C&D typically involves debris from buildings and other structures, such as shingles, aluminum, plywood, carpet, and other building materials damaged by the storm.
Residents are required to separate piles of C&D from vegetative debris. It is important to convey this information clearly to the public through the media and to set deadlines by which this debris is to be placed at the curb. Our deadline was set at Oct. 31, nearly two months after we began picking up debris. We experienced problems with public service announcements, particularly with the print media. Often, the announcements were not printed the way we had written them and confusion resulted.
Despite several large display ads placed in the newspapers, in addition to radio and TV announcements, we still had many residents putting debris out after the deadline and not following guidelines. Furthermore, we found a large amount of debris not related to the storms but resulting from trimming or removal of healthy, undamaged trees—all of which was not eligible for FEMA reimbursement. At that point, we directed code enforcement officers to homes not following guidelines, and where appropriate, they wrote citations.
In early December (approximately three months after the storms), we determined that the contractor had made a minimum of two passes. We directed residents to report missed debris piles, and we assigned inspectors to visit each of these sites to determine whether the debris was obviously storm-related. We conveyed this information daily to the debris pickup contractor if removal of the debris was eligible for reimbursement, or to our code enforcement department if it was ineligible.
In addition to debris from private property, there also was vegetative debris falling from the public right of way, stumps, and “leaners” and “hangers.” Leaners are trees than are leaning and present a hazard to vehicles or pedestrians. Hangers are branches left hanging in trees that present the same hazards. Stumps are an expensive issue to handle. Management of stump removal became more challenging as FEMA policy dealing with stumps changed several times during the debris-pickup process.
FEMA field representatives assigned to Marion County were present during the entire recovery effort. They consistently advised us that Marion County's response was outstanding. However, at times when they brought directives from the regional FEMA offices, there were inconsistencies that made it challenging to meet their directives.Tree Removal
One such inconsistency arose from a February 2005 decision from FEMA that determined the new stump policy would be retroactive to the beginning of our recovery efforts, even though we had exceeded FEMA's earlier direction. Several additional challenges arose with our stump-related operations due to continuing FEMA policy changes.FEMA decided to undertake a search to verify the origination of 10% of the stumps collected to determine eligibility for reimbursement. The result was that the origination of more than 99% of the stumps was verified. Dissatisfied with this result, FEMA later decided to do a 40% sampling. Still later, FEMA decided to run 100% against an electronic screening list. These studies resulted in a lower percentage of verifications, but we are convinced this is because nearly six months has passed, making original sites nearly impossible to find.A regional FEMA official insisted that a section of the contract between the county and the emergency management contractor be renegotiated to treat smaller stumps—24 inches or less in diameter—as ordinary debris and the larger ones at a per stump fee based on size—25 to 36 inches, and 37 inches or greater. In the end, we had to deal with 1824 stumps at costs based on size, from $600 to $900 per stump or a total cost for stumps of nearly $1.2 million. Although the FEMA representative actually signed the amendment, FEMA now says he had no authority.FEMA told us we could treat stumps from improved, landscaped, private property placed in the right of way by property owners the same as those from the right of way. However, since completing this operation, FEMA decided to only reimburse for the stumps originating on private property at the rate applied to ordinary debris regardless of the size.FEMA did not have the manpower to follow the stump crews for verification of eligibility, so we worked out monitoring and documentation procedures that were acceptable to them. Although numbering and photographing stumps was not required, we opted to do this anyway. FEMA maintains that since some of these photos show loaded stumps (rather than in place), the documentation is not acceptable as proof of eligibility.
Despite our judicious adherence to FEMA directives, this issue, which is still unresolved, could cost us a substantial amount of money, possibly in the hundreds of thousands of dollars. Based on our experience, I cannot stress enough the importance of understanding FEMA directives and regulations and maintaining a working dialogue with FEMA.
Brian Thomason, vice president of Grubbs Emergency Services, is a veteran of a number of debris cleanup operations. When asked about the FEMA directives in this emergency Thomason said, “I have never experienced this inconsistency. During this event, we never know from day to day what to expect, what new decision would come down. The policy interpretations applied retroactively are creating hardships all around the state. It's almost become laughable, but nobody's laughing.”