...provided to FEMA for Project Worksheet (PW) development.
Often times however, FEMA decides to use its experts to develop a scope and cost estimate while issues regarding substantial damages are overlooked and/or completely ignored. This results from a combination of factors, including a lack of policy experience and confusing substantial damage with FEMA repair versus replacement policy (50% Rule). Additionally, since elevation and flood-proofing are typically mitigation projects, FEMA often claims that these are not Codes and Standards but simply mitigation options to be explored under section 406 of the Stafford Act. As has been discussed in previous issues of Disaster Recovery Today however, funding for Codes and Standards is not interpretive or optional, whereas the decisions to fund 406 mitigation measures are based on myriad complicated and often misunderstood criterion and can be denied.
The following excerpt from a letter in April 2007 from FEMA’s Acting Assistant Administrator, Disaster Assistance Directorate, sums it up nicely:
“Structural Repair – Locally adopted floodplain management ordinances that comply with the NFIP meet the criteria for standards found in 44 CFR 206.226(d). Floodplain management ordinances contain provisions that are referred to as ‘triggers.’ This means that a certain level of damage to a structure may require repair to undamaged portions of the structure. For example, a substantially damaged structure must be flood-proofed or elevated...
SOURCE: Jennifer Smits/FEMA Photo Library