costs and are only eligible under the Management Costs allowance. They cannot be claimed as direct project costs or Direct Administrative Costs (DAC).

However, if an applicant discovers discrete disaster damage to a specific facility during a post-declaration survey, the exact inspection costs for that distinct structure become eligible as direct DAC, provided they are itemized and tracked to that specific project folder. Detailed follow-up engineering inspections to map out the precise repair blueprint or calculate exact debris quantities are fully eligible as part of the primary restoration or debris removal project worksheet. For partially damaged utility or linear systems (such as a sewer or water line), eligible inspection costs must be prorated based strictly on the percentage of the system that sustained actual disaster damage. For example, if an applicant inspects 500 linear feet of a sewer line but documents damage along only 100 linear feet, only 20% (one-fifth) of the total inspection cost is eligible.

Five Key Takeaways for CTA FEMA Compliance

1. Isolate Macro Scouting from Direct Project Worksheets: Charge all high-level, widespread damage scouting and initial debris location surveys strictly to your general management cost baseline rather than individual project files.
2. Track Facility Inspections directly to Projects: Route structure-specific engineering inspection costs to that distinct project's worksheet to qualify those hours for Direct Administrative Costs.
3. Apply Pro-Rata Math to Linear Utility Inspections: Document the exact total footage of any inspected pipeline or linear system and reduce the claimed inspection cost proportionally if only a fraction contains disaster damage.
4. Adhere to FEMA 352 for Seismic Screenings: Utilize the explicit evaluation parameters of FEMA 352 when inspecting and documenting post-earthquake damage to buildings constructed with welded steel-moment frames to ensure eligibility.
5. Separate Rapid Safety Placarding from Damage Appraisals: Ensure that rapid life-safety screenings ("red-tagging") are explicitly documented as short-term safety actions under Category B, keeping them isolated from long-term engineering repair appraisals.

‍