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PAPPG v5.0 · Appendix I · pages 299–311

Work Eligibility by Type of Facility

FEMA’s quick-reference checklists of eligible and ineligible work for each kind of facility: roads and bridges, levees and other water control facilities, buildings, equipment and vehicles, contents, utilities, and parks. Each section shows what FEMA will and won’t fund by category of work, the records to keep, and the PAPPG pages.

7 topicsEligible vs. ineligible tablesCategories A–G and IWaivers need FEMA HQ approval
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Appendix I › VII. Work Eligibility Considerations for Parks, Recreation, and Other

What work on parks, recreation facilities and beaches is eligible?

Work eligibility: parks, recreational and other facilities (Categories B and G)
pp. 310–311
Short answer
Emergency protective measures and stabilization for an immediate threat are eligible. Appendix I’s parks table mainly lists what is not eligible: federally constructed beaches and shoreline works, private nonprofit parks and recreation facilities, natural unimproved features, destroyed crops, and private or homeowners’ association beaches and dunes. Engineered beaches qualify only under specific criteria; general Category G eligibility is in Chapter 8.
What FEMA requires
  • Common EHP laws: NEPA, NHPA, Coastal Zone Management Act, Coastal Barrier Resources Act, ESA, Clean Water Act, EOs 11988 and 11990, and possible local NFIP requirements.
  • Eligible (Category B): emergency protective measures for an immediate threat, including bracing, shoring, barricades, safety fencing, sandbagging, and emergency repairs or stabilization.
  • Work performed under urgent circumstances that restores the facility’s pre-disaster design and function under codes and standards is permanent work, not emergency work.
  • Not eligible (Category G): restoring federally constructed beaches or shoreline protection; PNP parks and recreational facilities, including supporting roads, buildings and utilities; natural, unimproved features; destroyed crops; and private and homeowners’ association beaches or dunes.
  • Restoration of engineered beaches is subject to specific eligibility criteria in Chapter 8. For general Category G eligibility of public parks and recreational facilities, see Chapter 8.
<table class="pt-table"><thead><tr><th>Category</th><th>Eligible</th><th>Not eligible</th><th>Other considerations</th></tr></thead><tbody><tr><td>B: Emergency</td><td>Bracing, shoring, barricades, fencing, sandbagging, and emergency repairs or stabilization for an immediate threat</td><td>Urgent work that restores pre-disaster design and function under codes and standards (that is permanent work, not emergency work)</td><td>None</td></tr><tr><td>G: Restoration</td><td>Not listed in Table 45; see Chapter 8 for Category G eligibility</td><td>Federally constructed beaches or shoreline protection; PNP parks and recreational facilities, including their roads, buildings and utilities; natural, unimproved features; destroyed crops; private and homeowners’ association beaches or dunes</td><td>Engineered beaches are subject to specific eligibility criteria</td></tr></tbody></table>
Documentation

Records showing beaches or shoreline features were engineered and maintained, and documentation of supporting facilities such as roads, buildings and utilities within parks.

Watch out · Govstar advice
Urgent work that actually restores a park facility to its pre-disaster design is permanent work, not emergency work, with a different deadline and documentation. Label it correctly from the start.
PAPPG v5.0 pp. 310–311 · Table 45
Read this in the PAPPG
Appendix I › VI. Work Eligibility Considerations for Utilities

What utility work is eligible for water, sewer, power and communications systems?

Work eligibility: utilities (Categories B and F)
pp. 308–310
Short answer
Eligible: emergency protective measures and repairs, limited right-of-way clearing for access, and permanent repair or replacement of system components, including inspecting damaged parts and buried parts where there is evidence of damage. Not eligible: lost revenue, higher operating costs such as buying replacement power, and general surveys such as blanket sewer video inspection.
What FEMA requires
  • Covers water storage, treatment and delivery; power generation, transmission, distribution and storage (including natural gas, wind turbines, generators, substations and lines); sewage collection and treatment; and communication systems.
  • Common EHP laws: NEPA, NHPA, ESA, Clean Air Act, Clean Water Act, EOs 11988 and 11990, and possible local NFIP requirements.
  • Labor: for debris removal and permanent work, straight time and overtime are eligible for both budgeted and unbudgeted labor. For emergency protective measures, only overtime is eligible for budgeted labor; both are eligible for unbudgeted labor.
  • Utilities are eligible for mitigation and codes and standards upgrades.
  • Inspection of inaccessible structures or components is eligible only when there is evidence of damage, such as sunken ground above a water pipeline.
<table class="pt-table"><thead><tr><th>Category</th><th>Eligible</th><th>Not eligible</th></tr></thead><tbody><tr><td>B: Emergency</td><td>Bracing, shoring, barricades, fencing, sandbagging and emergency repairs to prevent further damage; limited right-of-way clearing for access</td><td>Lost revenue from a shutdown; increased operating costs, such as buying replacement power</td></tr><tr><td>F: Restoration</td><td>Permanent repair or replacement of system components, even if not contiguous; inspection of damaged components; inspection of inaccessible components when there is evidence of damage; conductor replacement under specific criteria</td><td>General post-disaster surveys, inspections and assessments, such as routine video inspection of sewer lines</td></tr></tbody></table>
Documentation

Labor records separating budgeted and unbudgeted staff and straight time from overtime; evidence of damage for inaccessible components (such as sunken ground over a pipeline); and conductor replacement analysis where applicable.

Watch out · Govstar advice
Blanket video inspection of a sewer system is ineligible. Inspect where there is visible evidence of damage, such as sinkholes or backups, and record that evidence before sending the camera in.
PAPPG v5.0 pp. 308–310 · Table 44
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Appendix I › V. Work Eligibility Considerations for Contents

What contents work is eligible, from furniture to files and collections?

Work eligibility: contents (Categories B and E)
pp. 307–308
Short answer
Eligible: moving and storing contents to prevent more damage, replacing destroyed contents with items of similar age, condition and capacity, treating irreplaceable items, recovering records, and re-shelving replacement library books. Not eligible: new items when used ones are available, new databases, data re-entry or scanning, and replacing rare books, collections or objects.
What FEMA requires
  • Contents include furnishings, equipment, consumable supplies, files, records, research contents, animals, irreplaceable collections and objects, library books and publications.
  • Contents may be replaced with different items used for the same general purpose, but eligible funding is capped at the estimated cost of equivalent items.
  • Irreplaceable items are eligible for condition assessment, stabilization and treatment; replacement of rare books, collections or objects is not.
  • Research contents and animals are ineligible for replacement if no comparable item or animal is available at a reasonable cost.
<table class="pt-table"><thead><tr><th>Category</th><th>Eligible</th><th>Not eligible</th></tr></thead><tbody><tr><td>B: Emergency</td><td>Removing and storing contents to prevent more damage</td><td>None listed</td></tr><tr><td>E: Restoration</td><td>Replacing destroyed contents with items of similar age, condition and capacity; assessing, stabilizing and treating irreplaceable items; recovering records; re-shelving and cataloging replacement library books</td><td>New for used (unless used isn’t reasonably available); new databases; re-entering data or scanning paper files into computers; deciphering photocopies; research contents or animals with no comparable replacement; replacing rare books, collections or objects</td></tr></tbody></table>
Documentation

An inventory of damaged contents with age and condition, replacement pricing for comparable used or new items, and records of stabilization and treatment for irreplaceable items.

Watch out · Govstar advice
FEMA funds the equivalent of what you lost, not an upgrade. You may buy different items for the same purpose, but funding is capped at the estimated cost of equivalent items, so price used equivalents where they exist.
PAPPG v5.0 pp. 307–308 · Table 43
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Appendix I › IV. Work Eligibility Considerations for Buildings, Equipment, and Vehicles

What building, equipment and vehicle work is eligible, and what isn’t?

Work eligibility: buildings, equipment and vehicles (Categories B, E and I)
pp. 304–307
Short answer
Eligible: mud and water removal, mold remediation, bracing and sandbagging, demolition for an immediate threat, safety placarding inspections, earthquake frame evaluations, and repair or replacement of buildings, equipment and vehicles to pre-disaster condition. Not eligible: mold from poor maintenance, unneeded slab removal, code and substantial-damage inspections, extra capacity for growth, and ADA fixes you were already cited for.
What FEMA requires
  • Common EHP laws: NEPA, NHPA, Clean Air Act, ESA, EOs 11988 and 11990.
  • Mud and silt removal needed to restore the facility is permanent work (Category E) and must be done with the restoration.
  • Demolition may not be eligible if securing the structure and area is enough to protect the public.
  • Earthquake frame repair to pre-earthquake design under FEMA 352 Chapter 6 is eligible only if FEMA approves a specific scope before the work; related architectural finishes and fire retardants are also eligible.
  • Restoration: provide construction dates; check historic register listings; identify floodplain location (1% chance, or 0.2% for critical actions); consider building, roof and system age and maintenance to separate disaster damage from pre-existing damage; comply with required codes.
  • Public housing authority facilities are eligible for permanent work only if Congress does not appropriate HUD funds for emergency capital needs for the facility.
<table class="pt-table"><thead><tr><th>Work</th><th>Eligible</th><th>Not eligible</th></tr></thead><tbody><tr><td>Water, mud and silt removal (B)</td><td>From eligible facilities, done quickly to address an immediate threat</td><td>On private property unless the threat is widespread, you have legal authority, and you have rights-of-entry and hold-harmless agreements</td></tr><tr><td>Mold remediation (B or E)</td><td>For an immediate threat or with restoration, including post-remediation sampling</td><td>Mold from poor maintenance or failure to protect the facility promptly; pre-remediation sampling that finds no mold</td></tr><tr><td>Emergency protective measures (B)</td><td>Bracing, shoring, barricades, fencing, sandbagging, emergency repairs</td><td>None listed</td></tr><tr><td>Demolition (B)</td><td>For an immediate threat, including imminently collapsing private structures</td><td>Removing slabs, foundations, pads or driveways that pose no hazard (except HMGP buyouts)</td></tr><tr><td>Safety inspections (B and I)</td><td>Placarding public and private buildings for safe entry and use</td><td>Inspections for elevation or relocation decisions, code compliance, substantial damage, or flood-fight fill removal</td></tr><tr><td>Earthquake steel frame evaluation (E)</td><td>Evaluating welded steel moment frames for disaster damage; approved repairs</td><td>Preliminary screening, analytical studies, and inspections that find no significant damage</td></tr><tr><td>Restoration (E)</td><td>Repair or replacement to pre-disaster design, capacity and function; like-for-like equipment and vehicles</td><td>Tax assessments; added capacity for growth; ADA fixes you were cited for before the incident</td></tr></tbody></table>
Documentation

Construction dates of all buildings in the project; National or state historic register status; floodplain status; age and maintenance records for the roof and building systems; mold sampling results; and, for earthquake frame repairs, FEMA’s approved scope before work begins.

Watch out · Govstar advice
Mold is lost most often to delay. If you can’t dry a building quickly, document why (no power, no access) and the steps you took, so the mold isn’t blamed on a failure to protect the facility.
PAPPG v5.0 pp. 304–307 · Table 42 · FEMA 352
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Appendix I › III. Work Eligibility Considerations for Water Control Facilities

What work on levees, dams, channels and basins is eligible?

Work eligibility: water control facilities (Categories A, B and D)
pp. 301–303
Short answer
Eligible: debris removal for an immediate threat, flood fighting, emergency repairs to engineered and maintained facilities, silt removal to restore their capacity, and permanent repair or replacement. Not eligible: work only to protect farmland, raising levees, dewatering to dry land, natural channels and shorelines, and facilities under the Corps of Engineers’ permanent repair authority.
What FEMA requires
  • Covers dams and reservoirs, irrigation and water conveyances, aqueducts, drainage channels, sediment and debris basins, stormwater basins, coastal shoreline protection, flood control works, and navigational and shipping channels.
  • Stormwater drainage built with road projects inside the right-of-way is Category C, not D.
  • Common EHP laws: NEPA, NHPA, ESA, Clean Water Act, EOs 11988 and 11990; waterway work usually needs a Section 404 permit.
  • Debris rules differ for navigable and non-navigable waterways. Separate incident debris from pre-existing debris and debris from other incidents.
  • The Corps of Engineers can do flood fighting but cannot reimburse applicants for their own flood fighting.
  • A waiver for ineligible work requires FEMA’s Assistant Administrator for Recovery.
<table class="pt-table"><thead><tr><th>Category</th><th>Eligible</th><th>Not eligible</th></tr></thead><tbody><tr><td>A: Debris</td><td>Debris removal from natural features or engineered facilities to eliminate an immediate threat</td><td>Debris removal only to protect agricultural land; debris surveys; flood control works under another federal agency; federally maintained navigable waterways</td></tr><tr><td>B: Flood fighting and emergency repairs</td><td>Flood fighting; emergency repairs of engineered, maintained facilities; repairing deliberate breaches; secondary levees riverward of a primary levee; emergency repairs of works under another federal agency</td><td>Measures only to protect agricultural land; permanently raising levee height or capacity; dewatering mainly to dry land</td></tr><tr><td>D: Capacity restoration</td><td>Debris and silt removal to restore capacity of engineered, maintained facilities</td><td>Flood control works under USACE authority</td></tr><tr><td>D: Restoration</td><td>Permanent repair or replacement, including PNP irrigation that supplies drinking water, fire suppression or electricity generation</td><td>Natural channels, lakes and shorelines; agricultural-only PNP irrigation; federally constructed shoreline protection</td></tr></tbody></table>
Documentation

Maintenance records showing the facility was engineered and maintained; evidence separating incident debris from pre-existing sediment; and documentation of whether another federal agency (such as the Corps of Engineers) has authority over the facility.

Watch out · Govstar advice
“Engineered and maintained” is the deciding phrase. Without maintenance records showing regular desilting or upkeep, FEMA treats a channel or basin like a natural feature, and sediment removal becomes ineligible.
PAPPG v5.0 pp. 301–303 · Table 41
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Appendix I › II. Work Eligibility Considerations for Roads and Bridges

What road and bridge work is eligible, and what isn’t?

Work eligibility: roads and bridges (Categories A, B and C)
pp. 300–301
Short answer
Eligible: debris removal for an immediate threat, emergency access and emergency repairs to keep roads passable, and permanent repair or replacement of roads, culverts and bridges. Not eligible: federal-aid highways (FHWA’s program), extra lanes, lost tolls, loss of useful life, routine maintenance, and private roads except in narrow emergency-access cases.
What FEMA requires
  • Applies to roads (surface, base, shoulders, ditches, guardrails, lighting, signs, sidewalks), drainage structures (culverts, low-water crossings) and bridges (decking, piers, girders, abutments, slope protection, approaches).
  • Common EHP laws: NEPA, NHPA, ESA, Clean Water Act, Clean Air Act, EOs 11988 and 11990. Work in waterways usually needs a Corps Section 404 permit and may involve local NFIP requirements.
  • Debris: separate incident debris from debris from other recent events and household waste.
  • Emergency access on private property: obtain rights-of-entry and agreements to indemnify and hold the federal government harmless.
  • Permanent work: separate minor incident damage from age, traffic and frequent rain damage; provide construction dates for culverts and nearby structures; H&H studies are required if replacing a culvert with a differently sized structure.
  • A waiver for ineligible work requires FEMA’s Assistant Administrator for Recovery.
<table class="pt-table"><thead><tr><th>Category</th><th>Eligible</th><th>Not eligible</th></tr></thead><tbody><tr><td>A: Debris</td><td>Debris removal and disposal to eliminate an immediate threat</td><td>Debris placed on public rights-of-way from commercial property unless FEMA approves; construction and renovation materials</td></tr><tr><td>B: Emergency access</td><td>Clearing or emergency repair of access roads and bridges to keep them passable, including strictly temporary access</td><td>Private roads unless no other access exists, damage blocks emergency access, and (for repairs) it eliminates temporary housing needs</td></tr><tr><td>B: Emergency repairs</td><td>Repairs to address an immediate threat</td><td>Emergency repair of federal-aid highways (FHWA)</td></tr><tr><td>C: Restoration</td><td>Permanent repair or replacement</td><td>Loss of useful life; lost tolls; extra lanes (except code-required one-to-two-lane bridge widening); routine maintenance; federal-aid highway repairs (except for Tribal Nations)</td></tr></tbody></table>
Documentation

Construction dates for culverts and nearby structures; maintenance records to separate disaster damage from age and wear; H&H studies if changing culvert size; and rights-of-entry and hold-harmless agreements for any work on private roads.

Watch out · Govstar advice
Road damage is often challenged as age, traffic wear or frequent rain rather than the disaster. Pair before-and-after photos with maintenance records, especially for gravel and older paved roads.
PAPPG v5.0 pp. 300–301 · Table 40
Read this in the PAPPG
Appendix I › I. General Work Eligibility Considerations for Facilities

Which PAPPG rules apply to every facility, whatever its type?

Work eligibility considerations for all facilities
pp. 299–300
Short answer
Every facility runs through the same core rules: facility and general work eligibility (Chapter 4), cost eligibility (Chapter 6), emergency work and debris rules (Chapter 7), EHP review for all work (Chapter 10), and, for permanent work, codes and standards, hazard mitigation, the 50 percent rule, relocation, floodplains and landslides (Chapter 8). Appendix I then lists facility-specific eligible and ineligible work.
What FEMA requires
  • Table 39 lists the PAPPG sections that apply to all facilities and when each applies (see table).
  • EHP review covers all work, including ground disturbance for staging areas, access roads, parking, landscaping, grading or utilities.
  • The 50 percent rule is an early decision on whether to repair or replace; it is not a full calculation of all eligible costs.
  • A policy waiver for any ineligible work in the facility tables requires approval from FEMA’s Assistant Administrator for Recovery.
<table class="pt-table"><thead><tr><th>Rule</th><th>Applies to</th></tr></thead><tbody><tr><td>Facility eligibility (Ch. 4)</td><td>All permanent work</td></tr><tr><td>General work eligibility (Ch. 4)</td><td>All work</td></tr><tr><td>Cost eligibility (Ch. 6)</td><td>All eligible work</td></tr><tr><td>Emergency work and debris removal (Ch. 7)</td><td>All Category A and B work</td></tr><tr><td>Environmental and historic preservation (Ch. 10)</td><td>All work, including staging, access roads, parking, grading and utilities</td></tr><tr><td>Codes and standards (Ch. 8)</td><td>Upgrades required by codes or standards</td></tr><tr><td>Hazard mitigation (Ch. 8, Appendix J)</td><td>Cost-effective measures that reduce future damage</td></tr><tr><td>Repair vs. replacement, the 50% rule (Ch. 8)</td><td>Early decision on repair or replace</td></tr><tr><td>Relocation (Ch. 8)</td><td>Destroyed facilities restored at a new location</td></tr><tr><td>Floodplain considerations (Ch. 8)</td><td>All permanent work in or affecting a floodplain</td></tr><tr><td>Landslides and slope stabilization (Ch. 8)</td><td>Facilities damaged by incident-triggered slope failure</td></tr><tr><td>Building code and floodplain administration (Ch. 8, Category I)</td><td>Code and NFIP administration and enforcement</td></tr><tr><td>Temporary relocation (Ch. 7)</td><td>Certain essential community service facilities</td></tr></tbody></table>
Documentation

Varies by facility type; see the facility-specific topics in this appendix.

Watch out · Govstar advice
Appendix I is a quick-reference checklist, not the rule itself. When a project turns on one of these points, go back to the chapter it cites, since that is what FEMA and appeal reviewers rely on.
PAPPG v5.0 pp. 299–300 · Table 39
Read this in the PAPPG
Govstar summarizes FEMA’s Public Assistance Program and Policy Guide, version 5.0 Amended, for disasters declared on or after January 6, 2025. “Watch out” notes are Govstar practitioner advice, not FEMA policy. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.