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?

FEMA term

Final grouping; Category I and Category Z grouping

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 practitioner 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.

Govstar summarizes FEMA’s Public Assistance Program and Policy Guide in plain language and links to the official text. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.