Changes and Clarifications Grouped by General PAPPG Topic

Summary of Changes‌

This PAPPG version incorporates the following changes:

‌Table 1. List of Changes and Clarifications Grouped by General Topic

Topic

Highlighted V5 Improvements

Tribal Nations

 To support the protection of tribal significant artifacts, culturally sensitive landscapes and sites, cultural resources, and human remains; clarified that FEMA will not require photos, site maps, and specific location details (such as GPS coordinates) for locations where these cultural artifacts are located;

 Clarified that FEMA will accept a Tribal Nation’s certified damage assessment, scope of work for restoration, and estimated costs for traditional tribal residences or tribal ceremonial buildings;

 Clarified that for locations where only tribal members are allowed, site inspections by FEMA staff are not permitted;

 Clarified that mutual aid agreements or memoranda of understanding are available resources for Tribal Nations and provided guidance on reimbursement when there is no pre-existing written agreement; and,

 Clarified that if a Tribal Nation received funding from the Bureau of Indian Affairs or Federal Highway Administration for construction or maintenance of tribal roads, those roads are still eligible for FEMA PA funding under a presidentially declared disaster.

Resilience

 Included language about resilience considerations throughout;

 Clarified that PA mitigation measures can be implemented for all hazards, not just the hazard that caused the damage;

 Added information and reference to the benefit-cost analysis (BCA) Toolkit;

 Increased opportunities to mitigate improved projects involving facility replacement or relocation; and,

 Expanded Appendix J to include additional measures, with two measures focused on wildfire

Simplification

 As a result of stakeholder feedback, removed non-regulatory processes for inclusion in other PA guidance;

 Where possible, removed “may” and “should,” and replaced with “must” to clarify requirements; and,

 Redefined acronyms at the beginning of each chapter and reduced acronym use.

Topic

Highlighted V5 Improvements

Documentation and Requirements

 Clarified documentation and information requirements for small projects and large projects;

 Reduced documentation and information requirements for small projects;

 Incorporated PA’s sampling procedures;

 Clarified that maintenance records are not always required to substantiate damage;

 Included more options for documentation to support legal responsibility; and,

 Removed requirement for pre-approval prior to completing private property debris removal.

Added Content

 Incorporated Validated as You Go (VAYGo) content and resources;

 Added subsection titled “Telecommunications Equipment Purchase;”

 Added “self-insurance or self-insured retention” to list of insurance types; and,

 Included insurance commitment opportunities which benefit applicants experiencing subsequent disasters.

Clarifications

 Clarified road damage from damage caused by submerged and inundated as distinct types of damage;

 Clarified that snow assistance is not authorized for emergency declarations; and,

 Conveyed FEMA’s support to report suspicious activities as well as who and how to report.

Private Non-Profit (PNP)

 Consolidated private non-profit information into one section;

 Explained for-profit entities’ ineligibility; and,

 Clarified that Houses of Worship and faith-based organizations are considered private nonprofit organizations.

Sheltering

 Removed pre-approval requirement for non-congregate sheltering activities in traditional settings (i.e., hotels/motels, dormitories, etc.);

 Removed childcare services as a standalone emergency protective measure and is now only eligible when associated with emergency sheltering; and,

 Expanded emergency sheltering eligibility to include survivors’ “household pets, service animals, assistance animals” and removed requirement for pet owners to be sheltered for pet sheltering to be eligible.

Topic

Highlighted V5 Improvements

Environmental and Historic Preservation (EHP)

 Explained and provided examples of projects that have potential to impact EHP resources;

 Provided guidance on navigating the EHP compliance process;

 Clarified documentation requirements for streamlined EHP reviews and complex EHP reviews;

 Provided EHP considerations by category of work; and,

 Provided examples of project types that may have impacts to natural and cultural resources.

Statutory and Regulatory Updates

 Incorporated the revision to 2 C.F.R. Part 200 which integrates Office of Management and Budget (OMB)'s policy priorities and strives to reduce agency and recipient burden;

 Updated guidance from the Payment Integrity Information Act, which supersedes the Improper Payments Elimination and Recovery Improvement Act; and,

 Added compliance with EO 14148, Initial Recissions of Harmful Executive Orders and Actions

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Changes and Clarifications Grouped by General PAPPG Topic