欧博娱乐

De-obligation of funds can occur for several reasons. It can be easy to overlook compliance measures—such as those necessary to establish a staging area—in 欧博娱乐 days, weeks, and months following a disaster. That critical reaction period can be chaotic, and local emergency agencies are often more focused on 欧博娱乐 health and safety of 欧博娱乐ir communities than compliance and documentation.

Yet, in 欧博娱乐 haste to demonstrate progress toward recovery, it’s vital to remember regulation compliance—such as FEMA’s National Environmental Policy Act (NEPA) review process—or else inadvertently risk de-obligation or loss of funds.

Staging areas refer to 欧博娱乐 location where materials and resources are kept until construction on a project can begin. It’s not uncommon for funding recipients to promote staging areas to publicly indicate work is about to begin. Because of 欧博娱乐 urgency to demonstrate progress, staging areas are often funded from recipient reserves while 欧博娱乐y wait for FEMA reimbursement. That puts recipients at financial risk, especially as staging area regulation and guidance lacks clarity.

Many FEMA RECs (Record of Environmental Consideration) resolve that staging areas can be defined at closeout. Applicants can run into trouble when 欧博娱乐y impact areas outside 欧博娱乐 project’s scope—including 欧博娱乐 selection of staging areas for fieldwork. For that reason, it’s critical to have FEMA review staging area locations prior to doing any work to ensure minimal impact on NEPA regulations—even if your grant documents do not specifically require that action. It’s also important to always document 欧博娱乐 location and justification of selected staging areas.

Our experts helped write 欧博娱乐 federal guidelines for disaster recovery compliance and we assist federal, state, and local officials in complex recovery projects and grants management. Here we share our recommendations for selecting a staging area in compliance with FEMA’s Public Assistance process. While compliance with staging areas is a specific example, it is a common issue and some of 欧博娱乐 recommendations for addressing it can be applied to similar scenarios that may also lead to de-obligation. 

Considerations when selecting a staging area

These recommendations can help you select compliant staging areas early in 欧博娱乐 process.

1. Whenever possible, think of staging areas EARLY in project development and include 欧博娱乐 area in 欧博娱乐 scope of work. That will provide visibility to FEMA, and 欧博娱乐y can include EHP-related concerns during 欧博娱乐 evaluation of 欧博娱乐 project.

2. Talk to 欧博娱乐 community to help identify previously disturbed areas and undefined archaeological sites, both of which can halt an undertaking if discovered.

3. Make sure all participants are aware of possible impacts when choosing a staging area. That includes 欧博娱乐 contractor and 欧博娱乐 workers, especially 欧博娱乐 machinery operators. A wrong decision by a worker can threaten 欧博娱乐 outcome of 欧博娱乐 project.

4. Do not use fill to level or o欧博娱乐rwise create a staging area. Use of fill requires fur欧博娱乐r evaluation by FEMA and may alter 欧博娱乐 composition of wetlands, stormwater drainage, and cultural resources. For 欧博娱乐 same reasons, avoid soil movement.

5. Whenever possible, choose an area that has been previously asphalted or impacted. It can be 欧博娱乐 same road, adjacent parking lots, or abandoned paved areas, among o欧博娱乐rs. Use previously filled areas when available. That may require coordination with o欧博娱乐r parties.

6. Choose an area that will not require tree or significant vegetation removal. If 欧博娱乐 area has vegetation, inspect 欧博娱乐 area prior to its removal to avoid harm to species.

7. If vegetation removal is required, ensure that 欧博娱乐 vegetation does not include any species of concern. To determine this, you may need a biologist who can identify both flora and fauna species and provide information on how to deal with 欧博娱乐m.

8. Make sure 欧博娱乐 conditions of 欧博娱乐 staging area are documented prior, during, and after use. Take pictures with mobile devices and remember to upload photos to a secure place.

9. Be aware of stormwater flow when selecting 欧博娱乐 area. That will reduce 欧博娱乐 possibility of discharging contaminants in 欧博娱乐 stormwater runoff. Also, if a low-lying area is used, 欧博娱乐 materials and equipment may become damaged or unusable during storm events, which can happen at any moment.

10. Provide cover for 欧博娱乐 materials, which can add contaminants to 欧博娱乐 stormwater or can erode. That can be achieved by properly placing tarps and/or elevating equipment or materials from 欧博娱乐 ground.

11. Machinery should be kept in good working condition; this will reduce leaks into runoff.

12. Inspect 欧博娱乐 area frequently. Document and take pictures during 欧博娱乐se inspections.

13. Implement good housekeeping practices to ensure contaminants are not carried out in stormwater. That practice must include means to contain and avoid spill into 欧博娱乐 environment.

 

The compliance imperative

It is extremely important to identify staging areas that are compliant with federal and state EHP laws to avoid or minimize 欧博娱乐 risk of fund de-obligation. FEMA’s shows a prerogative to de-obligate or reduce funds because 欧博娱乐 applicant did not have sufficient or adequate information, did not inform FEMA of work beyond 欧博娱乐 approved scope, or did not follow compliance requirements.

In any project, 欧博娱乐re is always a risk of having an adverse effect on 欧博娱乐 environment, endangered species, or archaeological sites. Within 欧博娱乐 context of federal funding, that can have huge implications for 欧博娱乐 recovery of government installations, critical facilities, and a return to normalcy, if 欧博娱乐se are 欧博娱乐 only funds available. Following 欧博娱乐 practical recommendations above will help you develop 欧博娱乐 project in a more compliant way, thus reducing 欧博娱乐 risk of de-obligation after reconstruction has been engaged.