Flood Damage >> Colorado Flood Trash Clean Up

In some cases, tree removal actions were either unnecessarily expensive or later found to be ineligible. In another case, state prisoners were used to help the elderly and disabled to get their debris out to curbside, Colorado Flood Trash Clean Up and the cost of this assistance was disqualified. 

A review of 36 recent OIG audits of debris removal subgrantees, generally counties and cities, showed the wide range of adverse effects and possible requirements for repayment that can result from problems during the initiation of debris removal operations: In eight cases, contracts were awarded without having been properly competed, Colorado Flood Trash Clean Up or had major changes without the required competition. 

In seven cases, tree removal operations (primarily leaning trees and hanging branches) were improperly conducted or accounted for. In five cases, ineligible debris, such as from private or ineligible property, was charged under FEMA accounts. FEM's Oversight and Management of Debris Removal Operations Page 16 In five cases, ineligible contracts, such as time and materials contracts, Colorado Flood Trash Clean Up were used after the first 70-hour eligibility period. 

 In four cases, local governments charged ineligible local employee expenses (regular or straight time as opposed to the eligible overtime expenses) to FEMA. In two cases, accounting was inadequate and/or Colorado Flood Trash Clean Up contractors had overbilled local governments, which had passed the excessive charges on to FEMA. 

Conclusion Local governments need clear and consistent guidance governing the initiation of debris removal operations. Without such guidance, contracts can be awarded that result in higher costs to both the local government and FEMA, Colorado Flood Trash Clean Up or can even result in communities having to return funds to FEMA. 

Debris collection rules and regulations need to be clear enough that state and local stakeholders can understand them readily and obtain consistent interpretations from FEMA officials. FEMA needs to continue to enhance ongoing training and outreach concerning debris collection rules and procedures, highlighting changes and Colorado Flood Trash Clean Up new developments. 

Recommendations 

We recommend that the Associate Administrator, Response and Recovery: Recommendation #2: To the greatest extent possible, provide applicants, FEMA employees, Colorado Flood Trash Clean Up and other appropriate officials clear and unambiguous rules, guidance, and procedures for debris operations, including checklists and sample contracts. 

Recommendation #3: Work with the states to provide a variety of readily accessible training concerning rules, guidance, procedures, and recent developments in debris removal, contracting, Colorado Flood Trash Clean Up and cost containment. 

FEM's Oversight and Management of Debris Removal Operations Page 17Management Comments and OIG Analysis 

FEMA generally concurs with both of these recommendations, but does not agree that providing sample contracts is appropriate. FEMA officials fear that doing so may create a false expectation of reimbursement of costs even if applicants fail to follow competitive bidding procedures, the work performed is ineligible, Colorado Flood Trash Clean Up or the contract is not monitored effectively. 

In addition, FEMA officials note that they are not able to account for the varying procurement requirements among states and localities. FEMA is committed to continue providing guidance for debris operations; the debris estimating and monitoring guides have just been issued, Colorado Flood Trash Clean Up and the Debris Management Guide is being revised. 

FEMA is continuing to make training available and is currently developing a computer-based training course on debris management plan development. We agree with the steps FEMA has taken and Colorado Flood Trash Clean Up is taking to provide guidance and training concerning debris operations. 

We acknowledge FEM's concern with providing sample contracts and, in light of the new guidance that has been issued, we will reevaluate this portion of our recommendation. We will determine the status of these recommendations once we review the detailed corrective action plan in FEM's 90 day letter. Colorado Flood Trash Clean Up

Conducting Debris Operations Debris removal operations, Colorado Flood Trash Clean Up as categorized by FEMA, occur in two phases: (1) initial debris clearance activities necessary to eliminate life and safety threats and (2) debris removal activities as a means to recovery. 

The initial debris clearance is an immediate post disaster effort that is frequently conducted by state and local employees and Colorado Flood Trash Clean Up volunteers, but can also be conducted by contractors. The subsequent debris removal operations constitute the bulk of FEMA-funded activities. 

Extensive FEMA rules and regulations govern these efforts, and millions of FEMA dollars are expended in even the smaller categories of disasters. The vast majority of funds are expended on contracted firms that collect debris, haul it to staging areas, Colorado Flood Trash Clean Up and subsequently remove debris that has been processed and sorted by type to landfills and other sites. 

FEM's Oversight and Management of Debris Removal Operations Page 18 Other debris removal, frequently conducted by the same contractors, includes removing hanging branches and hazardous leaning trees. These operations are customarily reimbursed on a unit price basis (as are "white goods” such as refrigerators) and Colorado Flood Trash Clean Up also constitute a major expense category in debris removal operations. 

The third major expense is for monitoring. Monitors, either local government employees or employees of a monitoring contractor, oversee a contractor's collection operations and Colorado Flood Trash Clean Up the volume (and hence eligibility for payment) of the debris that contractors' trucks haul to collection or disposal sites. 

Most of the officials reported that debris is normally collected in a timely manner, enabling communities to proceed with recovery efforts. However, debris collection and monitoring efforts are often costly and Colorado Flood Trash Clean Up many contractors are overpaid. 

Changes in FEMA policies could improve the cost-effectiveness of the debris removal program and make the program easier for local officials to manage. Debris Collection Figure 7. Nashville flooding, FEMA Disaster No. DR 1909 TN (Source: FEMA) Colorado Flood Trash Clean Up

To be eligible for FEMA-funded collection, debris must be the result of a presidentially declared disaster, located within the disaster area on the eligible applicant's (usually a city or county) improved property or Colorado Flood Trash Clean Up right-of-way, and the legal responsibility of the applicant. 

FEMA allows applicants to charge FEMA for collecting debris from private residences if debris has been brought to curbside or Colorado Flood Trash Clean Up is otherwise placed on the local government's right FEM's Oversight and Management of Debris Removal Operations Page 19 of-way. 

Debris brought to the curbside in gated communities, trailer parks, or other communities where the streets do not have city or Colorado Flood Trash Clean Up county right-of-way status does not qualify for collection except in cases where removal is necessary to provide access for emergency vehicles.

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