Department of Homeland Security 

Office of Inspector General 

American Samoa 2009 
 
 

Earthquake and Tsunami: 
 
 

After-Action Report 
 
 

OIG-11-03 October 2010 
Office ofInspector General 

u.s. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

OCT 2 5 2010 

Preface 

The Department of Homeland Security (DHS) Office ofInspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of the Federal Emergency 

Management Agency's response to the 2009 earthquake and resultant tsunami in 

American Samoa. It is based on interviews with employees and officials of relevant 

agencies and institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

Matt Jadacki 

Assistant Inspector Gen ral 

Office of Emergency Management Oversight 

-

... 
Table of Contents/Abbreviations 

Executive Summary .............................................................................................................1 
 
 

Background..........................................................................................................................2 
 
 

Results of Review ................................................................................................................6 
 
 

Improving Oversight of High-Risk Grantees .................................................................6 
 
 

Recommendation .........................................................................................................10 
 
 

Management Comments and OIG Analysis ................................................................11 
 
 

Restoring Power to Disaster Survivors ........................................................................13 
 
 

FEMA’s Permanent Housing Construction Pilot Program ..........................................17 
 
 

Recommendations........................................................................................................23 
 
 

Management Comments and OIG Analysis ................................................................24 
 
 

Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................26 
 
 

Appendix B: Management Comments to the Draft Report .......................................28 
 
 

Appendix C: The Territory of American Samoa.......................................................34 
 
 

Appendix D: Financial Data for American Samoa ....................................................35 
 
 

Appendix E: Major Contributors to this Report........................................................37 
 
 

Appendix F: Report Distribution ..............................................................................38 
 
 

Abbreviations 

ASPA American Samoa Power Authority
 

CFR Code of Federal Regulations 
 

DBAS Development Bank of American Samoa 
 

DHS Department of Homeland Security 
 

DOI Department of the Interior 
 

EMOT Emergency Management Oversight Team 
 

ESF Emergency Support Function 
 

FAR Federal Acquisition Regulation 
 

FBI Federal Bureau of Investigation 
 

FEMA Federal Emergency Management Agency 
 

GAO Government Accountability Office 
 

HUD U.S. Department of Housing and Urban Development
 

IA Individual Assistance 
 

JFO Joint Field Office 
 

OIG Office of Inspector General 
 

OMB Office of Management and Budget 
 
 

PaTH Partnership for Temporary Housing 
 
 
PA Public Assistance 

TAC Technical Assistance Contract 

TAO Territorial Audit Office 

TOHS Territorial Office of Homeland Security 
OIG
 
 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

In the wake of a devastating earthquake and tsunami in American 

Samoa, we deployed an Emergency Management Oversight Team 

to American Samoa in November 2009. The team’s objectives 

were to: (1) promote accountability by instituting measures and 

processes to evaluate the actions of federal emergency 

management professionals; (2) serve as an independent entity for 

oversight of response and recovery activities; and (3) review the 

Federal Emergency Management Agency’s response to the disaster. 

Through its authority under the Robert T. Stafford Disaster Relief 

and Emergency Assistance Act (Public Law 100-707), the Federal 

Emergency Management Agency provided disaster assistance to 

American Samoa. This assistance included temporary housing, 

grants for rebuilding efforts, construction of permanent housing, 

and repairs to critical infrastructure such as schools and power 

plants. Three issues came to the forefront during our oversight of 

the response and recovery activities. 

First, the American Samoa government has serious internal control 

and financial accountability problems. Short of designating the 

American Samoa government as a high-risk grantee, the Federal 

Emergency Management Agency has taken a number of other 

actions to help address these concerns. 

Second, of particular concern are the federal funds provided for 

restoration of the Satala Power Plant, which represents 75% of all 

Public Assistance funding. High cost projects such as this one 

should be closely monitored. 

Third, the agency is building permanent homes for individuals to 

replace homes destroyed by the tsunami. The need for better 

planning, the high costs of the simple homes being built, and the 

use of one large contractor to build all the homes raises questions 

about this permanent housing construction pilot program and the 

precedent it will set for future disasters. 

We are making four recommendations to improve the efficacy of 

the agency’s disaster assistance recovery activities. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 1
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 2
 
 


 

Background 

On September 29, 2009, American Samoa was struck by an 8.3 

magnitude earthquake. The earthquake generated a tsunami with 

waves reaching 5.1 feet in Pago Pago, the territory’s capital, 

causing flooding in portions of the island. More than 30 people 

were killed and hundreds were injured. The combination of the 

earthquake, tsunami, and flooding resulted in a devastating amount 

of damage on the island of Tutuila. A local power plant was 

disabled, 241 homes were destroyed, 308 homes had major 

damage, another 2,750 dwellings reported some damage, one 

school was destroyed and four others sustained substantial damage. 

Most of the damage was caused by the tsunami rather than the 

earthquake. 

Figure 1. Map of American Samoa 

Source: Nations Online Project 

Within 24 hours of the earthquake and tsunami, the President 

issued a federal disaster declaration. The declaration authorized 

funds for Individual Assistance (IA), such as temporary housing; 

Public Assistance (PA), such as debris removal and emergency 

protective measures; Hazard Mitigation; and other forms of 

assistance. Two amendments were made to the original disaster 

declaration. These amendments provided for: 
•	 90% federal cost share for permanent repairs, and 

•	 100% federal cost share for debris removal and emergency 

protective measures for the first 30 days following the 

disaster. 

Figure 2. FEMA Disaster Recovery Center in Utulei,

 American Samoa 

Source: DHS OIG 

Under the Robert T. Stafford Disaster Relief and Emergency 

Assistance Act (Public Law 100-707) (Stafford Act), FEMA can 

provide multiple forms of assistance to disaster affected areas. The 

PA grant program provides assistance to state, local, and tribal 

governments, as well as certain nonprofit organizations, so that 

communities can quickly respond to and recover from major 

disasters or emergencies. Grants may be used for debris removal; 

emergency protective measures; the repair, replacement, or 

restoration of publicly owned facilities such as utilities, schools, 

and hospitals damaged in the disaster; and road and bridge repair. 

The IA grant program provides assistance, including temporary 

housing or rental assistance, to individuals affected by a disaster or 

emergency. Mission assignments allow FEMA to engage other 

federal agencies to carry out specific tasks, such as debris removal 

and power restoration. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 3
 
Figure 3. FEMA’s Disaster Funding in American Samoa 

Source: OIG analysis of FEMA’s disaster financial data, as of September 2010 

Since the disaster declaration more than 11 months ago, federal 

assistance to American Samoa, including FEMA’s operational 

expenses, has exceeded $125.5 million, and an additional $4.3 

million is planned for future distribution. As of September 21, 

2010: 

•	 More than $37.4 million in disaster assistance was granted 

for housing and disaster-related needs; 

•	 321 individuals received assistance grants of $30,300 each; 

•	 More than $102.8 million was requested for debris 

removal, emergency protective measures, and the repair or 

rebuilding of public buildings and other infrastructure; 

•	 Temporary housing and sheltering was provided to those 

whose homes were destroyed or left uninhabitable; and 

•	 Funds were allocated for the construction of approximately 

45 permanent homes. 

FEMA and its federal partners project that more than $18.6 million 

will be used to reduce or eliminate long-term hazard risk to the 

people and their property. 

Although the relief aid efforts were well received by the American 

Samoa people, FEMA faced a number of challenges in providing 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 4
 
assistance. Samoan culture has strong indigenous customs and 

traditions that revolve around the extended family (the aiga) and 

the communal land system. In Samoa, a matai (chief), controls the 

family’s communally owned land for the common good of all 

family members. Family members are expected to help the matai 

by providing the resources and financial contributions needed for 

special occasions and events, such as church building dedications, 

weddings and funerals. Ultimately, the matai decides who can live 

or build on the communally owned land as well as what type of 

resources and contributions are needed from family members. 

FEMA acknowledged this custom, and worked with the people to 

come to an agreement on the distribution and ownership of the 

homes to be built. 

American Samoa is an unincorporated part of the United States. 

At the time of the disaster, two tuna canneries accounted for about 

80% of employment. The prime source of income for American 

Samoa is the United States through multiple grants and other forms 

of funding. Of all the contributing agencies, the Department of 

Homeland Security is the second highest grantor. As of September 

30, 2008, total expenses for governmental activities amounted to 

$196,261,843, and of that $102,705,363 (52%) were funded 

through grants and contributions. The chart below shows the 

distribution of funding sources for American Samoa. Taxpayers 

accounted for 41% of funding, direct beneficiaries 5%, and grants 

and other contributions accounted for 54%. 

Figure 4. American Samoa Government Funding Sources 

Direct 

Grants and 

Contributions 

54% 

Taxpayers 

41% 

Beneficiaries 

5% 

Source: OIG analysis of American Samoa’s FY 2008 financial statements 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 

Page 5 
 

Results of Review 

In November 2009, we deployed an Emergency Management Oversight Team 

(EMOT) to assess federal recovery and response activities in American Samoa. 

We also assisted in coordinating information requests of federal and territory 

auditors, evaluators, and investigators. In addition, we informed FEMA and the 

American Samoa government of steps needed to ensure accountability and 

prevent fraud, and to monitor high-risk areas prone to fraud, waste, and abuse. 

We met with the Governor, American Samoa cabinet officials, FEMA personnel 

in American Samoa and Hawaii, and other federal officials in American Samoa. 

FEMA, despite the distance from the continental United States and limited 

commercial transportation, had an initial response team of 50 people, food, water, 

and commodities on the ground within 24 hours of the disaster declaration to 

provide the support and assistance needed by the survivors. FEMA provided a 

well-structured and well-disciplined Joint Field Office (JFO) for first responders 

and a Disaster Recovery Center for the people affected by the disaster. The 

Disaster Recovery Center alone had more than 21,000 visits. In addition, there 

was excellent communication among FEMA, the American Samoa government, 

disaster survivors, and media outlets, which reassured the survivors and kept the 

government up to date on response and recovery efforts. However, we identified 

three areas of concern relating to high-risk grantees, restoration of power, and 

permanent housing construction. 

Improving Oversight of High-Risk Grantees 

In September 2010, FEMA anticipated providing more than $92 million in 

federal disaster assistance grants to the American Samoa government for 

infrastructure repairs and hazard mitigation. In comparison, the U.S. 

Department of the Interior (DOI) annually provides the American Samoa 

government with approximately $22.7 million in grant funds for the 

operation of the local government, including the judiciary.1 Figure 5 

shows the federal grant funds FEMA has provided to the American Samoa 

government from October 1, 2006, to September 15, 2010. 

1

 According to the DOI’s Office of Insular Affairs, the American Samoa government does not have 

sufficient local revenues to fund the entire operating costs of its government. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 6
 
 

 

 

 

Figure 5. FEMA Grant Funding in American Samoa 

Source: OIG Analysis of USAspending.gov data. 

Independent public accountants and federal auditors have repeatedly 

identified material weaknesses with the American Samoa government’s 

ability to manage and account for federal funds. A material weakness is a 

significant deficiency, or combination of significant deficiencies, that 

significantly increase the likelihood that the internal controls will fail.2 

Since 1997, the American Samoa government’s financial audits have 

resulted in either a disclaimer of opinion or a qualified opinion. In 

September 2005, the DOI OIG reported that the American Samoa 

government had not controlled expenditures, produced timely and accurate 

financial reports, or taken effective corrective actions on previously 

identified deficiencies.3 

In May 2007 we identified systemic deficiencies in the American Samoa 

government’s grants management practices and controls and questioned 

over $1.7 million in claimed grant costs. In February 2010, the American 

Samoa Territorial Auditor told us that he had significant concerns about 

the American Samoa government’s ability to effectively oversee the 

increased amount of grant funds to be received given American Samoa’s 

2

 Internal controls comprise the plans, methods, and procedures that an organization uses to meet missions, 
 
 

goals, and objectives, and in doing so (1) support performance-based management and (2) help prevent
 
 


fraud, waste, and abuse.
 
 3 American Samoa: Top Leadership Commitment Needed to Break the Cycle of Fiscal Crisis (P-IN-AMS0117-2003, September 2005).
 
 


American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 7
 
 

 

internal control weaknesses, the absence of a fully integrated financial 

system, and local funds’ liquidity issues that put pressure upon American 

Samoa government officials to divert grant funds to pay bills for non-grant 

purposes. In March 2010, the U.S. Government Accountability Office 

(GAO) questioned the American Samoa government’s ability to manage 

federal capital improvement grants, given that the American Samoa 

government official responsible for administering such funds had been 

absent from the island for the past 3 years.4 In July 2010, American 

Samoa’s independent public accountants told us that the government’s 

system controls are frequently circumvented and overridden since there is 

no incentive to follow the rules. 

Federal regulations stipulate that a grantee or subgrantee may be 

considered high risk if the recipient: 

• Has a history of unsatisfactory performance; 

• Is not financially stable; 

• Has a management system that does not meet regulatory standards; 

• Has not conformed to terms and conditions of previous awards; or 

• Is otherwise not responsible. 

The U.S. Department of Agriculture, U.S. Department of Education, U.S. 

Department of Health and Human Services, DOI, and U.S. Department of 

Transportation have designated American Samoa as a high-risk grantee.5 

Because high-risk designations are made by individual agencies and this 

information is not consolidated at the federal government level, each 

grantor made the determination independently. Reasons identified for the 

high-risk designation included delinquent audits, noncompliance with laws 

and regulations, failure to resolve audit findings or to follow up on review 

findings, incurring unallowable or questionable costs, and weak systems 

for monitoring the programs and managing program data. 

Grants awarded to high-risk recipients include special conditions or 

restrictions that correspond to the high-risk condition. Examples of such 

special conditions or restrictions include additional project monitoring; 

payment on a reimbursement basis; requiring additional, more detailed 

financial reports; establishing additional prior approvals; and requiring the 

grantee or subgrantee to obtain technical or management assistance. 

Corrective actions that must be taken and the time allowed for completing 

these actions are provided in writing to the grantee. Once corrective 

4 U.S. INSULAR AREAS: Opportunities Exist to Improve Interior’s Grant Oversight and Reduce the
 
 


Potential for Mismanagement (GAO-10-347, March 2010). 
 
 5 U.S. INSULAR AREAS: Economic, Fiscal, and Financial Accountability Challenges (GAO-07-119, 
 
 

December 2006). 
 
 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 8
 
 

 

 

 

actions have been completed resolving the high-risk condition, the grantor 

may remove the special conditions or restrictions. 

According to the DOI, the American Samoa government was designated a 

high-risk grantee in an effort to improve accountability for federal funds. 

Such a designation requires American Samoa grantees to comply with 

special conditions for future or existing grants. The DOI also indicated 

that the high-risk designation would be removed once the American 

Samoa government meets three conditions: 

1.	 Completes two consecutive Office of Management and Budget 

(OMB) Circular A-133 single audits by the statutory deadline, 

resulting in unqualified opinions; 

2.	 Has a balanced budget, as confirmed by independent auditors, for 

the two consecutive years, without regard for nonrecurring 

windfalls such as insurance settlements; and 

3.	 Is in substantial compliance with its fiscal reform plan. 

In lieu of formally designating the American Samoa government as a 

high-risk grantee, FEMA has taken many positive steps to identify and 

address the risks posed by the American Samoa government’s poor 

internal controls. The responsibility for administering grants transitioned 

from DHS Office of Grants and Training to FEMA in April 2007.6 At that 

time, the FEMA Region 9 Administrator initiated a full review of DHS 

grant programs provided to American Samoa. The outcome of this review 

included FEMA regional staff providing American Samoa with technical 

assistance and close monitoring. Additionally, FEMA limited the 

American Samoa government’s access to all but a few grant funds and 

implemented a restricted cash draw-down process.7 DHS restrictions 

placed on grants began in December 2005, while DHS Grants & Training 

still had oversight responsibilities. As of August 2010, FEMA has kept 

these measures in place. 

While the above FEMA actions are noteworthy, we remain concerned 

about the lax accountability in American Samoa. For example, the 

6

 Under the Post-Katrina Emergency Management Reform Act, the DHS Grants & Training was moved 

into FEMA and renamed the Office of Grant Programs. This move gave FEMA the responsibility for 

administering most DHS grant programs. The move was effective on April 1, 2007. Previously, DHS 

Grants & Training had an agreement with the American Samoa Territorial Office of Homeland Security 

(TOHS) to not designate them as a high-risk grantee given concern at the time (December 2005) that such a 

designation might stall forward progression that was being made and perhaps be used as a leveraging tool 

to alter the TOHS organizational structure. 

7

 Under this process, American Samoa is to submit requests for expenditures related to specified grants to 

FEMA for review and approval, prior to FEMA releasing any funds. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 9
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 10
 
 


 

American Samoa government8 uses a stand-alone, customized system to 

manage FEMA grant funds that is not fully integrated into the American 

Samoa government financial accounting system and has not been 

separately audited. Consequently, a significant increase in grant funds 

may pose unforeseen challenges that FEMA’s “in lieu of high-risk” 

approach may not effectively and efficiently address. By designating 

American Samoa as a high-risk grantee in accordance with 44 Code of 

Federal Regulations (CFR) 13.12, corrective actions that must be taken 

and the time allowed for completing these actions are provided in writing 

to the grantee. 

If the results of the 2010 OMB Circular A-133 single and program audits 

are disclaimed and include material qualifications, FEMA should consider 

formally designating American Samoa as a high-risk grantee in 

accordance with federal regulations given the history of unsatisfactory 

performance; lack of financial stability; non-conformance to terms and 

conditions of previous awards; and systemic internal control deficiencies. 

Improving federal oversight and monitoring will improve the efficiency 

and accountability of programs in American Samoa, to the benefit of most 

American Samoans. 

Recommendation 

We recommend that the FEMA Regional Administrator, Region 9: 

Recommendation #1: Continue to take all necessary actions to 

ensure that the American Samoa government properly expends and 

accounts for federal grant funding. Based on the results of the FY2010 Office of Management and Budget Circular A-133 audits and 

according to federal regulations, these actions should include 

consideration of whether to designate American Samoa as a highrisk grantee. 

8

 According to American Samoa’s independent public accountants, the Territorial Office of Fiscal Reform 

and the American Samoa Disaster Recovery Office. 
Management Comments and OIG Analysis 

FEMA concurred with this recommendation and agreed that they 

would continue to take all necessary actions to ensure that the 

American Samoan government properly expends and accounts for 

federal grant funding under FEMA’s administrative purview. 

FEMA, short of formally designating the American Samoa 

government as a high-risk grantee, has implemented a number of 

actions to help address concerns with the American Samoa 

government’s ability to properly expend and account for federal 

grant funds. In addition, American Samoa has worked with FEMA 

over the years to improve its internal controls. However, we 

remain concerned that FEMA’s “in lieu of high-risk” approach 

may not effectively and efficiently address the lax accountability in 

American Samoa given that: 

1.	 FEMA anticipates providing more than $92 million in 

federal disaster assistance grants to American Samoa for 

infrastructure repairs and hazard mitigation; 

2.	 The American Samoa government has a history of 

unsatisfactory performance in managing and accounting for 

federal grant funds, including those from FEMA; 

3.	 The American Samoa government is not financially stable; 

4.	 The American Samoa government uses a stand-alone, 

customized system to manage FEMA grant funds that is not 

fully integrated into the American Samoa government 

financial accounting system and has not been separately 

audited; 

5.	 The American Samoa government has not conformed to 

terms and conditions of previous awards according to the 

American Samoa Territorial Auditor, independent public 

accountants, federal auditors, and FEMA grant monitoring 

officials; and 

6.	 Local funds’ liquidity issues put pressure upon American 

Samoa government officials to divert grant funds to pay 

bills for non-grant purposes. 

If the results of the FY-2010 OMB Circular A-133 single and 

program audits are disclaimed and include material qualifications, 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 11
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 12
 
 


FEMA should consider formally designating the American Samoa 

government as a high-risk grantee in accordance with federal 

regulations. Such a designation would require the American 

Samoa government to comply with special written conditions for 

future or existing grants and corrective actions that must be taken, 

including the time allowed for completing these actions. 

We consider this recommendation open and unresolved, pending 

review of corrective actions taken. 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 13
 
 


Restoring Power to Disaster Survivors 

The Satala Power Plant is a 13,215-square-foot building located on the 

coastline in the village of Satala on the island of Tutuila. The plant 

provided electrical power generation to the American Samoa Power 

Authority (ASPA) system and was a primary source of power for the 

shipyard, the waterfront industrial area, and the power grid on the eastern 

end of the island. After the earthquake and tsunami, water entered the 

building through doors, sound attenuator panels, and cabling trenches. 

The initial set of waves reached 11 feet high and submerged the building 

and equipment in salt water. The second wave was about 4 to 5 feet high 

and had more energy, knocking down barrels of waste oil and sludge, 

causing significant contamination. In addition, the cooling equipment, 

sound baffles, generators, transformers, switchgear, and other equipment 

were damaged by the submergence in saltwater and contamination with 

oil. As a result of the damage, the power generation capacity was lost. 

Figure 6. Destroyed Generator at Satala Power Plant 

Source: DHS OIG 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 14
 
 


Timeline for Restoration of Power 

2009 

3⁄4 September 29: 

• Power plant is flooded, causing power outages on the island. 

3⁄4	 October 1–15: 

•	 Three-tier plan is developed. 

•	 FEMA gives ASPA 6 months to complete all emergency work; soon 

after, an additional 6-month extension is granted. 

•	 Initial inspection of the Satala Power Plant is conducted to assess the 

damage. 

3⁄4	 October 15–31: 

•	 56 emergency generators from FEMA and ASPA are put into 

operation (Tier I). 

•	 Additional inspections of the Satala Power Plant are conducted. 

•	 FEMA determines that the plant is not repairable. 

•	 Installation of 27 generators (Tier II) begins. These generators are 

rented from an outside vendor. 

3⁄4	 November 15–30: 

•	 Tier II generators are installed. 

•	 Planning for replacement of the Satala Power Plant (Tier III) begins. 

2010 

3⁄4 February 15–28: 

•	 Tiers I and II have been fully implemented. 

•

Tier III of this project involves the rebuilding of the Satala Power Plant. 	 Planning for Tier III is ongoing. 

The Satala Power Plant is capable of providing 29.5 megawatts of power, 

although only 23 megawatts were operational at the time of the disaster. 

In coordination with the U.S. Army Corps of Engineers, U.S. Department 

of Energy, and ASPA, FEMA assembled a power restoration team to 

assess damages at the Satala Power Plant and to develop a strategy to 

restore power in American Samoa. FEMA’s power restoration strategy 

consisted of three phases (referred to as tiers) that addressed short-, near-, 

and long-term power requirements. 

After the disaster, FEMA estimated the total costs to replace the Satala 

Power Plant to be $52.2 million, to be funded through a PA Grant. The 

project was designated a “replacement project,” meaning the costs are not 
 

 

 

 

capped9 and may ultimately exceed $52.2 million. FEMA is required to 

reduce replacement costs by the amount of anticipated insurance 

proceeds.10 ASPA anticipates $19 million in insurance proceeds from the 

National Flood Insurance Program and a private insurance policy. 

However, ASPA has requested that FEMA fund the full cost of the project 

because it intends to use the insurance proceeds as collateral on a loan, to 

be used for financing government operations. A lender has not been 

found; therefore, at this time the status of the insurance proceeds is 

uncertain. In addition to the replacement costs, FEMA is spending $7.6 

million on temporary power generation (Tier II).11 

Figure 7. FEMA Public Assistance Funding to American Samoa 

Other 

21% 

Power Restoration 
 
 

Project
 
 

79% 
 
 

Source: OIG analysis of FEMA disaster funding data 

Due to the high dollar cost of this project, FEMA plans to continue to 

closely and aggressively monitor all aspects of the Satala power plant 

project. We agree with this decision. FEMA needs to document each step 

of the restoration, and maintain a timeline with completion dates, to ensure 

that tasks are completed in a timely manner. In addition, FEMA needs to 

9

 44 CFR 206, Subpart G provides regulations for cost reimbursement under the PA program. A project 

designated an “improved project” caps the total costs eligible for reimbursement by FEMA. A 

“replacement project” is one in which the total costs eligible for reimbursement by FEMA are not capped. 10 According to 44 CFR 206.250(c), “Actual and anticipated insurance recoveries shall be deducted from 

otherwise eligible costs...” 

11 The $7.6 million cost is dependent upon the reconstruction project; if the plant is not rebuilt in the next 

year or two, temporary power generation project costs could increase to more than $25 million, as 

temporary generators are being rented. The primary funding source for these generators will continue to be 

FEMA, on a cost reimbursable basis. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 15
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 16
 
 


monitor management of funds to ensure that funds are being used as 

designated. ASPA might not have its insurance proceeds available at the 

time of construction, yet FEMA must adhere to the CFR so there is no 

duplication of benefits. Close monitoring of the funds will increase 

transparency, assure that the power plant is restored, and protect U.S. 

taxpayers’ interests. 
 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 17
 
 


 

 

 

FEMA’s Permanent Housing Construction Pilot Program 

Within 10 days of the disaster, FEMA elected to use its authority under the 

Stafford Act to commence a pilot program to build permanent housing in 

American Samoa.12 The decision to build permanent housing was based 

on the following conclusions: 

•	 Insufficient available rental housing; 

•	 Unfeasibility of transporting temporary housing, such as mobile 

homes, thousands of miles by sea; 

•	 Limited supply of labor and materials; and 

•	 Impracticality of moving families off the island where American 

Samoans have lived for generations. 

At the time of the disaster, FEMA had no plans in place for building 

permanent housing in insular areas such as American Samoa. FEMA chose 

not to activate Emergency Support Function 14, Long-Term Community 

Recovery (ESF #14)13 under the National Response Framework. FEMA 

said that the U.S. Department of Housing and Urban Development (HUD) 

had no presence on the island and that the disaster was too small to 

activate this function. However, FEMA’s National Housing Strategy calls 

for HUD’s leadership when permanent housing is needed. As the lead 

agency, FEMA serves as the coordinator for ESF #14; HUD is one of the 

primary ESF #14 agencies. FEMA’s Transition Binder (prepared for the 

Presidential transition team in 2008) recommends increased use of ESF 

#14. 

FEMA decided to use its Individual Assistance–Technical Assistance 

Contract14 (IA-TAC) contractors, the Partnership for Temporary 

Housing15 to build the homes. This decision appears to have been made 

before FEMA determined the availability of local resources as mandated 

by the Stafford Act16 or publicized the proposed acquisition of services and 

conducted market research as required by the Federal Acquisition 

12According to Section 408 (c)(4) of the Stafford Act, the President may provide financial or direct 

assistance to construct permanent housing in insular areas outside the continental United States and in 

other locations in cases in which (1) no alternative housing resources are available, and (2) the types of 

temporary housing assistance described in paragraph (1) are unavailable, unfeasible, or not cost effective. 13 ESF #14 promotes successful long-term recovery for communities suffering significant damages. 14 IA-TAC contractors support FEMA’s implementation of its IA programs. FEMA divided the country 

into four regions, and each of the four IA-TAC contractors has the lead responsibility in one of the regions. 15 The Partnership for Temporary Housing is a limited liability corporation consisting of DynCorp 

International, LLC; Dewberry; and Parsons Corporation. It was the IA-TAC contractor responsible for the 

region that includes American Samoa. 

16 Section 307(a) requires that preference be given to firms and individuals doing business primarily in the 

area affected when federal funds are expended for debris removal, reconstruction, and other activities. 
 

 

Regulation (FAR).17 FEMA selected the Partnership for Temporary 

Housing to build the homes in October 2009, but did not publicize the 

acquisition or conduct market research until November 2009. According 

to FEMA Housing Strategy white paper created on October 30, 2009, 

when the permanent housing construction pilot is approved, “the intention 

would be to implement the program by utilizing...the current IA-TAC, 

PaTH for construction labor.” According to an October 31, 2009, email 

among various FEMA officials involved in the housing project on 

American Samoa: “The JFO [Joint Field Office] expects a Task Order for 

permanent construction is imminent and will happen within the next two 

weeks. [FEMA official’s name] is requesting that one or two PaTH staff 

be deployed, as early as tomorrow, to start preparing for a housing 

operation.” FEMA’s decision to use the Partnership for Temporary 

Housing for the permanent housing pilot soon after the disaster was 

confirmed by a knowledgeable FEMA official. 

Figure 8. FEMA Home Under Construction in American Samoa 

Source: American Samoa Department of Commerce 

17 FAR Part 5 requires publicizing of contract actions to increase competition, broaden industry 

participation in meeting government requirements, and assist small business concerns in obtaining 

contracts. FAR Part 10 requires agencies to conduct market research before soliciting offers. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 18
 
 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 19
 
 


 

Additionally, building permanent homes was not within the scope of the 

FEMA/Partnership for Temporary Housing contract. Section 5.1 of the 

contract, awarded on May 14, 2009, lists more than ten housing-related 

tasks the contractor may undertake, none of which involve building 

permanent private homes. FEMA modified the contract on December 28, 

2009, to add “General Construction Services” terms and conditions. 

However, the FAR requires that the normal acquisition processes be 

followed if needed services are outside the scope of the existing contract. 

FEMA rejected each of the nine companies that expressed interest in 

building the needed homes in response to FEMA’s November 4, 2009, 

Request for Information. Reasons for rejection included not being 

licensed to do business in American Samoa, no experience in building on 

American Samoa, and no experience in building private residences. 

However, the Partnership for Temporary Housing, which did not respond 

to this Request for Information, could not meet some of those same 

requirements. 

In FEMA’s November 4, 2009, Request for Information, interested parties 

were to indicate their ability to build up to 150 homes. Although more 

than 150 homes had been destroyed on the island, former homeowners 

were given the option of receiving a cash payment or having a new home 

built. As of November 20, 2009, only three American Samoans had 

chosen the new home option. Ultimately, only 45 people opted to have 

FEMA build them a home. 

FEMA acknowledged that in its desire to help survivors, assumptions are 

quickly made and acted upon, and then require revision as time passes. In 

the past, these assumptions have resulted, for example, in travel trailers, 

mobile homes, and modular homes being bought and not used,18 

underutilized base camps being constructed,19 and unneeded mobile 

medical units being leased,20 at a cost to the taxpayers of millions of 

dollars. We understand FEMA’s desire to help disaster survivors as 

quickly as possible, but this desire must be tempered by proper planning 

and a concern for the costs involved. 

In American Samoa, had FEMA looked at the ratio of Samoans choosing 

to receive cash rather than request a home, FEMA may have realized that 

many fewer than 150 homes needed to be built. Thus, it may have been 

possible to build all the needed homes by using a combination of local 

small businesses, volunteer organizations (who said they could build 20 

homes) and foreign companies. Meeting the need in this manner may 

18 FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina, OIG-08-93, Sept.2008.
 
 
 19 Improvements Needed in FEMA’s Disaster Contract Management, OIG-10-53, Feb. 2010.
 
 
 20 ibid 
 
 
 

 

 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 20
 
 


 

have provided FEMA with more valuable lessons learned for future 

building in the territories than could be learned from the use of one large 

American business. 

Another reason given for rejecting bidders was the Buy American Act.

21 

The FAR creates exceptions to the Buy American Act, but the market 

research team did not recognize or consider these exceptions.22 

Additionally, the Buy American Act applies only to the purchase of 

materials to be put to public use. Because the homes being built under the 

pilot were for individual, private use, the Buy American Act appears to be 

inapplicable, and thus foreign construction companies could have been 

considered for the construction program. Interested foreign companies 

from Australia and New Zealand, which were licensed builders on 

American Samoa, may have been able to build the houses at a lower cost 

to the taxpayer. The interested Australian company estimated the cost of 

the homes at $250,000 and the New Zealand company at $240,000, far 

below the high end of the estimated costs discussed below. 

FEMA set a goal to complete the home construction on the 1-year 

anniversary of the disaster, September 29, 2010. This date was not based 

on any analysis of the time it would reasonably take to build the number of 

homes needed. It may have been simply a symbolic choice, but it led 

FEMA to eliminate companies and volunteer organizations that were 

unable to meet the self-imposed deadline. 

According to 2000 Census data, more than 80% of American Samoan 

homes had zero to three bedrooms and more than 60% were valued at less 

than $60,000. The homes to be built by FEMA were based on plans 

developed by the Development Bank of American Samoa (DBAS). The 

homes are basic two- and three-bedroom, one-bathroom block homes, 

approximately 920 square feet for the two-bedroom and 1,262 square feet 

for the three-bedroom homes. Historically, DBAS loaned applicants 

approximately $40,000 to build two-bedroom homes and $60,000 to build 

three-bedroom homes.23 

The initial estimates provided to FEMA were three to four times higher 

than the DBAS loan amounts. FEMA proceeded with the pilot, even as 

unanticipated factors increased the costs. For example, archeological 

monitoring was required at every site, and landfill had to be tested. The 

21 41 United States Code §10a-10d. 

22 FAR § 25.202 23 A direct comparison between DBAS loan amounts and the actual costs to FEMA of building the homes 

cannot be made because (1) the relationship between the loan amounts and the actual costs of building are 

not known, (2) the homes to be constructed under FEMA’s purview are subject to more stringent building 

standards and other federal laws, and (3) the loan amounts do not include site preparation and related costs. 
cost of rebuilding was in flux for months owing to unapproved design 

plans and disagreements between FEMA’s IA-TAC personnel and the 

U.S. Army Corps of Engineers over what should and should not be 

included in the cost of home building. Because FEMA did not have 

construction expertise, it negotiated an interagency agreement with the 

U.S. Army Corps of Engineers to supply construction project management 

services. If all services are utilized, this 9-month agreement will cost $3.7 

million. 

Figure 9. FEMA-Built Home in American Samoa 

Source: FEMA 

Under pressure to move forward, FEMA gave the Partnership for 

Temporary Housing a “Notice To Proceed” in January 2010, which 

authorized $3.9 million to build up to eight homes. FEMA intended to use 

the actual costs incurred by the Partnership for Temporary Housing to 

determine the true cost of the homes, determine the independent 

government estimate of the building costs, and negotiate a firm fixed-price 

task order with the Partnership for Temporary Housing for building the 

remaining houses. 

 

A ground-breaking ceremony was held on January 11, 2010. Construction 

on the first home began in February. However, it is unclear how 

construction could have begun without an approved design plan, since the 

U.S. Army Corps of Engineers did not turn in the final design plans until 

March 23, 2010. As months went by, FEMA continued to receive 

estimates of costs and debate what should be included in the cost of the 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 21
 
 

 

Security, Material Corps of Engineers Overhead, and Other 14% 

Archeologist Office 3% 17% 

6% Contingency 

11% 

Construction 
 

33% 
 General & 

Administrative

 4% 

Other Direct Costs 

Site Prep 5% 

7% Program Management 

pilot. FEMA received varying estimates of costs, ranging from $140,000 

to $381,000. Several FEMA officials acknowledged that the cost to build 

the homes was high − one official claimed to have had “sticker shock” 

after realizing the costs involved − but believed that it was simply the cost 

of doing business. 

In addition, FEMA faced difficulties with site demolition and preparation. 

The land that an American Samoa family lives on is not just land; they 

have a “deep-rooted” connection and past with it. Traditionally, the 

Samoan people bury their loved ones on the aiga property with elaborate 

gravesites to signify a bond with the land and to remain close to the 

family. As a result, during the site demolition and preparation process, 

workers found remains of generations of family members. Additionally, 

archeological artifacts were found that required removal and study.24 This 

delayed the building process and increased costs. 

Figure 10. Estimated Distribution of Costs per Home 

Source: OIG analysis of FEMA data 

According to the applicable federal regulation that implements Section 

408 of the Stafford Act: “Permanent housing construction ...must be 

consistent with current minimal building codes and standards, where they 

exist, or minimal acceptable construction industry standards in the area, 

including reasonable hazard mitigation measures, and federal 

environmental laws, and regulations. Dwellings will be of average 

quality, size, and capacity, taking into account the needs of the 

24 Any activities that involve ground disturbance trigger a review for historic preservation consideration to 

comply with numerous federal laws, such as the National Historic Preservation Act, the Resource 

Conservation and Recovery Act, and the Archeological Resources Protection Act of 1979. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 22
 
 

occupant.”25 The building specifications being used for construction of 

the houses were improved to a higher standard than those customarily 

used in American Samoa, in violation of this regulation.26 Additionally, 

U.S. Army Corps of Engineers included commercial specifications in the 

final residential building plans. 

 

FEMA advised us in early September that a specific task order agreement 

for the Partnership for Temporary Housing’s services for the permanent 

housing construction pilot program in American Samoa had been reached. 

Eight homes have been completed; 37 homeowners are still waiting for 

their new homes, eleven months after the tsunami struck. FEMA is 

preparing to obtain offers from other parties to build the remaining homes. 

Recommendations 

We recommend that the Federal Emergency Management Agency 

Associate Administrator, Response and Recovery: 

Recommendation #2: Conduct a comprehensive “lessons 

learned” study of the permanent housing construction pilot 

program in American Samoa no later than 90 days following 

completion of the pilot and use that study as the basis for: 

•	 Future policies regarding insular areas; 

•	 The decision-making process for how and when to use 

permanent construction; 

•	 The decision-making process for who should build the 

homes; and 

•	 Determining the use of local resources and voluntary 

organizations. 

Recommendation #3: Develop comprehensive, executable, and 

regularly updated permanent housing plans for insular and other 

areas for which the Federal Emergency Management Agency has 

the authority to construct permanent housing under Section 408 of 

the Stafford Act. Such plans should include the use of local and 

volunteer resources to the maximum extent possible, consideration 

of Emergency Support Function #14 in the development of these 

plans, and approval by the cognizant state, territorial, or tribal 

leaders. 

25 44 CFR 206.117(c)(3).
 
 
 26 The standard used was the 2006 International Residential Building Code/2006 International Building 
 
 

Code.
 
 


American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 23
 
We recommend that the Federal Emergency Management Agency 

Chief Counsel: 

Recommendation #4: Determine whether the Buy American Act 

applies to the Federal Emergency Management Agency 

construction of permanent housing authorized by Section 408 of 

the Stafford Act, and work with the appropriate officials to 

incorporate such determination into relevant policies and 

procedures. 

Management Comments and OIG Analysis 

FEMA concurs with Recommendation #2. This recommendation 

is unresolved and open until FEMA conducts a pilot study and the 

lessons learned are used to establish policies for permanent 

housing plans. 

FEMA concurs in part with Recommendation #3. FEMA does not 

concur with the requirement that permanent housing plans be 

approved by the applicable local government, because FEMA’s 

authority to build permanent housing is no longer limited 

geographically; thus, the “local government” may be at the 

State/Territorial level.” Our use of the phrase “local government” 

was meant to refer to the highest level of government, be it a state, 

territory or tribal area. We have revised the recommendation 

accordingly. Based on this revision, we consider the 

recommendation unresolved and open until such plans are 

established. 

FEMA’s Office of Chief Counsel determined that FEMA’s 

permanent housing program is subject to the Buy American Act, 

but pursuant to Recommendation #4 the FEMA Office of Chief 

Counsel will review the Act and make a determination of its 

bearing on FEMA’s authority to build permanent homes for private 

use. We will pursue this matter further with DHS Office of the 

General Counsel if FEMA’s Office of Chief Counsel determines 

that the Buy American Act applies to the building of homes for 

private use. This recommendation is unresolved and open, 

pending review of corrective actions taken. 

FEMA’s comment letter contained some comments not directly 

related to recommendations. FEMA officials deny selecting the 

Partnership for Temporary Housing to build permanent homes 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 24
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 25
 
 


before the necessary acquisition steps were taken. We based our 

conclusion on pre-decisional documents, emails, and the testimony 

of a knowledgeable FEMA official involved in the process. 

FEMA officials in Region 9 provided us with final documentation 

and email which they assert refutes our conclusion. 

We have updated the number of homes completed and the status of 

the task order between FEMA and the Partnership for Temporary 

Housing. 
Appendix A 

Purpose, Scope, and Methodology 

As a result of Federal Disaster Declaration 1859, we deployed an 

EMOT consisting of auditors and one investigator to American 

Samoa from November 4 to 23, 2009. Our objectives were to (1) 

promote accountability instituting measures and processes to 

evaluate the actions of federal emergency professionals, (2) serve 

as an independent entity for oversight of disaster response and 

recovery activities, and (3) determine whether FEMA had 

identified and taken steps to effectively mitigate the risk of fraud, 

waste, and abuse or mismanagement of its assistance. 

Relevant criteria included Robert T. Stafford Disaster Relief and 

Emergency Assistance Act, Public Law 93-288, as amended; Code 

of Federal Regulations; and FEMA disaster assistance policies. 

We performed extensive document review and analysis of FEMA’s 

deployment and JFO operation records, standard operating 

procedures, directives and policies, budgetary information, 

program data, e-mails, and statistical information. We reviewed 

prior federal audit reports; Single Audit Act results maintained in 

the Federal Audit Clearinghouse for the American Samoa 

government, FYs 1997 through 2008; the American Samoa 

government Single Audit Act reports, FYs 2007 through 2008; and 

the American Samoa government audited financial statements, FYs 

2007 and 2008. 

We interviewed officials from FEMA Headquarters, FEMA 

Region 9, FEMA Pacific Area Office, U.S. Department of the 

Interior, U.S. Department of Justice/Federal Bureau of 

Investigation (FBI) in Hawaii and in American Samoa, the 

American Samoa Territorial Audit Office, and auditors from the 

certified public accounting firm that performs the American Samoa 

government’s single audits. We also met with more than 60 key 

officials, including FEMA officials at the JFO and the American 

Samoa Governor and his representatives. 

During our deployment, we participated in FEMA and American 

Samoa government joint situation meetings and visited the Disaster 

Recovery Center and damaged areas (ASPA power plant in Satala, 

Pago Pago bay area, villages of Leone, Nua/Seetaaga, Amanave, 

and Poloa). 

We conducted this review between November 2009 and June 2010 

under the authority of the Inspector General Act of 1978, as 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 26
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 27
 
 


Appendix A 

Purpose, Scope, and Methodology 

amended, and according to the Quality Standards for Inspections 

issued by the Council of the Inspectors General on Integrity and 

Efficiency. 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 28
 
 


1.'(,. n.-,o_ot_s-...!

........... 01: 1')('1

8 i ,..tIf! FEMA

Sqlttmber 18, 20 I0

~IEMOR.A:'\DIJM FOR,

FRO":

SUBJECT: FEMA R I1SC 10 Revised Draft OHSlOIG R~[}(ln 011 American

Samoa (10--/16-£,110·1-'£,\£'1)

On Jul~ 28, 2010. ~'our olr"", forwankd 10 FE~1A leadership .. dr:lft report lilkd: .'I_riean SDIIlOO

1009 Enr/hquukt und Tsltnumi: .~".ActiOtf Rt'fKwt. fh:1t draft report cnntaincd Ih1: n:cummcndatiUllS

for FE\1t\ \Q consider 1oI;lh t'I.'SfICC1. to its rcsponsihitiliCo' in pr'O"iding disaster a;:siSl3nl.~ wthe disastcr

SUl'vivoo M\d go\TTYlIDl'ntal ¥llCk~ in LIlt Territor) ofAmtricsn Samoa, FJ-.:\1A provi<k-d a written

respollSC W this dr.tn. report. as "''tJl a.~ met with yourofficc 10 diSCUM uur tooctrns wilh eatain

elem..:ms therooL On SeptC'mbcr 10, 2010, your onico: fUl'\\olUdtd a mcroor,mdum li{l~'d: Re"6't'd Draft

Nt/IOr/: Am,'rk(!J/ Samuu 2009 EaJ'/hqualw and TSI/nami, After·Ac/ion Rt'(XJrI. That memorandum

convcyw an altachmcm r~visinl! Reconmlcndalion I and supporting 13J1guaSt, l1ll:' lno:mnrandwn

wnhcr inditllied thaI additional modifl('31mlo tho: original drafi report would bo: made, incillding ..

rrtraclion ofRL'\.VIIllIl<:Ildation 2, Ba~ on thc L".:visions \Q the original drafl n..'POI1, FE.\oIA t'I.'Stinds liS

original ",,'lillen re:>pLlIlse. and submi~ thls rt'\'Ued reply, FF.MA's fe' is:d r~10C1ch ofthe four

rcmauung!\:port rtCOntrncndalioM fullo~'$.

(JIG flM-jsdl RtrolrlmcmJutlOn1!L

('wililll/e III /IIkt! all nt""~WI,'afliol1J /0 CII,lUr,' 111m Ih.. A/IIt!ricl/ll &mHiII glll'l:rnmfll/ jlIojl(!fly i'XP~IIJ~

amI a"i1JlInUlorfi'deruf Il'oll/jimdins. &md /Ill tw n',rtllt.~ ()flh~ 20m OiJia u(,Hullag,'melll mrd

RI/dgel Circuli":I-IJJ ulIJiu wltl ill m:C'JrJilnCI: wi/II /fikml rrgulmiom', "W~t /lCriQflS shill.lll indl/M

nmdJum;OII 011 ..'he1ht, ,Ilntr/<'WI .'1,IlIIOO (orflwlfy ikfiRlfflled /1 lIigINi$! gramt'...

..u.tA concurs Yoith thi~ It\'lsed m:oo:m;:l1od~llOO.lUId WI: ..ill ('()lfriIlM to w.e $11 n...~' .etloo, ro

m~ur... th:ll the AmmCl\l\ Samoan gOlcmmcnt propffi)' cX;:;;:nds and XC,I\lIlI~ f<)f fe,'k-raJ VdIll fimd:flg

th:ll is ullJer FnH's ttdmill;5frolill! pun';""",

\Vhi!e the narr.tlive accoll1jXlnying and supportinG the UKi r~omml,xL1tion pro\'ltk-s ~'Ol1Sidt'rablc

detail on th... con«rll$ Td~t~-d to the- qUlllil)' of American samoa's finnndal accountability regarding

FE-'1A·adlllmi.lo:r\:u g:'llIll funding. il dots ItOl do.-qUtl jl.lStil.-e 10 Ill.: history of aggressi\'t l\C1io,u and

sigi'lificen! mhancernen;: clt'orts allderoktn b~ American SanlOl. ,'Ill! FL\1A RClll(lfl IX 10 ~;j~'ely

adc!te.>s those Cl'IICeI't\S, DOl does il C'ljuibbl) ra.vgnize &~ nl.:llSUr.lble tmpt'o...cmC'D~ In qu:l!itari\c

Appendix B 

Management Comments to the Draft Report 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 29
 
 


occountabiJily th(1SC ctforB (C~crtl.'d by both American Samoo FE~A) Iw\'~' proJUCL-d. We bdic\"c

those. fam, effons aud achlev¢menL~ - detailed below - atc noteworthy, and dcscn'C adnowlcdgemcr,l.

• ,\lthough not officially dcslgnated ~high risk" by I>HS!FEMA, American Samoa has beensirx:c l)e(:emher 2()fJ5 - de.~ignaled "in lieu of high risk"- As 1I n,:sull <.lfthis lancr desig.nalion.

and for all inlentS and pUI'p('Sl:S. AmL'J"ican Sllmu3 has h.:en eflccti\d) opcr-Jling (ami

imprQving! wilhin a "high risk'- accountability ~'11Vlronmem for nearly 5 years. ensuring SlriCl

arid closely monitored accounwility for both disast~ and non-disastcr grant tUnding, and

b.:lpinB to reStore tnc public lrust.

• Uy letler daled tktober 19. 2007, Governor Tutatimo nXluL~lcd tlull fE~Ii\ l\.'Store funding for

American Samoa f'ublic AssisWllce and I tlli'..ard Mili~tion GUlIlt Programs for open disasters.

In response_ Ih" rEM.t\ Regional AdminiSlr.,l1or initi:MJ and wmpl..ted - m conjunction with the

FEMA IkadqU3rteTS Natiotml Prcparedness Dinxloratc and Grant ?rograms Direetorate - a full

:md eomprchcnsive review ofFEMA gratn programs pmvidcd 10 Am~riean $amoa, including

direct on-site assessments. In h:broary 2008. FEM," convent'll a hi~-Ic"cIlVorking group

(c()nlprised of Region IX leadership and slaff and key FE\M hc.'ldquancrs ollicials. 10 include

representati"..s from the Pmgnun Devdopmem and Administration and Financial O\'ersight and

Accoullwbility offices und.... tnc (ir-,mt I'rngruntS Dirt\:lorale) to review progmm l'I.'quircmcnts

and. most imponantly. develop 8 rigorous Wrre<:tive ltction pl,m to authoritalively guide

!\mcrican Samoa's gram eligihility re:.10ralion dfoltS. The working group also cstablish~·

II/ifiting high ri.d. rl'qllirt'menli' - demanding critcria for the release ofsjl'.:cilicd grant fimds. 10

include a rt'Str;cted dr~w-do\\'n process that r""'llires s.ubSlantial jusliiicalion and a [.;udully

moniiored documentation approval process to ,mabie thc distribLllion offunds. By working

c1oS('ly and collabordll\"dy \\;th Amenean Samoa offiCIal>: lIy acti"..I}" promoting rigorolL~

accountability: lIy instiluting meaSUrL"S lUId pr~~~s 10 CllSun: dose lUId L'OlItinuL'd oH'rsiglll:

and by requiring detailed and dcmullding correclive actions, [:r~\1A took .md sustained

aggressil't and fllnili!menwlly >ound SIl"PS to help American SJlmoa down lhe path towards

financial al.:counl1lbililY and. cl"cmually. grant cligibilily restoration.

• Crucial to lhe m<,asur~'d and validated improvcm~n1 in pcrtonnancc of American SilIlloa was the

COOl"''T31ive de\-t'!upmenl of U corret:li\'1.: aclion plan to authoritativety "ddress identified

deticiellde.~. In Deeemoor ~OO8. Region IX S!.'nt a !<oller 10 G>lt"elllOr T ulalililo n:garding the

st.:'llllS ofthe Inspector (jent'ra! 3udillindings (OIG-4i-02) ior Homeland Sccwily grJnts for

Iiscal yeaN 2002, 2003 and 2004_ and n:qUCSlOO thaI a corru.:tive action plWl be submiHt:d til

oodless the audil lkdmgs. The Idler also requtst<,d information or documentation 011 corn:clive

xtlons ~ltm American Samva implemented to address the lIOll-compliance issucs tdemilicd in

the Ir,spt'clor G{"llcra! report_ The: leUer stipulaled tl\ll' approval orille eotl"Cctive action pilln \\'!IS

a fUl:lOr in:my Jc:t<'rminatioll to rdcas.: funds. and th,tl oul.o;t.andinl! issues mllSt be If,atis(adiJrily

addre.ss<.'<! before FBI." would nllow American Samoa to b;: placed on rcstncted "ash drawdowlI starns for Ii\'<: spt'(,ified prep.1n:dn,-ss grows, E~'cn lhen. fEM." wl1lruls rcmain('(llighl.

as the restricted ca~h draw.uuwn process re<]uires Anleriean SltlIlOO. to sllbmit requt'Sls for

.,;pcnditUf\:s rdU\L"d to specified granl.'; to fE\1.,\ for revicv. and llpprovuL pri,,)r to FEMA

rekasittg any f;,;nds.

Appendix B 

Management Comments to the Draft Report 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 30
 
 


• The ln~p',;l.'.tor GCIll.'rIl1311dit (OIG--I7-iJ2) iJcmilil'd sevcrnl audit lindin~s nnd recomnlCndntions

ri:'quirinp; corm:lil'e l\I;tjon. Accordingly, FEMA directed Americ:.ul Samoa to pro\"ide a

corrective aCllon plan to ;)'ulhoril;l.ti\'cly rem.:djal.:> thl:: thr~ recommendations ofthe report

Specifically. Anll.'l'ican S3moa "as require.:! to (I) provide sUPP'ming d(>\,'Uffilmtation within-l5

days p~inillQ to the qucSlion~ CO>.""tS identilied in th... lirst m.:olllmcndaulollt; (2) prOVide

sup['Orting d,}Cum<:mation for cdl poorlCs. priming ~'(Ists and gasoline charges ldcntified in a

S<'c.lnd re~'Ollltll<,ndallon; ,md (3) Allleric.an Samo.:l was required to r.::pay funds for disallowed

pUl\;har.t:S identified in a r.-comrncnd3tion, American S:unoa suhmitled thdr cOfTCnivc action

plan and supplemc!lrol intormation in Fehruary 2009, <.\1\ time, and as f("qucStcd. FE1'>lA 1lO1C'd

thal Americ:.ul S,unoa SI111J'wlll' \l'l) c<)(lperat;I'<" aIld moronsi\'e 10 inquiries alld rC\juests r'lr

supplememal documenwliun during \he com:ctivc action plan r.::vicw process.

• FEMA conducted an on-site programmatic and financial review in :'-·hy 2009 to asse;..~ the

corrective aetion.i impkmenl.\,'d by AmC'rican Samoa 10 address non-complinncc i>sues idetltifil~1

b)' thc Insp<;etor G('tlCfal, and to ~nsure that policies aOO procedures wc!\: in place In proper1r

account for reccipl wd cxpo.:nditure of IJIIS alld FEMA preparedness, mitigation and disaster

funds. The: results orthc review determined that Amcrican Samoo would be placed in restricted

cash df~w,liown SWtllS once the funds lor audit diSfllto\\'ances were returned, The funding

frd:zc W"ilS lined for mitigation and disaster programs, as well as the specified prcp3fcdness.

grant programs. lIowe\'er, in funhernnl'e [lITEMA's f);5ponstbility to ensure littlll1cial

oversight. American Samoa \:ominul.'S lU ht: on a restricled cash drJw-down statllS. H:MA

l\:glOlllll s\flIT continue to closcly monitor (oolh pmgnunmatieal1y and financially) American

Samoa progmms. eotlljllue to pm\'jde te.:hnical as.iislancl:, and continue to conduct

admini~trJlh'c compliance n:l'iews in an ongoing etroM to SlJ.'>uin suund lllhninbtrJIl\'c pmcticcs

and financial occoomability, >iultiple Visits during the past year ha\'c facilitated tIltd atflrmcd

American SlIIlIU~ acl;ountability improvements. and this high k\"d of Sl.-'l"llliny willl;ominue.

• At thc timl.' ufthc Scpt~lIlber 2009 diSflster e\'ent, th~ FEMA Rcgiun IX Regional Administrator

had restricted access by Aml.'J'ican Samoa to all bot a reI'.' gram fUndi. pt'ndil1l! t1~ final OUtl;OJnl;

ofongoing in\,l;stigaliol1s and the implementation of a eompr.:h.:n,i\"~ and figorous COm:Clivc

aetiOll plan 10 l'llSUn: the intcgrity ofthese progroms. I[owc\,er. lllWtJIoil!uolIs humanitmian

cut1Sidcrn\ions demllnded that FEMA not dcny critical di>a.'>ler a.<;;<;islllll<::t' to othef\\;se cHl;iblc

American Samoan residents al1ected b~' the disastcr; accordingly. FEMI\ appropriately

authoriLed Individual and HousdlOlds Program funding 10 11c pmvid~d 10 tligible UWI\;<.!uals

and flUllllics. FE:vtA also assllrcd officials of American Samua thatthc d.:cision to suspend

funding for ot1\\.'r "EMAgran\.'l would n0t affecl the Federal resJXlllSC to" PrcsidemiJl disasler

declaration,

RL'£.ardlcss ofthe !"onnal d('Sigimtion of All~rican Samoa«~ "high risk"'~' othcr j(xkral

agencil;s, lhe regulatory pnx:cs.> allol\'s lor each awnrding ogency to sep;lrJtcl,. and

ioocpendently ddermlllC the need to ~<)lJS1der a grantee til' sub-gnml~·'high risk,"' l>ased on the

fiw criteria sp.,."ified m 44 ('FR, Sc.:tiol113 )2. The awarding agency applies U'.e criteria in the

context ofthe l;\lITem ronditious ilnd eapaNlities. for managing ~pc{'!fir /(fWll uwardJ. While

)

Appendix B 

Management Comments to the Draft Report 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 31
 
 


FEt\tl\ is l.'QgniZllllt ofother agcnty high-risk designations. FEMA has separalely lUld

inderendcntly d<:l~'nnln~d lhal its tl.lfrent policy and nlClhodolog} fdr ,\m('riClln Samoo -o.t II

IJ(!piiu IIII}wSl! grum S)"Stt:fflS IIrat suppllr' I·EM" pmgnl/llS - is dle.:!i~·". and Ihat OIlier agency

··hig.h risk" delerminations apply to srsl~mic conditions Ihm :Ire nOl rdC\'llnl to FEMA'g !lr:ml

progrnms.

QK; Ijrco/llmwiqllol1 1>1:

COnd"CI II compr/:'hclISll't! ··Ie.~.<on~ 1/:,(Jr1/l:'d" SIUd) ojtilt· JJerll/III1"/1/ !lmbitlr. ct)II)',rllctiQt! pilOl

pragram in :lmrrlcan .1111I1100 no falt'r lhun 90 d<l}'S followi"g completion afthe pilQ/ ami u.~ l/wl $/udy

iZS ,hI:' bosisfvr'

• FlllllTe poIiri!:'.J regwding In.w/ar Qrt(U:

• 'TN Ikdfinft.nlUting prtKl!$J}i>r 110... and ...hell/o uu ~rmltnefllCOMlrut'lion:

• 1M fll:'rislon-mlIking JIf"tlaMftIr '<rho Mfuufd bw/d,k hv~, and

0I)tt_mil/8'hI:',," oflocu/rntJlllrtS und 1'Oi~tUQr)' orylon!:asiotls.

FE:..tA agrees \\ith 1M premise ofUus rte()ntJnmlbtion Ilnd funy int<:nds U) wndurt:a -kssons 1..:::JmOOassessmtnt Repl'l::I<lIlatl\\.'S from FBIA H~UllnefSh:a\'e :already sp.:ru lime in ,'\meric:ul Sllmoa

gatherinlll0:ss0ns-kumed ~l.h,::d 10 litis Msnsnl~lt. T~ kamcd lessons \'oill ulumatdy mlonn.nd

support chan~ts 10 pulicits and proccdUl'CS. 110.....e\·er. lhere m: II. nwnlxr of an<:Htl:l1ies or disc~pall\:"ies

in the rc:port. \'ohich w~ address below.

• ~. Conct:Jtlllll! th..: 3\:lcetion of PartnefShip for ·l ..mpnr.lry Housing (P.".TH): The report

sLll.... Uutt FEMA Sl."kClcd PATillO lluild 1M homes in C'k;lo'tll;r. bIll it did 1\01 COndllct lhe

markel re~areh until Nowmbcr 200lJ. 'j his is il\;!CCUr.tt.., The deeision 10 Ulilizc PATII was

millie l!&;r lho.: cnmpunks provided their respons.cs I,) Inc Kl.'t.ll~sl for Infonnnlion lind ~'arkct

K.:seW'Ch Revi....... all.! ArlIllYSIS.

• ~;COl1t"<I1Iing rolt oftho: U.S. l~partlllellt ofl10using and Urban [k\dopmenl

lHl!D): SUlC~' HLJ) dlle's r.Ol ha\t: a presence in American SanlO3- It.< fk"dormt'llL Bank of

A/l)(rican (nlM,)) serves as their rcp~selUlIti\'c for adminu;!Cring HUD 101l1U. The loan

pm&r,\lll ultliz.-s the DBAS plans. DRAS WliS lIl.1i\cly m~,-J In the Hoo:'II1" T&1: Force.

• ~: Cor.c<l1ling lbe u.;c oflocal housing contl'llCton:. Foilovoi.'I£ lJk l.'3rthtiualc:wid

lSi.IR:lfIIi·~I;lIcd destruction. FEMA performed :m :mal, >is uft.'le Iong'lam housing IlCC'd and

XtClmilW..,J!h.fI pcrmaneuly con.<tru.."11lll> homes fOl'" digibk disaster Slto-ivors would best meet

!he houting~. FE.\fA performed I \1arkCl Resnrch Rc\'ieoo. and Anll!YSb aod req","~

l~ (OOlnoo.:iOl: information and 10 budd an Vo:JlCl"ted IlXal of ISO bomc:s. Multlpk

ro:::p;mi~ ItipoJnJo.:d. btll tlJe)' did r>(Il mcel: tilt cnlcna to SCl'H b pnmc con\Jlllt.."1Of for \'lInIl\L';

Appendix B 

Management Comments to the Draft Report 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 32
 
 


reasons. such s:s the companies did not h.:l\'e a l.1rf;e enough labor foree 10 m~"\,'t tbe need ofthe

tonlmCt Of !h~' did IIOl possess lhe finlll'.ci:d feli<lllfte!> 10 CO\'(1' lhe COSI of n13h:rials ,uld 1o\11gC1,

~: Concerning the sdCClion or Pi\TIl: To help e):!lCdite the rehuildiog process. FEMi\

lookeJ ttl Pi\TH, liS 1~'Chmcal a~mlafl(;c contraclor, Technical assistanCC conlI1\ClS a~ in place

10 CJlS<Jr~ lh31 r~urces are available and slDuding by TO complete a disnsler Bollsin!> mis~i()n.

aud are ""warded 10 vendors ,m a n:gionld basis Io\;th funding dt!;igl'laled for vClldors 10 mainlain

readin~'Ss 10 IlSsisl in \'llrious huw;ing mls.~iollS. At the lime oflbe disaster. Region IX Imd a

l~hnknl assistanee contrm.1 in place \\;!h PA rHo

• ~: Concerning lh<: sda;li,m of PATI! Once the Marl:et Rcscan:h 1«:vK:w and Analysis

resulls dttmnined lhat 00 b:al firms were a ,'iahk nptinn, PA111 was Sdc..:l(,..,j as the prime

cootnlC\Ol' for the ~n,g project for lbe initi31 eiilll (bJle: a 100II "endor is e.~ptCltd to

be 31o\lIl'ded !he Phase 2 comr:tet to build the fI.-mainin; approximately 30 homes under tht pilOl

program). PATH has prevIOUS oonsltUction experi~ building rcsid.:ntUI houWlg. including

militat) housing. in 11a......ii.. MWourl. Idahow Nonh Carolina. P,>\T111til'S prmen 10 !».\c

lIl:CCS$ 10 rmancia:ll\.~ for projcm which rtquire funds in ach'3llcc and tIllS performed

suc:c&::ssfull~ on FE..\tA rontrxts since 2006, Although P.\ru \\'3.S designaled as lhe prime

contractor. it IS oo!C'.'o·onh) 1M a numba'of American Samoa·b:Jscd linns ....eu ~1C'Cled lIS subcontrllt1ors for the project

• ~: ('-Onecming lhc US<: of volunteer Ofl!anir.:IlIQf'l: The ro:pon implic$ that FEMA did I'ICll:

me an cITon to utiliu mlunl~ orpnilllliuns. On III kJ.Sl four separnle occasions. FE.\otA

lead<.'fthip consullCd ....;lh Menl)unile Ilisas:cr Srn'ices......ho was repr<smting the o~r

\'oluntccr orl:amil:lluuns. 10 discus.' lheir ability Tl'l Ctlnstrucl homes_ In every ca.~. they wt1'C IlO\

able 10 build lh~ nwnb.:r urhomes required hy the PCnnantnl Hou.'ling CO!1SInIClion program,

Infi1cad. they provided assistan~'lollu lOOse homes th:ll could be l\.'PllII\.'t!. ThiS acllOlI freed up the

limited pool of wor\.:~'n; 10 focus on recon~lnlClion, FE..\lI\ has SJ)l;:nl o\'t~r S260.000 In

invilllliunallr.lvcl and supply requirements for O\'cr 120 individuals providing \'oluntnry

S\:rvici:1l.

• _~lI&ill: Concerning the num~r ofhul11<.':'l ~'()mplctcd: All cililit homl:s memioned in 1M ft(l(lM

were wmpletcd b) I\ugusl 9, 2010. '1'11(' \it~ prepa:allOO ",ur\.: fOllen addiliiOlUlI ~itC>lIS al$O

completc.

(IlG RrCtI1llJ',..lnJoIWlI if):

lJ,.>q>lop .'OIJlfJ'thtnJlI't. I:Xt<.1dQiJk (m1 rrguiarl)' upr.IuNd~'tI!{IIWI" /lQ1JS;ngplomfcJ' ;lI$u!UI' and

OIMr tiI'l'ilJ..fa, I4hfrh t'" Fr.kra! f.mergclICv MCII'Ogl'fll<'n! A]!e'lf) hos tN o",hority IfJ COflJlTlIi't

fXmIORl'tT' houiJrg 1I11(kr Sn:'Wn.J~ o/lh.t SloffanJ ..fa Such plom should indlltk tit.: usc oflocul

UIII1 wI;ut{e~ ft.WUTO!:J lO,ht- "..mi1lW1JI wen! pomblt conshk'iJtWll of&lc-r1l.mt) ."1IIJPl" fiulcrkM

#!/ In 1M dr,":opmmI o/thatpiCM. and apJTGWII b) IN fiX4/ go...nr~t..ru o(/~Sf p/.t.w {indtalitlfl

itJ irIIIaifl8lJwhurity !(UIl))

,

Appendix B 

Management Comments to the Draft Report 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 33
 
 


FE..\1A tontun; with lhe dc.~irabilily and need for Sl;alabk, lIc-:iblc, eXtCU1;lbli: (l<:nTl3n~'1'I1 housing

plans. as well as ",hh the recommendation tllm s~th plolls illcludc the particiJXllion ofESH14 and

maxmliL~ the use of local and ~oluntccr lC:;OUl\:eS, However. FE;'.L'\ dOl:S not concur thal. it IS ellher

applOprial~ or l\,;.liSlit to ll.-Xluir~ luc,I! gowrmn.:nt approval I!,! slilllding FEMA-dc\'l;lopcd plans. The

OIG Tl:commcndalion indicates llut such plaM should N developed lor ...., imll/lir and oth,'r arMsfor

which Irn' FtdtfiJ/ [mergellq MUflagenwlU Agcncy has the amhorit)' to COllSrruct pernll/1/CllllJou5ing

lIIuJ~r &dion 408 oflhe SwfJ<)rdAct, " h shot,h1 be llokd that $.."";li"n 408 illlpo~ no gcogrdpllJl;

limits on the President's authority to providc penTIanCnl housin,g, !\ccordin~y. pcrroaTI.:-nt construction

may be authorized in any area that Olherwise meets the criteria establi~hed in Section 408(c)(4),

Aceoroingly, the appropriale and r~'lIliSlic coordination antlupproval h:vcllor FEM!\ would Ix: (tllhe

StaleIT~rrilOry lel'el, not allhe indi\idnallocal gOI..:rnmem leveL

The nalTlnive accompanying this recommendation Slales thm "FEJL1. chose nollO OCll1'(lIe Etm'fg('nC}'

Support Function /4, Long-Term Communily Ri'cmt'ry (£SF:;14j l/flikr IIU! ,\'arionof Responsl'

Fmlnt'll'ork, " The I\:pon fails 10 r~l1ed lhat Ihl' GOVL'T1I[)f of Am~:nc(lJl Samoa ~pcc\licall~ staled he did

not want \0 activate ESF 14. nor does the tepol1 acknowledge that it woLlld be ~ntirely ill3ppropriaLe for

FEMA to rcquir~ a sUP)XJl1ctJ T~-rritory 10 accept a form of f~-den11 a,SisllUteC that it bas dearly dcdin~'d,

OfG Rf/cmnnIenOOlian ~4:

Dl,'lermine l{Ihe Buy Am,'rimn A,'I flflPlil'~- IU 11/1.' Federal Emagmq MIIIUlgmll'nI Agrnq ,'om'lfII,'I;U/!

oJixrnumenl hOI/J-ing Il1IlhuJ'b:d by SCCliolt -108 oflh" Sra.fJQrd ..let lind It'Qfk It'ilh IiiI' appropriate

l1Jicials fO inClJrpOrlll1' .wcll delaminali,m in/a rcfl'l'on/ policies lind procet/llfCS,

FEMA I{e,ron~:

FP-IA and its Oificc ot'Chi"fCounsd (OCC) do not agree with the as$l.'nion thaI the Buy /\m"rican

Act (Bf\A) is IlQt applicable to seclion W8. pcmlancm housrng conSlruction. The permancllt

conslruction orhou~ing under the' SI:lfTonl ,\.,.t app,:,lfS 10 1~t.l1 "'ithin the.: BAA ddinitioll for public usc,

panicularly since FEMA is conltaetinf! for thl' "'erk dircctly. Ho\\"cvcr, ~r the recommendation. oce

will det~nlline whether lhc BAA applies to stetion 4U~ projects and work with I'EMA Otl1ce of

Aequj.ilious 10 ~n~un: lhl' BAA is prup..:rly &pplkd 10 rUlUrC prot.'\lrClll~nt aClion.,

cc: David K.~ufman. Dil\."Clor. OPPA

6

Appendix B 

Management Comments to the Draft Report 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 34
 
 


Appendix C 

The Territory of American Samoa 

American Samoa (AS) is an unincorporated part of the United 

States, located in the South Pacific Ocean about halfway between 

Hawaii and New Zealand. As a territory, American Samoa is 

administered by the Office of Insular Affairs, U.S. Department of 

the Interior. Each of the islands became a territory of the United 

States on April 17, 1900, when the Deed of Cession was signed. 

Prior to that date, Germany and the United States shared ownership 

of the islands; Germany owned the western part of the territory and 

the United States owned the eastern part. The five volcanic islands 

have rugged peaks and limited coastal plains with a hot and humid 

climate. Because of the rough terrain, very limited amounts of 

land can be inhabited. Together, the islands are about 199 square 

miles in area and the population is 65,628. Most of the population 

is of Samoan ancestry. As of 2005, 29.8% of American Samoa 

was unemployed. Their social basis is the land and 90% of the 

land is communally owned by families that are led by chiefs called 

matais. Religion is also very predominant in the American Samoa 

culture and much of the village life centers around the church. The 

American Samoa government structure is very similar to that of the 

United States, in that there is an executive, legislative, and judicial 

branch. The executive branch is led by the Governor and 

Lieutenant Governor. The legislative branch consists of the House 

of Representatives, which is elected by popular vote, and the 

Senate, whose members are selected by the matais. The judicial 

branch is a part of the U.S. judicial system. Agricultural products 

of American Samoa include oranges, limes, mangoes, alligator 

pears, yams, pineapples, papayas, breadfruit, and dairy products. 
Total Category 

Public Assistance Work Categories Amounts 

A – Debris Removal $ 990,831 

B – Emergency Protective Measures 39,512,040 

C – Roads and Bridges 565,991 

D – Water Control Facilities 702,664 

E – Buildings and Equipment 10,756,832 

F – Utilities 55,350,507 

G – Parks, Recreation, and Other 3,171,551 

Z – State Management 663,759

 Rounding 1 

Total $ 111,714,176 

Fiscal Year FEMA Other Federal 

Agencies 

Total Federal 

Grants 

2007 $ 2,724,758 $ 94,983,585 $ 97,708,343 

2008 3,807,605 125,497,726 129,305,331 

2009 (794,612) 121,342,469 120,547,857 

Subtotal $ 5,737,751 $341,823,780 $347,561,531 

201027 35,748,614 206,520,502 242,269,116 

Total $41,486,365 $548,344,282 $589,830,647 

 

Appendix D 

Financial Data for American Samoa 

Chart 1. Federal Grants Funding 

Chart 2. Disaster 1859 Public Assistance Funding, by Work Category 

Source: FEMA Public Assistance Summary dated September 21, 2010 

This chart represents total requested funds for all public assistance projects. Project costs 

are not reduced to reflect possible federal cost share provisions. 

27 As of September 24, 2010. 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 

Page 35
 
 

 

American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 36
 
 


Appendix D 

Financial Data for American Samoa 

Chart 3. Public Assistance Projects Obligated 

American Samoa Applicant Project Total 

American Samoa Community College $ 1,702 

American Samoa Environmental Protection Agency 24,384 

American Samoa Power Authority 12,606,088 

American Samoa Telecommunications Authority 358,135 

ASG - Territorial Office Of Financial Reform 597,383 

Department of Administrative Services 21,385 

Department of Agriculture 47,779 

Department of Education 89,237 

Department of Health 68,741 

Department of Human And Social Services 7,237 

Department of Human Resources 7,067 

Department of Marine And Wildlife Resources 542,859 

Department of Parks And Recreation 294,414 

Department of Port Administration 880,312 

Department of Public Safety 156,519 

Department of Public Works 369,376 

Dept of Legal Affairs/Territorial Registrar Office 4,043 

Development Bank of American Samoa 110,220 

High Court of American Samoa 50,574 

LBJ Tropical Medical Center 9,120 

Legislature Of American Samoa 114,860 

Museum Of American Samoa - Jean P. Haydon Facility 33,170 

Office Of Procurement 283,775 

Territorial Administration On Aging 163,661 

Territorial Office Of Homeland Security 179,845 

Total $ 17,021,886 

Source: FEMA as of September 2010. 
 
 

This chart displays the PA projects that have been obligated. 
 
 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 37
 
 


Appendix E 

Major Contributors to this Report 

Don Bumgardner, Division Director 

Trudi Powell, Supervisory Auditor 

Arona Maiava, Senior Auditor 

Vince Roth, Assistant Special Agent in Charge 

Polin Cohanne, Senior Program Analyst 

John Woo, Senior Auditor 

Puja Patel, Program Analyst 
American Samoa 2009 Earthquake and Tsunami: After-Action Report 
 
 

Page 38
 
 


Appendix F 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Under Secretary for Management 

FEMA Administrator 

FEMA Deputy Administrator 

FEMA Regional Administrator, Region IX 

FEMA Audit Liaison 

Director of Local Affairs, Office of Intergovernmental Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.