B.2. Mitigation Reconstruction

Mitigation reconstruction is the construction of an improved, elevated structure on the same site where an existing structure and/or foundation has been partially or completely demolished or destroyed. These projects include either total or partial demolition of the structure and result in the construction of code-compliant and hazard-resistant structures on elevated foundation systems. Mitigation reconstruction projects are not allowed in the regulatory floodway or Coastal High Hazard Area (Zones V, VE and V1-V30 on FIRMs). Mitigation reconstruction projects must be designed using the best available data, including Base Flood Elevations, if available. Activities that result in the construction of new living space at or above the Base Flood Elevation will be considered only when consistent with the mitigation reconstruction requirements.

Mitigation reconstruction projects are eligible under HMGP, HMGP Post Fire, BRIC and FMA. Mitigation reconstruction projects cannot be combined with other activity types in the same project subapplication to ensure the subapplication scope, schedule and budget adhere to program requirements.

Eligible activity categories under HMGP, HMGP Post Fire, BRIC and FMA are summarized in Table 20.

Eligible mitigation reconstruction costs are limited to a $220,000 federal share per structure. Some eligible activities, such as administrative allowances and permitting allowances, permitting fees and accessible facilities or ramps compliant with applicable accessibility standards^[422] when required or requested by the owner, do not need to be included in the $220,000 maximum federal share.^[423]  Required accessibility standards may include construction of ADA-compliant access facilities or ramps when an owner or a member of the owner’s family has a permanent disability and a physician’s written certification. An ADA-compliant access to ingress/egress is allowable for assistance unless specified otherwise in applicable state or local codes. If ramps are not technically feasible, a mechanical chair lift may be installed.

The activities that are eligible as part of a federal award in mitigation reconstruction are divided into three categories: consultation and project scoping, pre-construction activities, and construction activities. The activities in each category that are eligible to the extent reasonable and necessary to perform the project purpose and their assistance limits are identified in Table 21.

Mitigation reconstruction projects include either total or partial demolition of the site. All demolition debris shall be removed and taken to an approved landfill. The following must be considered during demolition:

• Asbestos and lead-based paint must be dealt with appropriately.
• Existing associated structures, garages and above-grade concrete slabs must be removed.
• Abandoned septic tanks, if not removed, must be emptied and the floors and walls must be cracked or crumbled to prevent the tank from holding water. The tank must be filled with sand or another clean fill.
• All foundation and basement walls not included in the project footprint shall be removed to at least one foot below the finished grade of the site or as necessary to construct the new foundations.
• All basements not included in the mitigation reconstruction project footprint shall be filled with compacted clean fill. Prior to filling, basement floors should be provided with a minimum 1-foot-diameter hole in the floor to allow for drainage.
• Only trees that restrict the mitigation reconstruction work on any structure may be removed.
• Any abandoned utilities shall be terminated at least 2 feet below the finished grade of the site.
• Any abandoned wells shall be capped, and associated components removed.
• All disturbed areas must be graded and leveled; the top 12 inches of soil should be capable of supporting vegetation in areas not included in the reconstructed footprint.

Table 20: Eligible Mitigation Reconstruction Activities

Activity	HMGP	HMGP Post Fire	BRIC	FMA
Project scoping	Yes	Yes	Yes	Yes
Pre-construction activities	Yes	Yes	Yes	Yes
Construction activities	Yes	Yes	Yes	Yes
§  Structural shell	Yes	Yes	Yes	Yes
§  Interior partitioning	Yes	Yes	Yes	Yes
§  Utility equipment	Yes	Yes	Yes	Yes
§  Fixtures	Yes	Yes	Yes	Yes
Demolition and removal activities	Yes	Yes	Yes	Yes

Table 21: Eligible Mitigation Reconstruction Activities and Assistance Limits

Activity	Subject to Federal Share Assistance Limit of $220,000
Project scoping
Structure verification (e.g., size of pre-existing structure)	No
Preliminary elevation determination	No
Phase I environmental site assessment	No
Engineering feasibility study (e.g., Can an existing structure be elevated? Is mitigation reconstruction feasible?)	No
BCA	No
Title search (e.g., ownership verification)	No
Pre-construction activities
Site survey (i.e., boundaries, elevation)	No
Soils/geotechnical testing; testing for asbestos and lead-based paint	No
Archaeological assessment Phase I	No
Local, state and federal permitting (e.g., EHP and USACE)	No
Architectural/engineering design/plans/specifications	No
Plan review	No
Construction activities
Permitted disposal of routine asbestos, lead-based paint and household hazardous wastes incidental to demolition	No
EHP mitigation as required as a special award condition	No
Demolition/removal	Yes
Erosion control/grading/drainage	Yes
Utility connections	Yes
Landscaping for site stabilization (e.g., seeding)	Yes
Walkways and driveways not required to meet accessibility standards	Yes
Elevated foundation construction	Yes
Inspection of foundation system	No
Structural shell
Framing	Yes
Exterior doors	Yes
Windows (includes protection)	Yes
Access/egress	Yes
Exterior classing	Yes
Roofing	Yes
Interior partitioning
Drywall	Yes
Trim	Yes
Painting	Yes
Interior doors	Yes
Insulation	Yes
Utility equipment
Heating, ventilation and air conditioning	Yes
Water/wastewater plumbing	Yes
Electrical panel and wiring	Yes
Hot water heater	Yes
Fixtures
Sinks/toilets/showers	Yes
Lighting	Yes
Cabinets and countertops	Yes
Flooring	Yes
Building inspections	No
Certificate of occupancy	No
Final Elevation Certificate (FEMA Form 086-0-33)	No
Owner displacement costs	No
Tenant displacement costs	No
Prepare and record flood insurance requirement (after construction finalized)	No

Some mitigation reconstruction activities and their associated costs are not eligible. Ineligible costs include but are not limited to the following:

• Landscaping for ornamentation (e.g., trees, shrubs).
• Decks and garages not included as part of the foundation system.
• All construction activities not specifically noted in the HMA Guide and not specifically approved by FEMA in advance.
• Site remediation of hazardous materials.

A general list of ineligible activities is included in Part 4.

Applicants and subapplicants must demonstrate that mitigation projects are cost-effective. Projects must be consistent with Part 5.

Mitigation reconstruction projects in the SFHA may use the $205,000 pre-calculated benefit for elevations. For details on this pre-calculated benefit, refer to B.3.2.4.1. Pre-Calculated Benefits for Elevation. For up-to-date information on the dollar value of the pre-calculated benefit, refer to the FEMA “Benefit-Cost Analysis” webpage.

FEMA limits the federal cost share of mitigation reconstruction project to $220,000 per structure. However, the costs captured in the BCA must reflect the total project cost required to complete the mitigation activity, not just the federal share.

Projects must be consistent with Part 4. Mitigation projects funded by HMA programs must be both feasible and effective at mitigating the risks of the hazard(s) for which the project was designed. A project’s feasibility is demonstrated through conformance with accepted engineering practices, established codes, standards, modeling techniques or best practices.

All mitigation reconstruction activities must be completed in accordance with the latest published editions of the International Codes and Federal Flood Risk Management Standard requirements. FEMA will use the latest published edition of American Society of Civil Engineers (ASCE)/Structural Engineering Institute (SEI) Standard 24, Flood Resistant Design and Construction (referred to as ASCE 24), or its equivalent as the minimum design criteria for all HMA-assisted mitigation reconstruction projects in flood hazard areas.

FEMA will use the latest published edition of ASCE 24 or its equivalent as the minimum design criteria for all HMA-assisted structure mitigation reconstruction projects in flood hazard areas. These flood hazard areas include floodways, coastal high-hazard areas and other high-risk flood hazard areas such as alluvial fans, flash flood areas, mudslide areas, erosion-prone areas and high-velocity areas. ASCE 24 addresses design and construction requirements for new buildings and Substantial Improvements to existing buildings (including repair of substantial damage) located, in whole or in part, in flood hazard area. ASCE 24 sets forth requirements for elevation, foundation designs, enclosures below elevated buildings, materials, wet and dry floodproofing, utility installations, building access and miscellaneous structures (e.g., decks, porches, patios, garages, chimneys and fireplaces, pools and above- and belowground storage tanks).

In addition, all mitigation reconstruction projects in flood hazard areas must also comply with the requirements established by the Federal Flood Risk Management Standard, conform to local floodplain regulations, and be permitted by the local floodplain administrator. All other applicable state and federal permits must also be obtained.^[424] Refer to Part 4.I for more information about these requirements.

FEMA published Guidance for Applying ASCE 24 Engineering Standards to HMA Flood Retrofitting and Reconstruction Projects (Nov. 2013) to assist applicants with the practicalities of how to apply the latest published edition of the ASCE 24 to their projects. ASCE/SEI24 applies to both new construction and substantial improvements.

The height to which a foundation can be constructed is a key factor in determining feasibility. Assistance in evaluating flood mitigation techniques can be found in FEMA 551, Selecting Appropriate Mitigation Measures for Floodprone Structures (March 2007). All proposed mitigation measures in FEMA 551 must be consistent with other HMA program criteria, such as eligible activities.

FEMA developed guidance for designing appropriate foundations based on the requirements of the International Codes and other applicable coastal construction standards. That guidance is included in FEMA P-550, Recommended Residential Construction for Coastal Areas: Building on Strong and Safe Foundations, Second Edition (Dec. 2009), which also includes sample foundation design calculations and drawings and detailed descriptions of the considerations for determining the feasibility of constructing to the required height. Although FEMA P-550 was developed in response to reconstruction needs after Hurricane Katrina, the design solutions can be used in coastal and non-coastal flood zones. FEMA P-550 recommends that users choose the appropriate foundation by following the Foundation Selection Decision Tree and that the sample designs be used for a maximum height of 8 feet for a closed foundation and up to 15 feet for an open foundation. A licensed design professional should be consulted to determine feasibility for residential structures with required foundation heights that are greater than 15 feet.

Mitigation reconstruction projects must be designed and constructed to the minimum standard as established by the requirements of the latest published editions of the International Codes. Structures, including all parts and appurtenances, must be designed and constructed to safely support all loads, including dead loads, live loads, roof loads, floor loads, wind loads, flood loads, snow loads, seismic loads and combinations of loads expected to be imposed on the structure as defined in the codes and related documents referenced in the codes. The construction of structures must result in a system that provides a complete load path capable of transferring all loads from the point of origin through load-resisting elements to the soils supporting the foundations.

One- and two-family dwellings must be designed and constructed to meet, at a minimum, the requirements of the latest published editions of the International Code Council (ICC) International Residential Code and ASCE 24. The standards include ICC Appendix G to the International Building Code (IBC), Flood Resistant Construction, for all occupancies including residential, commercial and other occupancies. The latest published edition of the International Codes will be the acceptable requirement if the jurisdiction has not adopted a consensus-based code or if the adopted code is older than the two latest published editions of the applicable International Codes.

Multi-family dwellings must be designed and constructed to meet, at a minimum, the requirements of the most recently published editions of the International Codes. These codes are the minimum applicable requirement until and unless a subsequent edition of that code is adopted by the governing jurisdiction. For purposes of this program, the absence of an adopted building code in a participating jurisdiction or a jurisdiction’s use of a building code that does not meet the International Codes’ requirements will not relieve the subapplicant from meeting the minimum design and construction requirements.

Installation of manufactured homes must follow regulations and guidance provided by the Department of Housing and Urban Development and the state administering agency. In addition, for installations in the SFHA, the flood provisions in the latest published edition of National Fire Protection Association (NFPA) 225, Model Manufactured Home Installation Standard, are the minimum requirement. This document details the standards for preparing sites and foundations on which manufactured homes are installed and the procedures for on-site installation of homes.

FEMA provides additional guidance, including recommended prescriptive pre-engineered foundation design in FEMA P-85, Protecting Manufactured Homes from Floods and Other Hazards, Second Edition (Nov. 2009). FEMA P-85 provides a best-practices approach in reducing damage from natural hazards.

Project construction documents, including design drawings and specifications, must be signed and sealed by a design professional licensed in the state the project is to be constructed in. The documents must also be certified for compliance with the codes, standards and minimum construction requirements specified in the HMA Guide. Construction documents must be produced prior to the start of construction but are not required for submittal as part of an application. The construction documents must include a statement from a design professional (i.e., a licensed architect or licensed professional engineer in the state the project is located in) that the design meets or exceeds the applicable most recently published editions of the International Codes. Construction documents based on standard details developed by a manufacturer or material supplier, including framing members, framing connections and roofing, and siding or appurtenance fasteners must be signed and sealed by a design professional licensed in the state the project is constructed in.

All subapplications submitted to FEMA must meet the EHP criteria in Part 4. All subapplications must provide the information described in Part 6 so that FEMA may perform the EHP review.

The Mitigation Reconstruction-Required Information for EHP Review FEMA job aid lists the documentation needed for projects for FEMA to complete the EHP compliance review process.

Mitigation projects sited within the SFHA are eligible only if the jurisdiction is participating in the NFIP. For FMA only, all properties included in a subapplication for mitigation reconstruction assistance must be NFIP-insured at the time of the opening of the application period. The flood insurance policy must be maintained throughout the period of performance and for the life of the structure. For more information, refer to Part 4.J.

For structures in the SFHA at the completion of the project and all structures receiving FMA regardless of location in the SFHA, flood insurance must be maintained for the life of the property.^[425] For more information, refer to Part 4.J.

All subapplications submitted to FEMA must meet the eligibility criteria in Part 4. All subapplications must have a scoping narrative in accordance with Part 6. Project-specific criteria are highlighted below.

FEMA may request additional information after the subapplication has been submitted to ensure all necessary information is received. However, all information required by the regulations and the HMA Guide must be received before an assistance decision and award or final approval can be made.

For mitigation reconstruction projects, the subapplication must include the following:

• In the mitigation activity section of the subapplication, an explanation of why the subapplicant has chosen mitigation reconstruction instead of the other available activity types.
• Latitude/longitude to the nearest sixth decimal place, site photographs, site maps, and project plans and specifications with the location of the structure clearly labeled on a FIRM.
• An activities description (as part of the scope of work) referencing industry standards or project plans and specifications.

All subapplications must include a line-item breakdown of all anticipated costs.

Subapplicants may apply for subrecipient management costs to cover administrative costs. Management costs must be included in the subapplication budget as a separate line item. More information about the requirements for management cost requests can be found in Part 13.

A detailed project budget shall be prepared by or under the supervision of the licensed design professional responsible for project design. Details pertaining to the project budget, such as submittal format, cost ranges, preparation requirements and source documentation are included in Part 6.

Each project requires a project budget as part of the technical and cost-effectiveness evaluation process. The project budget must include all reasonably anticipated project costs, including direct costs associated with project scoping and construction and closeout activities. The project budget should also be based on standard-grade construction.

Federal share assistance will be estimated and obligated on a per-square-foot basis; reimbursement will be in a manner consistent with standard recipient procedures. Based on the foundation type and required elevation height, the applicant or subapplicant must develop a square-foot cost for each potential combination of structure characteristics. All structures of the same type within a subapplication will have costs allocated at the same square-foot rate. Subapplicants will identify the type and number of structures of each possible combination to be included in the proposed project.

For cost-estimating purposes, the breakdown of structure types is based on the following structure and foundation characteristics:

• Structure type:
  • One story.
  • Two story.
• Foundation type:
  • Open foundation.
  • Closed foundation.
• Foundation height:
  • 0 to 5 feet.
  • 5 to 10 feet.
  • 10 to 15 feet.
  • Over 15 feet.

Applicants or subapplicants must provide documentation of all square-foot budgets. Costs must be provided in dollars-per-square-foot format. The costs must be based on the construction of fundamental, code-compliant structures with essential appurtenances as described. This will allow a comparative review of projects of varying types within a region and will ensure reasonable construction costs have been submitted.

The activities description in the scope of work for mitigation reconstruction projects is expected to include the following general construction-related activities:

• Pre-construction.
• Site preparation.
• Foundation construction.
• Structural shell construction.
• Interior finishes.
• Construction completion.

The activities are discussed further in Part 6.

In developing the mitigation reconstruction scope of work, the subapplicant should consider health issues involved with working with asbestos, mold and lead-based paint.

The subapplicant should document whether the structure can be safely elevated with a low likelihood of collapse or disintegration during the process and if there is the need for a licensed engineer or architect to ensure structure elevation is possible.

The square footage of a resulting structure must be no more than 10% greater than that of the original structure. Breezeways, decks, garages and other appurtenances are not considered part of the original square footage unless situated on the original foundation system. Original square footage must be documented in the subapplication through copies of tax records or other verifiable means.

To facilitate project development and to ensure all potential costs have been estimated, a conceptual design of proposed activities must be prepared during subapplication development.

Project scoping involves identifying and evaluating all aspects of a mitigation reconstruction project from beginning to end. This includes developing detailed project specifications, developing a work plan, and ensuring the project mitigates future damage to the reconstructed structure. During project scoping, consideration should be given to all factors that have the potential to significantly affect project implementation, including work schedule, project location, project cost and project effectiveness.

Although each structure’s construction will be designed by a licensed professional as part of the implementation of the project, basic design parameters for each structure must be established during project scoping, including foundation type, required foundation height, flood hazard conditions, appropriate wind design, project cost and site conditions. To aid potential subapplicants through the project scoping process, FEMA has developed detailed information regarding project budgets (refer to Part 6).

All reasonable and necessary costs, including anticipated project costs, direct costs associated with project scoping and project review, changes suggested by a licensed design professional, and costs for the pre-construction and construction activities listed in Table 21 are eligible project costs. All costs shall be based on the construction of fundamental, code-compliant structures as related to the codes and standards included or referred to in the HMA Guide.

The primary design parameters that must be considered during project scoping include:

• Foundation type: A key consideration for scoping mitigation reconstruction projects is the required type of foundation. The type of foundation for a specific mitigation reconstruction project is based on the location of the structure within a defined flood zone (based on the Base Flood Elevation, Advisory Base Flood Elevation or best available data) and the required height of the proposed structure above adjacent grade. During project scoping, the applicable flood zone or flood hazard area for each structure must be identified in addition to the associated foundation design requirements; this will help subapplicants determine the appropriate foundation type. The type of foundation that is selected affects the type and cost of construction and must be identified prior to subapplication submittal. Assistance in evaluating flood mitigation techniques can be found in FEMA 551. Detailed guidance on foundation designs and design parameters can be found in FEMA P-550.
• Foundation height: The required height to which a foundation must be constructed is a key factor in determining feasibility and cost. Assistance in evaluating flood mitigation techniques can be found in FEMA 551. FEMA developed guidance for designing appropriate foundations based on the requirements of the International Codes and other applicable coastal construction standards. That guidance is included in FEMA P-550, which also includes sample foundation design calculations and drawings. In this document, FEMA recommends sample designs and associated height limitations for various foundation types. For residential structures with required foundation heights greater than these limits, a licensed design professional must be consulted to determine feasibility.
• Wind design considerations: All mitigation reconstruction activities must be completed in accordance with the latest published editions of the International Codes, which include required wind design speed for the project location. An additional consideration is the requirement for the installation of shutters or other protective measures in windborne debris regions, defined as hurricane-prone regions located within 1 mile of the coastal mean high-water line where the basic design wind speed is 130 miles per hour (mph) or greater, or in areas where the basic wind design speed is 140 mph or greater, or Hawaii. During project scoping, projects located in these areas must be identified, and the associated cost of shutters or protective measures must be included in project costs.
• Seismic considerations: For purposes of code application, seismic reconstruction of buildings will be considered as new buildings. All mitigation reconstruction activities must be completed in accordance with the latest adopted editions of the International Codes and ASCE/SEI 7, Minimum Design Loads for Buildings and Other Structures, which include the required seismic design for the project location and expected seismic performance for new buildings. During project scoping, projects located within these areas must be identified and the associated cost of seismic design measures or protection must be included in project costs.
• Project cost: The requirements and preferences for mitigation reconstruction developed through the parameters described above will significantly affect the proposed activities’ cost. Proposed costs must be developed for consideration of mitigation options and completion of the BCA. Detailed guidance on costing procedures is available from the appropriate FEMA regional office. In addition to these specific parameters, other considerations may need to be addressed during project scoping, including:
  • Zoning requirements and other local ordinances.
  • Soil conditions.
  • Site access requirements.
  • EHP considerations.

HMGP, HMGP Post Fire, BRIC and FMA offer assistance for scoping and the development of engineering analyses to determine feasibility under project scoping/advance assistance. For more information, refer to Part 11.B.

If increased cost of compliance assistance through a standard flood insurance policy is used as cost-share for a project, policyholders have up to six years from the date of the underlying flood loss to complete the eligible mitigation activity. The increased cost of compliance payment is up to $30,000; it can be used as the non-federal match for demolition, elevation, relocation and floodproofing of a structure substantially damaged by flooding. Consideration of increased cost of compliance as local cost share should be early in the scoping or project development process.

All subapplications must provide information so FEMA can determine the feasibility and effectiveness of the proposed mitigation activity. Refer to Part 6 for more information.

All subapplications submitted to FEMA must meet the EHP criteria in Part 4. All subapplications must provide the information described in Part 6 so that FEMA may perform the EHP review.

Project implementation includes everything needed to complete the project. Implementation includes the pre-construction activities of plan review and inspection; site preparation; and all construction activities, including building the foundation and structural shell, completing the interior finishes, as well as obtaining all builder certifications.

Pre-construction activities for each structure include project design, analysis and permitting required to meet the assistance requirements.

The project design will be performed by or under the direct supervision of a design professional (i.e., a licensed architect or licensed professional engineer in the state the project is located in). The design must include all calculations, analysis and research necessary to determine the forces expected to act on the project structure. The design must account for all attachments and appurtenances. The selected structural framing members must be sufficient to provide a load path for all load-bearing members to transfer design loads to the foundations. The design must also account for the connections required to transfer loads from one member to another in accordance with the design concept.

Assistance in evaluating flood mitigation techniques can be found in FEMA 551. Design and construction techniques for building foundations can be found in FEMA P-550, which describes in detail the considerations for determining the feasibility of constructing to the required height. Although FEMA P-550 was developed in response to the reconstruction needs after Hurricane Katrina, the design solutions provided can be used in both coastal and non-coastal flood zones.

The design process must also include any testing required to establish site-specific design parameters, such as soil borings conducted as part of a geotechnical exploration, to determine foundation requirements.

Prior to construction, each subapplicant must obtain all applicable permits and pay all required permitting fees. Applicable permits are expected to include, but not be limited to:

• Zoning or land use approvals.
• Environmental permits or required certifications.
• Historic preservation approvals.
• Building permits.

Construction drawings and specifications must be reviewed by the local jurisdiction’s building official prior to the start of construction.^[426] If the local jurisdiction has not established a building department, the reviews must be conducted by an independent licensed design professional retained by the jurisdiction to conduct such reviews. The reviewing design professional must be licensed in the state in which the project is located. Payment for the reviewing design professional is an allowable cost. Construction inspections must be conducted to verify the project was constructed in full accordance with the approved design and the applicable International Codes. Construction inspections must be conducted by the office of the building official or under the direct supervision of a design professional licensed in the state where the project is located, as applicable.

Site preparation activities include demolition of existing structures, removal and disposal of project debris, site environmental restoration, utility relocation and site grading required as part of the project. The subrecipient must conduct a Phase I environmental site assessment in accordance with the EPA’s “all appropriate inquiries” rule and ASTM E2247.^[427] A clean-site certification from the appropriate federal or state agency is required for properties that were subject to remedial, removal, response or corrective actions for hazardous materials. Environmental site remediation costs are not eligible.

The following information covers the requirements for foundation construction, structural shell construction, interior finishes, construction completion, builder certification and certificate of occupancy.

Foundation construction activities include installation, monitoring and testing (if required) of foundations supporting the structure. Assistance in evaluating flood mitigation techniques can be found in FEMA 551. Design and construction techniques for building foundations can be found in FEMA P-550. FEMA P-550 describes in detail the considerations for determining the feasibility of constructing to the required height. Although FEMA P-550 was developed in response to the reconstruction needs after Hurricane Katrina, the design solutions provided can be used in both coastal and non-coastal flood zones. Additionally, NFIP Technical Bulletins can be used to meet floodplain management criteria for specific structures or geologic circumstances.

Installation of an open foundation system must be monitored to ensure the foundation elements are installed to the depth and achieve the load capacity specified in the construction documents. Foundation construction monitoring can be conducted by a building official or their designee, the licensed design professional responsible for the project design, or an independent agency.

Structural shell construction activities include all framing, load-carrying elements, attachments and building envelope components above the foundation. Because rough-in installation of electrical, communications, plumbing and mechanical systems may require drilling through or making notches in load-carrying elements, such rough-in work is also part of the structural shell construction activities. Structural shell construction activities must include an inspection of the completed shell prior to interior work covering the framing. The engineering inspection must verify the size, location and materials used in the construction are in conformance with the construction drawings and the applicable International Codes.

The results of an engineering inspection by, or under the direct supervision of, the responsible licensed design professional or an independent agency must be presented in a written report signed and sealed by the licensed design professional in charge of the monitoring. The engineering inspections must be conducted by a building official or their designee. The licensed design professional responsible for the project design may inspect the structure for quality control reasons.

Interior finish activities include installation of interior walls, flooring, wiring/lighting fixtures, insulation, plumbing and mechanical fixtures, kitchen/bath counters, cabinets, sinks, toilets, tubs/showers, and heating, ventilation, and air conditioning. Inspections of these interior finishes must be conducted in accordance with the requirements of the applicable International Codes.

At a minimum, all work must be performed by contractors licensed or registered in the state where they are working and who maintain appropriate insurance coverage. In addition, contractors must adhere to more stringent local requirements, where applicable.

Projects assisted under this program shall not be occupied, or the occupancy category changed, without prior issuance of a certificate of occupancy by the governing local jurisdiction. In jurisdictions that have adopted the International Codes, the certificate of occupancy shall be issued only after the building official inspects the structure and finds no violations of the provisions of applicable codes or other laws enforced by the building department, as well as the provisions and requirements of the HMA Guide.

In the absence of an adopted building code in a participating jurisdiction, or the absence of a designated building official, the required inspections shall be conducted by or under the direct supervision of an appropriate design professional licensed in the state where the project is located. In communities that have not adopted the International Codes, the state building commission shall determine the education, training, and experience requirements for inspectors responsible for conducting inspections.

Inspections required prior to the issuance of a certificate of occupancy include but are not limited to the following:

• Demolition inspection: Inspections shall be made after all utility connections have been disconnected and secured in such a manner that no unsafe or unsanitary conditions exist on the site during or after demolition operations.
• Foundation inspection: Inspections shall be made during foundation construction to verify the foundations have been installed to the depth and capacity specified in the construction documents.
• Floodplain inspection: Inspections must be made for properties located in the SFHA upon placement of the lowest floor and prior to subsequent vertical construction. Documentation of the elevation of the lowest floor must be provided by a land surveyor, engineer or architect authorized by law to certify elevation information in the state where the project is located. Handheld global positioning system (commonly known as GPS) -derived ground elevations are not acceptable to meet this requirement. In addition, setbacks and distances from water courses, the regulatory floodway, Zone V and the mapped limit of the 1.5-foot breaking wave zone must be checked prior to construction.
• Framing inspection: Inspections must be made after the roof is in place, including all framing and bracing, and after the plumbing, mechanical and electrical rough-ins are complete. The framing inspections must verify framing members are of the type, size and grade indicated on the construction documents and the connections and fasteners have been installed in accordance with the applicable codes and construction documents.
• Sheathing inspection: Inspections must be conducted after all roof and wall sheathing and fasteners are complete and, at a minimum, must include inspection of the roof sheathing, wall sheathing, sheathing fasteners and roof/wall dry-in.
• Final inspection: A final inspection must be completed to document compliance with all requirements of the International Codes, local floodplain ordinances and any other state or local regulations.

A comprehensive list of all required inspections, permits and certifications is included in the International Codes. Additional information on flood-related inspections, including sample checklists, can be found in the ICC/FEMA Reducing Flood Losses through the International Codes: Coordinating Building Codes and Floodplain Management Regulations, 5^th Edition document (Oct. 2019).

Recipients are required to report deviations from budget, project scope or objectives in accordance with Part 8. Recipients must request prior approvals from FEMA for budget and program plan revisions.^[428]

If the final design is not complete prior to award, once the project is awarded, the design must be finalized by a licensed design professional. Any changes to the scope of work or budget because of completing the final design or to address permitting requirements must be consistent with Part 8. Construction design activities are defined as construction activities; therefore, budget changes involving them must be consistent with Part 8.F.2.

Recipients and subrecipients must closeout projects in a timely manner consistent with Part 9.

In addition to the typical HMA program closeout processes, closeout of mitigation reconstruction projects generally includes the following:

• A certificate of occupancy and the Elevation Certificate (FEMA Form 086-0-33) for each structure in the subaward to certify the structure is code compliant and was elevated to the required elevation. FEMA will use the latest published edition of ASCE 24 or its equivalent as the minimum design criteria.
• A copy of a recorded deed for each structure, including requirements for maintenance and flood insurance requirements.
• A signed Acknowledgement of Conditions for Properties Using FEMA Hazard Mitigation Assistance form for each structure.
• A certification from a building official or licensed design professional verifying the structure was designed and constructed to the minimum standard of the two most recently published editions of the International Codes, even in locations where no code has been adopted.
• A front, rear and side photograph of the final structure, including the date of the photograph, structure address, latitude/longitude to the nearest sixth decimal place, source of photograph and name of the photographer.
• Verification by the recipient that final square footage is within 10% of original structure square footage at the time of closeout.
• Verification of flood insurance for each structure.
• Update of the structure site information in the FEMA electronic application system for each structure.