HMA Guide: Footnote 365

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365. Under 44 CFR § 80.5(a)(4), FEMA is responsible for “making determinations on the compatibility of proposed uses with the open space purpose, in accordance with 44 CFR § 80.19.” FEMA determined that grading and seeding is generally not a separate use; rather, grading and seeding of the building site is a necessary and reasonable part of a demolition.

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