T IDALBAS INGROUP.COM 3 entity that has legal authority to decide that disaster-generated debris on private property constitutes an immediate threat to life, public health, or safety, or to the economic recovery of the community at large. • The established, specific legal requirements for declaring the existence of a threat to public health and safety. Debris removal is historically a controversial issue when dealing with FEMA. There are concerns over where the debris came from, whether it was weighed properly, whether the contractor was procured in accordance with guidelines, etc. Unfortunately, many decisions are made prior to FEMA’s arrival, so it becomes imperative to document and photojournal all activities. A Subrecipient should attempt to do the following, until further direction is provided by the state and FEMA: • Photograph areas of heavy debris that are to be removed and processed. • Contract for debris removal on either a per ton or cubic yard basis. • Attempt, where possible, to limit removal activity until a clear scope of work may be defined. • Use force account personnel or contractors to monitor the debris removal activities. • Track force account hours and equipment by documenting who, what, when, where and why. Also describe types of equipment and how long it was used. • Gain a right-of-entry (hold harmless) agreement before removing debris from private property. • Read and become familiar with FEMA’s Public Assistance Program and Policy Guide (PAPPG) at fema.gov.2 It is not uncommon for FEMA to place “debris teams” in the field to monitor how a Subrecipient and their representatives (contractors) are handling debris removal. Often these teams will monitor and generate reports that are then submitted to the state and FEMA. It is imperative that Subrecipients receive copies of all such reports, in case determinations made in the field are in error. In larger scale disasters, the state and FEMA may also utilize the expertise of the United States Army Corps of Engineers (USACE) for planning, monitoring and providing guidance. 2https://www.fema.gov/sites/default/files/documents/fema_pappg-v4-updated-links_policy_6-1-2020.pdf
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