Department of Homeland Security 

Office of Inspector General 

FEMA’s Oversight and Management of 
 
 

Debris Removal Operations 
 
 

OIG-11-40 February 2011 
Office ofInspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

FEB 2 3 2011 

Preface 

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

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. 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 ofFEMA's management and 

oversight of debris removal operations. It is based on interviews with employees and 

officials of relevant federal, state, and local 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 ofthose who contributed to the preparation ofthis report. 

Matt Jadacki 

Assistant Inspector General 

Office ofEmergency Management Oversight 

~-
Table of Contents/Abbreviations 

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

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

Results of Audit.......................................................................................5 

Debris Planning............................................................................................................... 5
 
 


Pilot Program Impact on Planning.............................................................................. 6 
 
 

Contractor Management Challenges........................................................................... 7 
 
 

The Impact of Debris Planning................................................................................... 8 
 
 

Conclusion .................................................................................................................. 8 
 
 

Recommendation ........................................................................................................ 9 
 
 

Management Comments and OIG Analysis ............................................................... 9
 
 


Initiating Debris Operations.......................................................................................... 10 
 
 

Educating Applicants Concerning Debris Removal Operations............................... 12 
 
 

Initiating a Debris Removal Contract ....................................................................... 12 
 
 

The Results of Problems in Initiating Debris Collection Operations ....................... 16 
 
 

Conclusion ................................................................................................................ 17 
 
 

Recommendations..................................................................................................... 17 
 
 

Management Comments and OIG Analysis ............................................................. 18
 
 


Conducting Debris Operations...................................................................................... 18 
 
 

Debris Collection ...................................................................................................... 19 
 
 

Debris Volume Assessment at Collection Sites........................................................ 21 
 
 

Conclusion ................................................................................................................ 24 
 
 

Recommendations..................................................................................................... 25 
 
 

Management Comments and OIG Analysis ............................................................. 26
 
 


FEMA Management and Oversight.............................................................................. 27 
 
 

Management and Oversight Structure and Approach............................................... 28 
 
 

Surge Capacity Is Crucial ......................................................................................... 29 
 
 

Unclear and Ambiguous Guidance ........................................................................... 30 
 
 

No Substitute for FEMA “Boots on the Ground”..................................................... 32 
 
 

Delayed Project Closeouts Exacerbate Problems ..................................................... 33 
 
 

Developing a Performance Measurement Framework ............................................. 33 
 
 

Conclusion ................................................................................................................ 34 
 
 

Recommendations..................................................................................................... 34 
 
 

Management Comments and OIG Analysis ............................................................. 35 
 
 

Appendixes 

Appendix A: Purpose, Scope, and Methodology.......................................................37 
 
 

Appendix B: Management Comments on the Draft Report ......................................38 
 
 

Appendix C: Major Contributors to This Report ......................................................44 
 
 
Appendix D: Report Distribution ..............................................................................45 

Acronyms 

DAE Disaster Assistance Employee 

DHS Department of Homeland Security 

DR Disaster Declaration Number 

EMI Emergency Management Institute 

FEMA Federal Emergency Management Agency 

FY Fiscal Year 

GAO Government Accountability Office 

IMAT Incident Management Assistance Team 

OIG Office of Inspector General 

PA Public Assistance 

TAC Technical Assistance Contractor 
OIG
 
 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Federal Emergency Management Agency’s Public Assistance 

program has expended more than $8 billion over the past 11 years 

reimbursing applicants, primarily cities and counties, for removing debris 

resulting from natural disasters. In general, this has been a successful 

effort. Vast amounts of debris have been removed and disposed of, 

allowing communities to proceed toward recovery unencumbered by piles 

of debris. Better planning, contracting, and oversight of debris operations, 

however, could enable these operations to be conducted in a more costeffective manner. 

Debris planning can allow communities to be better prepared for a disaster 

by identifying debris collection and disposal sites, identifying potential 

debris contractors, and preparing debris removal contracts in advance of a 

disaster. Only a minority of states and local governments currently have 

such plans in place. A pilot program that operated in 2007–2008 was 

successful in encouraging the development of debris plans, but momentum 

has been lost since the Congressional authority for the pilot program 

expired. 

Decisions made in the first few days after a disaster are critical in 

determining the success of a debris removal operation. Despite improved 

federal and state efforts to ensure that local governments are prepared for 

debris removal operations, they are often unprepared. Qualified Federal 

Emergency Management Agency staff, advising on debris removal, can 

help local governments determine what needs to be done, but they are not 

always available when needed. Debris removal operations are frequently 

more expensive than necessary and would benefit from improved 

monitoring. 

The quality of management and oversight remains a key element in 

success or failure of the program. While the Federal Emergency 

Management Agency has made significant strides in this area, 

opportunities remain for further improvement. Federal disaster response 

teams need to address debris expertise. Debris removal guidance is often 

unclear and ambiguous. Finally, an integrated performance measurement 

system would provide federal and state officials and stakeholders with the 

data and tools to measure, analyze, and improve debris operations. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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Background 

One of the key challenges following a major natural disaster is the proper 

and timely management and disposal of disaster debris. Debris can 

include waste soils and sediment, vegetation, construction materials, and 

personal property, and can be commingled with a variety of hazardous 

wastes. This debris can overwhelm existing landfills and present daunting 

logistical challenges. The ability of residents to return and live in a safe 

and healthy environment depends on the quality of the debris response. 

The Federal Emergency Management Agency (FEMA), through its Public 

Assistance (PA) program,1

 provides funding and technical assistance for 

debris removal, implementation of emergency protective measures, and 

permanent restoration of eligible facilities and infrastructure. Detailed 

requirements exist to determine eligibility of debris removal work for 

federal reimbursement, but, in general, eligible activities must (1) be the 

direct result of a presidentially declared disaster, (2) occur within the 

designated disaster area, (3) be the legal responsibility of the applicant at 

the time of the disaster, and (4) be in the public interest. 

The primary responsibility for post disaster debris removal, including the 

management of debris removal and monitoring operations, rests with the 

affected states and communities. The capability to achieve this mission 

varies greatly across the Nation and is largely a function of experience, 

resources, and leadership at all levels. The state serves as the grantee for 

PA grants while the county or city receives funds as a subgrantee. A 

number of other entities, including federal agencies, private-sector 

contractors, nonprofit and voluntary organizations, and the citizenry at 

large all play key roles in removing disaster debris. Local governments 

manage the debris collection process. They can either perform debris 

collection work with local employees or use debris collection contractors. 

If contractors are used, their work and charges should be monitored to 

ensure the contract costs are eligible for FEMA funding and to reduce the 

likelihood of waste, fraud, and abuse. Monitors can be local government 

employees or can be provided by a monitoring contractor. 

Any debris removal operation has three primary phases: planning, 

initiation, and implementation. This report describes the major activities 

1

 The Robert T. Stafford Disaster Relief and Emergency Assistance Act, P.L. 93-288, as amended, 42 

U.S.C. § 5121 et seq. (Stafford Act) authorizes the FEMA Public Assistance Program to award federal 

funding to state and local governments, federally recognized tribes, and eligible private nonprofit 

organizations to assist them in their disaster response and recovery activities. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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occurring in each phase, along with our observations regarding FEMA’s 

performance in the management and oversight of each phase. 

Debris planning consists of actions conducted by a state or locality in 

advance of a disaster to prepare for an effective and efficient debris 

removal effort. Elements of a sound debris plan include a clear definition 

of roles and responsibilities of the major participants, an identification of 

debris staging and final disposal sites, a process for handling various types 

of vegetative and non-vegetative debris, a process for handling hazardous 

waste, and at least two prequalified contractors to remove debris. Plans 

should also address the roles of state, county, and municipal employees 

who may be engaged to provide direct labor support. 

Debris project initiation consists of activities conducted after the disaster 

to start debris removal. These activities, which have significant financial 

implications, may occur in a compressed and stressful period when search 

and rescue operations are under way and the community is struggling to 

provide basic services to citizens. Key activities in the initiation phase 

include: 

•	 Organizing government and contractor resources and personnel; 

•	 Conducting preliminary damage assessments and estimates; 

•	 Preparing and executing competitively bid contracts for debris 

removal and monitoring; and 

•	 Developing management and operational protocols and processes. 

The implementation phase consists of two primary work streams: debris 

removal and debris monitoring. Debris removal is generally performed by 

a combination of contractor and government personnel and equipment, 

and consists of removing and disposing of vegetative and non-vegetative 

debris in accordance with eligibility and procedural guidelines developed 

by FEMA. Debris monitoring may be likewise performed by some 

combination of contractor and government personnel and consists of 

verifying the eligibility, volume, and basis for cost of debris removal and 

disposal activities. 

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Table 1. FEMA expenditures or 

obligations for debris removal 

Removing debris is expensive; as 

table 1 shows, FEMA has 

expended or obligated more than 

$8 billion to reimburse applicants 

for eligible debris removal 

activities for fiscal years (FYs) 

2000–2010. The costs of debris 

removal are greater than 

represented in the table since this 

is the federal share. Most 

disasters require a 25% nonfederal (state and applicant) share 

toward the full cost of debris 

removal. However, under the 

Stafford Act there is flexibility 

when the severity of the disaster 

overwhelms the state, the 

applicant cost-share can, with 

Presidential authorization, be 

adjusted downward and in some cases can even be eliminated. 

Fiscal 

Year Total Expended or Obligated for 

Debris Removal($ millions) 

2000 $206.9 

2001 $376.3 

2002 $617.2 

2003 $212.6 

2004 $233.3 

2005 $1,316.3 

2006 $2,461.2 

2007 $753.9 

2008 $266.7 

2009 $1,347.3 

2010 $209.6 

 Total $8,001.3 

The Post-Katrina Emergency Management Reform Act of 20062 directed 

FEMA to conduct a pilot PA program to reduce the overall cost of federal 

public assistance to state and local governments, increase grant flexibility, 

and expedite assistance to eligible state and local governments. 

Participation by state and local governments in the program was 

voluntary. The pilot program included four key debris-related provisions: 

	 	 Provide grants on the basis of estimates for large projects up to 

$500,000; 

	 	 Provide an additional 5% federal cost share for applicants with 

FEMA-approved debris management plans in place; 

	 	 Allow applicants to retain the salvage value of recyclable debris; 

and 

	 	 Reimburse regular time salaries and benefits of permanently 

employed staff performing debris-related activities. 

FEMA operated the pilot program from June 1, 2007, through December 

31, 2008 when Congressional authority for the pilot program expired. 

2

 The Post-Katrina Emergency Management Reform Act of 2006 (P. L. 109-295), Title VI—National 

Emergency Management, Department of Homeland Security Appropriations Act of 2007. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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Results of Audit 

Debris Planning 

State and local governments are encouraged to plan for, and are 

expected to manage, their own debris removal operations 

following an emergency or major disaster, with eligible costs being 

reimbursable under the PA program. As part of debris planning, 

state and local governments are encouraged to prequalify local or 

regional debris removal contractors to ensure the immediate 

availability of coordinated debris removal support following a 

debris-producing event. Federal, state, and local officials agreed 

that another important element of debris planning and preparation 

is identifying debris disposal sites in advance. By developing a 

debris management plan, communities will be better prepared to 

address disaster-related debris in a time-efficient manner, thereby 

expediting the recovery process. Additionally, a sound and 

properly executed debris management plan should enhance an 

applicant’s ability to document its costs and reduce the time and 

administrative burden of applying for PA grant assistance. 

Figure 1. Nashville flooding, FEMA Disaster No. DR 1909 TN (Source: FEMA) 

To assist state and local governments in developing a debris 

management plan, FEMA provides training to state and local 

officials. Only a minority of states, most of them in hurricaneprone locations, currently have a plan in place. Most local 

governments also do not have such plans in place. FEMA does not 

determine whether a plan is approved or disapproved, as it did 

during the pilot program. However, FEMA continues to review 

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debris plans that are submitted to the regional offices. Regional 

and state officials said that confusion exists regarding FEMA’s 

role in approving plans, perhaps as a result of these changes. 

Pilot Program Impact on Planning 

FEMA’s pilot PA program included the provision of an additional 

5% federal cost share, not to exceed a total of 100%, to applicants 

having a FEMA-approved debris management plan and at least 

two prequalified debris and wreckage removal contractors 

identified prior to a disaster. To assist state and local governments, 

FEMA provided a debris management plan outline and the 

checklist that FEMA would use for plan approval. FEMA 

requirements did not include identifying disposal sites as part of 

the management plan’s content. Further, FEMA trained 3,409 

state and local officials in 21 states and three territories on the 

development of debris management plans in FY 2008 under the 

pilot program. 

Participating states said that having a debris management plan and 

prequalified debris contractors facilitated better-organized and 

managed debris removal operations. FEMA received feedback on 

the pilot program from regional, state, and local stakeholders, who 

said that the pilot program encouraged debris planning. The debris 

workshops and the increase in federal cost share provided 

incentives for states and localities to develop and maintain debris 

plans. One FEMA regional PA official described the mandated 

expiration of the pilot program as “the worst thing FEMA could 

have done,” noting that local jurisdictions were active in 

developing debris plans but lost interest when the program was 

terminated, and financial incentives and resources were withdrawn. 

A comprehensive debris management plan takes a significant 

amount of time to develop and implement at the local level. The 

planning provision of the pilot program was not widely used until 

later in the implementation phase; 180 of the total 234 project 

worksheets for planning were prepared during the last 4 months of 

the pilot program. Local officials said some FEMA regions were 

slow to process and approve the plans and many plans were, 

therefore, not approved during the pilot program. FEMA 

headquarters officials said that delays in approval were often due 

to the necessity for FEMA to work with some applicants to assist 

them in compiling a plan that would meet the criteria for approval. 

Additionally, many state and local officials said that they did not 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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have a major debris-generating event during the program, so they 

did not participate. 

Contractor Management Challenges 

Disaster planning and preparedness are essential in addressing 

disaster-related debris in a time-efficient manner. Also, 

prequalifying local or regional debris removal contractors ensures 

the immediate availability of coordinated debris removal support. 

These two elements assist communities not only in preparing for 

debris operations, but also in handling the large influx of potential 

debris contractors. These contractors arrive almost immediately 

after an event, often days or weeks before FEMA debris 

specialists. Without planning and FEMA debris policy knowledge, 

communities are not well prepared to control the contracting 

process. 

Certain contractors with experience in multiple disasters have 

learned how to “beat the system,” allegedly using FEMA logos on 

their personal items, making it appear that they are FEMA 

employees, and claiming to be “FEMA certified.” According to 

FEMA policy, FEMA does not recommend, pre-approve, or certify 

any debris contractor. 

Some contractors are adept at exploiting flaws in the system. 

Contractors were reported to “lowball” their bids and compensate 

by collecting ineligible debris, including debris well beyond the 

right-of-way, and even clear-cutting on public lands. Some 

contractors were reported to coordinate bids between companies. 

Others promote monitoring firms that are related to, or even owned 

by, their company. 

FEMA reimburses direct administrative costs incurred by grantees 

and subgrantees that are properly documented and directly 

chargeable for a specific project. This means that local 

governments can contract out the management of a debris removal 

project and be reimbursed at the cost-share rate established for the 

disaster declaration. Contractors promise local governments that 

they will maximize the money obtainable from FEMA and that all 

of the local government’s costs will be reimbursed if they are hired 

to handle all aspects of the debris operations. This presents an 

enticing arrangement for local governments because it is simple, 

and many local governments do not have the staff or funding to 

handle the operations on their own. As a result, administrative 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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costs can be disproportionately high as a percentage of total project 

cost. Several officials told us that administrative costs were 

“getting out of control.” 

The Impact of Debris Planning 

Tennessee was struck by severe storms, flooding, straight-line winds, and 

tornadoes beginning on April 30, 2010, and continuing until May 18, 2010. DR 

1909 was declared on May 4, 2010. 

Figure 2. Nashville flooding, FEMA Disaster No. DR 1909 TN (Source: FEMA) 

The Metro Nashville Office of Emergency Management had rewritten its local 

debris management plan, which included locations of staging and landfill sites, in 

2009. A draft contract had already been prepared when the May 2–3, 2010, 

flooding struck. The city sent the contract and plans to FEMA and the Army 

Corps of Engineers and received comments within hours. As a result, a contractor 

was in place within 3 days and debris removal started within 7 days after the 

event. The result of their efforts was effective and efficient debris removal at a 

reasonable cost. 

Conclusion 

Debris management plans help communities prepare for disasterrelated debris removal and ultimately enhance the recovery 

process. To be effective, however, these plans need to identify 

critical elements of the debris removal process, including the 

prequalification of contractors and the identification of disposal 

sites. Such plans need to be reviewed and approved in a timely 

manner. FEMA regional offices have not been clearly in charge of 

this role and some did not approve plans in a timely manner under 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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the pilot program. Since the states are the grantees for FEMA 

debris funding, which is sub-granted to counties and cities, it 

would be appropriate for the states rather than FEMA to approve 

local government debris management plans. It is also likely that 

the states could do so in a timelier manner. 

Recommendation 

We recommend that the Associate Administrator, Response and 

Recovery: 

Recommendation #1: 

•	 Provide a provision of an additional 5% federal cost share, 

not to exceed 100%, to applicants with a FEMA-approved 

debris management plan and at least two prequalified 

debris and wreckage removal contractors identified prior to 

a disaster. 

•	 Require disposal site identification to be part of the debris 

management plan. 

•	 Allow qualified states that have completed their own plan 

to approve local jurisdictions’ debris disposal plans. 

Management Comments and OIG Analysis 

FEMA concurs with the first and second parts of the 

recommendation. The agency is considering revisions to its 

regulations that would incorporate an increased federal share 

initiative and would require PA applicants to identify debris 

management sites and final disposal sites in their debris 

management plans in order to qualify for the increased federal 

share. FEMA is still considering the third part of the 

recommendation and will evaluate a significant role for states in 

the review and approval of debris management plans. 

We agree with the initiatives FEMA is considering to improve the 

debris planning process. We will determine the status of this 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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recommendation once we receive the detailed corrective action 

plan in FEMA’s 90 day letter. 

Initiating Debris Operations 

The decisions made in the first few days after a disaster are critical 

in determining how successful a debris removal operation will be. 

However, such decisions are made at a time when decision makers, 

primarily county and city officials, are fully occupied, if not 

overwhelmed, by more immediate problems such as assisting 

endangered residents, clearing access to hospitals and other vital 

routes, and restoring electricity, water, and other critical services. 

FEMA regulations allow for reimbursement of less restrictive time 

and materials procedures during the first 70 hours after a disaster. 

FEMA strongly encourages applicants to limit time and materials 

contracts to the first 70 hours, because after that initial period 

applicants should have enough data to competitively procure unit 

price or lump sum debris removal contracts. Applicants that 

choose to use time and materials contracts beyond 70 hours may 

jeopardize their funding from FEMA. In order to be eligible for 

reimbursement, applicants must satisfy PA eligibility criteria 

throughout the entirety of the debris removal operation. 

While local government officials repeatedly said how critical such 

reimbursement is to their often cash-strapped governments, many 

are not well prepared to comply with FEMA debris removal 

regulations. Poor preparedness could lead to decisions that waste 

significant amounts of funds, make part of debris removal 

operations ineligible for FEMA reimbursement, or delay debris 

removal. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Figure 3. Missouri ice storm, FEMA Disaster No. DR 1403 MO (Source: FEMA) 

Despite significantly improved FEMA and state efforts to ensure 

that local governments are prepared for debris removal operations, 

many local governments are not well informed concerning the 

procedures they need to follow to establish economical and 

regulation-compliant debris removal operations. Their contracts 

with debris removal firms are critical to determine whether 

operations will be efficient, economical, and compliant with 

regulations. However, local governments can not obtain FEMAapproved contracts to use as a model because FEMA policy does 

not provide for approved debris removal contracts. Debris 

estimates, which are important to obtain lowest-possible-cost 

contracts, are sometimes not reliable. Qualified FEMA staff to 

advise on debris removal are often not onsite early in the project 

when they are needed to advise on initiating operations. Local 

officials said the debris removal program regulations are lengthy, 

complex, and difficult to master, and FEMA staff does not always 

provide a consistent interpretation of debris removal regulations. 

For example, this can be a problem when FEMA staff turnover 

results in local officials being told that the procedures that had 

already been approved are no longer acceptable. As a result, local 

governments often conduct debris removal operations that are not 

as economical as they could be and do not comply with 

regulations. Consequently, local funds and FEMA program funds 

are wasted on unnecessary or inappropriate debris removal 

expenditures, and local governments do not receive, or are directed 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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to return, FEMA funds to which they believed they would be 

entitled. 

Educating Applicants Concerning Debris Removal Operations 

FEMA and state officials emphasized that a key to effective debris 

removal operations is providing information and training to state 

and local governments prior to disasters. FEMA offers debris 

management courses at the Emergency Management Institute 

(EMI), and FEMA regional officials have conducted regional 

training for those unable to attend EMI courses. Local officials 

said these courses were helpful. Others said they had been able to 

attend FEMA regional disaster conferences, which were responsive 

to their needs. 

Many of the state disaster officials we interviewed said they also 

provide training at the state level in debris removal operations, and 

that FEMA is willing to participate in such training upon request. 

Several local government officials said their funding and staffing 

have been reduced in recent years and it is difficult for them to 

attend training conferences. Some said they had studied FEMA 

manuals concerning debris removal practices and FEMA policy; 

however, others are not prepared for the decisions they must make 

in the immediate aftermath of a disaster. 

Initiating a Debris Removal Contract 

While some local governments can conduct their own debris 

monitoring and debris removal efforts, many must rely on 

contractors, especially for larger disasters. In general, to be 

eligible for FEMA assistance, operations must be conducted under 

a contract that complies with FEMA requirements. To accomplish 

this, some states have initiated statewide contracts for debris 

removal and monitoring, others provide local governments with 

model contracts and have authorized pre-disaster contracting, and 

others provide local governments with a list of state-recommended 

contractors. 

In some states, however, local governments have none of these 

advantages when faced with initiating debris removal. Many have 

not developed a debris removal plan, do not have a contract ready 

to offer to bidders, and have had no prior contact with possible 

contractors. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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Figure 4. Dangerous debris situation (Source: FEMA) 

Local officials said they have had up to 90 contractors contact 

them in the immediate aftermath of a disaster. Some contractors 

travel to the disaster site and repeatedly contact local officials, 

encouraging officials to immediately contract with their firm. 

Others falsely claim to be FEMA certified or even FEMA related. 

Many offer to manage the entire disaster response operation and 

claim to be able to obtain the maximum amount of FEMA funding 

for disaster operations. Some not only offer to remove debris but 

also provide monitors to oversee their own efforts. In the face of 

such efforts, local governments need quick advice and assistance. 

In spite of these obstacles, most of the local officials we 

interviewed were able to get satisfactory contractors through a 

contracting process they considered acceptable. However, many 

have asked for a FEMA-approved standard contract to assist them 

in ensuring that their contracting was in full compliance with 

FEMA requirements. FEMA officials responded that it is not 

appropriate for FEMA to provide a preapproved contract. The 

local governments, not FEMA, are contracting with the debris 

removal and monitoring firms, and FEMA is not a party to the 

contract. However, FEMA will review contracts that local 

governments develop, and the Army Corps of Engineers (Corps) 

has several sample contracts available on its website. A city that 

used the contract review process said that both FEMA and the 

Corps provided comments on its proposed contract within hours of 

receiving it. 

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Debris estimating—assessing the total volume of debris that has to 

be dealt with before it is actually collected—is an art and science 

that is still developing. Results have been mixed, however. 

Officials in one county said while they had received an estimate of 

100 tons of vegetative debris that they used as the basis for 

soliciting proposals, the actual amount collected turned out to be 

450 tons. Had the competing contractors known that there would 

be so much volume, they might have submitted lower bids per ton, 

and both FEMA and the community would have realized 

significant savings. 

The rules governing debris removal and monitoring are lengthy 

and complex. The FEMA Debris Management Guide, FEMA P325, covers all the major aspects of debris removal. The guide is 

149 pages long plus 92 pages of appendices. Some of the rules, 

such as those governing the eligibility of damaged trees (leaning 

trees and hanging branches), are complex and even confusing. A 

local government official faced with initiating debris removal 

operations in the wake of a disaster does not have the time to 

master all of these rules. And even those who have studied the 

guidelines find that some of their questions are not addressed. 

Figure 5. Leaning trees from FEMA Disaster No. DR 1682 WA (Source: FEMA) 

State and local officials described debris removal as a “gray area” 

in contracting and said some of the debris policies are ambiguous. 

Some unclear areas concerned the eligibility of tree removal or 

saving operations; assisting the elderly and disabled in getting their 

debris out to the curbside; what the allowable preference for local 

contractors can include; whether gated communities and areas 

without public roads, such as trailer parks, can be made eligible; 

and whether funding new landfills for dump sites is an eligible 

expense. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Figure 6. Removing an eligible hanging branch (Source: FEMA) 

State officials said that FEMA needs to do a better job of keeping 

all involved informed concerning new and evolving FEMA 

policies concerning debris removal. FEMA does provide a threepage fact sheet, “Debris Removal Applicant’s Contracting 

Checklist,” that can offer timely assistance in initiating a quick 

response, but it cannot cover all of the debris removal program’s 

rules and requirements. 

Qualified FEMA debris removal staff can be of great assistance in 

informing local officials of the FEMA rules and requirements and 

interpreting the more ambiguous requirements. In some cases, 

however, FEMA debris management specialists were not onsite 

until 3 or more weeks after the disaster, when contracts had already 

been awarded and contractors were hauling away debris. While 

some FEMA staff had arrived earlier, they did not have the 

necessary debris specialist skills. FEMA officials conceded that 

the FEMA staff who respond early to disasters, such as the 

Incident Management Assistance Teams, do not necessarily have 

adequate knowledge of debris removal rules, regulations, and 

procedures. 

Because the rules governing debris removal are lengthy, complex, 

and sometimes ambiguous especially when determining vegetative 

debris eligibility, different FEMA officials sometimes give local 

officials different interpretations of these rules. This can lead to 

debris removal actions that some FEMA officials had considered 

appropriate later being ruled inappropriate, and even to a partial 

loss of FEMA funding. Local officials reported that sometimes 

FEMA employees onsite cannot agree on the eligibility of a 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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procedure, such as removing a tree, and have to halt operations 

until a supervisor can be called to the site. 

In other cases, FEMA staff turnover at a disaster site, combined 

with the ambiguity of some of the rules, has resulted in a 

community being told that the procedures that had been approved 

were no longer acceptable and had to be changed. Perhaps of most 

concern to local officials, since it can lead to denial or return of 

funds, is when procedures that FEMA onsite officials have 

approved are later ruled unacceptable by FEMA regional officials, 

or by state or federal auditors. 

The Results of Problems in Initiating Debris Collection 

Operations 

Problems in initiating debris collection operations can lead to 

significant and costly problems during collection efforts, including 

the ineligibility of claimed costs and subsequent demands for 

repayment of federal funds. State and local officials said that some 

requests for proposals were issued that could have resulted in 

contracts allowing contractors to monitor their own performance. 

In one case, a debris collection contractor was allowed to hire its 

own subsidiary company as a debris monitoring contractor. In 

some cases, tree removal actions were either unnecessarily 

expensive or later found to be ineligible. In another case, state 

prisoners were used to help the elderly and disabled to get their 

debris out to curbside, and the cost of this assistance was 

disqualified. 

A review of 36 recent OIG audits of debris removal subgrantees, 

generally counties and cities, showed the wide range of adverse 

effects and possible requirements for repayment that can result 

from problems during the initiation of debris removal operations: 

	 	 In eight cases, contracts were awarded without having 

been properly competed, or had major changes without 

the required competition. 

	 	 In seven cases, tree removal operations (primarily 

leaning trees and hanging branches) were improperly 

conducted or accounted for. 

	 	 In five cases, ineligible debris, such as from private or 

ineligible property, was charged under FEMA accounts. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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	 	 In five cases, ineligible contracts, such as time and 

materials contracts, were used after the first 70-hour 

eligibility period. 

	 	 In four cases, local governments charged ineligible 

local employee expenses (regular or straight time as 

opposed to the eligible overtime expenses) to FEMA. 

	 	 In two cases, accounting was inadequate and/or 

contractors had overbilled local governments, which 

had passed the excessive charges on to FEMA. 

Conclusion 

Local governments need clear and consistent guidance governing 

the initiation of debris removal operations. Without such 

guidance, contracts can be awarded that result in higher costs to 

both the local government and FEMA, or can even result in 

communities having to return funds to FEMA. Debris collection 

rules and regulations need to be clear enough that state and local 

stakeholders can understand them readily and obtain consistent 

interpretations from FEMA officials. FEMA needs to continue to 

enhance ongoing training and outreach concerning debris 

collection rules and procedures, highlighting changes and new 

developments. 

Recommendations 

We recommend that the Associate Administrator, Response and 

Recovery: 

Recommendation #2: To the greatest extent possible, provide 

applicants, FEMA employees, and other appropriate officials clear 

and unambiguous rules, guidance, and procedures for debris 

operations, including checklists and sample contracts. 

Recommendation #3: Work with the states to provide a variety of 

readily accessible training concerning rules, guidance, procedures, 

and recent developments in debris removal, contracting, and cost 

containment. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Management Comments and OIG Analysis 

FEMA generally concurs with both of these recommendations, but 

does not agree that providing sample contracts is appropriate. 

FEMA officials fear that doing so may create a false expectation of 

reimbursement of costs even if applicants fail to follow 

competitive bidding procedures, the work performed is ineligible, 

or the contract is not monitored effectively. In addition, FEMA 

officials note that they are not able to account for the varying 

procurement requirements among states and localities. FEMA is 

committed to continue providing guidance for debris operations; 

the debris estimating and monitoring guides have just been issued, 

and the Debris Management Guide is being revised. FEMA is 

continuing to make training available and is currently developing a 

computer-based training course on debris management plan 

development. 

We agree with the steps FEMA has taken and is taking to provide 

guidance and training concerning debris operations. We 

acknowledge FEMA’s concern with providing sample contracts 

and, in light of the new guidance that has been issued, we will 

reevaluate this portion of our recommendation. We will 

determine the status of these recommendations once we review the 

detailed corrective action plan in FEMA’s 90 day letter. 

Conducting Debris Operations 

Debris removal operations, as categorized by FEMA, occur in two 

phases: (1) initial debris clearance activities necessary to eliminate 

life and safety threats and (2) debris removal activities as a means 

to recovery. The initial debris clearance is an immediate post 

disaster effort that is frequently conducted by state and local 

employees and volunteers, but can also be conducted by 

contractors. The subsequent debris removal operations constitute 

the bulk of FEMA-funded activities. Extensive FEMA rules and 

regulations govern these efforts, and millions of FEMA dollars are 

expended in even the smaller categories of disasters. The vast 

majority of funds are expended on contracted firms that collect 

debris, haul it to staging areas, and subsequently remove debris 

that has been processed and sorted by type to landfills and other 

sites. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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Other debris removal, frequently conducted by the same 

contractors, includes removing hanging branches and hazardous 

leaning trees. These operations are customarily reimbursed on a 

unit price basis (as are “white goods” such as refrigerators) and 

also constitute a major expense category in debris removal 

operations. The third major expense is for monitoring. Monitors, 

either local government employees or employees of a monitoring 

contractor, oversee a contractor’s collection operations and the 

volume (and hence eligibility for payment) of the debris that 

contractors’ trucks haul to collection or disposal sites. 

Most of the officials reported that debris is normally collected in a 

timely manner, enabling communities to proceed with recovery 

efforts. However, debris collection and monitoring efforts are 

often costly and many contractors are overpaid. Changes in 

FEMA policies could improve the cost-effectiveness of the debris 

removal program and make the program easier for local officials to 

manage. 

Debris Collection 

Figure 7. Nashville flooding, FEMA Disaster No. DR 1909 TN (Source: FEMA) 

To be eligible for FEMA-funded collection, debris must be the 

result of a presidentially declared disaster, located within the 

disaster area on the eligible applicant’s (usually a city or county) 

improved property or right-of-way, and the legal responsibility of 

the applicant. FEMA allows applicants to charge FEMA for 

collecting debris from private residences if debris has been brought 

to curbside or is otherwise placed on the local government’s rightFEMA’s Oversight and Management of Debris Removal Operations 
 

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of-way. Debris brought to the curbside in gated communities, 

trailer parks, or other communities where the streets do not have 

city or county right-of-way status does not qualify for collection 

except in cases where removal is necessary to provide access for 

emergency vehicles. 

Figure 8. Nashville flooding, FEMA Disaster No. DR 1909 TN (Source: FEMA) 

Some contractors, in order to increase their payments under their 

debris removal contract, will collect ineligible debris, such as 

debris not located on the right-of-way, and haul it to the collection 

site for payment. This can happen at any time, but it is more likely 

to occur as the recovery effort is winding down and eligible debris 

is less plentiful. We were told of cases where contractors had even 

gone onto state lands or into neighboring counties or parishes to 

collect ineligible vegetative debris. Some contractors, who are 

paid for the mileage their trucks accumulate during the operations, 

have also been accused of putting on unnecessary miles, and even 

of driving in circles. Monitors can prevent or report such ineligible 

debris collecting and mileage, but only if they are present at the 

time of the collections. It is expensive to have an individual in 

every one of the contractor’s trucks, as some communities have 

done. Also, FEMA officials have advised that “debris monitors 

should never be in a debris removal contractor’s truck”. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Figure 9. Debris-monitoring tower, FEMA Disaster No. DR 1791 TX (Source: 

FEMA) 

Local government officials said that the eligibility rules for 

collections can appear inequitable to their constituents and difficult 

to enforce. For example, residents of trailer courts, gated 

communities, and other less accessible communities may not 

receive the same level of debris removal services as more 

accessible locations. Elderly and disabled residents who cannot 

haul debris to curbside may miss out on FEMA-reimbursed debris 

removal services. 

The rules governing leaning trees and hanging branches are 

complex and difficult to interpret. We were told that some 

contractors make unnecessary multiple cuts on a damaged tree to 

increase their payments. It was also alleged that during one recent 

disaster, a contractor cut hundreds of ineligible trees and claimed 

them for reimbursement. Tree operations are frequently a source 

of disputes between applicants and FEMA, and even FEMA 

employees may not agree on eligibility. 

Debris Volume Assessment at Collection Sites 

FEMA officials said most of the excessive costs in the debris 

program are the result of overstated volumes of collected debris. 

Most debris collection is paid for on a volume basis. The 

following occurs at the collection site: 

• The contractor’s trucks arrive at a collection site. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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• A monitor (usually located in a monitoring observation 

tower at the debris management site) assesses what 

percentage of the truck’s volume is full of debris. 

•	 This percentage is then multiplied by the truck’s declared 

maximum volume (as previously certified and announced 

on a placard on the side of the truck) to determine the 

volume of debris to be credited for the load. 

•	 This amount is noted on a load ticket. 

•	 Copies of the load ticket are given to the truck driver and 

to accounting. 

Figure 10. Unloading vegetative debris, FEMA Disaster No. DR 1909 TN (Source: 

FEMA) 

Problems arise because load tickets often go through many hands 

as they are routed from the debris disposal site to the applicant. A 

recent DHS investigation determined that four individuals from a 

debris-monitoring company conspired to falsify debris load tickets, 

causing FEMA to pay more than $700,000 in fraudulent costs. 

FEMA, state, and local government officials all have monitoring 

responsibilities, but the applicant has the primary responsibility. 

Officials from all of these organizations said there are numerous 

ways to cheat this volume-based system. Some contractors put 

false bottoms in their trucks after the load capacity has been 

certified to overstate credited volumes. Contractors switch or alter 

placards to make it appear that the truck was certified for a larger 

volume than was actually the case. A former debris contractor 

employee reported that he had witnessed trucks being issued 

fraudulent load certificates. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Monitors may overstate the percentage load of trucks entering the 

staging area or landfill. This can occur because of a need for 

training or capability on the part of the monitor, intimidation of the 

monitor by the debris hauler, or collusion between the monitoring 

company and the hauling company. These factors can overstate 

volume estimates by 20% or more. That this is occurring can be 

shown by the fact that the volume percentages assessed are 

frequently lower whenever the operation is observed by state, 

local, or federal employees than when only the truck drivers and 

monitors are at the site. 

One experienced state official said when he was working as a 

temporary employee in an out-of-state disaster, he observed that 

237 trucks in succession had been recorded as 100% full prior to 

his arrival at a busy monitoring tower. While he was personally in 

the tower, the monitors recorded loads at 60% to 70%; after he left, 

the load assessments went back to 100%. This official took photos 

and measurements at the dump sites and landfills and came up with 

lower percentages than the monitors. He also said that towers 

sometimes remained unoccupied for up to 45 minutes. 

Another official reported he had seen trucks consistently being 

rated as being 80% or more full when they “were not nearly that 

full.” He said that two colleagues also witnessed similar incidents. 

A FEMA after-action report for Hurricanes Gustav and Ike 

estimated that FEMA may have overpaid $20 million for debris 

removal and disposal because qualified monitors were not present 

at key times and debris load volumes were consequently 

overestimated. 

Federal, state, and local officials reported that options are available 

for reducing these problems. One state’s officials said they “do not 

ever” contract for monitoring services; instead they use local 

employees who are perceived as less vulnerable to intimidation or 

collusion. In states that use private sector monitoring firms, 

government officials need to ensure that monitors are competent, 

properly trained, and aware of their rights and responsibilities. 

FEMA, state, and local officials could oversee all aspects of debris 

operations to minimize fraud and excessive charges. The problem 

here, of course, is cost. Monitoring costs in operations we 

reviewed ranged from 20% to 33% of the total cost of debris 

operations. Other reviews have reported monitoring costs of as 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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much as 50% of total debris costs. Having enough FEMA, state, 

or local officials present to monitor the monitors increases the 

direct cost of oversight even more. In such cases, oversight may 

cost more than the operations being overseen. 

Figure 11. Truck scale in action (Source: FEMA) 

Conclusion 

Debris removal is generally performed effectively and in a timely 

manner, but not necessarily at the lowest possible cost. Debris 

monitoring presents opportunities for improvement, as current 

methods leave FEMA and its applicants vulnerable to potential 

waste, fraud, and abuse. 

The effectiveness and integrity of monitoring activities could be 

improved by having local governments perform monitoring, 

especially if they are sharing in collection costs. This could be 

funded by authorizing FEMA payment for force account labor as 

was done under the pilot program. Paying for local government 

employees to address leaning trees and hanging branches could 

also provide a more secure, lower cost approach to handling these 

potentially complicated and difficult-to-control efforts. 

If contracted monitors are used, local officials must ensure that the 

monitoring company does not have an inappropriate relationship 

with the debris collection contractor, and that monitors are 

qualified, trained, and accurate. FEMA should ensure that in cases 

where the federal government is reimbursing 100% of all debris 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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costs, additional federal oversight is in place, since the incentives 

for local oversight have been diminished. 

One option for reducing collection and monitoring costs is to pay 

contractors based on the weight of debris collected rather than 

volume. Trucks could be weighed on truck scales when they arrive 

at the collection site and again when they depart, with the 

difference being an accurate measure of the weight of the debris. 

Local officials reported that this system worked well and that truck 

scales could be rented easily and at a reasonable cost for the period 

that collection centers were operating. No system is totally 

foolproof. Drivers could still inflate debris weights by wetting 

down the debris prior to taking it to the collection site or even by 

adding gravel, but these actions should be apparent at the 

collection site. 

Making weighing systems the basis of an automated load ticket 

accounting system could further reduce the possibility of fraud and 

result in improved and better controlled accounting systems for 

debris collection costs. 

Recommendations 

We recommend that the Associate Administrator, Response and 

Recovery: 

Recommendation #4: Provide force account labor reimbursement 

to cover local governments’ costs of employing workers to monitor 

debris collections and to remove leaning trees and hanging 

branches, and encourage them to undertake such responsibilities. 

Recommendation #5: Strengthen the requirements involved in 

monitoring contracts to ensure that no relationships exist between 

debris collection contactors and monitoring contractors, and that 

monitors are properly trained and capable of independent and 

accurate performance. 

Recommendation #6: Explore advanced technologies to 

supplement monitoring staff such as GPS in trucks or surveillance 

cameras. 

Recommendation #7: Assess weight-based rather than volumebased payment for debris collection and investigate whether such 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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systems could be efficiently linked to debris payment accounting 

systems. 

Management Comments and OIG Analysis 

FEMA generally concurs with all of these recommendations, but 

notes that the Agency is not a party to contracts between applicants 

and contractors. Therefore, the Agency cannot require the use of 

advance technology as monitoring tools. FEMA acknowledges 

that weight-based monitoring and payment systems have some 

advantages over volume-based systems, but said these are not 

immune from potential waste, fraud, and abuse and still require 

proper monitoring and oversight to be effective. FEMA is 

considering revisions to its regulations that would incorporate the 

force account straight time labor reimbursement component of the 

PA Pilot Program. FEMA is updating its guidance in both the 

Debris Contracting Guidance Fact Sheet and the Debris 

Monitoring Guide to stress that debris monitors should not have a 

relationship with debris removal contractors. FEMA stays abreast 

of current technologies in order to provide appropriate technical 

assistance to applicants when they are considering technology 

applications as part of their monitoring operations. FEMA also 

can provide appropriate funding, such as for the rental of 

temporary scales, during debris operations. 

We agree with the steps that FEMA is taking to improve the 

conduct of debris operations. We understand that FEMA is not a 

party to contracts between applicants and contractors and cannot 

require the use of advance technology as monitoring tools. 

However, FEMA can encourage the use of cost-effective advance 

technology for monitoring, such as weight-based monitoring and 

payment systems, by publicizing and encouraging the use of these 

systems including offering financial incentives. We will determine 

the status of these recommendations when we receive the detailed 

corrective action plan in FEMA’s 90 day letter. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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FEMA Management and Oversight 

FEMA’s management and oversight of debris operations is subject 

to many of the overall challenges associated with managing the 

complex and geographically diverse Public Assistance program. 

For example, our December 2009 report3 concluded that the 

implementation of FEMA’s PA program was hindered by untimely 

funding determinations, deficiencies in program management, and 

poorly designed performance measures. The report identified 

opportunities for improvement in a number of areas relevant to 

debris removal operations: 

	 	 Inconsistent and tardy eligibility determinations 

	 	 Inaccurate costs and scopes of work in initial project 

worksheets 

	 	 Undue delays and deferrals in making decisions regarding 

cost overruns and scope changes prior to closeout 

	 	 Insufficient detail regarding scopes of work 

	 	 Inappropriate negotiations with subgrantees on eligibility 

	 	 Failure to accept subgrantees’ supporting documentation 

	 	 Repetitive documentation requests 

	 	 Unreasonable cost estimates 

The report concluded that these program management deficiencies 

are caused principally by turnover, inexperience, and lack of 

training within FEMA’s disaster workforce. We reported that 

these capability gaps are exacerbated by the need for a clear and 

consolidated body of PA guidance, and highlighted debris issues 

specifically in the following summary: 

FEMA’s policy on debris removal is unclear and thus open to 

interpretation. As a result, some communities have been denied 

eligibility for debris removal costs, while others have received 

reimbursements for identical costs. About $180 million in debris 

removal costs after the 2004–2005 disasters in Florida 

demonstrate the significance of clarifying the debris removal 

policy. 

3

 Assessment of FEMA’s Public Assistance Program Policies and Procedures, OIG-10-26, December 2009. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Our current review confirmed some of these earlier observations 

but also identified additional opportunities for improvement in 

management and oversight of the debris program. 

Since large-scale debris events are fortunately rare, plans, systems, 

and processes cannot be easily tested in a “real-time” environment. 

Many of our observations and findings regarding FEMA’s 

management and oversight of debris operations reflect the 

perceptions of frontline personnel and have not been validated in 

an actual debris-generating event. 

Management and Oversight Structure and Approach 

FEMA manages and oversees debris operations through multiple 

components, including a headquarters policy office, 10 regional 

offices, and disaster-specific field command organizations. 

FEMA’s Public Assistance Division, Policy and Regulations 

Branch, in Washington, DC, develops and oversees the 

implementation of the full range of policies and regulations. Two 

employees in this branch work exclusively on debris removal 

policies and regulations. Branch employees also develop training 

materials for use nationally to create awareness and understanding 

of current and emerging debris management issues. Headquarters 

staff occasionally deliver this training in person or in coordination 

with FEMA regional staff. 

A Debris Task Force is appointed for each major disaster. The 

Task Force is based at the Joint Field Office and comprises a 

Debris Team Leader, one or more Debris Technical Specialists, 

and one or more Debris Monitoring Specialists. The Task Force 

often includes personnel from other federal and state agencies. It 

is charged with establishing a framework for FEMA assistance for 

debris operations and creating a historical record. It also creates a 

specific debris strategy for major events. We reviewed the strategy 

documents for Hurricane Ike and the 2010 central Tennessee 

floods, and they were comprehensive and actionable. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Although FEMA regions normally send one or two permanent, 

full-time employees to an event (who may include debris 

specialists from another FEMA region), most of the Debris Task 

Force is comprised of FEMA disaster assistance employees 

(DAEs). As one FEMA regional official told us, “The DAEs do 

the heavy lifting.” Problems arise since DAEs are not always 

debris specialists, whereas applicants depend almost solely on their 

advice. Regional officials said the DAE debris expertise is thinning 

due to turnover and burnout. 

Surge Capacity Is Crucial 

As discussed earlier, decisions made in the first few days after a 

disaster are critical in determining the success of a debris removal 

operation. This decision making takes place at a time, however, 

when state and local officials, the primary decision makers, are 

overwhelmed by more immediate problems such as assisting 

endangered residents, clearing access to hospitals and other vital 

routes, and restoring electricity, water, and other critical services. 

The consensus among regional, state, and local officials 

interviewed is that FEMA must do a better job of providing rapid 

and sufficient surge resources with the capability, skills, and 

authority to drive key initiation and early implementation 

decisions. As the entity that funds from 75% to 100% of eligible 

debris removal costs, FEMA has a vested interest in ensuring 

optimal decision making and project control. Further, given the 

complex web of organizations that have a role in a typical 

disaster—state and local government agencies, other federal 

agencies, private sector contractors, nonprofit organizations, and 

voluntary organizations—there is no substitute for clear, focused 

leadership. 

If FEMA cannot deliver the needed technical expertise, the odds 

increase that costs and eligibility of debris removal will become 

problematic during the recovery phase of the disaster. 

Communities may be forced to evaluate and select debris removal 

and monitoring contractors without possessing the necessary 

expertise or familiarity with FEMA contracting guidance and 

requirements. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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An effective surge can help mitigate the impact of a lack of predisaster debris planning. Cedar Rapids, IA, for example, did not 

have a debris plan in place prior to major spring flooding in 2008, 

but the debris removal operations went well. A key was the direct 

technical consulting support for the grantee and subgrantees before 

contracts were awarded. A joint team of FEMA and Iowa 

Homeland Security debris specialists assisted in this effort. FEMA 

Region VII staff said “getting in early” is the key to helping 

communities determine whether contactors are providing 

reasonable cost estimates. 

Unclear and Ambiguous Guidance 

Many officials expressed frustration over unclear and ambiguous 

debris regulations and policies, which hinder effective debris 

removal and disposal, and create misunderstanding and distrust 

between FEMA and state and local governments. 

This ambiguity stems not from a lack of effort by FEMA—in fact, 

the current Public Assistance Debris Management Guide4

 is over 

200 pages including appendices, and covers eligibility, planning, 

and operations in some depth—but rather from the complexity and 

inherent uncertainty of debris removal and disposal. The 

interpretation of how to apply a particular regulation for a specific 

debris occurrence varies greatly depending on who is doing the 

interpreting. The consequences for FEMA and the grantees can be 

profound, with audits disallowing millions of dollars of costs that 

FEMA personnel authorized earlier. 

4

 FEMA Public Assistance Debris Management Guide, FEMA-325, July 2007. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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Figure 12. Examples of recent debris-related FEMA publications 

One state emergency management office we interviewed was in 

the process of responding to a request to repay millions of dollars 

for debris removal costs from a 2002 ice storm. This office, with a 

PA staff of three, said debris removal was “the biggest gray area in 

contracting” and “the toughest nut to crack—a constant source of 

headaches for us.” This office reported that its applicants had 

“passed every decision through layers of FEMA approvals” at the 

time the original disaster cleanup was under way, and it was only 

informed years later that certain vegetative debris removal was 

ineligible for reimbursement. 

Several applicants have encountered problems with tipping fees.5 

FEMA reimburses tipping fees to compensate applicants for the 

5

 Tipping fees are fees that landfills charge to cover their operating and maintenance costs. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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diminished capacity of a landfill resulting from the disposal of 

disaster-generated debris. FEMA disallowed $7.7 million in 

tipping fee charges in an Alabama county based on the argument 

that the applicant based tipping fees on the volume of raw 

vegetative debris instead of the diminished volume of burned 

debris. FEMA challenged tipping fees in a Tennessee county 

because different rates had been applied for in-county and out-ofcounty debris removal contractors per the county’s customary 

practice. We reviewed the latest FEMA guidance and found only 

two limited references to tipping fees; neither addressed the above 

issues. 

Recent controversies in Kentucky and New York have centered on 

the appropriateness of debris removal costs; in both cases FEMA 

disputed the costs paid to contractors for debris removal even 

though the costs were arrived at through competitive bidding. 

While competitive procurement usually establishes that the debris 

removal rates are reasonable, it does not establish that a contractor 

removed only eligible debris. Nor does it ensure that proper 

documentation exists to substantiate an applicant’s claim. 

No Substitute for FEMA “Boots on the Ground” 

There is widespread agreement among state and local officials that 

a visible FEMA presence at a disaster site has a direct impact on 

reducing fraud and abuse. A commonly cited example involves 

load calls from debris monitors in towers. Debris specialists and 

public assistance officials said when no FEMA employee is 

present, incoming trucks are virtually all recorded at or near 100% 

capacity, but as soon as a FEMA employee or official 

representative is in the tower, the load calls drop to 60% to 70%. 

These anecdotal observations were supported by findings from a 

FEMA after-action report: 

During the early stages of this disaster, the limited 

availability of DAEs and TACs [Technical Assistance 

Contractors] prevented FEMA from manning the debris 

towers. Due to this applicant monitors made higher calls. 

This resulted in a 15 to 20% increase in debris costs 

statewide. Most of the calls were between 90 to 100%. If 

available personnel could be quickly deployed FEMA 

would have saved $20 million on this disaster alone.6 

6 FEMA Remedial Action Issue 1791-I-47, Event # 1781-DR-TX, Texas Hurricane Ike, March 31, 2010. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Delayed Project Closeouts Exacerbate Problems 

A key debris management and oversight issue is the need to 

estimate, scope, and close out projects appropriately and timely. 

Numerous officials reported that waste, fraud, and abuse tend to 

multiply toward the end of debris projects, when the debris mission 

starts winding down and contractors become “more creative in 

filling their trucks.” This is a theme that cuts across all PA 

program areas and has been addressed by us, the Government 

Accountability Office (GAO), and others. Our recent report7 

identified a number of recommendations for closing out disasters 

more promptly and efficiently. 

Developing a Performance Measurement Framework 

Although FEMA spends hundreds of millions of dollars a year to 

support, plan, and implement debris removal programs across the 

country, there is no integrated performance measurement 

framework to manage and provide oversight over this complex 

activity. A contractor has been hired to develop an improved 

tracking system. Ideally, program managers would have access to 

information to measure, analyze, and improve program 

performance. An integrated performance measurement system 

would enable managers to compare performance in different 

regions, under different scenarios, to provide fact-based 

information to partners and stakeholders regarding costs, 

contractor and partner performance, effectiveness, efficiency, and 

other factors determined to be important to future decision making. 

The need for a performance measurement framework surfaced at a 

number of states and localities. Officials said it would be helpful 

to have historical and comparative cost data to assist in the 

evaluation and selection of debris removal and monitoring 

contractors. FEMA is working with a contractor to develop a cost 

model database that states and communities can use to compare 

prices of specific items, which will make the market for debris 

removal and monitoring services more open and transparent. 

Another area where better data is needed involves comparing the 

use of local government employees with the use of contractors to 

perform various activities. Many officials believe that the overall 

cost of debris removal and monitoring would be reduced by using 

7

 Opportunities to Improve FEMA’s Disaster Closeout Process, OIG-10-49, January 2010. 

FEMA’s Oversight and Management of Debris Removal Operations 
 

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local government employees and reimbursing municipalities for 

this direct labor cost for a limited period. 

Conclusion 

The quality of FEMA’s management and oversight, especially 

following major disasters that overwhelm local capacity, is perhaps 

the key element in the success or failure of debris operations. 

Debris events are complex and involve multiple private and public 

sector entities working together in an often chaotic post disaster 

environment. FEMA has made significant strides toward 

improving its management and oversight capacity, but 

opportunities remain for further improvement. These opportunities 

involve the staffing, structure, and design of key management and 

oversight activities. Debris expertise is not always clearly evident 

in FEMA’s early response teams assigned to a disaster. FEMA 

personnel may not always be positioned in locations to optimize 

their oversight and control functions. Debris guidance is at times 

incomplete, unclear, or ambiguous despite FEMA’s attempts to 

address all aspects of debris removal. A more principles-based 

rather than rules-based regulatory framework that allowed for 

increased local decision making could be an improvement over the 

present system. Finally, an integrated performance measurement 

framework would give FEMA and its stakeholders data and tools 

to measure, analyze, and improve debris operations. 

Recommendations 

We recommend that the Associate Administrator, Response and 

Recovery: 

Recommendation #8: Modify disaster assistance employee 

deployment processes to ensure that Incident Management 

Assistance Teams and other FEMA first responders include one or 

more debris specialists with the experience and management skills 

to assist communities in the crucial early stages of planning and 

implementing debris removal activities. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

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Recommendation #9: Continue to refine cost data to determine 

whether having qualified FEMA or local personnel present in all 

debris towers, major staging areas, and on the ground as roving 

monitors during significant debris-generating events would be 

cost-effective. 

Recommendation #10: Develop a performance measurement that 

FEMA headquarters and regional personnel can use to measure, 

analyze, and improve debris program performance. This should be 

designed for easy analysis of cost and performance data across 

regions, disasters, and contractors. 

Management Comments and OIG Analysis 

FEMA generally concurs with Recommendations #8 and #10 but 

does not concur with Recommendation #9. FEMA supports the 

intent of Recommendation #8 but believes the way to address this 

issue is to ensure that there are adequate numbers of experienced 

employees in the disaster workforce, rather than modifying the 

deployment process. FEMA will continue its efforts to increase 

the size of its resource pool and speed the deployment of technical 

expertise to support applicants during the early stages of planning 

and implementation of debris removal operations. 

With regard to Recommendation #9, FEMA considers its current 

monitoring program to be the most prudent use of FEMA’s 

resources and taxpayer dollars and believes it avoids unnecessary 

duplication of effort. Due to applicants using different monitoring 

strategies, FEMA believes it is difficult to determine the cost 

savings and would likely prevent the performance of a conclusive 

analysis of the cost-effectiveness of an increased monitoring 

presence as compared to FEMA’s current approach. 

For Recommendation #10, FEMA agrees with the need to develop 

a performance measurement system, with cost and performance 

data, to measure, analyze and improve debris program 

performance. FEMA is currently developing a Quality 

Assurance/Quality Control tool that provides a framework to 

measure quality and performance throughout the entire PA 

program. In addition, FEMA has worked to improve debris 

estimating and to develop automated or digital systems that will 

improve the collection of debris data in the field. FEMA is 

currently working to develop a cost database of unit price debris 

FEMA’s Oversight and Management of Debris Removal Operations 
 

Page 35
 
removal costs to assist PA staff and applicants when determining 

whether or not a cost is reasonable. 

We agree with the actions FEMA has taken and is taking to 

develop performance measurement systems including usable cost 

and performance data as recommended in Recommendation #10. 

We believe such a refinement of cost data should eventually result 

in systems that allow enhanced decision-making such as the 

assessment of whether increased monitors would be cost-effective 

as recommended in Recommendation #9. FEMA officials would 

then have a sound basis for asserting that their current monitoring 

practice is the most prudent use of FEMA’s resources and taxpayer 

dollars or whether increased (or reduced) monitoring might be 

more fiscally sound. While we agree that FEMA should continue 

efforts to have adequate numbers of skilled and experienced 

employees in the disaster workforce, we believe there is a clear 

need for the deployment process to be adjusted to ensure that 

FEMA early responders include individuals with adequate 

experience and management skills to assist communities in the 

crucial early stages of planning and implementing debris removal 

activities, as is recommended in Recommendation #8. We will 

determine the status of these recommendations once we receive the 

detailed corrective action plan in FEMA’s 90 day letter. 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 36
 
 

Appendix A 

Purpose, Scope, and Methodology 

The purpose of this review was to determine whether opportunities 

exist to improve FEMA’s management and oversight of debris 

removal operations following major disasters. Specific areas we 

examined included regional, state, and local debris planning; 

contractor selection, utilization, and management; debris removal 

and disposal operations; debris-monitoring operations; and general 

program management and reporting functions. 

We interviewed officials from FEMA headquarters, 10 FEMA 

regions, 10 states and 5 municipalities that had recently 

experienced a major debris-generating event, other federal 

organizations, public policy organizations, and academia. We 

reviewed all GAO and OIG reports issued in the past 5 years for 

audits and reviews that included debris management within their 

scopes of work. 

We conducted fieldwork in the District of Columbia and 

Tennessee. We judgmentally selected Tennessee to review debris 

activities related to flooding in Nashville and other areas in central 

and western Tennessee. The May 3–5, 2010, Nashville flooding 

(FEMA DR-1909 TN) was the largest debris event during the time 

we were conducting fieldwork. 

We researched federal laws, regulations, policies, guidance, 

published reports, and other information related to FEMA’s Public 

Assistance program with an emphasis on Category A debris 

removal eligibility and costs. 

We conducted our review under the authority of the Inspector 

General Act of 1978, as amended, and according to the Quality 

Standards for Inspections issued by the President’s Council on 

Integrity and Efficiency (now the Council of the Inspectors 

General on Integrity and Efficiency). 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 37
 
 

U.S. O~purm'l'nt \lr IIO"'eland Seeu

500 C Slre,·!. SW

\\'",h"'lIlon.l)(: 2().j72

DEC 2 3 2010

Mr. Matt Jadacki

Assistant Inspector Inspector General General

Office of Emergency Management Oversight

Office of Inspector General

U.S. Depanment of Homeland Security

Washington, DC 20528

Re: Office of Inspcctor General Draft Report: FEMA s Oversight and Ma/lagement o.rDebri~·

Remova! Operaliolls

Dear Mr. Jadacki:

The Department of Homeland Security'S Federal Emergency Management Agency (FEMA)

appreciates the opportunity to review and respond to the Office of Inspector Gencnll (010) draft

report, FEMA 's Ovcrsiglll and MCII/agcmell! ojDebris Remova! OperaliulJ.I. FEMA is actively

resolving the issues identified in the audit.

It should be noted that various sections of the draft report do not accurately characterize FEMA's

responsibilities in relation to debris removal operations. The draft report often implies that

FEMA controls and manages debris removal operations. However, the management of debris

removal and monitoring operations is the primary responsibility ofstate, tribal and local

governments (applicants). The PA Program is a supplemental assistance grant program, through

which FEMA reimburses applicants for their eligible debris expenses. FEMA also provides

applicants with operational and eligibility guidance and technical assistance with respect to

debris removal activities.

In recent years, FEMA has provided additional guidance to PA applicants on debris removal

operations and stressed the import<lnce of debris management planning. From June 1,2007

through December 31,2008, FEMA implemented the PA Pilot Program. authorized by Congress,

which included incentives for the development of debris management plans, debris recycling,

and the use of local government stafr(force account labor) to perfoml dcbris removal and

monitoring operations. In 2007, FEMA iSSlled the Debris ManagemeJII Guide (FEMA-325),

which is currently bemg updated. FEMA also updated its debris contracting guidance with the

September 27, 2010, issuance of Recovery Fact Sheet 9580.201, Dcbris COllfracring Guidance,

which includes a sample bid sheet. FEMA issued the Deb,.i~· Monitoring Guide (FEMA 327)

electronically in December 201 0 to provide applicants with additional guidance. Hard copies of

the Guide will be available for distribution in January 20 II. It should be noted th<lt FEMA

encourages participation from its stakeholders by issuing drafts ofits debris policies and

publications for public comment prior to finalization. FEMA is also developing a computer

based course on debris management planning in order to make this training more accessible and

to reach more PA applicants.

Appendix B 

Management Comments on the Draft Report 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 38
 
 

The OIG makes II recommendations in its draft report. FEMA's responses to those

recommendations follow:

Recommendation #1:

• Provide a provision of an additional S% federal cost share, not to exceed 100%, to

applicants with a FEMA-approved debris management plan and at least two

prequalified debris and wreckage removal contractors identified prior to a disaster.

FEMA concurs with this part ofthe recommendation. However, current FEMA regulations do

not authorize the PA Program to provide applicants with an increased federal share above the

established cost share for each disaster declaration. FEMA is considering revisions to its

regulations that would incorporate the increased federal share initiative implemented as part of

the PA Pilot Program.

• Require disposal site identification to be part of the debris management plan.

FEMA concurs with this part ofthe recommendation. FEMA's Debris Management Guide

(FEMA 325), and its debris training courses stress the importance ofdisposal site selection as

part ofdebris management planning. During the PA Pilot Program, FEMA required PA

applicants to identify debris management sites (DMS) and final disposal sites in order to receive

the increased federal share. FEMA did not approve debris plans that did not identify a DMS or

disposal site. As mentioned previously, FEMA is considering revisions to its regulations to

incorporate the increased federal share component ofthe PA Pilot Program, which would require

PA applicants to identify DMS and final disposal sites in their debris management plans.

• Allow qualified states that have completed their own plan to approve local

jurisdictions' debris disposal plans.

FEMA is considering this part ofthe recommendation. FEMA encourages states to promote the

development and maintenance oflocal debris management plans. As part ofour considerations

to revise FEMA regulations to incorporate the increased federal share component ofthe PA Pilot

Program, FEMA will consider a significant role for states in the review and approval ofdebris

management plans.

R«ommendation #2: To the greatest extent possible, provide applicants, FEMA

employees, and other appropriate officials clear and unambiguous rules, guidance, and

procedures for debris operations, including checklists and sample contracts.

FEMA concurs with this recommendation with the caveat below. FEMA has provided, and will

continue to provide, debris operations guidance to FEMA PA staff, to Grantees, to applicants,

and to the general public. This includes the Debris Management Guide (FEMA 325), which is

currently under review to ensure that this guidance remains current, comprehensive, and

incorporates lessons learned. FEMA is providing additional guidance on debris estimating and

Appendix B 

Management Comments to the Draft Report 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 39
 
 

monitoring in the Debris Estimating Field Guide (FEMA 329) and the Debris Monitoring Guide

(FEMA 327) both of which were issued in December 20IO. FEMA also performs regular

periodic reviews of all PA policies and guidance to ensure that they are up to date, accurate, and

appropriately address current policy issues.

FEMA does not agree, however, that providing sample contracts is appropriate. Applicants are

responsible for procuring debris contracts and FEMA is not a party to those contracts. By

providing sample contracts, FEMA may create a false expectation ofreimbursement ofcosts

even ifapplicants fail to follow competitive bidding procedures, the work performed is

ineligible, or the contract is not monitored effectively. In addition, FEMA cannot account for the

varying procurement requirements among states and localities. FEMA provides PA applicants

guidance on contract procurement in Recovery Fact Sheet 9580.201, Debris Contracting

Guidance. This Fact Sheet includes recommended provisions for debris removal and debris

monitoring contracts, includes a standard bid sheet, and includes guidance on evaluating

proposed equipment and labor rates. Additionally, FEMA reviews proposed debris contracts for

PA applicants, upon request.

Recommendation #3: Work with the states to provide a variety of readily accessible

training concerning rules, guidance, procedures, and recent developments in debris

removal, contracting, and cost containment.

FEMA concurs with this recommendation. FEMA currently has, and will continue to make,

debris training available through the Emergency Management Institute (EMI), FEMA Regional

Offices, and online. Current debris courses include the week long "Debris Management" (E202)

course at EMI, a one-day Debris Management Plan Development course conducted throughout

the Nation upon request, and the Independent Study Course "Introduction to Debris Operations in

FEMA's Public Assistance Program" (IS~632) available on CD-ROM. FEMA is currently

developing a computer-based training course on debris management plan development. States

may request additional training through their respective FEMA Regional Offices.

Recommendation #4: Provide force account labor reimbursement to cover local

governments' costs of employing workers to monitor debris collections and to remove

leaning trees and hanging branches, and encourage them to undertake such

responsibilities.

FEMA concurs with this recommendation. FEMA encourages PA applicants to use force account

labor to conduct their debris removal operations. FEMA currently reimburses PA applicants for

force account overtime hours. FEMA also reimburses applicants for the use of "applicant~owned"

equipment. Current FEMA regulations do not authorize the PA Program to reimburse force

account straight time hours. Under the PA Pilot Program, FEMA had the authority to fund an

applicant's force account straight time for debris removal operations. FEMA is considering

revisions to its regulations that would incorporate the force account straight time reimbursement

component ofthe PA Pilot Program.

Recommendation #5: Strengthen the requirements involved in monitoring contracts to

ensure that no relationships exist between debris coUection contaetors and monitoring

Appendix B 

Management Comments to the Draft Report 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 40
 
 

contractors, and that monitors are properly trained and capable ofindependent and

accurate performance.

FEMA concurs with this recommendation. FEMA updated its debris contracting guidance in the

September 27,2010 Recovery Fact Sheet 9580.201, Debris Contracting Guidance. The Debris

Monitoring Guide (FEMA 327) also provides applicants with monitoring guidance. Both

documents stress that debris monitors should not have a relationship with debris removal

contractors. Upon request from states, FEMA will provide debris monitoring training as part of

the technical assistance that FEMA offers to PA applicants.

Recommendation #6: Explore advanced technologies to supplement monitoring staffsuch

as GPS in trucks or surveillance cameras.

FEMA concurs with the recommendation in that FEMA supports applicants' use ofrelevant

technology to improve their monitoring operations and may provide reimbursement for utilizing

such technologies. However, debris monitoring is the primary responsibility ofPA applicants.

FEMA does not concur with the recommendation to the extent that FEMA is not a party to

contracts between applicants and contractors, and carmot require the use of advance technology

as monitoring tools. FEMA stays abreast ofcurrent technologies in order to provide appropriate

technical assistance to applicants when they are considering technology applications as a part of

their monitoring operation.

Recommendation #7: Assess weight-based rather than volume-based payment for debris

collection and investigate whether such systems could be efficiently linked to debris

payment accounting systems.

FEMA generally concurs with the recommendation, as FEMA currently accepts the use of

weight-based systems as a basis for reimbursement. FEMA acknowledges that weight-based

monitoring and payment systems have some advantages over volume-based systems. However,

as stated in the draft report, weight·based systems are not immune from potential waste, fraud, or

abuse and both weight-based and volume-based systems require proper monitoring and oversight

to be effective. FEMA can provide funding for the use oftemporary scales during debris

operations and encourages applicants to utilize such systems where appropriate.

Recommendation #8: Modify disaster assistance employee deployment processes to ensure

that Incident Management Assistance Teams and other FEMA first responders include one

or more debris specialists with the experience and management skills to assist communities

in the crucial early stages of planning and implementing debris removal activities.

FEMA concurs with the objective ofthe recommendation. Shortly after an emergency or

disaster declaration, and in some cases in advance, FEMA deploys Debris Task Force Leaders

and establishes debris task forces to coordinate FEMA's debris operations. FEMA debris

specialists and monitors are also deployed to disaster areas in advance or shortly after a

declaration. FEMA also augments its field staff with debris contracting and monitoring

specialists from the U.S. Anny Corps of Engineers. Each ofthese individuals works closely with

impacted states and local applicants to provide them with technical assistance. However, from

Appendix B 

Management Comments to the Draft Report 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 41
 
 

FEMA's perspective, the best way to address this issue is to ensure that there are adequate

numbers ofskilled and experienced employees in the disaster workforce, rather than modifying

deployment processes. FEMA will continue its efforts to increase the size ofits resource pool

and speed the deployment oftechnical expertise to support applicants during the early stages of

planning and implementing debris removal operations.

Recommendation #9: Continue to refme cost data to determine whether having qualified

FEMA or local personnel present in aU debris towers, major staging areas, and on the

ground as roving monitors during significant debris-generating events would be costeffective.

While FEMA fully supports appropriate and adequate monitoring as part ofdebris removal

operations, FEMA does not concur with this recommendation. FEMA advises PA applicants

that the size ofthe monitoring operation should be commensurate with the size and needs ofthe

debris removal operations. Applicants utilize different monitoring strategies based on the type of

contract, the geographic area and the types and quantity ofdebris. When using unit price

contracts for example, applicants should have monitors present at the pick-up, staging, and

disposal sites. FEMA employs a roving debris monitor methodology wherein debris monitors

make regular, repeated and random checks ofdebris operations. FEMA then focuses additional

attention and effort on debris operations with identified non-eompliance issues. FEMA also uses

additional debris monitors for special debris operations, such as the removal of contaminated

debris or debris removal from private property or waterways. This is the most prudent use of

FEMA's resources and taxpayer dollars and avoids unnecessary duplication of effort.

FEMA does not intend to station monitors at aU pick up, staging, or disposal sites as a standard

operating procedure. In addition, due to the difficulty in detennining cost savings from that

approach, it is unlikely that FEMA can perfonn a conclusive analysis to detennine ifthat

approach is more cost effective than FEMA's current practice.

Recommendation #10: Establish clear requirements for prompt and efficient project

closeouts.

FEMA responded to this recommendation in "Opportunities to Improve FEMA 's Disaster

Closeout Process, OIG-IO-49, January 2010. ,. FEMA has since developed a Project Closeout

Standard Operating Procedure (SOP) for use by PA staff at Joint Field Offices. However, the

draft report on debris confuses the completion ofa debris removal operation with project

closeout. These are two discrete actions. Project closeout refers to the reconciliation of project

estimates, data, documentation and invoices with the approved scope of work. It is an

administrative function that does not impede the completion of an applicant's debris removal

operation. In accordance with Title 44, Code of Federal Regulations 206.204, "Project

Perfonnance", debris removal must be completed within six months ofthe emergency or disaster

declaration unless there are extenuating circumstances for which the impacted state or FEMA

grant an extension. The draft report suggests that delayed project closeout encourages debris

removal contractors to remove ineligible debris. However, this is not the case and adequate

debris monitoring by the applicant prevents the removal ofineligible debris. Additionally,

FEMA encourages the use of unit price and lump sum contracts that pay contractors based on the

Appendix B 

Management Comments to the Draft Report 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 42
 
 

amount ofdebris removed rather than the use oftime and materials contracts which pay

contractors based on the number of hours worked. The use of unit pricc or lump sum contntcts

along with debris monitors reduccs thc amount ofincligible debris collected. Time and materials

contracts that do not have "tennination for cause" or "not to exceed'· clauses encourage debris

removal contractors to work slower or to remove ineligible debris.

Recommendation #J 1: Dcvelop:1 pcrformance measurcmcnt that FEMA hcadquarters

and regional personncl call usc to measurc, analyzc, and improve debris program

performance. This should be designed for casy analysis of cost and performance data

across regions, disasters, and contractors.

FEMA a!,'TCCS with this approach in general. FEMA is cUlTently developing a Quality

Assurance/Quality Control (QAlQc) tool that provides a fntmcwork to measure quality and

performance throughout the entire PA Program, not just individual categories of work. The

QAlQC tool is bascd on tcn quantitative perfonnance metries and one qualitative pccr rcview

process, designed to measure key aspects of PA pcrformancc against ccrtain goals or

benchmarks. These metrics, which are standardized across the pro!:>'Tam, are intended to provide

a consistent method ofmeasuring quality and performance across thc program, and to align

efforts at all levels with the PA mission and needs ofPA stakeholders. This tool will be applied

to FEMA's PA Program, including for projects (hat reimburse applicants for the cost oftheir

debris operations, across all FEMA Regions and disasters.

In addition, FEMA is continually working to improve PA Program perfonmmce. For example,

FEMA has developed a Debris E~·fimalillg Field Guide to promote consistent debris estimating.

FEMA is also working with the U.S. Anny Corps of Engineers to enhance its hurricane debris

estimating modules. Additionally, FEMA is developing intemal sollware to improve its debris

estimating capacity. Since 2005, FEMA has worked to develop automated or digital systems that

will improve the collection of debris data in the field. FEMA is currently working to develop a

cost database of unit price debris removal costs to assist PA staff and llpplicllnts when

dctemlining whether or not a cost is reasonable. All ofthesc effol1S are aimed at improving,

streamlining and expcditing the PA process with rcgard to debris removal operations.

Once again, thank you for (he opportunity to comment on the draft report. I look fonvard to

working with you on future homeland security and emergency m;magement engagements.

Sincerely,

David J. Kaufman

Director

Office of Policy Planning and Analysis

Appendix B 

Management Comments to the Draft Report 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 43
 
 

Appendix C 

Major Contributors to this Report 

Kaye McTighe, Director 

 Donald Norman, Auditor 

Craig Anderson, Auditor 

Stuart Josephs, Auditor 

Kimberly Gilliland, Program Analyst 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 44
 
 

 

 

 

Appendix D 

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, Management 

Federal Emergency Management Agency 

Administrator 

Chief of Staff 

Assistant Administrator, Response and Recovery 

Chief Financial Officer 

Director, Office of Management 

FEMA Audit Liaison (Project Code 10-012-EMO-FEMA) 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

FEMA’s Oversight and Management of Debris Removal Operations 
 
 

Page 45
 
 

(a) Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General 

(OIG) at (202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web 

site at www.dhs.gov/oig. 

(b) 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. 
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.