Appendix I › II. Work Eligibility Considerations for Roads and Bridges

What road and bridge work is eligible, and what isn’t?

FEMA term

Work eligibility: roads and bridges (Categories A, B and C)

Short answer

Eligible: debris removal for an immediate threat, emergency access and emergency repairs to keep roads passable, and permanent repair or replacement of roads, culverts and bridges. Not eligible: federal-aid highways (FHWA’s program), extra lanes, lost tolls, loss of useful life, routine maintenance, and private roads except in narrow emergency-access cases.

What FEMA requires

Applies to roads (surface, base, shoulders, ditches, guardrails, lighting, signs, sidewalks), drainage structures (culverts, low-water crossings) and bridges (decking, piers, girders, abutments, slope protection, approaches).
Common EHP laws: NEPA, NHPA, ESA, Clean Water Act, Clean Air Act, EOs 11988 and 11990. Work in waterways usually needs a Corps Section 404 permit and may involve local NFIP requirements.
Debris: separate incident debris from debris from other recent events and household waste.
Emergency access on private property: obtain rights-of-entry and agreements to indemnify and hold the federal government harmless.
Permanent work: separate minor incident damage from age, traffic and frequent rain damage; provide construction dates for culverts and nearby structures; H&H studies are required if replacing a culvert with a differently sized structure.
A waiver for ineligible work requires FEMA’s Assistant Administrator for Recovery.

<table class="pt-table"><thead><tr><th>Category</th><th>Eligible</th><th>Not eligible</th></tr></thead><tbody><tr><td>A: Debris</td><td>Debris removal and disposal to eliminate an immediate threat</td><td>Debris placed on public rights-of-way from commercial property unless FEMA approves; construction and renovation materials</td></tr><tr><td>B: Emergency access</td><td>Clearing or emergency repair of access roads and bridges to keep them passable, including strictly temporary access</td><td>Private roads unless no other access exists, damage blocks emergency access, and (for repairs) it eliminates temporary housing needs</td></tr><tr><td>B: Emergency repairs</td><td>Repairs to address an immediate threat</td><td>Emergency repair of federal-aid highways (FHWA)</td></tr><tr><td>C: Restoration</td><td>Permanent repair or replacement</td><td>Loss of useful life; lost tolls; extra lanes (except code-required one-to-two-lane bridge widening); routine maintenance; federal-aid highway repairs (except for Tribal Nations)</td></tr></tbody></table>

Documentation

Construction dates for culverts and nearby structures; maintenance records to separate disaster damage from age and wear; H&H studies if changing culvert size; and rights-of-entry and hold-harmless agreements for any work on private roads.

Watch out · Govstar practitioner advice

Road damage is often challenged as age, traffic wear or frequent rain rather than the disaster. Pair before-and-after photos with maintenance records, especially for gravel and older paved roads.

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.