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PAPPG v5.0 · Chapter 5 · pages 70–74

Damage and Impact Information

How you tell FEMA what the disaster damaged, and how FEMA turns that list into projects: what the impact list must include, its 60-day deadline and when FEMA extends it, how debris, emergency work and damaged facilities are grouped, and when a site gets its own project. Every section is written as the question applicants actually ask, with FEMA’s requirements, the records you need, and the exact PAPPG pages.

5 topicsImpact list due 60 days after the scoping meetingGrouped by category and sectorCategories I and Z: one project each
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Chapter 5 › II.D–F Final Grouping; Category I and Category Z Grouping

When should a site or facility be split into its own project?

Final grouping; Category I and Category Z grouping
pp. 73–74
Short answer
After the initial grouping, FEMA splits out sites that would slow down or complicate the rest: complex environmental reviews, flood zones, sites needing design or studies, facilities with all work complete, complex facilities, possible ineligible work, and oversized projects. All Category I code and floodplain work goes in one project, and all Category Z management costs go in one project.
What FEMA requires
  • After initial grouping, FEMA separates sites or facilities into their own projects for the reasons in the table.
  • For facilities needing design or studies, FEMA later amends the project with the facility’s scope of work and cost once the repair method is decided, rather than creating a separate project.
  • Work items on the same facility may not be separated even if some are complete and others are not. Only a facility with all work complete is separated from one without.
  • Private nonprofits should separate critical service facilities from non-critical ones so critical facility projects are not delayed by the SBA loan determination (see Chapter 3).
  • All building code and floodplain management administration and enforcement activities (Category I, DRRA Section 1206) are grouped in one project.
  • All grant management activities (Category Z, DRRA Section 1215 and the management costs policy) are grouped in one project.
<table class="pt-table"><thead><tr><th>Separate the site or facility if it…</th><th>Why</th></tr></thead><tbody><tr><td>Needs a complex environmental or historic review</td><td>So the review doesn’t hold up the rest</td></tr><tr><td>Is in a special flood hazard area</td><td>Floodplain requirements apply</td></tr><tr><td>Needs design or studies to decide how to restore it</td><td>FEMA amends the project once the repair is set</td></tr><tr><td>Has 100 percent of its work complete</td><td>Completed work is handled differently</td></tr><tr><td>Is complex and needs specialized technical support</td><td>For example wastewater plants, dams, hospitals, schools</td></tr><tr><td>Potentially has ineligible work</td><td>Keeps disputes contained</td></tr><tr><td>Would make a project too burdensome to review</td><td>Too many sites in one project</td></tr><tr><td>Is agreed by you and FEMA to be illogical to combine</td><td>Specific circumstances</td></tr></tbody></table>
Documentation

Information that shows why a site should stand alone: its flood zone status, any expected environmental or historic issues, whether design or studies are needed, and whether all work on the facility is complete.

Watch out · Govstar advice
A facility can only be split out as “complete” if all its work is complete. You can’t separate the finished parts of one facility from the unfinished parts. Private nonprofits should keep critical service facilities in separate projects so they aren’t held up waiting on the SBA loan determination.
PAPPG v5.0 pp. 73–74 · DRRA §§ 1206, 1215
Read this in the PAPPG
Chapter 5 › II.C Initial Permanent Work Grouping (Categories C–G)

How does FEMA group damaged facilities into permanent work projects?

Grouping impacts into projects: Categories C–G
pp. 72–73
Short answer
By infrastructure sector: for example all roads, bridges and culverts in one group, all school campuses in another, the entire water distribution system in another. Administrative and support facilities at a site, such as sheds, parking lots, fences and equipment, go in the same project as the primary facility, but you must still list each one separately on the impact list.
What FEMA requires
  • FEMA initially groups damaged facilities by infrastructure sector (see table).
  • Administrative and support facilities at a site go in the same project as the primary facility.
  • You must list each damaged facility as a separate impact, whether primary or ancillary. FEMA uses the site identifier you provide to group them.
  • Support facilities include buildings, sheds, restrooms, pumping stations, towers, contents, equipment, vehicles, fences, parking lots, access roads, signage, lighting, sidewalks, ditches, catch basins, piers, trails, pools and ball fields.
  • For private nonprofits, not all support facilities are eligible (see Chapter 3).
<table class="pt-table"><thead><tr><th>Sector</th><th>Each of these is one initial group</th></tr></thead><tbody><tr><td>Transportation</td><td>Roads, bridges, low water crossings and culverts · Mass transit · Airports · Ports and harbors</td></tr><tr><td>Water control</td><td>Dams and reservoirs · Canals, channels, ditches, acequias and aqueducts · Stormwater basins · Shoreline protection (levees, berms, seawalls)</td></tr><tr><td>Education</td><td>All school campuses</td></tr><tr><td>Housing</td><td>All public housing campuses</td></tr><tr><td>Health</td><td>All hospital campuses and medical facilities</td></tr><tr><td>Emergency services</td><td>All police, fire and emergency operations centers</td></tr><tr><td>Other government</td><td>Courthouses, prisons, administrative and other non-emergency buildings</td></tr><tr><td>Energy</td><td>Power generation plants · Entire transmission and distribution system · Entire natural gas system</td></tr><tr><td>Water and wastewater</td><td>Treatment plants · Entire water distribution system · Entire wastewater collection system · Entire irrigation system</td></tr><tr><td>Communications and IT</td><td>All communication systems</td></tr><tr><td>Natural and cultural resources</td><td>Parks, golf courses and fish hatcheries · Beaches · Cemeteries, tribal burial grounds and sacred sites · Libraries, museums and galleries</td></tr></tbody></table>
Documentation

An impact list that lists every damaged facility separately, primary and ancillary alike, with a site identifier so FEMA can group support facilities with their primary facility.

Watch out · Govstar advice
If a support facility isn’t listed on its own line with the same site identifier, it can be missed entirely. For private nonprofits, not every support facility is eligible, so check facility eligibility before listing them.
PAPPG v5.0 pp. 72–73 · 44 CFR 206.201(k)
Read this in the PAPPG
Chapter 5 › II.A–B Initial Debris Removal and Emergency Protective Measures Grouping

How does FEMA group debris removal and emergency protective measures into projects?

Grouping impacts into projects: Categories A and B
pp. 71–72
Short answer
FEMA first groups work by category and facility type, then splits out sites that need their own project. Debris is grouped by where it was: public property, waterways, private non-commercial property, commercial property and private roads. Protective measures are grouped as private property demolition, general response, work on private property, work involving construction or repairs, and each temporary facility.
What FEMA requires
  • FEMA, the recipient and the applicant work together to group impacts into projects in two steps: create groups by category of work and facility type, then identify sites or facilities that should be separate projects.
  • Facilities under another federal agency’s authority, or ineligible for PA (for example, facilities not in use at the time of the incident), must not be put in a project. Withdraw them from the impact list, or FEMA will issue an ineligibility determination.
  • Grouping should never be based on project size or grant administration considerations.
<table class="pt-table"><thead><tr><th>Category</th><th>Each of these is one initial group</th></tr></thead><tbody><tr><td>A: Debris removal</td><td>Public property · Waterways · Private non-commercial property · Commercial property · Private roads</td></tr><tr><td>B: Emergency protective measures</td><td>Private property demolition · Emergency response activities (not on private property) · Protective measures on private property · Measures involving facility construction or repairs · Each individual temporary facility</td></tr></tbody></table>
Documentation

An impact list detailed enough for FEMA to sort each debris site and protective measure into the right group: where the debris was (public property, waterway, private or commercial property, private road) and whether a protective measure was on private property, involved construction or repairs, or was a temporary facility.

Watch out · Govstar advice
Private property work is grouped separately for a reason: it faces stricter eligibility review. Keep its costs, approvals and legal authority separate from your public right-of-way work from the first day.
PAPPG v5.0 pp. 71–72 · 44 CFR 206.201(k)
Read this in the PAPPG
Chapter 5 › I.A–B Impact List Deadline; Inundated and Submerged Roads

When is the impact list due, and can we get more time?

Impact list submission deadline; inundated and submerged roads
pp. 70–71
Short answer
Within 60 days of your recovery scoping meeting. FEMA may extend it if you ask in writing and justify it with circumstances beyond your or the recipient’s control, such as a site you can’t reach, or new categories of work approved after your meeting. Roads still under water may also get more time so they can be assessed once the water recedes and the soil dries.
What FEMA requires
  • Identify and report all incident-related impacts and damage within 60 days of attending the recovery scoping meeting.
  • FEMA may extend the deadline if you request it with justification based on extenuating circumstances beyond your or the recipient’s control, for example an inaccessible site, or an area where FEMA approved more categories of work after the meeting.
  • Inundated and submerged roads should not be assessed until flood waters recede and saturated soil dries out, so surface damage can be judged properly. If the water hasn’t receded by the deadline, FEMA may approve an extension for those sites.
  • You must tell FEMA about roads flooded by closed basin flooding that may stay under water indefinitely (see Chapter 8).
Documentation

The date of your recovery scoping meeting, the date you submitted the impact list, and for any extension, a written request with the justification and evidence (for example, photos or reports showing a site was still inaccessible or under water).

Watch out · Govstar advice
The 60 days start at the recovery scoping meeting, not when you finish assessing. Request any extension before the deadline, in writing, with the specific sites and the reason each one could not be assessed.
PAPPG v5.0 pp. 70–71 · 44 CFR 206.202(d)(1)(ii), (f)(2)
Read this in the PAPPG
Chapter 5 › I. Impact List

What goes on the impact list, and how detailed does it need to be?

Impact list (damage inventory)
p. 70
Short answer
Every damaged facility, every site with debris, and every major emergency protective measure taken to protect the public, listed by location with a rough cost. You also say whether you will claim management costs (Category Z) or building code and floodplain work (Category I). It does not need detailed damage descriptions or final costs, and FEMA does not use it to decide how much you receive.
What FEMA requires
  • List each damaged facility, each site with debris impacts, and each overarching emergency protective measure taken to address immediate threats to the public.
  • Identify whether you are claiming management costs, or building code and floodplain management administration and enforcement work.
  • List each item by location with a rough estimate of cost.
  • Detailed descriptions, damaged components within a facility and final cost estimates are not required at this stage.
  • FEMA does not use the impact list to determine the amount of assistance.
<table class="pt-table"><thead><tr><th>Required for every site or activity</th><th>Example</th></tr></thead><tbody><tr><td>Facility name or unique identifier</td><td>Campus or site name</td></tr><tr><td>Facility type</td><td>Building, road or system</td></tr><tr><td>Specific location (required)</td><td>Address or GPS coordinates</td></tr><tr><td>General description</td><td>Damage, protective measures, or approximate type and quantity of debris</td></tr><tr><td>Approximate cost</td><td>Rough estimate</td></tr><tr><td>Status of work</td><td>Not started, in progress or complete</td></tr><tr><td>Date of original construction</td><td>Year the facility was built</td></tr><tr><td>Project priority level</td><td>Your priority for the site</td></tr></tbody></table>
Documentation

Your damage inventory with the eight required items for each site, plus photos and notes you gathered while identifying damage. FEMA does not use the rough costs to set your funding, so a reasonable estimate is enough at this stage.

Watch out · Govstar advice
Anything left off the impact list is very hard to add later. List every site you suspect, including ancillary items like fences, signs and parking lots, and withdraw the ones that turn out ineligible rather than missing one.
PAPPG v5.0 p. 70 · 44 CFR 206.201(l)
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.