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There are a few recent changes within FEMA’s Public Assistance program. Effective October 1, 2014, the small project threshold minimum amount increased from $3,000 to $3,040 and the small project threshold maximum increased from $120,000 to $121,600. In other words, damage to a site must total at least $3,040 to be considered eligible, and damages over $121,600 will be written up as “large projects” which eventually require a close-out version based on actual documented costs. Other changes include the countywide per capita indicator raising 1.7 percent to $3.56, and the statewide indicator to $1.41 per capita. The State and counties must meet these thresholds in eligible damages prior to the Governor submitting a federal disaster declaration request. These changes apply to all disasters declared on or after October 1, 2014. Another big change is ERAF implementation. The Emergency Relief and Assistance Fund (ERAF) rules which will go into effect for any future disaster declared after October 23, 2014.
Financial Procedures. The Vermont Dept. of Public Safety (DPS) finance team encourages towns to read every portion of the subgrant agreements they send out for each disaster. The sub-grant agreement includes information on how to request reimbursement for your projects. It also includes information and a federal form to report the status of your large projects on a quarterly basis. Applicants are federally required to report large project programmatic progress quarterly until all their large projects are all closed out (date deadlines are January 30, April 30, July 30, October 30 and at final closeout). This form must be sent to email@example.com for all disasters after Irene each quarter until all large projects are closed out, even if there are no changes since the previous report. We have many towns not yet reporting on their large projects.
Once a town’s large project is 100% complete, the town must go through “closeout” of the project by submitting a complete package of invoices, checks, and other documentation of work completed for the entire project. Email Kim.Canarecci@state.vt.us to receive a closeout checklist of what is required. The ERAF (state share) and balance of the federal share for large projects can only be paid out after all large projects are closed out, and upon submittal of a final reimbursement request (502F form) and signed Project Completion and Certification Report. All of this information is also addressed in your subgrant agreement.
Project Documentation. With FEMA requirements, towns shouild document and photograph frequently. It is important that towns keep maintenance records/daily logs of their work on roads, culverts and bridges, e.g. when the town places gravel, cleans out culverts, and performs bridge inspections. FEMA requires this documentation following a disaster to verify that damages were not pre-disaster and that structures were maintained regularly by the applicant. It is in the town’s best interest to also photograph its bridges during every inspection to show the current condition on the bridge. If the town has a bridge that is not long enough to receive an inspection from the state, it is still a good idea for the town to inspect it periodically or hire someone to do so. If it becomes damaged during a disaster, FEMA will see verification that the applicant took responsibility for maintaining it, and there should be no question whether the damage is eligible.
July 28, 2014 Flooding Update. Flooding hit Windham and Windsor counties on July 28, 2014, and the State of Vermont requested a federal disaster declaration. On September 23, FEMA Administrator Craig Fugate denied the Governor’s request. The Vermont Agency of Transportation is turning to its state emergency grant program in the hope of helping towns pay for road repairs.