Flood Damage >> Flooding Garbage Cleanup

Recommendation #8: Modify disaster assistance employee deployment processes to ensure that Incident Management Assistance Teams and Flooding Garbage Cleanup other FEMA first responders include one or more debris specialists with the experience and managementskills to assist communities in the crucial early stages of planning and implementing debris removal activities.

 FEMA concurs with the objective ofthe recommendation. Shortly after an emergency or disaster declaration, Flooding Garbage Cleanup and in some cases in advance, FEMA deploys Debris Task Force Leaders and establishes debris task forces to coordinate FEMA's debris operations. 

FEMA debris specialists and monitors are also deployed to disaster areas in advance orshortly after a declaration. FEMA also augments its field staffwith debris contracting and monitoring specialists from the U.S. Anny Corps ofEngineers. Flooding Garbage Cleanup

Each ofthese individuals works closelywith impacted states and local applicants to provide them with technical assistance. However, from Appendix B Management Comments to the Draft Report FEMA’s Oversight and Management of Debris Removal Operations Page 41FEMA's perspective, the best way to addressthis issue isto ensure that there are adequate numbers ofskilled and experienced employees in the disaster workforce, Flooding Garbage Cleanup rather than modifying deployment processes. 

FEMA will continue its efforts to increase the size ofits resource pool and speed the deployment oftechnical expertise to support applicants during the early stages of planning and Flooding Garbage Cleanup implementing debris removal operations. 

Recommendation #9: Continue to refme cost data to determine whether having qualified FEMA orlocal personnel present in aU debris towers, majorstaging areas, Flooding Garbage Cleanup and on the ground as roving monitors during significant debris-generating events would be costeffective. 

While FEMA fully supports appropriate and adequate monitoring as part ofdebrisremoval operations, FEMA does not concur with thisrecommendation. FEMA advises PA applicants that the size ofthemonitoring operation should be commensurate with the size and Flooding Garbage Cleanup needs ofthe debrisremoval operations. 

Applicants utilize different monitoring strategies based on the type of contract, the geographic area and the types and quantity ofdebris. When using unit price contracts for example, applicantsshould have monitors present at the pick-up, staging, Flooding Garbage Cleanup and disposal sites. 

FEMA employs a roving debris monitormethodology wherein debris monitors make regular, repeated and random checks ofdebris operations. FEMA then focuses additional attention and Flooding Garbage Cleanup effort on debris operations with identified non-eompliance issues. 

FEMA also uses additional debris monitors forspecial debris operations, such asthe removal ofcontaminated debris or debris removal from private property or waterways. This is the most prudent use of FEMA'sresources and taxpayer dollars and avoids unnecessary duplication ofeffort. FEMA does not intend to station monitors at aU pick up, staging, Flooding Garbage Cleanup or disposal sites as a standard operating procedure. 

In addition, due to the difficulty in detennining costsavings from that approach, it is unlikely that FEMA can perfonn a conclusive analysis to detennine ifthat approach is more cost effective than FEMA's current practice. Flooding Garbage Cleanup

Recommendation #10: Establish clear requirements for prompt and efficient project closeouts. FEMA responded to this recommendation in eOpportunities to Improve FEMA 's Disaster Closeout Process, OIG-IO-49, January 2010. ,. Flooding Garbage Cleanup

FEMA has since developed a Project Closeout Standard Operating Procedure (SOP) for use by PA staffatJoint Field Offices. However, Flooding Garbage Cleanup the draft report on debris confusesthe completion ofa debrisremoval operation with project closeout. 

These are two discrete actions. Project closeout refersto the reconciliation ofproject estimates, data, documentation and Flooding Garbage Cleanup invoices with the approved scope ofwork. It is an administrative function that does not impede the completion ofan applicant's debris removal operation. 

In accordance with Title 44, Code ofFederal Regulations 206.204, eProject Perfonnancee, debrisremoval must be completed within six months ofthe emergency or disaster declaration unlessthere are extenuating circumstances for which the impacted state or Flooding Garbage Cleanup FEMA grant an extension. 

The draft reportsuggeststhat delayed project closeout encourages debris removal contractors to remove ineligible debris. However, this is not the case and Flooding Garbage Cleanup adequate debris monitoring by the applicant preventsthe removal ofineligible debris. 

Additionally, FEMA encouragesthe use ofunit price and lump sum contracts that pay contractors based on the Appendix B Management Comments to the Draft Report FEMA’s Oversight and Flooding Garbage Cleanup Management of Debris Removal Operations Page 42amount ofdebris removed rather than the use oftime and materials contracts which pay contractors based on the number ofhours worked. 

The use of unit pricc or lump sum contntcts along with debris monitors reduccs thc amount ofincligible debris collected. Time and materials contracts that do not have etennination for causee or enot to exceed· clauses encourage debris removal contractors to work slower or Flooding Garbage Cleanup to remove ineligible debris. 

Recommendation #J 1: Dcvelop:1 pcrformance measurcmcnt that FEMA hcadquarters and regional personncl call usc to measurc, analyzc, and improve debris program performance. This should be designed for casy analysis of cost and performance data across regions, disasters, Flooding Garbage Cleanup and contractors. 

FEMA a!,'TCCS with this approach in general. FEMA is cUlTently developing a Quality Assurance/Quality Control (QAlQc) tool that provides a fntmcwork to measure quality and performance throughout the entire PA Program, not just individual categories ofwork. Flooding Garbage Cleanup

The QAlQC tool is bascd on tcn quantitative perfonnance metries and one qualitative pccr rcview process, designed to measure key aspects of PA pcrformancc against ccrtain goals or Flooding Garbage Cleanup benchmarks. 

These metrics, which are standardized across the pro!:>'Tam, are intended to provide a consistent method ofmeasuring quality and Flooding Garbage Cleanup performance across thc program, and to align efforts at all levels with the PA mission and needs ofPA stakeholders. 

This tool will be applied to FEMA's PA Program, Flooding Garbage Cleanup including for projects (hat reimburse applicants for the cost oftheir debris operations, across all FEMA Regions and disasters. In addition, FEMA is continually working to improve PA Program perfonmmce. 

For example, FEMA has developed a Debris Field Guide to promote consistent debris estimating. FEMA is also working with the U.S. Anny Corps ofEngineers to enhance its hurricane debris estimating modules. Additionally, FEMA is developing intemal sollware to improve its debris estimating capacity. Flooding Garbage Cleanup

Since 2005, FEMA has worked to develop automated or digital systems that will improve the collection ofdebris data in the field. FEMA is currently working to develop a cost database ofunit price debris removal costs to assist PA staff and llpplicllnts when dctemlining whether or Flooding Garbage Cleanup not a cost is reasonable. 

All ofthesc effol1S are aimed at improving, streamlining and expcditing the PA process with rcgard to debris removal operations. Once again, thank you for (he opportunity to comment on the draft report. Ilook fonvard to working with you on future homeland security and Flooding Garbage Cleanup emergency management engage.

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