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PAPPG v5.0 · Chapter 7 · pages 115–166

Emergency Work Eligibility

What FEMA pays for in the first days and months after a disaster: debris removal (Category A), and emergency protective measures (Category B) such as flood fighting, emergency operations, medical care, evacuation and sheltering. Every section below is written as the question applicants actually ask, with FEMA’s requirements, the records you need, and the exact PAPPG pages.

32 topicsCategories A and BDue 6 months from declarationImmediate threat: within 5 years
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Chapter 7 › XIII.X–XIV Elections and Polling; Damage Caused During Performance of Emergency Work

Is election support eligible, and what if our crews damaged property during the response?

Elections and polling activities; damage caused during performance of emergency work
pp. 165–166
Short answer
Election-related work is eligible when the disaster damages polling facilities or voting equipment. Repairing public property, supplies or equipment damaged during eligible emergency work is eligible when the damage was caused by severe conditions, unavoidable, and not from misuse.
What FEMA requires
  • Repairs are added to the Category A or B project, even if the repair itself is permanent.
  • Replacing damaged trees, shrubs or ground cover is not eligible, nor are crops.
  • For equipment damage, show maintenance records proving it was in good condition, and when, where and how it was damaged.
  • Damage to private property is eligible only for an easement you must repair, or property you leased for sheltering or debris staging where the lease makes you responsible.
  • Damage from snow work outside the approved period is not eligible.
Documentation

Maintenance records, incident reports describing how damage occurred, and lease or easement terms for private property.

Watch out · Govstar advice
Write an incident report the day equipment is damaged. A reconstructed account months later rarely meets the “unavoidable” test.
PAPPG v5.0 pp. 165–166
Read this in the PAPPG
Chapter 7 › XIII.W.4 Emergency Berms on Beaches

Can we build emergency sand berms to protect property after beach erosion?

Emergency berms on beaches
pp. 164–165
Short answer
Yes, when erosion leaves improved property exposed to damage from a 5-year storm. Cost-effective emergency berms to protect against that storm are eligible; they are not meant to restore the beach permanently.
What FEMA requires
  • Show that the 5-year still water level plus wave runup exceeds the post-incident elevation of the primary dune.
  • FEMA funds up to 6 cubic yards of sand per linear foot above the 5-year still water level or the pre-incident profile, whichever is less, plus base sand below it if needed.
  • Imported sand is eligible only if recoverable sand is insufficient or regulations prohibit using it, and the source meets environmental rules.
  • Dune grass is eligible only when required by permit as a uniform practice; later maintenance is not.
  • A berm on a natural beach does not make it an eligible Category G facility in future disasters, and sand volumes can’t be pooled across disasters.
Documentation

Pre- and post-storm beach profiles, the 5-year water level and runup calculation, sand quantities and sources.

Watch out · Govstar advice
Survey beach profiles before storm season. Without a pre-incident profile, the eligible volume is hard to establish.
PAPPG v5.0 pp. 164–165
Read this in the PAPPG
Chapter 7 › XIII.W.3 Mold Remediation

Will FEMA pay to remove mold after flooding?

Mold remediation
pp. 163–164
Short answer
Yes, as an emergency protective measure, when the mold resulted from the incident and not poor maintenance or a failure to act promptly. If you couldn’t act quickly, document why.
What FEMA requires
  • Eligible work: wet vacuuming, damp wiping and HEPA vacuuming; removing contaminated wallboard, plaster, carpet, ceilings and fixtures; and cleaning contaminated HVAC, ductwork, plumbing and mechanical systems.
  • Sampling must be done by an indoor environmental professional not employed by the remediation company. Pre-remediation sampling is eligible only if it finds mold; post-remediation sampling to confirm completion is eligible.
  • Acceptable reasons for delay include power loss, flooding, inaccessibility, damaged HVAC, or not enough resources.
  • FEMA looks for pre-existing water problems: bad window seals, standing water, poorly maintained gutters or stained ceiling tiles. See PAPPG Appendix H.
Documentation

Sampling reports, the remediation scope, photos, and records explaining any delay in drying the building.

Watch out · Govstar advice
Start drying out buildings immediately and log the date. A gap between the flood and the first action invites a “failure to mitigate” finding.
PAPPG v5.0 pp. 163–164 · Appendix H
Read this in the PAPPG
Chapter 7 › XIII.W Emergency Repair or Stabilization

Can we make temporary repairs or stabilize a landslide before permanent work?

Emergency repair or stabilization; slope stabilization
pp. 161–163
Short answer
Yes, temporary repairs that eliminate or lessen an immediate threat are Category B. Repairs that restore pre-disaster design and function are permanent work, even if done urgently (except power restoration).
What FEMA requires
  • Not eligible when another federal agency has authority over the facility: federal-aid highways (FHWA), flood control works (Corps) and watershed structures (NRCS). Tribal roads are eligible if BIA or FHWA doesn’t fund the work.
  • Slope stabilization: eligible for an incident-triggered landslide threatening life or improved property, limited to the least costly option within the threat area. Inspections and limited geotechnical studies are eligible to find out whether a threat exists.
  • Measures include emergency drainage, ground protection, partial excavation at the head of the slide, toe buttressing (gabions, rock toes, crib walls, soldier piles) and debris-flow barriers.
  • Operation Blue Roof for homes is federal direct assistance only.
Documentation

A description of the threat, engineering or geotechnical findings, and why the repair is temporary.

Watch out · Govstar advice
Label temporary repairs as temporary in your scope. Work that looks permanent gets moved to a permanent work project with different rules.
PAPPG v5.0 pp. 161–163 · 44 CFR 206.201(b), 206.226(a)
Read this in the PAPPG
Chapter 7 › XIII.V Snow-Related Activities

When will FEMA pay for snow removal?

Snow assistance
pp. 160–161
Short answer
Only when the President declares a snowstorm or specifically authorizes snow assistance, and only for a continuous 48-hour period each applicant chooses. Emergency declarations never include snow assistance.
What FEMA requires
  • Eligible snow work: de-icing, salting, sanding, snow dumps and snow removal during the 48 hours.
  • The period may be extended 24 hours where snowfall exceeds the record by at least 50 percent.
  • Once your period is approved, you can’t change it, and contracts covering longer periods are funded only for the 48 hours.
  • Other emergency measures, such as search and rescue and sheltering, aren’t limited to the 48 hours.
  • Snow clearing needed to perform other eligible work, such as reaching downed power lines, is eligible outside the window.
Documentation

Records showing the start and end of your chosen 48-hour period, and labor, equipment and contract costs within it. See PAPPG Appendix K.

Watch out · Govstar advice
Pick the 48 hours with your heaviest costs, not the first 48. You can’t change the choice later.
PAPPG v5.0 pp. 160–161 · 44 CFR 206.227 · Appendix K
Read this in the PAPPG
Chapter 7 › XIII.U Temporary Relocation of Essential Services

Can we move essential services to a temporary facility while ours is repaired?

Temporary relocation of essential services; temporary facilities
pp. 156–160
Short answer
Yes, for essential governmental services when the facility is unsafe, inaccessible or destroyed and can’t be fixed quickly, or lacks a critical utility a temporary site would restore sooner. FEMA generally pays the least costly practical option among leasing, buying or building.
What FEMA requires
  • Eligible services include education, elections, police, fire and rescue, emergency medical care, homeless and domestic violence shelters, prisons, utilities, and their essential support facilities.
  • Not eligible: museums, zoos, community centers, libraries, houses of worship, senior centers, childcare and similar services.
  • Provide a cost analysis of at least three options; buying or building (other than modular units) needs FEMA approval first.
  • Eligible costs include replacing destroyed furniture and equipment once, alterations, restoring the temporary site, moving, required code upgrades and public notices. Utilities and operating costs are not.
  • The deadline is 6 months; only FEMA can extend it, up to 12 months if restoration will take longer, and further only if construction starts within 12 months.
  • If you buy or build, you must return FEMA’s share of the equity afterward.
Documentation

The three-option cost analysis, the damage assessment showing why the facility can’t be used, leases or purchase records, and the restoration schedule for the original facility.

Watch out · Govstar advice
Improved or alternate projects cut off temporary facility funding early. Decide your permanent strategy before committing to a long temporary lease.
PAPPG v5.0 pp. 156–160 · Stafford Act § 403(a)(3)(D) · 44 CFR 206.204
Read this in the PAPPG
Chapter 7 › XIII.T Demolition of Private Structures

Can we demolish dangerous private buildings after the disaster?

Demolition of private structures
pp. 154–156
Short answer
Yes, when collapse is imminent and threatens the general public, as determined by the authority having jurisdiction with a licensed engineer, architect or other authorized individual. If fencing off the area removes the threat more cheaply, demolition is ineligible.
What FEMA requires
  • Notify FEMA and identify the property type; preliminary approval is encouraged.
  • Certify the threat, cite the specific law or emergency power used, confirm an authorized official ordered the work, indemnify the federal government, get rights-of-entry and permits, and comply with EHP.
  • Eligible related work includes capping wells, pumping septic tanks, filling basements and pools, hazmat testing, securing utilities, permits and title searches. Your own permit fees count only if above normal costs.
  • Debris and hazardous material removal can be Category A.
  • Commercial structures (businesses, apartments, condos, mobile homes in commercial parks) are generally ineligible.
  • Not eligible: structures condemned before the incident, removing slabs and driveways that pose no hazard (except in HMGP buyouts), and placing demolition debris on the right-of-way.
Documentation

The items listed above for each structure, plus insurance recovery efforts with the owner.

Watch out · Govstar advice
Have the qualified individual’s written finding of imminent collapse for every structure before demolition starts.
PAPPG v5.0 pp. 154–156
Read this in the PAPPG
Chapter 7 › XIII.R–S Safety Inspections; Animal Carcasses

Are post-disaster building safety inspections and carcass removal eligible?

Safety inspections; animal carcasses
pp. 153–154
Short answer
Yes. Inspections to decide whether public or private buildings are safe to enter and occupy, including red-tagging, are eligible. Removing and disposing of animal carcasses is eligible when they threaten public health.
What FEMA requires
  • Inspections must be for safety, not to assess damage.
  • Carcass removal can be Category A as part of debris operations, otherwise Category B; FEMA may require certification of the threat from health officials, HHS or USDA.
  • Small animals such as rodents usually don’t pose a threat unless a health official says so.
  • FEMA doesn’t fund carcass work another agency covers, such as NRCS, USDA’s Farm Service Agency, or EPA and the Coast Guard for contaminated carcasses.
Documentation

Inspection logs and placards, and health official certifications and disposal records for carcasses.

Watch out · Govstar advice
Label inspections clearly as safety inspections. Ones that look like damage assessments get reclassified as management costs.
PAPPG v5.0 pp. 153–154
Read this in the PAPPG
Chapter 7 › XIII.P–Q Infectious Disease Incident; Mosquito Abatement

Will FEMA pay for public health measures like disease response or mosquito control?

Infectious disease incident; mosquito abatement
pp. 152–153
Short answer
For infectious disease declarations, FEMA works with the CDC and issues disaster-specific guidance on which measures are eligible. Mosquito abatement is eligible when a public health official validates a specific threat in writing, and only for the increase over normal spending.
What FEMA requires
  • In an infectious disease declaration, FEMA may fund evacuation, moving supplies, and care and shelter directly related to the incident, as set out in the disaster-specific guidance.
  • Mosquito abatement eligibility is decided with the CDC. The eligible amount is disaster-related cost minus your average abatement spending over the three most recent non-disaster years (see PAPPG Appendix F).
Documentation

The public health official’s written validation, and three years of normal mosquito abatement spending.

Watch out · Govstar advice
Keep a clean three-year history of routine mosquito spending. It sets the baseline FEMA deducts.
PAPPG v5.0 pp. 152–153 · Appendix F
Read this in the PAPPG
Chapter 7 › XIII.O.3–4 Host-State or Host-Tribe Evacuation and Sheltering; Childcare Services

What if another state shelters our evacuees, and is childcare for sheltered families eligible?

Host-state or host-tribe evacuation and sheltering; childcare services
pp. 150–152
Short answer
A host state or tribe sheltering another jurisdiction’s evacuees can be reimbursed through mutual aid, or directly by FEMA, which pays 100 percent of its eligible costs. The impacted state then repays the non-federal share. Licensed childcare supporting sheltered families is eligible too.
What FEMA requires
  • Only congregate sheltering by the host is eligible.
  • Direct FEMA funding requires that the impacted state requested help, the host accepts evacuees based on need without restriction, the host transmits a written agreement, and its governor or tribal chief executive signs the FEMA agreement.
  • Hosts can also recover employees’ regular time, unused shelter capacity they provided, certain law enforcement, transport and medical costs, and returning evacuees home.
  • Not eligible: waived state park fees for self-evacuees, and gas cards, vouchers, debit cards or cash to evacuees.
  • Childcare: licensed day care and before- and after-school care for sheltered families, including labor, facility, supplies and commodities, in congregate or non-congregate settings.
Documentation

Host-state agreements, evacuee intake and tracking records, insurance checks for medical and ambulance costs, and childcare attendance and cost records.

Watch out · Govstar advice
The impacted state can’t offset its share with the host state’s volunteer labor, so budget for the full non-federal share.
PAPPG v5.0 pp. 150–152 · 44 CFR 206.202(f), 206.208(c)(3)
Read this in the PAPPG
Chapter 7 › XIII.O.2.ii Non-Congregate Sheltering

Can we shelter people in hotels, dorms or trailers?

Non-congregate sheltering (NCS)
pp. 145–150
Short answer
Yes, in limited, exigent circumstances. Hotels, motels, dormitories and retreat camps don’t need pre-approval; anything else, such as RVs, short-term rentals or ships, needs FEMA Headquarters approval first. FEMA pays a per-night, per-room amount.
What FEMA requires
  • Notify FEMA Headquarters and your Regional Administrator through the recipient within 5 days of starting NCS (or 5 days after the declaration if you started earlier).
  • Requests for non-traditional facilities need a justification, whether Transitional Sheltering Assistance was requested, the options with costs, and the timeframe.
  • Feeding and support services are generally limited to the first 30 days.
  • Not eligible: à la carte charges, unoccupied rooms or units, damage beyond the nightly rate at traditional facilities, and case management or behavioral health services.
  • Survivors’ homeowners insurance with living-expense coverage is not a duplication of benefits.
  • Extensions come in 30-day increments; ask at least 7 days before expiration. The Regional Administrator can approve up to 6 months from the declaration; FEMA Headquarters approves beyond that.
<table class="pt-table"><thead><tr><th>After 30 days, each household must</th><th>Notes</th></tr></thead><tbody><tr><td>Be in a county designated for both Individual Assistance and Public Assistance</td><td></td></tr><tr><td>Be registered with Individual Assistance and not have withdrawn</td><td></td></tr><tr><td>Document pre-disaster status as owner or renter of the primary residence</td><td></td></tr><tr><td>Have a primary residence that is uninhabitable or inaccessible because of the incident</td><td>Habitability can be based on IA data, home assessments or your own documented process</td></tr></tbody></table>
Documentation

A weekly data report through the recipient, with registration IDs, household contacts, counts by county, damaged dwelling addresses, habitability status, rooms occupied, check-in and check-out dates and shelter sites.

Watch out · Govstar advice
Start the weekly household data report in week one. Without it, extensions beyond 30 days are denied.
PAPPG v5.0 pp. 145–150
Read this in the PAPPG
Chapter 7 › XIII.O.2.i Congregate Sheltering

What shelter costs will FEMA reimburse?

Congregate sheltering
pp. 142–145
Short answer
FEMA reimburses state, local, tribal and territorial governments for congregate shelter facility, staff, supply and service costs while the shelter is actively housing survivors, including warming and cooling centers. FEMA pays only the government, even when it contracts the work out.
What FEMA requires
  • Facility: lease, utilities, minor modifications for habitability, ADA access, childcare or pet sheltering, restoration afterward, generators and secure medical storage.
  • Staff: medical, personal assistance, veterinary, public information, social workers, food service, custodial and National Guard.
  • Supplies: meals, cooking supplies, pet supplies, medical equipment and supplies, infant supplies, cots and bedding, hygiene kits, and set ratios for TVs (1 per 50), computers (1 per 25) and washers and dryers (1 each per 50).
  • Services: management, security, cleaning, transport for shelter support, personal assistance services, emergency medical and crisis care, limited outpatient care, and sheltering self-evacuees.
  • Payments to the Red Cross or other groups under a written agreement are eligible; their own mission costs are not. Volunteer agency labor counts only as a donated resource.
  • Not eligible: transporting residents to and from the shelter (other than medical), disaster case management, and most behavioral health services.
Documentation

Shelter population logs by night, staffing records, supply purchases, the facility agreement and any agreement with an operating organization.

Watch out · Govstar advice
Keep a nightly population count. Costs are eligible only while the shelter is actively in use, and the count proves it.
PAPPG v5.0 pp. 142–145
Read this in the PAPPG
Chapter 7 › XIII.O.1 Evacuation

What evacuation costs will FEMA pay for?

Evacuation
pp. 140–142
Short answer
Transporting survivors out and back, with household pets, service and assistance animals, luggage and durable medical equipment, is eligible, including emergency medical transport, using customary and appropriate transportation.
What FEMA requires
  • Eligible activities include moving patients from compromised medical or care facilities and back, emergency medical transport, buses and other vehicles from pre-set pickup points (including driver standby), paratransit for seniors and people with disabilities, tracking evacuees and animals, food and water and medical care during transport, and advance mobilization in threatened areas.
  • Ambulance staging must be part of a state, tribal, territorial or regional evacuation plan; funding ends when the area wasn’t impacted, evacuations and returns are complete, or demand returns to normal.
  • Not eligible: ambulance costs covered by insurance, Medicare or Medicaid; self-evacuee transportation; and livestock, exhibition animals and reptiles other than turtles.
Documentation

Evacuation orders, pickup and drop-off records, evacuee and animal tracking logs, and ambulance and transport invoices with insurance checks.

Watch out · Govstar advice
Household pets have a specific definition: dogs, cats, birds, rabbits, rodents and turtles. Track pets and service animals separately from livestock.
PAPPG v5.0 pp. 140–142
Read this in the PAPPG
Chapter 7 › XIII.N Emergency Medical Care

Will FEMA pay for emergency medical care when local systems are overwhelmed?

Emergency medical care
pp. 138–140
Short answer
When the local emergency medical system is destroyed, compromised or overwhelmed, FEMA funds extraordinary costs of operating emergency rooms and temporary medical facilities for survivors, for up to 30 days from the declaration unless FEMA approves more time.
What FEMA requires
  • Eligible care includes triage, tests and diagnosis, treatment and stabilization, first aid, a one-time 30-day prescription supply, vaccinations to prevent outbreaks, durable medical equipment, consumable medical supplies, temporary facilities and their equipment and security, and ambulances for immunizations and mobile units.
  • FEMA judges reasonableness using Medicare’s cost-to-charge ratio.
  • Not eligible: inpatient care after admission, follow-up or long-term treatment, and administrative costs.
  • Costs covered by private insurance, Medicare, Medicaid or another source are excluded; you must document that coverage was pursued, patient by patient.
Documentation

Patient-by-patient records showing insurance and other coverage was checked, plus facility, staffing and supply costs. Extensions need a justification and an analysis of options with costs.

Watch out · Govstar advice
Build insurance screening into intake from the first patient. Reconstructing coverage checks later is nearly impossible.
PAPPG v5.0 pp. 138–140 · Stafford Act § 312
Read this in the PAPPG
Chapter 7 › XIII.L–M Supplies and Commodities; Meals

Can we claim emergency supplies we handed out and meals for our workers?

Supplies and commodities; meals
pp. 137–138
Short answer
Yes. Life-sustaining commodities distributed to the community, and the space to store and distribute them, are eligible. Meals for employees and volunteers doing eligible emergency work are eligible under specific conditions.
What FEMA requires
  • Commodities: food, water, ice, hygiene items, cots, blankets, tarps, roof sheeting, generators, and food and supplies for pets and service animals; delivery to unsheltered residents where items can’t be bought; mass feeding by governments or nonprofits.
  • Meals: for workers not on per diem, when required by a qualifying labor policy, when severe conditions force extended hours without time to get food, or when food isn’t available to buy.
  • Meals must be brought to the work location and bought cost-effectively, such as bulk meals. Restaurant outings and individual meals aren’t eligible.
  • Purchased supplies and equipment may be subject to disposition rules.
Documentation

Purchase and distribution records, lease agreements for storage space, and meal invoices with the workers served and the condition that justified meals.

Watch out · Govstar advice
Order bulk meals delivered to the site. Reimbursing receipts from individual restaurant meals is a common disallowance.
PAPPG v5.0 pp. 137–138
Read this in the PAPPG
Chapter 7 › XIII.K Hazardous Materials

Will FEMA pay to clean up hazardous materials released by the disaster?

Hazardous materials (pollutants and hazardous substances)
pp. 136–137
Short answer
Yes. Separating, handling, stabilizing, pumping, cleaning up and disposing of hazardous materials are eligible, along with short-term testing to eliminate the immediate threat. Testing for long-term cleanup is not.
What FEMA requires
  • Comply with federal and state environmental requirements, get permits, notify agencies, and use certified hazardous waste specialists.
  • EPA (inland) and the Coast Guard (coastal) have their own authority to respond to oil and hazardous substance releases.
  • Hazardous material removal can be Category A when part of overall debris operations; otherwise it is Category B.
Documentation

Permits, agency notifications, test results, manifests and disposal records.

Watch out · Govstar advice
Call EPA or the Coast Guard early. If they have authority over the release, FEMA may not fund your cleanup of it.
PAPPG v5.0 pp. 136–137
Read this in the PAPPG
Chapter 7 › XIII.J Emergency Access

Can we clear or repair roads to reach cut-off communities, including private roads?

Emergency access
pp. 135–136
Short answer
Yes, when damage or debris isolates an essential community service or a community with survivors. Eligible work is limited to keeping access passable; further debris removal is Category A.
What FEMA requires
  • Clearing private roads (orphan roads, gated communities, homeowners’ association roads) is eligible when debris blocks emergency responders, limited to what keeps the road passable. No public-interest showing is required, but you need legal process or rights-of-entry and hold-harmless agreements.
  • Emergency repairs to private roads are eligible only if there is no other access, the repair economically avoids the need for temporary housing and sheltering, and you complete the legal steps.
Documentation

Maps of isolated areas, photos of the blockage or damage, and rights-of-entry for private roads.

Watch out · Govstar advice
“Push and toss” to open a road is Category B; hauling the debris away later is Category A. Track the two separately.
PAPPG v5.0 pp. 135–136
Read this in the PAPPG
Chapter 7 › XIII.I Emergency Operations Centers

Can we claim the costs of running our emergency operations center?

Emergency operations center (EOC) costs
p. 135
Short answer
Yes. Response activities run from the EOC are eligible when tied to eligible work, along with EOC operating costs such as increased utilities, facility leases, supplies and meals that meet FEMA’s meal rules.
What FEMA requires

EOC staff labor follows the force account labor rules: for budgeted staff on emergency work, overtime only.

Documentation

EOC activation and deactivation records, staff sign-ins, and utility, lease, supply and meal costs.

Watch out · Govstar advice
Record EOC activation levels and hours. They support both the operating costs and the overtime claimed.
PAPPG v5.0 p. 135
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Chapter 7 › XIII.H Flood Fighting

Is flood fighting, like sandbagging and pumping, eligible?

Flood fighting
p. 135
Short answer
Yes, when needed to reduce an immediate threat to life, public health and safety, or improved property, including sandbagging, dewatering behind a levee and raising a levee. It is eligible even at facilities in the Corps’ Rehabilitation and Inspection Program, because the Corps can’t reimburse flood fighting.
What FEMA requires
  • Repairing breaches you deliberately made to dewater is eligible as part of the emergency work project.
  • Dewatering agricultural and natural areas behind levees is not eligible.
Documentation

Records of the threat, the measures taken, and labor, equipment and materials used.

Watch out · Govstar advice
Photograph water levels and threatened property as you fight the flood. They prove the threat after the water recedes.
PAPPG v5.0 p. 135
Read this in the PAPPG
Chapter 7 › XIII.F Increased Operating Costs

Will FEMA pay higher operating costs during the emergency?

Increased operating costs
p. 134
Short answer
Only narrowly: costs tied to eligible emergency actions to save lives or protect health, safety or property, for a limited time, and tracked separately. Most increased operating costs are ineligible.
What FEMA requires
  • Can be eligible for a limited time: water testing and treatment right after the incident to counter a specific threat; fuel or electricity for increased pumping.
  • Ineligible even short term: patient care (except emergency medical care), administration, food (except as supplies or meals), staff working extra hours without doing eligible work, alternate power or water sources, school make-up days and related bus service, and adding landfill capacity.
  • For nonprofits, operating costs are generally ineligible unless done at a government’s request.
Documentation

Separate tracking of the added costs, the specific emergency action they supported, and the time period.

Watch out · Govstar advice
Set up a separate cost code for any increased operating cost on day one, with the specific threat it addresses.
PAPPG v5.0 p. 134
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Chapter 7 › XIII.E Pre-Positioning Resources

Will FEMA pay to stage equipment and supplies before the disaster hits?

Pre-positioning resources
p. 133
Short answer
Yes, if the equipment and supplies are used for eligible emergency work. Pre-positioning outside the declared area is also eligible for search and rescue, evacuation, sheltering or emergency medical care during evacuation, if the resources were ultimately used for the declared area.
What FEMA requires

Labor for pre-positioning follows the force account labor rules in Chapter 6.

Documentation

Records of what was staged, where and when, and how it was later used on eligible work.

Watch out · Govstar advice
Resources that were staged and never used are hard to claim. Document deployment, not just staging.
PAPPG v5.0 p. 133
Read this in the PAPPG
Chapter 7 › XIII.D Emergency Protective Measures Conducted by Private Nonprofit Organizations

What emergency work can a private nonprofit claim?

Emergency protective measures conducted by private nonprofit organizations
pp. 116, 133
Short answer
Generally only work to protect its own eligible facility and contents, and debris removal from that facility. Emergency services are a government responsibility, so a nonprofit providing them is paid through the government that asked for them in writing.
What FEMA requires
  • Services such as fire and rescue, animal control, ambulance evacuation and 211 call services are funded through the requesting government as the applicant.
  • Nonprofit medical and custodial care facilities can be reimbursed directly for patient evacuation.
  • In limited cases, FEMA reimburses a nonprofit directly when essential components are urgently needed to save lives, such as a hospital emergency room or a water or sewage plant.
  • A nonprofit volunteer fire department is a direct applicant if an agreement with a government legally authorizes it to provide emergency services in designated areas.
  • Nonprofit operating costs are generally ineligible, even for emergency services, unless performed at a government’s request.
Documentation

The written agreement or contract with the government entity, and records tying costs to your eligible facility.

Watch out · Govstar advice
Nonprofits that support response should sign agreements with their local governments before disaster season, so the work has a funded path.
PAPPG v5.0 pp. 116, 133
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Chapter 7 › XIII.C Emergency Protective Measures on Private Property

Can we do emergency work on private property?

Emergency protective measures on private property
pp. 132–133
Short answer
In limited cases: when the threat is so widespread it endangers the general public, you have legal authority to do the work, and you have rights-of-entry and agreements holding the federal government harmless.
What FEMA requires

Typical situations:

  • Demolishing unsafe private structures;
  • Removing animal carcasses;
  • Emergency access;
  • Pumping septic tanks or decontaminating wells that threaten pollution;
  • Building safety inspections; and
  • Slope stabilization. (Operation Blue Roof is federal direct assistance only.)

If the criteria aren’t met, the owner may qualify for Individual Assistance instead.

Documentation

Your legal authority to enter private property, the basis for finding a threat to the general public, and copies of rights-of-entry and hold-harmless agreements.

Watch out · Govstar advice
Use a standard right-of-entry form with hold-harmless language and keep a signed copy for every parcel.
PAPPG v5.0 pp. 132–133
Read this in the PAPPG
Chapter 7 › XIII.A–B Emergency Protective Measures

What response activities count as emergency protective measures?

Category B: Emergency protective measures
pp. 130–132
Short answer
Measures before, during and after the incident are eligible if they eliminate or lessen immediate threats to life, public health or safety, or cost-effectively prevent significant additional damage to improved property. FEMA may require an official certification of the threat.
What FEMA requires

Eligible measures include, among others:

  • Saving lives and protecting health and safety: pre-positioning resources, flood fighting, emergency operations centers, emergency access, supplies and commodities, medical care and transport, evacuation and sheltering, childcare for shelters, safety inspections, animal carcass removal, demolition, search and rescue, firefighting, security, temporary generators for essential services, public warnings, and recovery and storage of human remains.
  • Protecting improved property: emergency berms and temporary levees, emergency repairs such as covering a damaged roof, shoring and bracing, emergency slope stabilization, mold remediation, removing and storing contents, extracting water and mud quickly, and saving animals eligible for replacement.
  • Only under limited conditions: increased operating costs, mosquito abatement, temporary relocation of essential services, and snow activities when the declaration authorizes them.
Documentation

A description of each measure and the threat it addressed, plus labor, equipment, contract and supply records.

Watch out · Govstar advice
Keep a daily response log tying each activity to a specific threat. It is the backbone of a Category B project.
PAPPG v5.0 pp. 130–132 · 44 CFR 206.225
Read this in the PAPPG
Chapter 7 › XII.F Private Property Debris Removal

Can we remove debris from private property, private roads or commercial properties?

Private property debris removal (PPDR)
pp. 127–130
Short answer
Usually not. It is the owner’s responsibility. FEMA may make it eligible when debris is so widespread it threatens public health and safety or economic recovery, and the work must be in the public interest, not just benefit a few people.
What FEMA requires
  • Pre-approval isn’t required, but you must notify FEMA and identify the type of property; preliminary approval is encouraged.
  • You need written property identification, a certification of legal authority citing the source, indemnification of the federal government, rights-of-entry, permits and EHP compliance.
  • A public health authority or other legal authority must assert the threat, citing the specific legal requirements.
  • Private roads: unrestricted roads frequently used by the public are presumed in the public interest; gated or rarely used roads need a showing. Driveways and parking lots aren’t included.
  • Private homes: FEMA weighs debris location, volume, height, number of houses and blocks affected, and population.
  • Commercial property: typically ineligible because businesses are expected to carry insurance; get written pre-approval. Only the Regional Administrator can make an exception.
  • Pursue property owners’ insurance and credit FEMA its share.
Documentation

The items listed above, plus all standard debris documentation. Source: PAPPG Table 22.

Watch out · Govstar advice
Line up legal authority, rights-of-entry forms and the public health declaration before crews enter private property. Assembling them afterward is where PPDR claims fail.
PAPPG v5.0 pp. 127–130 · Stafford Act § 407 · 44 CFR 206.224
Read this in the PAPPG
Chapter 7 › XII.E Monitoring Contracted Debris Removal Operations

Do we have to monitor our debris contractors, and will FEMA pay for it?

Monitoring contracted debris removal operations
pp. 126–127
Short answer
You must monitor all contracted debris removal, from pickup to final disposal, and FEMA pays for reasonable monitoring. You can use your own staff, temporary hires, contractors or a mix.
What FEMA requires
  • Monitoring documents debris types and quantities, reductions and methods, and pickup and disposal locations.
  • Eligible activities include field supervision, monitoring at loading and disposal sites, compiling load tickets and monitor reports, and training monitors.
  • Professional engineers or other certified staff aren’t needed; using them is unreasonable unless you document why their qualifications were required.
  • FEMA trains your force account monitors on request.
Documentation

Load tickets, tower logs, monitor reports and monitor timesheets. See FEMA’s Public Assistance Debris Monitoring Guide.

Watch out · Govstar advice
Unmonitored loads are the costliest debris finding. Put a monitor at every loading and disposal point from day one.
PAPPG v5.0 pp. 126–127
Read this in the PAPPG
Chapter 7 › XII.D Disposal

What disposal costs will FEMA pay for debris?

Disposal; temporary debris staging and reduction sites; tipping fees
pp. 125–126
Short answer
FEMA funds efficient, cost-effective disposal, including reducing vegetative debris by mulching, grinding or burning, staging sites, and landfill tipping fees limited to costs of operating the landfill.
What FEMA requires
  • Recycling revenue reduces funding, less your costs to market the material. If the contract lets the contractor keep salvage to lower its bid, nothing is owed.
  • Staging sites: setup, operation and lease costs are eligible, plus restoration if the lease requires it.
  • Tipping fees: only fixed and variable landfill operating costs; special taxes for other government services are removed.
  • Lost landfill capacity is not eligible.
  • Disposal of sand on a public beach is eligible when it is the cheapest option.
<table class="pt-table"><thead><tr><th>Truck type</th><th>How much capacity FEMA counts</th></tr></thead><tbody><tr><td>Hand-loaded trucks and trailers carrying vegetative debris</td><td>50 percent of the monitor’s observed capacity</td></tr><tr><td>Trucks without solid tailgates</td><td>Up to 85 percent of certified capacity (a 15 percent reduction)</td></tr></tbody></table>
Documentation

Lease agreements for staging sites, permits, and the breakdown of your tipping fee showing operating components.

Watch out · Govstar advice
Get your landfill’s tipping-fee breakdown before the disaster. FEMA will strip out non-operating components, and you need the numbers to defend the rest.
PAPPG v5.0 pp. 125–126
Read this in the PAPPG
Chapter 7 › XII.C Privately-Owned Vehicles and Vessels on Public Property

Can we remove abandoned cars and boats left by the disaster?

Privately-owned vehicles and vessels on public property
p. 124
Short answer
Yes, from public property, if the vehicle or vessel blocks access to a public-use area, is abandoned, and you follow your own removal laws and document how you handled it.
What FEMA requires
  • The vehicle or vessel blocks access to a public-use area;
  • It is abandoned;
  • You follow applicable state, local, tribal or territorial removal ordinances; and
  • You document its handling.

Limited storage is eligible when removal is needed before the owner can be identified. If you find the owner, pursue storage and removal costs and credit FEMA its share.

Documentation

Photos, location, ordinance followed, owner search records, and storage and disposal records for each vehicle or vessel.

Watch out · Govstar advice
Run owner searches as you go. Recovered costs reduce FEMA’s share, so a missing paper trail looks like you didn’t try.
PAPPG v5.0 p. 124
Read this in the PAPPG
Chapter 7 › XII.B Waterways

Can we remove disaster debris from rivers, canals and channels?

Waterway debris; navigable and non-navigable waterways
pp. 123–124
Short answer
Only when the debris poses an immediate threat to life, public health and safety, or improved property. Debris the incident deposited that doesn’t meet that test is ineligible, and federally maintained navigable waterways are the responsibility of the Coast Guard and the Corps of Engineers.
What FEMA requires
  • Navigable waterways you maintain: debris obstructing vessels is eligible down to 2 feet below the low-tide draft of the largest vessel that used the waterway before the incident.
  • Non-navigable waterways and flood control works: eligible if the debris obstructs intakes, could damage bridges or culverts, or could flood improved property in a 5-year flood.
  • Debris in works built under NRCS watershed authority is ineligible even if NRCS can’t help. Works in the Corps’ Rehabilitation and Inspection Program are eligible for PA debris removal.
  • Random surveys are ineligible; a targeted survey (including side-scan sonar) is eligible once you show a specific threat area.
  • Coordinate first with EPA or the Coast Guard, the Corps (permits), NMFS and Fish and Wildlife, and with NRCS to avoid duplicate funding.
Documentation

Before-and-after satellite imagery or bathymetric surveys showing the debris was deposited by the incident, plus permits and agency coordination records.

Watch out · Govstar advice
Prove the debris is new. Without pre-disaster imagery or soundings, FEMA may treat it as pre-existing.
PAPPG v5.0 pp. 123–124
Read this in the PAPPG
Chapter 7 › XII.A Hazardous Limbs, Trees, and Stumps

Can we remove damaged trees, hanging limbs and stumps?

Hazardous limbs, trees and stumps
pp. 120–122
Short answer
Yes, when the incident damaged them enough to pose an immediate threat to life, public health and safety, or improved property. They are ineligible if the hazard existed before the incident, or if they are in a natural area and don’t threaten improved property or public-use areas.
What FEMA requires
  • Limbs: remove broken limbs threatening improved property or public-use areas. On private property, only limbs extending over the public right-of-way, removed from the right-of-way. Only the minimum cut is eligible.
  • Trees: damaged trees are hazardous if root, trunk or limb damage or their lean makes them a hazard, as assessed by the authority having jurisdiction with a qualified individual (forester, TRAQ-qualified assessor or certified arborist).
  • Choose a cost-per-tree or cost-per-parcel method and say which you used.
  • Bracing a tree is eligible as Category B. Pruning, trimming and landscaping are not.
  • Stump removal in areas with archaeological potential needs EHP review; stop work and notify FEMA if resources are found.
<table class="pt-table"><thead><tr><th>Situation</th><th>What FEMA funds</th></tr></thead><tbody><tr><td>Tree with 50% or more of root-ball exposed</td><td>Removing the tree and root-ball and filling the hole (not two separate unit costs)</td></tr><tr><td>Tree with less than 50% of root-ball exposed</td><td>Flush cut at ground level and disposal by volume or weight; grinding the stump is ineligible</td></tr><tr><td>Stump with 50% or more of root-ball exposed</td><td>Removal and filling the hole, or in-place grinding if cheaper</td></tr><tr><td>Stump not requiring extraction</td><td>Paid by volume or weight, not per stump</td></tr></tbody></table>
Documentation
  • Quantity removed; quantity, location and source of fill for root-ball holes; and the equipment used.
  • For each hazard, the location and photo or video of the specific immediate threat.

Source: PAPPG pp. 120–122.

Watch out · Govstar advice
Contract limbs as a one-time charge per tree, not per limb, and make sure stump prices include extraction, hauling, disposal and fill.
PAPPG v5.0 pp. 120–122
Read this in the PAPPG
Chapter 7 › XII. Debris Removal (Category A)

When is debris removal eligible for FEMA funding?

Category A: Debris removal; public interest
pp. 117–120
Short answer
Debris clearance, removal, recycling and disposal are eligible when removal is in the public interest: to eliminate immediate threats to life, health and safety or of significant damage to improved property, or to ensure the economic recovery of the community.
What FEMA requires
  • Debris includes vegetation, construction and demolition debris, sand, mud, silt, gravel, rocks, white goods, and vehicle and vessel wreckage. Snow is not debris.
  • Debris on improved public property and public rights-of-way, including federal-aid roads, is eligible. So is residential debris that residents were authorized to move to the right-of-way, for a limited period.
  • Commercial debris placed on the right-of-way is not eligible, nor is debris from construction or renovation work.
  • For private nonprofits, debris removal is limited to their eligible facility.
  • Debris removal from federally maintained navigable channels, agricultural land and natural, unimproved land is not eligible.
  • Removing debris to restore an engineered facility’s capacity is permanent work, not Category A.
Documentation
  • Small projects: estimated or actual quantities removed, reduced, disposed and recycled by type; proof of monitoring if contracted; staging and disposal site locations and types; permits; and proof waterway debris isn’t pre-existing.
  • Large projects: all of the above plus load tickets, photographs, tower logs, coordination with other agencies, quarantine-area disposal records, and threat documentation for hazardous trees, limbs and stumps.

Source: PAPPG Table 21.

Watch out · Govstar advice
Tell residents early and clearly what may go on the curb and for how long. Commercial and renovation debris mixed into the piles is the most common reduction.
PAPPG v5.0 pp. 117–120 · Stafford Act § 407 · 44 CFR 206.224
Read this in the PAPPG
Chapter 7 › XI. Eligibility Considerations for Emergency Work

What makes response work eligible as emergency work?

Emergency work (Categories A and B); immediate threat
pp. 115–117
Short answer
Emergency work is work that must be done immediately to save lives, protect public health and safety, protect improved property, or eliminate or lessen an immediate threat of more damage. It covers debris removal (Category A) and emergency protective measures (Category B), and is due within six months of the declaration.
What FEMA requires
  • An immediate threat is a threat of additional damage that can reasonably be expected within five years of the declared incident. The incident must have caused the threat, but the threat can come from a different kind of event, such as post-fire debris flows.
  • The work must be the legal responsibility of an eligible applicant.
  • For governments, eligibility turns mainly on the immediate threat and legal authority to do the work, not on facility eligibility.
  • For private nonprofits, emergency work is generally limited to debris removal from, and protective measures for, their own eligible facility.
  • The deadline is six months from the declaration unless the recipient or FEMA extends it, and FEMA weighs how urgently you acted.
Documentation
  • Small projects: a detailed description of the work; you can certify the immediate threat, link to the incident, improved property in a declared area, and legal responsibility.
  • Large projects: a detailed description of the work and the immediate threat, plus records showing the threat (technical reports, inspector reports, photographs) when it isn’t obvious.

Source: PAPPG Table 20.

Watch out · Govstar advice
Photograph and describe the threat before you remove it. Once the hazard is gone, proving it existed is much harder.
PAPPG v5.0 pp. 115–117 · 44 CFR 206.201(b), 206.204(c)–(d), 206.221(c), 206.223(a)(3)
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.