Debris Removal >> Trash Clean Up From Florida Hurricanes

We reported that these capability gaps are exacerbated by the need for a clear and consolidated body of PA guidance, and highlighted debris issues specifically in the following summary: FEMA's policy on debris removal is unclear and thus open to interpretation. As a result, some communities have been denied eligibility for debris removal costs, Trash Clean Up From Florida Hurricanes while others have received reimbursements for identical costs. 

About $180 million in debris removal costs after the 2004–2005 disasters in Florida demonstrate the significance of clarifying the debris removal policy. 3 Assessment of FEMA's Public Assistance Program Policies and Trash Clean Up From Florida Hurricanes Procedures, OIG-10-26, December 2009. FEMA's Oversight and Management of Debris Removal Operations Page 27

Our current review confirmed some of these earlier observations but also identified additional opportunities for improvement in management and oversight of the debris program. Since large-scale debris events are fortunately rare, plans, systems, and Trash Clean Up From Florida Hurricanes processes cannot be easily tested in a "real-time" environment. 

Many of our observations and findings regarding FEMA's management and oversight of debris operations reflect the perceptions of front line personnel and have not been validated in an actual debris-generating event. Management and Oversight Structure and Trash Clean Up From Florida Hurricanes Approach FEMA manages and oversees debris operations through multiple components, including a headquarters policy office, 10 regional offices, and disaster-specific field command organizations. 

FEMA's Public Assistance Division, Policy and Regulations Branch, in Washington, DC, develops and oversees the implementation of the full range of policies and Trash Clean Up From Florida Hurricanes regulations. Two employees in this branch work exclusively on debris removal policies and regulations. Branch employees also develop training materials for use nationally to create awareness and understanding of current and emerging debris management issues. 

Headquarters staff occasionally deliver this training in person or Trash Clean Up From Florida Hurricanes in coordination with FEMA regional staff. A Debris Task Force is appointed for each major disaster. The Task Force is based at the Joint Field Office and comprises a Debris Team Leader, one or more Debris Technical Specialists, and one or more Debris Monitoring Specialists. 

The Task Force often includes personnel from other federal and state agencies. It is charged with establishing a framework for FEMA assistance for debris operations and Trash Clean Up From Florida Hurricanes creating a historical record. It also creates a specific debris strategy for major events. We reviewed the strategy documents for Hurricane Ike and the 2010 central Tennessee floods, and they were comprehensive and actionable. 

FEMA's Oversight and Management of Debris Removal Operations Page 28Although FEMA regions normally send one or two permanent, full-time employees to an event (who may include debris specialists from another FEMA region), Trash Clean Up From Florida Hurricanes most of the Debris Task Force is comprised of FEMA disaster assistance employees (DAEs). 

As one FEMA regional official told us, "The DAEs do the heavy lifting." Problems arise since DAEs are not always debris specialists, Trash Clean Up From Florida Hurricanes whereas applicants depend almost solely on their advice. Regional officials said the DAE debris expertise is thinning due to turnover and burnout. Surge Capacity Is Crucial As discussed earlier, decisions made in the first few days after a disaster are critical in determining the success of a debris removal operation. 

This decision making takes place at a time, however, when state and local officials, the primary decision makers, are overwhelmed by more immediate problems such as assisting endangered residents, clearing access to hospitals and other vital routes, and Trash Clean Up From Florida Hurricanes restoring electricity, water, and other critical services. 

The consensus among regional, state, and local officials interviewed is that FEMA must do a better job of providing rapid and sufficient surge resources with the capability, skills, and Trash Clean Up From Florida Hurricanes authority to drive key initiation and early implementation decisions. As the entity that funds from 75% to 100% of eligible debris removal costs, FEMA has a vested interest in ensuring optimal decision making and project control. 

Further, given the complex web of organizations that have a role in a typical disaster—state and local government agencies, other federal agencies, private sector contractors, nonprofit organizations, and voluntary organizations—there is no substitute for clear, focused leadership. If FEMA cannot deliver the needed technical expertise, Trash Clean Up From Florida Hurricanes 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 Trash Clean Up From Florida Hurricanes requirements. FEMA's Oversight and Management of Debris Removal Operations Page 29 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, but the debris removal operations went well. A key was the direct technical consulting support for the grantee and Trash Clean Up From Florida Hurricanes 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 reasonable cost estimates. Unclear and Ambiguous Guidance Many officials expressed frustration over unclear and ambiguous debris regulations and Trash Clean Up From Florida Hurricanes policies, which hinder effective debris removal and 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 Trash Clean Up From Florida Hurricanes covers eligibility, planning, and 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 Trash Clean Up From Florida Hurricanes the grantees can be profound, with audits disallowing millions of dollars of costs that FEMA personnel authorized earlier. 

FEMA Public Assistance Debris Management Guide, FEMA-325, July 2007. FEMA's Oversight and Trash Clean Up From Florida Hurricanes Management of Debris Removal Operations Page 30 Figure 12. Examples of recent debris-related FEMA publications 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, with a PA staff of three, said debris removal was "the biggest gray area in contracting" and Trash Clean Up From Florida Hurricanes "the toughest nut to crack—a constant source of headaches for us."

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