Debris Removal >> Removal_Tree Removal Insurance

If FEMA cannot deliver the needed technical expertise, the odds increase that costs and eligibility of debris removal will become problematic during the recovery phase of the disaster. Communities may be forced to evaluate and select debris removal and monitoring contractors without possessing the necessary expertise or familiarity with FEMA contracting guidance and Removal_Tree Removal Insurance requirements. 

An effective surge can help mitigate the impact of a lack of predisaster debris planning. Cedar Rapids, IA, for example, did not have a debris plan in place prior to major spring flooding in 2008, Removal_Tree Removal Insurance but the debris removal operations went well. A key was the direct technical consulting support for the grantee and subgrantees before contracts were awarded. 

A joint team of FEMA and Iowa Homeland Security debris specialists assisted in this effort. FEMA Region VII staff said "getting in early is the key to helping communities determine whether contractors are providing Removal_Tree Removal Insurance reasonable cost estimates. 

Unclear and Ambiguous Guidance Many officials expressed frustration over unclear and ambiguous debris regulations and policies, which hinder effective debris removal and Removal_Tree Removal Insurance disposal, and create misunderstanding and distrust between FEMA and state and local governments. 

This ambiguity stems not from a lack of effort by FEMA—in fact, the current Public Assistance Debris Management Guide 4 is over 200 pages including appendices, and covers eligibility, planning, and Removal_Tree Removal Insurance operations in some depth—but rather from the complexity and inherent uncertainty of debris removal and disposal. 

The interpretation of how to apply a particular regulation for a specific debris occurrence varies greatly depending on who is doing the interpreting. The consequences for FEMA and Removal_Tree Removal Insurance the grantees can be profound, with audits disallowing millions of dollars of costs that FEMA personnel authorized earlier. 

One state emergency management office we interviewed was in the process of responding to a request to repay millions of dollars for debris removal costs from a 2002 ice storm. This office, Removal_Tree Removal Insurance with a PA staff of three, said debris removal was "the biggest gray area in contracting and "the toughest nut to crack—a constant source of headaches for us." 

This office reported that its applicants had "passed every decision through layers of FEMA approvals" at the time the original disaster cleanup was under way, Removal_Tree Removal Insurance and it was only informed years later that certain vegetative debris removal was ineligible for reimbursement. Several applicants have encountered problems with tipping fees. 

FEMA reimburses tipping fees to compensate applicants for the diminished capacity of a landfill resulting from the Removal_Tree Removal Insurance disposal of disaster-generated debris. FEMA disallowed $7.7 million in tipping fee charges in an Alabama county based on the argument that the applicant based tipping fees on the volume of raw vegetative debris instead of the diminished volume of burned debris. 

FEMA challenged tipping fees in a Tennessee county because different rates had been applied for in-county and Removal_Tree Removal Insurance out-of county debris removal contractors per the county's customary practice. We reviewed the latest FEMA guidance and found only two limited references to tipping fees; neither addressed the above issues. 

Recent controversies in Kentucky and New York have centered on the appropriateness of debris removal costs; in both cases FEMA disputed the costs paid to contractors for debris removal even though the costs were arrived at through competitive bidding. While competitive procurement usually establishes that the debris removal rates are reasonable, Removal_Tree Removal Insurance it does not establish that a contractor removed only eligible debris. 

Nor does it ensure that proper documentation exists to substantiate an applicant's claim. No Substitute for FEMA "Boots on the Ground" There is widespread agreement among state and Removal_Tree Removal Insurance local officials that a visible FEMA presence at a disaster site has a direct impact on reducing fraud and abuse. A commonly cited example involves load calls from debris monitors in towers. 

Debris specialists and public assistance officials said when no FEMA employee is present, Removal_Tree Removal Insurance incoming trucks are virtually all recorded at or near 100% capacity, but as soon as a FEMA employee or official representative is in the tower, the load calls drop to 60% to 70%. These anecdotal observations were supported by findings from a FEMA after-action report: 

During the early stages of this disaster, the limited availability of DAEs and TACs [Technical Assistance Contractors] prevented FEMA from manning the debris towers. Due to this applicant monitors made higher calls. This Removal_Tree Removal Insurance resulted in a 15 to 20% increase in debris costs statewide. Most of the calls were between 90 to 100%. 

If available personnel could be quickly deployed FEMA would have saved $20 million on this disaster alone. Delayed Project Closeouts Exacerbate Problems A key debris management and oversight issue is the need to estimate, scope, and close out projects appropriately and timely. Numerous officials reported that waste, fraud, and abuse tend to multiply toward the end of debris projects, when the debris mission starts winding down and Removal_Tree Removal Insurance contractors become "more creative in filling their trucks." 

This is a theme that cuts across all PA program areas and has been addressed by us, the Government Accountability Office (GAO), and others . Our recent report 7 identified a number of recommendations for closing out disasters more promptly and Removal_Tree Removal Insurance efficiently. Developing a Performance Measurement Framework 

Although FEMA spends hundreds of millions of dollars a year to support, plan, and implement debris removal programs across the country, Removal_Tree Removal Insurance there is no integrated performance measurement framework to manage and provide oversight over this complex activity. A contractor has been hired to develop an improved tracking system. 

Ideally, program managers would have access to information to measure, analyze, and improve program performance. An integrated performance measurement system would enable managers to compare performance in different regions, under different scenarios, to provide fact-based information to partners and stakeholders regarding costs, contractor and partner performance, effectiveness, efficiency, and Removal_Tree Removal Insurance other factors determined to be important to future decision making. 

The need for a performance measurement framework surfaced at a number of states and localities. Officials said it would be helpful to have historical and comparative cost data to assist in the evaluation and selection of debris removal and monitoring contractors. FEMA is working with a contractor to develop a cost model database that states and Removal_Tree Removal Insurance communities can use to compare prices of specific items, which will make the market for debris removal and monitoring services more open and transparent.

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