Page 13 - Nov-Dec2017 Vol35 No5
P. 13
» Have database of processing post-event, that bypass or expedite please consider the following: 2017 CONFERENCE TECHNICAL SESSION
operations – keep contact the normal competitive procurement • The assistance provided by FEMA is
information up-to-date, and have process.
a printed copy in case of power • Be cautious of contractors that may subject to the cost share provisions,
outages. jeopardize reimbursements due including any administrative costs.
to contract provisions, pricing or • Direct Federal Assistance for debris
» Identify/approve sites for practices that are not reasonable and operations should only be used for
temporary debris management. do not conform to Federal, state and emergency clearance for immediate
local law. lifesaving issues. Beyond emergency
» Support debris management • Submit contracts prior to execution to clearance, debris contracts should be
operations of other state agencies TEMA/FEMA for review of eligibility. established by the local governments if
and local governments (with TEMA and FEMA cannot approve the need exists.
coordination through TEMA). contracts, but can provide advice on • If the disaster is catastrophic and
potential contract terms that could Direct Federal Assistance is needed
Contracting for Removal possibly jeopardize reimbursement. beyond emergency debris clearance,
To be eligible for reimbursement under No contractor has the authority to FEMA may provide the assistance
determine eligibility. needed, which may be subject to the
the Public Assistance Program, contracts Requesting Direct Federal Assistance cost share provisions by TEMA and
for debris removal must meet rules for In catastrophic events, direct federal FEMA.
Federal grants, which means they are assistance can be provided by FEMA to Federal Responsibilities
subject to the Common Rule specifying support the local government. If requested, FEMA can provide Direct
uniform administrative requirements for The request is made by TEMA to Federal Assistance to support the state
grants to states and local governments. FEMA if circumstances justify the need and local jurisdictions. Direct Federal
FEMA’s common rule provisions can be for Direct Federal Assistance. Policy Assistance can be provided for activities
found in 2 CFR §200. #9523.9 has been issued by FEMA to related to emergency debris clearance,
detail the requirements and scope for removal and disposal as per Sections
It is important to remember that Direct Federal Assistance, including 402(4), 403 and 407 of the Stafford Act.
if the local government contract for provisions for funding at 100 percent Should the need arise, FEMA may
debris removal does not comply with federal share for a limited period. choose to use its mission assignment
Federal grant requirements, then If assistance is needed by FEMA to authority to allow the U.S. Army Corps
the local government runs the risk provide debris management operations, of Engineers or another Federal agency
of a determination by FEMA that
the costs are not eligible for federal Continued on page 15
reimbursement. Three critical points are:
• Be careful to avoid entering into
contracts, whether pre-event or
View online at tnpublicworks.com 13
