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Chapter 1: Declarations and Planning

The Stafford Act authorizes the president to provide federal assistance when the magnitude of an incident or threatened incident exceeds the affected state, local, Tribal Nation, and territorial (SLTT) government capabilities to respond and recover. This chapter explains requirements for damage assessments, declaration requests, FEMA's evaluation criteria, the contents of the declaration, and the initial administrative requirements for a state, Tribal Nation, and territorial (STT) government to receive assistance.

I. Damage Assessments

After an incident causes widespread damage, the STT government conducts an initial damage assessment before requesting a joint Preliminary Damage Assessment (PDA) to confirm the need for federal assistance. When the STT government determines that the incident exceeds its ability to respond, it requests a joint PDA with FEMA.

The Initial Assessment

Structural Assessment Targets

The initial damage assessment plays a critical role in establishing the baseline parameters of the disaster environment. It must systematically address the following factors:

  • Identify affected jurisdictions experiencing severe impacts.
  • Identify damaged infrastructure requiring critical repairs or stabilization.
  • Provide preliminary cost estimates for response and recovery efforts.
  • Collect data to assess the broad need for federal assistance, including evaluating local resource capacity to support ongoing response and recovery operations.

Joint PDAs

Estimation and Documentation Mechanics

During a joint PDA, FEMA, SLTT governments, and certain private nonprofit (PNP) organization officials work together to estimate and document the impact and magnitude of the incident. Accurate and comprehensive PDAs are critical to enabling efficient response and recovery. FEMA's Preliminary Damage Assessment Guide provides detailed information to assist staff involved with damage assessments and describes how FEMA utilizes the information when preparing requests for major disaster declarations.

Regional Waiver Conditions

The Regional Administrator consults with the STT to determine if the requirement for a joint PDA may be waived based on the severity and magnitude of the incident.

Insurance Verification Requirement

Insurance Notice: Applicants must provide insurance policies when requested during a PDA, as FEMA only considers costs that would be eligible for reimbursement through the Public Assistance (PA) Program in its declaration determination.

Terminology

Lifecycle Entity Definitions

When an entity applies for PA funding, it is an applicant. Once an applicant receives funding, it is a subrecipient.

Simplified Framework Designations
  • Applicant: Applied by FEMA throughout this document to refer to the responsible entity for a project rather than making constant distinctions between an entity as the applicant, recipient, or subrecipient.
  • Recipient/Subrecipient: Utilized selectively when necessary to differentiate between the two entities in grant administration.

II. Declaration Request

The governor or tribal chief executive requests a declaration from the president through FEMA.

Tribal Nation Options

Jurisdictional Paths to Assistance

A Tribal Nation may elect to be a recipient or a subrecipient under a state or territorial declaration, or request its own declaration as a recipient. A Tribal Nation may seek different types of assistance through Tribal Nation and state declarations. For example, a Tribal Nation may seek PA and the Hazard Mitigation Grant Program (HMGP) through the state, while seeking Individual Assistance (IA) through a tribal declaration.

Duplication of Benefits Bar

Important Restriction: A Tribal Nation cannot receive the same type of assistance (e.g., PA, IA, and HMGP) through both tribal and state declarations for the same incident. This is necessary to ensure that FEMA does not provide duplicative benefits.

Deadlines and Extensions

Submission Timelines

  • Submission Window: For state and territorial declaration requests, the governor must submit the request no later than 30 days after the incident occurs.
  • Extensions: FEMA extends the deadline if the governor submits a written time extension request within 30 days of the incident, providing reasonable justification for the delay.
  • Tribal Guidance: If the Tribal Nation wishes to be its own recipient, additional guidance for this process is detailed in the Tribal Declarations Interim Guidance.

Expedited Declarations

Catastrophic Incident Accelerated Requests

When a severe or catastrophic incident occurs, the governor or tribal chief executive may submit a declaration request prior to completion of the PDA. This process is referred to as an expedited declaration request.

Scope Restrictions on Expedited Awards

Limitation Notice: In accelerated circumstances, assistance is strictly limited to that which would address immediate needs (lifesaving or life-sustaining items) based on rapid assessments until the PDA is fully completed.

III. Declaration Evaluation

Generally, FEMA uses PDA information to evaluate the need for assistance under the PA Program as follows:

  • Emergency Declarations: FEMA evaluates whether available resources and authorities are adequate and whether federal assistance under Section 502 of the Stafford Act is necessary to supplement SLTT efforts to save lives, protect property, and public health and safety, or to lessen or avert the threat of a catastrophe.
  • Major Disaster Declarations: FEMA reviews facility impacts and cost information to ensure the estimated amounts do not include costs for ineligible items, costs covered by insurance, or costs above and beyond what is necessary to restore the facility to pre-disaster design and capacity (e.g., resiliency/mitigation measures), or facilities under authority of another federal agency. FEMA evaluates the estimated cost of assistance and other factors when making a recommendation to the president for whether assistance is warranted.
Snow Assistance Request Rule

Snow Assistance Note: FEMA will only provide authorization for snow assistance under a major disaster declaration when specifically requested. Requests for snow assistance are only eligible for major disaster declarations and must be submitted with a winter storm or snowstorm declaration request. Additional information is available in Appendix K: Snow Declarations.

A. State and Territorial Governments

Major Disaster Primary Evaluation Criteria

For state and territorial governments, FEMA's evaluation for a major disaster declaration is based on six primary factors:

  1. Estimated cost of assistance;
  2. Localized impacts;
  3. Existing insurance coverage;
  4. Previous mitigation efforts;
  5. Recent multiple disasters; and
  6. Other federal agency programs.
Local Concentration Mechanisms

FEMA compares the estimated eligible amounts to the established annual per capita indicators. To account for localized impacts when the statewide per capita impact is low, FEMA evaluates whether there are extraordinary concentrations of damage resulting in significantly high per capita impacts at the local government level.

Mitigation and Disaster History Overlap

To encourage hazard mitigation, FEMA considers whether SLTT government mitigation measures taken prior to the incident likely reduced the damage impacts, especially if such mitigation averted damage that would have increased the estimated eligible cost above the per capita indicator.

FEMA also evaluates the overall impacts of federal and STT declarations that have occurred within the past 12 months and the extent to which the STT government has expended their funds. If there were disasters prior to the 12-month period that still have substantial impacts on SLTT governments, FEMA also considers impacts from those disasters.

B. Tribal Nations

Minimum Cost Threshold Factors

FEMA will consider a declaration request from a federally recognized Tribal Nation if the estimated PA-eligible damage or costs meet or exceed the threshold for the minimum damage amount per the Tribal Declarations Interim Guidance.

Tribal Multi-Factor Review Index

FEMA evaluates Tribal Nation requests for a major disaster declaration based on the following specific factors:

  • Types and amounts of damage;
  • Economic impact of the incident;
  • Tribal Nation resources and demographics;
  • 24-month disaster history and previous mitigation efforts;
  • Insurance structures and unique conditions affecting Tribal Nations; and
  • Other federal agency programs and relevant information.
Onsite Technical Assistance Resources

The Tribal Declarations Interim Guidance is a comprehensive resource for Tribal Nations on Stafford Act declarations, disaster assistance, and related requirements. Tribal Nations may request technical assistance at no cost.

Tribal Liaison Deployment Rules

Direct Support: At any time prior to, during, and after a Tribal Declaration request, Tribal Nations may request from FEMA the deployment of a Tribal Liaison Officer (TLNO), when available, to provide direct, onsite technical assistance.

IV. Declaration Determinations

For FEMA to provide assistance, the president must declare that an emergency or major disaster exists. The declaration establishes the:

  • Type of incident and incident period;
  • Designated areas and types of assistance; and
  • Federal cost share and Federal Coordinating Officer (FCO).

A. Incident Type

Formal Legal Classifications

The declaration designates the type of incident (e.g., hurricane, wildfire, or earthquake).

  • Emergency Declarations: An incident is any instance determined by the president that warrants supplemental emergency assistance to save lives, protect property, and public health and safety, or to lessen or avert the threat of a catastrophe.
  • Major Disaster Declarations: An incident is any natural catastrophe (including any hurricane, tornado, storm, high water, wind-driven water, tidal wave, tsunami, earthquake, volcanic eruption, landslide, mudslide, snowstorm, or drought) or, regardless of cause, any fire, flood, or explosion. Major disaster declarations may include a combination of incident types.

B. Incident Period

Duration Constraints

The declaration designates the incident period, which is the span of time during which the federally declared incident occurred. This period varies in duration, depending on the incident. The declaration includes an incident start date and typically includes an end date to the incident period, though in some cases, the end date may be designated as "continuing".

C. Designated Areas

Declared Boundary Management

The declaration specifies which areas (e.g., county, parish, city, or tribe) are eligible to receive federal assistance, referred to as the "declared area". FEMA may add additional areas after the initial designation.

Addition Requests and Cutoffs

To request an addition, the governor or the governor's authorized representative (GAR), or for Tribal Nation declarations, the tribal chief executive or tribal authorized representative (TAR), must submit the request within 30 days of the declaration date or the end of the incident period, whichever is later. FEMA will extend the deadline if a written extension request providing justification for the delay is submitted within the 30-day window.

D. Types of Assistance

Authorized Program Divisions

The declaration designates the types of federal assistance authorized, which differ between emergency and major disaster declarations and may vary among declared areas.

  • Emergency Declarations: The president may authorize limited immediate and short-term assistance essential to save lives, protect property, and public health and safety, or to lessen or avert the threat of catastrophe.
  • Major Disaster Declarations: The president may authorize Individual Assistance (IA), Hazard Mitigation Programs, and PA. Through IA's Individuals and Households Program (IHP), FEMA provides assistance to eligible individuals and households. FEMA provides risk management resources to prioritize risk reduction through its Hazard Mitigation Grant Program (HMGP).
Wildfire Program Distinctions

FEMA Regional Administrators have the authority to issue Fire Management Assistance Grant (FMAG) declarations for wildfires that threaten to cause such destruction that would constitute a major disaster. The FMAG Program is separate and distinct from the PA Program.

E. Federal Cost Share

Grant Matching Principles

The assistance FEMA provides through its PA Program is subject to a federal cost share, which means that FEMA provides funding for a portion of the project and the recipient or applicant is responsible for the remaining portion. The federal cost share ensures local interest and involvement through financial participation.

Escalation Threshold Metrics
  • Minimum Threshold: The federal cost share is not less than 75 percent of the eligible costs.
  • Cost Share Increases: FEMA recommends an increase up to 90 percent if actual federal obligations, excluding administrative costs, meet or exceed a qualifying threshold. For debris removal and emergency protective measures specifically, the federal cost share may be increased in certain circumstances, and for limited periods of time, if warranted.
Cross-Federal Fund Matching Rules

Applicants may only apply other federal award funds toward the PA non-federal cost share if the other federal agency has specific statutory authority allowing its funds to be used to meet cost-share requirements. For example, the U.S. Department of Housing and Urban Development's (HUD's) Community Development Block Grant (CDBG) Program may be used toward the non-federal cost share on PA projects if certain requirements are met.

Project-Level Restrictions

Important Rule: FEMA applies the federal cost share at the project level. Therefore, any other agency's federal funds must be applied at the project level and cannot be used across multiple projects (except for permanent work alternative procedure projects). Applicants cannot apply PA funds toward the non-federal cost share of other federal agency awards.

F. Declaration-Related Appeals

Appeal Timelines and Authority

  • States and Territories: If FEMA denies a declaration, types of assistance, or areas, the governor may submit an appeal through the Regional Administrator. The appeal and any justification must be submitted within 30 days of the denial letter date. If additional time is needed, a time extension request citing the reason for delay must be submitted within 30 days of the denial letter.
  • Tribal Nations: If certain types of assistance or certain areas requested to be authorized in the declaration are denied, the tribal chief executive may submit an appeal per the Tribal Declarations Interim Guidance.
Executive Appeal Execution Restrictions

The governor, tribal chief executive, GAR, or TAR may appeal or request time extensions to appeal a denial of the types of assistance or areas. However, only the governor or tribal chief executive may appeal, or request a time extension to appeal, a full declaration denial. FEMA's Assistant Administrator for the Recovery Directorate at FEMA Headquarters approves time extensions when there is a justified reason for delay.

V. Recipient Administrative Requirements

There are several administrative requirements recipients must fulfill before FEMA obligates funds. FEMA provides funding to cover administrative costs related to managing grants and offers technical assistance at no extra cost.

A. Application for Federal Assistance

Mandatory Standard Forms List

The declared state, Tribal Nation, or territory must complete and submit the following Standard Forms (SFs) before FEMA provides assistance:

  • "Application for Federal Assistance" (SF-424);
  • "Budget Information for Non-Construction Programs" (SF-424A);
  • "Assurances for Non-Construction Programs" (SF-424B);
  • "Budget Information for Construction Programs" (SF-424C); and
  • "Assurances for Construction Programs" (SF-424D).
Prime Award Period of Performance

The SF-424 includes the period of performance (POP) for the PA award (referred to as the prime award). The prime award POP begins on the first day of the incident period and initially extends four years from the declaration date.

B. FEMA-State/Tribal Nation Agreement

Commitments and Conditions

After every declaration, FEMA and the applicable STT government enter into a FEMA-state agreement (FSA) or FEMA-Tribal Nation agreement (FTA) that defines the understanding, commitments, and conditions under which FEMA provides assistance. FEMA and the governor or tribal chief executive must sign this agreement before FEMA provides assistance.

Exigent Services Exception

Emergency Rule: If necessary because of exigent circumstances, FEMA may authorize essential emergency services or housing assistance under the Individuals and Households Program while the agreement is actively in process for signature.

C. Payment Management System

Direct Deposit and Access Setups

FEMA provides PA funding to recipients via the U.S. Department of Health and Human Services (HHS) Payment Management System. Therefore, if an entity is a recipient for the first time, it must request access to the Payment Management System and complete the "Direct Deposit Form" (SF-1199A) to obtain a FEMA-specific account before FEMA can provide funding.

D. Public Assistance Administrative Plan

Mandatory Program Administration Layouts

Recipients must have a FEMA-approved administrative plan that describes how they intend to administer the PA Program before FEMA provides PA funding for any project. At a minimum, the administrative plan must include:

  • The agencies responsible for program administration.
  • Identification of staffing functions, the source of staff to fill the functions, and the management and oversight responsibilities of each function.
Required Procedure Tracking Blocks

The plan must detail clear operational procedures for:

  • Notifying potential applicants of program availability and conducting applicant briefings.
  • Assisting FEMA in determining eligibility and participating in preliminary damage assessments.
  • Establishing PA mitigation and insurance requirements and processing appeals or extensions.
  • Complying with administrative and audit requirements of 2 C.F.R. § 200, 2 C.F.R. § 3002, and 44 C.F.R. § 206.
  • Processing requests for advances of funds, reimbursements, and determining staffing and budget requirements.
Submission and Amendment Cycles

State and territorial recipients must submit their administrative plan to FEMA annually. Additionally, an amendment is required for each disaster declaration to address the specifics of the new incident. Tribal Nations submit their PA administrative plan for each declared disaster in which they are a recipient. Subrecipients do not require PA administrative plans.

E. Hazard Mitigation Plan

Long-Term Risk Reduction Guidelines

Hazard mitigation is most effective when implemented under a comprehensive, long-term mitigation plan that considers future conditions. Communities engage in mitigation planning to identify risks and vulnerabilities to develop long-term strategies for protecting people and property from future incidents.

Permanent Work Prerequisite

Plan Prerequisite: Recipients must have a FEMA-approved hazard mitigation plan before FEMA can provide PA funding for any permanent work. A recipient must show in its plan how it intends to reduce risks from natural hazards. Recipients are required to update the plan every 5 years.

VI. Recipient-Led Public Assistance

FEMA has found that recovery efforts are most successful when locally executed, state or Tribal Nation managed, and federally supported. This approach forms the basis of recipient-led PA operations. While it may not be suitable for widespread disasters that could overwhelm local, state, or Tribal Nation resources, recipient-led PA events offer opportunities to build local capacity and capability while addressing the specific needs of the recovering community.

Function Delegation Index

Recipient-Led Functions

In recipient-led PA events, recipients can lead any of the following key PA functions in lieu of FEMA:

  • Customer service;
  • Site inspections; and
  • Scoping and costing.

Retained FEMA Functions

In addition to any support requested by recipients, FEMA maintains the following core responsibilities:

  • Oversight of the PA operation and quality control reviews;
  • Law, regulation, and EO compliance reviews; and
  • Final eligibility determination and obligation authority.

Capacity and Candidacy Evaluation

Primary Ingestion Suitability Factors

FEMA and the recipient discuss whether a recipient-led PA operation is appropriate given the recipient's current capacity. Typically, the best candidates for recipient-led PA are recipients with the following factors:

  • Recent disaster experience and adequate recipient staff or staff augmentation mechanisms.
  • A fiscal accounting system that tracks specific projects, withstands audit, and may be used to evaluate appeals.
  • An established record of meeting deadlines for PA grant management activities.

Agreement Operational Rules

Execution Deadlines

To opt-in to recipient-led PA, the Regional Administrator and the governor/GAR, or the tribal chief executive/TAR, must enter into an operational agreement as an addendum to the FSA or FTA.

The 72-Hour Operational Window

Sign-off Cutoff: After generating and issuing the operational agreement addendum, recipients have a strict 72 hours to sign. The Regional Administrator may approve late requests to participate in recipient-led PA after the 72 hours have lapsed at their sole discretion.

FEDERAL REGULATIONS & LAWS CITED

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