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Chapter 8 › II.D, II.G Ineligible Upgrades; Permit Requirements

What upgrades won’t FEMA pay for, and what about extra work our permit requires?

FEMA term
Ineligible upgrades; permit requirements
Short answer

Upgrades based on guidelines, recommended practices or other non-mandatory provisions are ineligible, as is added capacity for population growth. Extra work a permitting agency requires is eligible only if it meets four narrow conditions.

What FEMA requires

  • Ineligible: upgrades recommended by design standards, guidelines, policies or industry practices that don’t meet the code criteria.
  • Ineligible: added capacity needed because of growth or increased use, even if a code requires it.
  • Upgrades that improve resistance to future damage may still qualify as Section 406 mitigation or through the Hazard Mitigation Grant Program.
  • Permit-required work under a code that fails the criteria is eligible only if it doesn’t change size, capacity or function; applies to the type of repair; is reasonable for the damage; and is an established, enforced, uniform practice for all similar facilities.

Documentation

The permit and the permitting agency’s written requirement, plus evidence it is applied uniformly to similar projects.

Watch out · Govstar practitioner advice

A permitting officer’s discretionary recommendation, such as “build a bridge instead of the culvert,” isn’t a code. Without a written, adopted standard, the extra cost is yours.

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.