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Chapter 5: Damage and Impact Information

The Public Assistance (PA) Program provides reimbursement to address damage, debris impacts, and emergency protective measures necessary as a direct result of the declared incident. This chapter provides information on determining what damage and impacts are eligible, identifying damage and impacts, finalizing the list of impacts, and logically grouping into project applications.

I. Impact List

Applicants must submit a list that includes each facility damaged, each debris impacted site, and each overarching emergency protective measure taken to address immediate threats to the general public. Applicants must also identify whether they are claiming management costs or work and costs for building code, floodplain management administration, or enforcement activities. An applicant lists the information by location with a rough estimate of the associated cost.

Baseline Ingestion Fields

Each activity and impacted site in the initial impact list must systematically include the following data points:

  • Facility name or unique identifier (e.g., campus name or site);
  • Facility type (e.g., building, road, or system);
  • Specific location defined by address or global positioning system (GPS) coordinates (required);
  • General description of damage, emergency protective measures, or approximate type and quantities of debris;
  • Approximate cost and project priority level; and
  • Current status of work and the date of original facility construction.

Impact List Submission Deadline

Sixty-Day Reporting Window

Applicants are required to identify and report all incident-related impacts and damage to FEMA within 60 days of attending a recovery scoping meeting.

Extenuating Circumstances Extensions

FEMA may extend the deadline to identify and report the impacts if an applicant submits a request with justification based on extenuating circumstances beyond the recipient's or applicant's control. Qualified extension scenarios include:

  • Access to a specific site is physically blocked or hazardous due to ongoing incident impacts.
  • An applicant is located within an area where FEMA approved additional categories of work after the initial recovery scoping meeting was completed.

Inundated and Submerged Roads

Post-Flood Soil Stabilization Delay

Inundated and submerged roads should not be assessed until flood waters have receded to ensure safety and allow time for saturated soil to dry out. Allowing adequate time for saturated soil to dry out is necessary to effectively determine if eligible surface damage has occurred.

Indefinite Submersion Notices

Regulatory Match: If flood waters have not receded prior to the 60-day deadline, FEMA may approve a time extension for those sites if it remains feasible to wait until water recedes to safely assess damage. Applicants must formally inform FEMA if roadways experience inundation from closed basin flooding that may result in indefinite submersion due to an inability to drain.

II. Grouping Impacts into Projects

FEMA, the recipient, and the applicant work together to combine documented impacts, facilities, and sites into logical projects. This is a two-step process where entities first create groups based on categories of work and facility types, and then identify individual sites or facilities that must be isolated into separate projects.

Explicit Grouping Inclusions and Bars

Ineligible Site Exclusion Mandate

Facilities under the authority of other federal agencies or those that are ineligible for PA (such as inactive or partially inactive structures) must not be formulated into a project. Applicants must withdraw these sites from their impact list, or FEMA will issue a formal ineligibility determination.

Administrative Ingestion Restrictions

Prohibited Practices: Logical grouping frameworks must be driven strictly by infrastructure and category alignment. Grouping combinations must never be based on project size thresholds or grant administration convenience.

A. Initial Debris Removal Grouping (Category A)

FEMA initially separates debris removal work into independent project groups based on the following property types:

  • All debris removal from public property;
  • All debris removal from waterways;
  • All debris removal from private non-commercial property;
  • All debris removal from commercial property; and
  • All debris removal from private roads.

B. Initial Emergency Protective Measures Grouping (Category B)

FEMA initially groups Category B immediate threat operations into separate project applications by activity type:

  • All private property demolition activities;
  • All emergency response activities, excluding those performed on private property;
  • Any emergency protective measures executed directly on private property;
  • All emergency protective measures that involve structural facility construction or repairs; and
  • Each individual temporary facility established to address immediate incident impacts.

C. Initial Permanent Work Grouping (Categories C-G)

FEMA groups permanent infrastructure restoration projects into separate applications based on distinct infrastructure categories:

1. Transportation

All roads, bridges, low water crossings, culverts, mass transit facilities (subways/railways), airports, ports, and harbors.

2. Water Control

All dams, reservoirs, canals, drainage channels, ditches, acequias, aqueducts, stormwater retention/detention basins, and shoreline protection facilities (levees, berms, seawalls, sand revetments).

3. Education, Housing, and Health

All school campuses, public housing campuses, hospital complexes, and standalone medical facilities.

4. Emergency Service and Other Government Facilities

All police stations, fire stations, emergency operations centers (EOCs), courthouses, prisons, administrative complexes, and non-emergency civic buildings.

5. Energy and Utilities

Power generation plants (including wind turbines, generators, and substations within the plant confines), alongside the entire power transmission, power distribution, and natural gas systems.

6. Water/Waspwater and Communications

All water and wastewater treatment plants, entire water distribution systems, entire wastewater collection networks, entire irrigation systems, and all communication systems.

7. Natural and Cultural Resources

All public parks, golf courses, fish hatcheries, public beaches, cemeteries, tribal burial grounds, sacred sites, libraries, museums, and art galleries.

Ancillary Structure Consolidation

FEMA includes administrative and support facilities at a site in the same project as the primary facility, though applicants must report each damaged structure as a separate line item on the impact list. Supporting structures include maintenance sheds, storage yards, pump stations, parking lots, ramps, fences, and sidewalks.

III. Final Project Separation Criteria

Complex Isolation Factors

After initial grouping, FEMA isolates specific sites or facilities out into separate projects if they meet any of the following technical conditions:

  • The site is anticipated to require complex Environmental and Historic Preservation (EHP) reviews.
  • The facility is located within a Special Flood Hazard Area (SFHA).
  • The structure requires specialized funding for architectural/engineering design or engineering studies to determine the proper method of restoration.
  • The facility has 100 percent of all work items completed, provided that incomplete work items on the same facility are not split up.
  • The facility is highly complex and requires specialized technical support for project formulation (such as heavily damaged wastewater plants, large dams, major hospitals, or schools).
  • The scope of work potentially contains ineligible elements.
  • The initial project application is too burdensome to review due to an excessive number of combined sites, necessitating a split by geographical location.
Private Nonprofit Critical Service Separation

SBA Staging Rule: PNP applicants must separate critical service facilities into distinct projects from noncritical service facilities. This prevents projects containing critical infrastructure from being delayed while noncritical facilities await Small Business Administration (SBA) loan determinations.

A. Building Code and Floodplain Ordinance Activities (Category I)

All administrative and enforcement activities eligible under the Disaster Recovery Reform Act (DRRA) Section 1206 must be grouped together within a dedicated Category I project application.

B. Grant Management Activities (Category Z)

All grant management activities eligible under DRRA Section 1215 and FEMA's Public Assistance Management Costs policy must be grouped into a dedicated Category Z project application.

FEDERAL REGULATIONS & LAWS CITED

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How does FEMA PA treat Final Grouping?

Compliance CTA: Use Final Grouping to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

How does FEMA PA treat Initial Permanent Work Grouping (Categories C-G)?

Compliance CTA: Use Initial Permanent Work Grouping (Categories C-G) to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

How does FEMA PA treat Initial Emergency Protective Measures Grouping (Category B)?

Compliance CTA: Use Initial Emergency Protective Measures Grouping (Category B) to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

How does FEMA PA treat Initial Debris Removal Grouping (Category A)?

Compliance CTA: Use Initial Debris Removal Grouping (Category A) to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

How does FEMA PA treat Grouping Impacts into Projects?

Compliance CTA: Use Grouping Impacts into Projects to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

How does FEMA PA treat Inundated and Submerged Roads?

Compliance CTA: Use Inundated and Submerged Roads to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

What should an applicant know about Impact List Submission Deadline?

Compliance CTA: Use Impact List Submission Deadline to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

How does FEMA PA treat Impact List?

Compliance CTA: Use Impact List to control the project pipeline. Submit impacts by the required deadline, group damages into logical projects by category and facility/system, and preserve site-level descriptions, dimensions, photos, coordinates or alternative sensitive-location documentation, initial estimates, and documentation showing how the final grouping supports eligible scope, cost, and closeout.

Official Reference Document

PAPPG Chapter Asset

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