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Debris removal is usually the most expensive activity that takes place after an event.
Today we’re going to talk about how to get + keep eligible debris reimbursements. Debris removal is usually the most expensive activity that takes place after an event. You want to be sure that you get reimbursed for eligible expenses and you want to be sure you get to keep the reimbursements you get. To help mi Debris_Resource_
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Remember 3 things to help maximize your reimbursements and minimize your risk . . .
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Ownership of the entire process. Documentation: Know the rules!
Plan + prepare. Ownership of the entire process. Documentation: Know the rules! Prove up quantities. Prove up eligibility of work. Briefly speak to each of the 3 and the importance of each in planning for a debris causing event Debris_Resource_
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Before we begin . . . DMS: Debris management site Force Account: In-house labor and/or equipment. FHWA: Federal Highway Administration Debris_Resource_
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Before we begin . . . (Continued . . . )
LDEQ: Louisiana Department of Environmental Quality OFAs: Other Federal agencies PW: Project Worksheet
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Before we begin . . . (Continued . . . )
R.S.: Revised Statute 9500 Series: Series of regulation guidance from FEMA
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Authorities Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), § 403 and 407. Section 311 of the Stafford Act, along with Title 44 of the Code of Federal Regulations, lays out the rules of the road as they relate to FEMA Public Assistance. Our job, at GOHSEP, is to work with you and help you navigate the road successfully. Debris_Resource_
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Authorities (Continued . . . )
44 Code of Federal Regulations (CFR), § Section 311 of the Stafford Act, along with Title 44 of the Code of Federal Regulations, lays out the rules of the road as they relate to FEMA Public Assistance. Our job, at GOHSEP, is to work with you and help you navigate the road successfully. Debris_Resource_
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Develop a Debris Management Plan NOW . . .
Plan + prepare Develop a Debris Management Plan NOW . . . and use it! DOTD after hurricane Katrina (No Plan, No Contract, Develop a plan that fits your needs, Use it, Maintain it, OWN IT (ownership again) Discuss the advantages/disadvantages of pre and post contracting What do you clean up first (Response then Recovery) Push and Shove then pick up Debris_Resource_
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Plan + prepare (Continued . . . )
See FEMA: Debris Management Guide 325 (July 2007) chapters 5 – 14 for guidance. Contracting (pre- vs. post-event). Priorities (critical facilities, routes, etc.). DOTD after hurricane Katrina (No Plan, No Contract, Develop a plan that fits your needs, Use it, Maintain it, OWN IT (ownership again) Discuss the advantages/disadvantages of pre and post contracting What do you clean up first (Response then Recovery) Push and Shove then pick up Debris_Resource_
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Part II – Debris Management Planning Concepts
DOTD after hurricane Katrina (No Plan, No Contract, Develop a plan that fits your needs, Use it, Maintain it, OWN IT (ownership again) Discuss the advantages/disadvantages of pre and post contracting What do you clean up first (Response then Recovery) Push and Shove then pick up Part II – Debris Management Planning Concepts Debris_Resource_
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Plan + prepare (Continued . . . )
Push + shove Debris removal DOTD after hurricane Katrina (No Plan, No Contract, Develop a plan that fits your needs, Use it, Maintain it, OWN IT (ownership again) Discuss the advantages/disadvantages of pre and post contracting What do you clean up first (Response then Recovery) Push and Shove then pick up Debris_Resource_
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Plan + prepare (Continued . . . )
Debris management sites (DMS) . . . Louisiana Department of Environmental Quality (LDEQ) permitted . . . Force account labor + equipment vs. contract. Where are you going to take the debris? (Pre Planned and Permitted sites) Anywhere you haul debris to needs to be permitted LDEQ GAP analysis conducted will determine if you can do the work with your forces or you need contract help Developing you own scope of work and a schedule of pay items will help you make comparisons as well as control your contract. Debris_Resource_
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Plan + prepare (Continued . . . )
Do not use a boiler-plate plan. Develop a plan that fits YOUR needs. Address every possibility . . . E.g. Oil refinery, pogey boats, meat processing facilities, etc. Where are you going to take the debris? (Pre Planned and Permitted sites) Anywhere you haul debris to needs to be permitted LDEQ GAP analysis conducted will determine if you can do the work with your forces or you need contract help Developing you own scope of work and a schedule of pay items will help you make comparisons as well as control your contract. Debris_Resource_
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Better product more tailored to your needs
Where are you going to take the debris? (Pre Planned and Permitted sites) Anywhere you haul debris to needs to be permitted LDEQ GAP analysis conducted will determine if you can do the work with your forces or you need contract help Developing you own scope of work and a schedule of pay items will help you make comparisons as well as control your contract. Debris_Resource_
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Ownership of the process
Who is ultimately responsible? Applicant is ultimately responsible. The applicants that turn the entire process over to the Management/Monitoring firms and take a hands off approach are more likely to have a problem with everything, documentation, quantification, reimbursement etc. ACT LIJKE THE MONEY IS YOUR MONEY Always know what is going on. Turning loose of the process is like signing a blank check. Relationship FEMA and GOHSEP have with YOUR contractors, they do not work for anyone other than you FEMA and/or GOHSEP can provide technical assistance when you request (Pre or Post event) Debris_Resource_
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Ownership of the process (Continued . . . )
Assign someone from your staff as YOUR Debris Manager. Manage the monitor(s). In-house and/or contract. The applicants that turn the entire process over to the Management/Monitoring firms and take a hands off approach are more likely to have a problem with everything, documentation, quantification, reimbursement etc. ACT LIJKE THE MONEY IS YOUR MONEY Always know what is going on. Turning loose of the process is like signing a blank check. Relationship FEMA and GOHSEP have with YOUR contractors, they do not work for anyone other than you FEMA and/or GOHSEP can provide technical assistance when you request (Pre or Post event) Debris_Resource_
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Ownership of the process (Continued . . . )
Maintain independent relationship between monitor(s) and the debris contractor. Administer as your own. 25% cost share. De-obligation risk. The applicants that turn the entire process over to the Management/Monitoring firms and take a hands off approach are more likely to have a problem with everything, documentation, quantification, reimbursement etc. ACT LIJKE THE MONEY IS YOUR MONEY Always know what is going on. Turning loose of the process is like signing a blank check. Relationship FEMA and GOHSEP have with YOUR contractors, they do not work for anyone other than you FEMA and/or GOHSEP can provide technical assistance when you request (Pre or Post event) Debris_Resource_
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Ownership of the process (Continued . . . )
Emphasize: Failure to know what’s going on puts you at risk. The applicants that turn the entire process over to the Management/Monitoring firms and take a hands off approach are more likely to have a problem with everything, documentation, quantification, reimbursement etc. Always know what is going on. Turning loose of the process is like signing a blank check. Relationship FEMA and GOHSEP have with YOUR contractors, they do not work for anyone other than you FEMA and/or GOHSEP can provide technical assistance when you request (Pre or Post event) Debris_Resource_
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Who can help? and GOHSEP can provide technical assistance, when requested (pre- and post-disaster). The applicants that turn the entire process over to the Management/Monitoring firms and take a hands off approach are more likely to have a problem with everything, documentation, quantification, reimbursement etc. ACT LIJKE THE MONEY IS YOUR MONEY Always know what is going on. Turning loose of the process is like signing a blank check. Relationship FEMA and GOHSEP have with YOUR contractors, they do not work for anyone other than you FEMA and/or GOHSEP can provide technical assistance when you request (Pre or Post event) Debris_Resource_
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Documentation: Know the rules!
Follow the GOHSEP Debris Guide. Reference handout backside with FEMA debris related references Know what the procurement process is and follow the rules (Discussed earlier by Mr. Plaia) That cost are incurred have to be reasonable (FEMA determines what is reasonable as well as eligible) Owner again needs to monitor/manage the process either force account or contract of both Become familiar with Louisiana Dept. of Environmental Quality (LDEQ) rules for collection and disposal Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Procurement 44 CFR Part 13.36 Competitive. Cost reasonable or unreasonable? Reference handout backside with FEMA debris related references Know what the procurement process is and follow the rules (Discussed earlier by Mr. Plaia) That cost are incurred have to be reasonable (FEMA determines what is reasonable as well as eligible) Owner again needs to monitor/manage the process either force account or contract of both Become familiar with Louisiana Dept. of Environmental Quality (LDEQ) rules for collection and disposal Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Develop your own scope of work/pay items. Reference handout backside with FEMA debris related references Know what the procurement process is and follow the rules (Discussed earlier by Mr. Plaia) That cost are incurred have to be reasonable (FEMA determines what is reasonable as well as eligible) Owner again needs to monitor/manage the process either force account or contract of both Become familiar with Louisiana Dept. of Environmental Quality (LDEQ) rules for collection and disposal Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
FEMA Fact Sheet : Debris Removal Applicant’s Contracting Checklist. Debris Removal Contract Cost Analysis. Debris Operations Contract Bid Sheet. Reference handout backside with FEMA debris related references Know what the procurement process is and follow the rules (Discussed earlier by Mr. Plaia) That cost are incurred have to be reasonable (FEMA determines what is reasonable as well as eligible) Owner again needs to monitor/manage the process either force account or contract of both Become familiar with Louisiana Dept. of Environmental Quality (LDEQ) rules for collection and disposal Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Louisiana Department of Environmental Quality (LDEQ): Debris management site (DMS) permitting. Reference handout backside with FEMA debris related references Know what the procurement process is and follow the rules (Discussed earlier by Mr. Plaia) That cost are incurred have to be reasonable (FEMA determines what is reasonable as well as eligible) Owner again needs to monitor/manage the process either force account or contract of both Become familiar with Louisiana Dept. of Environmental Quality (LDEQ) rules for collection and disposal Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Louisiana Department of Environmental Quality (LDEQ): Disposal of storm-generated vegetative debris. R.S. 30:2413.1 Reference handout backside with FEMA debris related references Know what the procurement process is and follow the rules (Discussed earlier by Mr. Plaia) That cost are incurred have to be reasonable (FEMA determines what is reasonable as well as eligible) Owner again needs to monitor/manage the process either force account or contract of both Become familiar with Louisiana Dept. of Environmental Quality (LDEQ) rules for collection and disposal Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Develop a documentation template and ask FEMA to review and comment Labor hours and equipment hours documented correctly will validate equipment usage (operator charges 8 hours of time and the equipment usage is show as 12 hours) problem Recommend anything hauled be documented using a haul ticket (hard copy or electronic) FEMA 325 pg detail required documentation for Dangerous Trees, Limbs and stumps Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Leaners (tree that leans) + hangers (broken limb) + stumps: FEMA Debris Management Guide 325. October July 2007 FEMA 9500 series: Specific documentation requirements beyond haul tickets. Develop a documentation template and ask FEMA to review and comment Labor hours and equipment hours documented correctly will validate equipment usage (operator charges 8 hours of time and the equipment usage is show as 12 hours) problem Recommend anything hauled be documented using a haul ticket (hard copy or electronic) FEMA 325 pg detail required documentation for Dangerous Trees, Limbs and stumps Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
Each type of debris requires a specific type of documentation. Know what you need to provide to FEMA/GOHSEP. Chapter 3 of FEMA 325 describes Debris Removal form Public Property and the eligibility of such The level of documentation needed for PW formulation will be different than a request for reimbursement from GOHSEP. The GOHSEP documentation will need to be more detailed The cheapest thing you will ever buy is a digital camera to capture the threat Who removed the debris? (We Did), What kind of debris did you remove?(don’t remember)Where did you take the debris?(Don’t have any record of that) How Much did it cost? (500k) = no reimbursement for undocumented work Debris_Resource_
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Documentation: Know the rules! (Continued . . . )
WHO + WHAT + WHERE + WHEN + HOW MUCH! Chapter 3 of FEMA 325 describes Debris Removal form Public Property and the eligibility of such The level of documentation needed for PW formulation will be different than a request for reimbursement from GOHSEP. The GOHSEP documentation will need to be more detailed The cheapest thing you will ever buy is a digital camera to capture the threat Who removed the debris? (We Did), What kind of debris did you remove?(don’t remember)Where did you take the debris?(Don’t have any record of that) How Much did it cost? (500k) = no reimbursement for undocumented work Debris_Resource_
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Quantification: Reduces YOUR risk!
Best Practice/Best Protection: How much of what did you remove? BIGGEST PROBLEM AND THE BIGGEST HEADACHE All debris removal work should be quantified to determine if the work is reasonable Making a reasonable determination is impossible without some type of quantity and cost Minimize your risk and use best practices: Lump Sum Contracts (You Paid $100, to have debris removed, did you pay to get one stick or 100 sticks removed) Unit Price Contracts (capture everything reference pay items in your contract) Debris_Resource_
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Quantification: Reduces YOUR risk! (Continued . . . )
Some type of measurement: Cubic yards Tons Each Etc. BIGGEST PROBLEM AND THE BIGGEST HEADACHE All debris removal work should be quantified to determine if the work is reasonable Making a reasonable determination is impossible without some type of quantity and cost Minimize your risk and use best practices: Lump Sum Contracts (You Paid $100, to have debris removed, did you pay to get one stick or 100 sticks removed) Unit Price Contracts (capture everything reference pay items in your contract) Debris_Resource_
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Items not discussed today but a significant part of debris operations include:
Debris Eligibility Hazardous Waste Household Hazardous Waste White Goods Electronic Waste Soil + Mud + Sand Vehicles and Vessels Applicant Roles + Responsibilities (Other than Debris Manager) Debris Forecasting + Estimating Collection Strategy Debris Management Sites Debris Reduction/Recycling Infectious Waste Truck Certifications Salvage Value Private Property Debris Removal Private Property Demolitions Contracted Services FEMA Environmental + Historic Preservation Responsibility of Other Federal Agencies Truck Certifications Debris_Resource_
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Check FEMA 325 Debris Management Guide for details.
Knowing these five things will assist you in getting FEMA reimbursement as well as keeping the funds. Don’t let the grant become a short term loan. Joke about golf (Mike not being able to see very far----) Debris_Resource_
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3 things to remember . . . Plan + prepare.
Ownership of the entire process. Documentation: Know the rules! Prove up quantities. Prove up eligibility of work. Knowing these five things will assist you in getting FEMA reimbursement as well as keeping the funds. Don’t let the grant become a short term loan. Joke about golf (Mike not being able to see very far----) Debris_Resource_
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QUESTIONS? Remember, there is a Question card in your packet. If you have questions about the ICC or the process, write them down and we’ll address them at this afternoon’s Q & A session. Debris_Resource_
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To learn more . . . demagde.pdf vol1/content-detail.html Lift station/pump station roof is damaged during disaster. Applicant does not affect temporary roof repairs for several weeks/months. Pump and other contents under the roof is further damaged caused by not installing temp measures. Debris_Resource_
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Debris Manager Freddie Gardner 225.303.6610
OR contact GOHSEP Debris Manager Freddie Gardner Debris_Resource_
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