Wind Damage >> Local Wind Storm Cause Garbage Clean Up

FEMA did not approve debris plans that did not identify a DMS or disposal site. As mentioned previously, FEMA is considering revisions to its regulations to incorporate the increased federal share component of the PA Pilot Program, which would require PA applicants to identify DMS and final disposal Local Wind Storm Cause Garbage Clean Up sites in their debris management plans.  

Allow qualified states that have completed their own plan to approve local jurisdictions' debris disposal plans. FEMA is considering this part of the recommendation. FEMA encourages states Local Wind Storm Cause Garbage Clean Up to promote the development and maintenance oflocal debris management plans. 

As part ofour considerations to revise FEMA regulations to incorporate  the increased federal share component of the PA Pilot Program, FEMA will consider a significant role for Local Wind Storm Cause Garbage Clean Upstates in the review and approval of debris management plans. 

Recommendation #2: To the greatest extent possible, provide applicants, FEMA employees, and other appropriate officials clear and unambiguous rules, guidance, and procedures for debris operations, including checklists and sample contracts. FEMA concurs with this Local Wind Storm Cause Garbage Clean Up recommendation with the caveat below. 

FEMA has provided, and will continue to provide, debris operations guidance to FEMA PA staff, to Grantees, to applicants, and to the general public. This includes the Debris Management Guide (FEMA 325), which is currently under review to ensure that this guidance remains current, comprehensive, Local Wind Storm Cause Garbage Clean Up and incorporates lessons learned. 

FEMA is providing additional guidance on debris estimating and Appendix B Management Comments to the Draft Report FEMA’s Oversight and Management of Debris Removal Operations Page 39 Local Wind Storm Cause Garbage Clean Up monitoring in the Debris EstimatingField Guide (FEMA 329) and the Debris Monitoring Guide (FEMA 327) both ofwhich were issued in December 20IO. 

FEMA also performs regular periodic reviews of Local Wind Storm Cause Garbage Clean Up all PA policies and guidance to ensure that they are up to date, accurate, and appropriately address current policy issues. FEMA does not agree, however, that providing sample contracts is appropriate. Applicants are responsible for procuring debris contracts and FEMA is not a party to those contracts. 

By providing sample contracts, FEMA may create a false expectation ofreimbursement of Local Wind Storm Cause Garbage Clean Up costs even ifapplicants fail to follow competitive bidding procedures, the work performed is ineligible, or the contract is not monitored effectively. In addition, FEMA cannot account for the varying procurement requirements among states and localities. 

FEMA provides PA applicants guidance on contract procurement in Recovery Fact Sheet 9580.201, Debris Contracting Guidance. This Fact Sheet includes Local Wind Storm Cause Garbage Clean Up recommended provisions for debris removal and debris monitoring contracts, includes a standard bid sheet, and includes guidance on evaluating proposed equipment and labor rates. 

Additionally, FEMA reviews proposed debris contractsfor PA applicants, upon request. Recommendation #3: Work with the states to provide a variety of readily accessible training concerning rules, Local Wind Storm Cause Garbage Clean Up guidance, procedures, and recent developments in debris removal, contracting, and cost containment. FEMA concurs with thisrecommendation. 

FEMA currently has, and will continue to make, debris training available through the Emergency Management Institute (EMI), Local Wind Storm Cause Garbage Clean Up FEMA Regional Offices, and online. 

Current debris courses include the week long "Debris Management" (E202) course at EMI, a one-day Debris Management Plan Development course conducted throughout the Nation upon request, Local Wind Storm Cause Garbage Clean Up and the Independent Study Course "Introduction to Debris Operations in FEMA's Public Assistance Program" available on CD-ROM. 

FEMA is currently developing a computer-based training course on debris management plan development. States may request additional Local Wind Storm Cause Garbage Clean Up training through their respective FEMA Regional Offices. 

Recommendation #4: Provide force account labor reimbursement to coverlocal governments' costs of employing workers to monitor debris collections and to remove leaning trees and hanging branches, Local Wind Storm Cause Garbage Clean Up and encourage them to undertake such responsibilities. 

FEMA concurs with thisrecommendation. FEMA encourages PA applicants to use force account labor Local Wind Storm Cause Garbage Clean Up to conduct their debris removal operations. FEMA currently reimburses PA applicants for force account overtime hours. FEMA also reimburses applicants for the use of equipment. 

Current FEMA regulations do not authorize the PA Program to reimburse force account straight time hours. Under the PA Pilot Program, Local Wind Storm Cause Garbage Clean Up FEMA had the authority to fund an applicant's force account straight time for debris removal operations. 

FEMA is considering revisions to its regulations that would incorporate the force account straight time Local Wind Storm Cause Garbage Clean Up reimbursement component of the PA Pilot Program. 

Recommendation #5: Strengthen the requirements involved in monitoring contracts Local Wind Storm Cause Garbage Clean Up to ensure that no relationships exist between debris collection contractors and monitoring. 

Management Comments to the Draft Report FEMA’s Oversight and Management of Debris Removal Operations Page 40 Local Wind Storm Cause Garbage Clean Up contractors, and that monitors are properly trained and capable ofindependent and accurate performance. FEMA concurs with this recommendation. 

FEMA updated its debris contracting guidance in the September 27,2010 Recovery Fact Sheet 9580.201, Debris Contracting Guidance. The Debris Monitoring Guide (FEMA 327) also Local Wind Storm Cause Garbage Clean Up provides applicants with monitoring guidance. Both documents stress that debris monitors should not have a relationship with debris removal contractors. 

Upon request from states, FEMA will provide debris monitoring training as part of the technical assistance that FEMA offers Local Wind Storm Cause Garbage Clean Up to PA applicants. Recommendation #6: Explore advanced technologies to supplement monitoring staffsuch as GPS in trucks orsurveillance cameras. 

FEMA concurs with the recommendation in that FEMA supports applicants' use ofrelevant technology to improve their Local Wind Storm Cause Garbage Clean Up monitoring operations and may provide reimbursement for utilizing such technologies. However, debris monitoring is the primary responsibility ofPA applicants. 

FEMA does not concur with the recommendation to the extent that FEMA is not a party to contracts between applicants and contractors, and carmot require the use of Local Wind Storm Cause Garbage Clean Up advance technology as monitoring tools. 

FEMA stays abreast ofcurrent technologies in order to provide appropriate technical assistance to applicants when they are considering technology applications as a part of their Local Wind Storm Cause Garbage Clean Up monitoring operation. 

Recommendation #7: Assess weight-based rather than volume-based paymentfor debris collection and investigate whethersuch systems could be efficiently linked to debris payment accounting systems. 

FEMA generally concurs with the recommendation, as FEMA currently accepts the use of weight-based systems as a basis for reimbursement. FEMA acknowledgesthat weight-based monitoring and Local Wind Storm Cause Garbage Clean Up payment systems have some advantages over volume-based systems. 

However, as stated in the draft report, weight·based systems are not immune from potential waste, Local Wind Storm Cause Garbage Clean Up fraud, or abuse and both weight-based and volume-based systems require proper monitoring and oversight to be effective. 

FEMA can provide funding for the use oftemporary scales during debris operations and Local Wind Storm Cause Garbage Clean Up encourages applicantsto utilize such systems where appropriate. 

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

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