B.9. Wildfire Mitigation

Wildfire mitigation projects are any actions undertaken to decrease the risk of damage or loss of life from wildfires. FEMA wildfire mitigation activities can be assisted by HMGP, HMGP Post Fire and BRIC. Assistance under these programs is not available for wildfire mitigation beyond the parameters described in the HMA Guide.

This section addresses project eligibility requirements and lists the types of projects that FEMA will assist.

FEMA assistance will only be considered for clearly defined vulnerable buildings and structures. Eligible wildfire mitigation projects must clearly demonstrate mitigation of the risk from wildfire to residential and non-residential buildings and structures, including public and commercial facilities. Projects must be in a Wildland Urban Interface, be adjacent to or intermingled with the built environment, and provide protection to life and the built environment from future wildfires. The Wildland Urban Interface is an area where human-made structures and infrastructure (e.g., cell towers, schools and water supply facilities) are in or adjacent to areas prone to wildfire.

FEMA will only assist specific wildfire mitigation activities. These activities are summarized in Table 33.

Table 33: Eligible Wildfire Management Activities

Activity	HMGP	HMGP Post Fire	BRIC	FMA
Defensible space	Yes	Yes	Yes	No
Ignition-resistant building materials*	Yes	Yes	Yes	No
Ignition-resistant infrastructure**	Yes	Yes	Yes	No
- Ignition-resistant utility pole structures	Yes	Yes	Yes	No
- Repair/replace/upgrade water systems	Yes	Yes	Yes	No
Fire suppression system (sprinklers)***	Yes	Yes	Yes	No
Fuel reduction/vegetation management	Yes	Yes	Yes	No
Post-wildfire flooding prevention and sediment reduction measures:	Yes	Yes	Yes	No
- Reforestation, restoration and/or soil stabilization	Yes	Yes	Yes	No
- Ground cover vegetation re-establishment (e.g., seeding and mulching)	Yes	Yes	Yes	No
- Erosion prevention measures on slopes	Yes	Yes	Yes	No
- Flash flooding prevention measures resulting from runoff (e.g., drainage dips and debris traps)	Yes	Yes	Yes	No
Installing warning equipment and systems†	Yes	Yes	Yes	No

^* Only eligible if the property owner has completed or agrees to complete and maintain defensible space measures around the structure.

^** Part 12.B.10 contains additional information on this project type.

^*** Only external water hydration or thermal insulation systems are eligible.

^† Part 12.B.12 contains additional information on this project type.

B.9.2.2.1. Defensible Space

Creating defensible space involves creating a perimeter around a residential or non-residential building or structure by removing or reducing the volume of flammable vegetation, including clearing tree branches vertically and horizontally. The volume of vegetation is minimized, flammable vegetation is replaced with less flammable species, and combustibles are cleared in accordance with all applicable codes and best practices. FEMA recognizes the importance of creating defensible space for residential and non-residential buildings and structures in accordance with local fire codes; standards and design criteria provided by ICC, FEMA, the Fire Administration and the NFPA; well-established and proven techniques; and NFPA Firewise practices. FEMA recommends that ingress and egress to the building be maintained.

The required radius of defensible space around a building is related to the degree of the hazard, and the radius that is needed for an effective defensible space may therefore vary from one jurisdiction or building to another. In addition, the topography, specifically slope steepness and direction, and the arrangement, amount and flammability of the vegetation may require extending the perimeter.

Defensible space projects for residential structures, commercial buildings, public facilities and infrastructure must be implemented in conformance with local code requirements and standards for defensible space. FEMA recommends that projects use the design guidance in FEMA P-737, Home Builder’s Guide to Construction in Wildfire Zones (Sep. 2008) or FEMA P-754, Wildfire Hazard Mitigation Handbook for Public Facilities (Oct. 2008), if the latter presents a stricter standard.

Structural protection through ignition-resistant construction involves the use of non-combustible or ignition-resistant materials, technologies, assemblies and retrofit techniques on new and existing buildings and structures.

FEMA will consider a subapplication for an ignition-resistant building materials project only when one of the following has occurred:

• The property owner has previously created defensible space and agrees to maintain the defensible space in accordance with the HMA Guide. The subapplicant must include documentation describing the defensible space for each property in the application. FEMA will provide assistance for ignition-resistant construction projects only after the subapplicant has demonstrated that the defensible space activity is complete and has provided documentation (i.e., photographs and description of the defensible space).
• The subapplication includes both the defensible space and ignition-resistant construction projects as part of the same subapplication. The subapplicant must include a description of the defensible space for each property in the subapplication, and each property owner must agree to maintain the defensible space in accordance with the HMA Guide.

The protection of homes, structures and critical facilities using ignition-resistant construction techniques or non-combustible building materials must be implemented in conformance with the local fire-related codes and standards. FEMA recommends that projects use the International Wildland Urban Interface Code, FEMA P-737 or FEMA P-754 as appropriate.

FEMA may assist above-code projects in communities if the project is cost-effective and in conformance with all applicable eligibility criteria. Eligible activities include:

• Roof assemblies: Installation of roof coverings; roof sheathing; roof flashing; roof skylights; roof, attic and wall vents; and roof eaves and gutters that conform to any of the following ignition-resistant construction standards: (1) construction materials are ignition-resistant in accordance with nationally recognized testing standards, (2) construction materials are non-combustible or (3) construction materials constitute an assembly that has a minimum one-hour fire-resistant rating.
• Wall components: Installation of wall components, such as the fascia, windows, window glazing, doors, window frames and insulation that conform to any of the following ignition-resistant construction standards: (1) construction materials are ignition-resistant in accordance with nationally recognized testing standards, (2) construction materials are non-combustible or (3) construction materials constitute an assembly that has a minimum one-hour fire-resistant rating.
• Protection of fuel tanks: Protection of propane tanks or other external fuel sources.
• External water hydration and thermal insulation systems: Purchase and installation of external, structure-specific water hydration and thermal insulation systems (foam, fire-retardant and water sprinkler systems) with a dedicated delivery system and dedicated self-contained foam or retardant in sufficient volume to protect the structure. For water sprinklers, a cistern is acceptable if a dry hydrant with a fire department connection or other water source (e.g., lake, river, swimming pool) is available. FEMA will only consider the project when assurance is provided in the operations and maintenance plan that a system (e.g., geographic information system) will be maintained to identify property addresses with wildfire sprinkler systems and will be made available to the appropriate fire department.

During a wildfire, firebrands and airborne debris can breach windows, and convective heat and embers can penetrate utility openings, gaps around doors and other openings. Exterior water hydration systems can help extinguish flames before the building has been substantially damaged, protect nearby buildings and prevent the fire from igniting nearby combustible vegetation.

Hazardous fuels reduction involves the removal or modification of vegetative fuels proximate to the at-risk buildings or structures that, if ignited, pose a significant threat to human life and property, especially critical facilities. Hazardous fuels reduction includes thinning vegetation, removing ladder fuels, reducing flammable vegetative materials and replacing flammable vegetation with fire-resistant vegetation for the protection of life and property. Vegetation may include excess fuels or flammable vegetation.

Hazardous fuels reduction projects are implemented at the community level and extend beyond defensible space perimeters.

Hazardous fuels reduction projects will be designed to moderate fire behavior and reduce the risk of damage to life and property in the target area for mitigation. The natural variation in vegetation, topography and climate does not lend itself to a national design standard for hazardous fuels reduction activities. Hazardous fuels reduction projects will be designed and implemented in accordance with state and local codes and standards and best practices. The project design should include consideration of the landscape and intended function of the project, and the location and orientation of the project site should be designed with consideration of the likely direction and severity of a wildfire.

Hazardous fuels reduction may be accomplished using community-owned, rental or contract resources and equipment for mechanical treatments, such as disking, mowing, limbing, sawing, chipping, grinding, mulching and chopping. Chopping equipment may include chippers and saws. The equipment may not pose a risk of fire ignition (e.g., by using a spark arrestor).

Eligible activities include community-level vegetation management, vegetation removal, vegetation clearing and/or thinning, slash removal and vertical and horizontal clearance of tree branches to reduce the threat to human life and structures from future wildfires. Hazardous fuels reduction may include the following techniques:

• Chemical treatments, including herbicide applications with appropriate safeguards to ensure protection of human life, the environment and watersheds.
• Grazing or biomass conversion.
• Mechanical treatments, such as disking, mulching, chipping, grinding, mowing, limbing, chopping and removal of such material; material left on-site must meet appropriate depth practices in accordance with applicable codes and best practices.
• Biomass removal, including clearing straw, removing dead or dry vegetation, thinning, removing brush and pine straw, or removing blown-down timber from wind throw, ice or a combination.
• Biomass burning, including gathering vegetation into a pile for burning.
• Felling of standing burned trees and other hazardous trees perpendicular to a slope to help prevent erosion.
• Other industry-accepted techniques with FEMA’s approval.

Wildfires can leave slopes bare of vegetation, making them subject to erosion. Wildfires also can change the chemical composition of the surface soils, making them hydrophobic, which means they repel water rather than absorb it. Consequently, periods of intense and/or extended rainfall after a wildfire can result in runoff that could result in flash floods, debris slides and mudslides, which could pose a threat to life and property at the bottom of the slope.

Post-wildfire flooding preventive measures can be implemented to protect property at the base of slopes with hydrophobic soils because of wildfire. These measures may direct water away from the property and slow the flow of water down the slope. Post wildfire sediment reduction prevention measures are meant to mitigate the risk of sediment and mud flows after a wildfire has burned a watershed. Wildfires create the potential for landslides, mudflows and sediment flows, which increase the debris and sediments during flooding events. Prevention measures to mitigate the amount of sediment in post-wildfire runoff include the use of rock or log dams and sediment debris traps.

Flash flooding preventive measures are meant to mitigate risk of flooding after a wildfire event has burned the watershed upstream of a project area. Wildfires increase the risk of flooding by reducing the vegetation and increasing the ability of the soils in the watershed to retain water. These preventative measures include:

• Diversion channels (artificial channels built to reduce excess water flow) or deflection walls (generally reinforced concrete structures that can protect bridge abutments) can be used to slow and redirect the flow and movement of water across a slope rather than directly downward to a stream or wetland.
• Drainage dips (intentionally reverse grade built into a roadway) can divert water flow from the surface and direct it instead toward a discharge area.
• Emergency spillways (drainage channels constructed for discharge surplus water) can keep roads and bridges from washing out during floods.
• Water bars (berms of soil, straw, rock or bedded logs placed perpendicular to the slope) can protect against erosion, run off, and high water by preventing water from overcoming the slope.
• Culvert modifications and or removal to channel water off the burn region.

The following project activities and their associated costs are not eligible for FEMA assistance:

• Projects that do not protect homes, neighborhoods, structures or infrastructure.
• Activities associated with facilities or land owned by another federal entity where the specific authority relating to the activities lies with another federal entity.
• Projects to address ecological or agricultural issues related to land and forest management (e.g., insects, diseases, infestations, damage from extreme weather events affecting the forest-wide health).
• Irrigation of vegetation to avoid disease or drought-related infestation.
• Projects to protect the environment or watersheds.
• Projects for prescribed burning or clear-cutting activities.
• Projects for maintenance activities, deferred or future, without an increase in the level of protection.
• Projects for the purchase of fire-related equipment (e.g., vehicles, fire trucks) or communications equipment, except for warning equipment and systems.
• Creation and maintenance of access roads or staging areas for wildfire response equipment.
• Creation and maintenance of fire breaks.
• Purchase of equipment to accomplish eligible work (e.g., chainsaws, chippers).
• Projects for vegetation irrigation systems installed on the ground and designed to moisten the surface.
• Development or enhancement of fire suppression capability through the purchase of equipment or resources (e.g., water supply or sources, dry hydrants, cisterns not related to water hydration systems, dip ponds).
• Activities intended solely to remedy a code violation without an increase in the level of protection.

Before submitting an assistance application, the applicant must ensure that duplication of programs between federal agencies will not occur. FEMA will not provide assistance for activities for which it determines the specific authority lies with another federal agency or program. Wildfire mitigation is addressed by the federal government through a comprehensive legislative framework. FEMA recognizes that other federal departments and agencies, such as the Forest Service, Natural Resource Conservation Service, Fish and Wildlife Service, National Park Service, Bureau of Land Management and the Bureau of Indian Affairs, have primary wildland fire management responsibilities. These departments and agencies also have the primary responsibility for addressing ongoing forest management conditions, such as those caused by forest age, disease and pest infestation spreading to and from the federal lands onto adjacent non-federal lands.

While these and other federal agencies have the specific authority to protect the watersheds, forests, soils and timber resources and address forest management conditions, they also have authority to address wildfire hazard reduction, including hazardous fuels reduction, with primary attention on areas that are on or near federal lands. They may also assist state and local jurisdictions in efforts to protect the built environment in fire-prone areas of forests, ranges and grasslands. FEMA may assist projects that are complementary and adjacent to but not duplicative of projects assisted by other federal agencies.

If projects proposed for FEMA HMA hazardous fuels reduction are in a Wildland Urban Interface area, the applicant can check for potential duplication by contacting a local office of the Department of Agriculture or the Department of the Interior for information. HMA applicants are expected to be aware of any current or proposed hazardous fuels reduction projects under the Department of the Interior or the Department of Agriculture’s Forest Service and should provide an assurance to FEMA that there is no duplication of programs. If a project is already under consideration for assistance from another agency, the community should await the outcome of that decision before applying for HMA. If an agreement is already in place with another agency to perform hazardous fuels reduction but there is a delay in funding, HMA cannot be made available to substitute or replace other assistance. If Congress has specifically authorized another federal agency to perform a project, duplication of programs and HMA cannot be used regardless of whether there is a current appropriation.

FEMA does not have authority to assist projects on federal land owned by another federal entity or projects with the purpose of addressing forest health conditions or ecological or agricultural issues related to land and forest management (e.g., insects, diseases, damage from extreme weather events affecting the forest-wide health, pest infestations). FEMA mitigation authority targets at-risk buildings and structures without regard to the benefits to federal land and activities in areas outside the primary focus of other federal agency wildfire risk reduction programs. FEMA HMA for wildfires is focused on cost-effective, functional mitigation actions taken to reduce the risk to specific properties or buildings and structures from future wildfires or flood after fire. FEMA’s goal of reducing the risk from wildfire hazards to human life and property, including loss of function to critical facilities, is intended to complement, and not duplicate, the programs of numerous other federal agencies, such as the Forest Service or Bureau of Land Management, that fund wildfire risk reduction on non-federal lands.

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

The wildfire module of the FEMA BCA Toolkit considers Landscape Fire and Resource Management Planning Tools (LANDFIRE) data,^[470] timber costs, fire suppression costs and project effectiveness.

Project types that may be analyzed using the wildfire module include:

• Defensible space.
• Hazardous fuels reduction activities.
• Ignition-resistant construction.

In some cases, the Historic/Professional Expected Damage methodology may be appropriate if historical damage data is available.

Wildfire mitigation projects may qualify for ecosystem services benefits if they protect an existing natural area. Applying ecosystem services benefits to wildfire mitigation projects should be evaluated on a case-by-case basis, as the design of these projects can vary widely. In general, defensible space and ignition-resistant construction projects are not likely to qualify for ecosystem services benefits. A wildfire mitigation project may not include ecosystem services benefits if:

• It does not protect at least one contiguous acre of natural space, such as a forest or grassland.
• It involves the application of chemicals or other non-natural substances.

FEMA developed pre-calculated benefits for certain mitigation activities that reduce flood risk in wildfire impacted areas. Specifically, benefits of $5,250 per acre are available for the following post-wildfire mitigation project types:

• Soil stabilization.
• Flood diversion (which includes flash flooding prevention and sediment reduction measures).
• Reforestation.

If the cost of a given project does not exceed $5,250 per acre, it will be deemed cost-effective using the pre-calculated benefits methodology. Pre-calculated benefits cannot be combined with benefits from a traditional BCR calculated using the BCA Toolkit.

To use the post-wildfire pre-calculated benefits, the applicant would multiply the number of acres being mitigated by the total benefits per acre of $5,250. For example, if the project is to provide ground cover, soil stabilization and replanting for 1,000 acres and the benefit per acre is $5,250, the total project benefit amount would equal $5,250,000 ($5,250 multiplied by the number of acres—in this case, 1,000).

These pre-calculated benefits are based on the risk reduction and ecosystem service benefits provided by the forest and other vegetation with primary emphasis on the reduced flood risk these systems provide. Post wildfire mitigation projects that demonstrate they are cost-effective (a BCR ratio 1.0 or greater) using the pre-calculated benefits do not need to submit a separate BCA.

For up-to-date information on the dollar value of the pre-calculated benefits, refer to the FEMA “Benefits-Cost Analysis” webpage.

Projects must be consistent with Part 5. Mitigation projects assisted 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.

Wildfire mitigation projects must be technically feasible, effective at reducing risk, and designed and implemented in conformance with all federal, state and local requirements, including state and local building codes and land-use restrictions. FEMA urges the community or any entity implementing wildfire mitigation to use the materials and technologies that are in accordance with the ICC, FEMA, the Fire Administration and the NFPA Firewise recommendations, whenever applicable.

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 Wildfire Technical Review FEMA EHP job aid lists the documentation needed for projects for FEMA to complete the EHP compliance review process.

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.

Wildfire mitigation projects can be assisted by HMGP, HMGP Post Fire or BRIC. 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. The required information includes:

• Documentation that demonstrates that no duplication of programs will occur, that other federal programs have been investigated, and that the applicant has coordinated with other appropriate federal agencies.
• A statement acknowledging that a final operations and maintenance plan will be submitted to FEMA before project closeout.
• A map of the wildfire severity within the project area(s). Wildfire severity, also referred to as wildfire intensity, is influenced by fuels, climate and topography. Identifying the wildfire severity within a project area will demonstrate the potential for dangerous wildfires to occur.
• A map of the wildfire frequency within the project area(s). Wildfire frequency, also referred to as wildfire burn recurrence or wildfire return interval, is determined using historical fire report data. Identifying the wildfire frequency within a project area will demonstrate how often a wildfire is likely to occur.
• A FIRM showing project location and demonstrating the flood zone in which the project is located.

Provide map(s) showing the project area and the structures’ relationship to the Wildland Urban Interface or forested, range or grassland area. The maps should include the following elements:

• Contour data on the map or an additional map with the project’s boundary and contours.
• Latitude and longitude to the nearest sixth decimal place for all corners of the project area so the treatment area’s outline can be determined.
• Ignition-resistant construction: All structures within the project area(s) should be highlighted on the map.
• Hazardous fuels reduction and defensible space: Specific treatment polygons should be identified on the map. Maps should also identify the locations of the structures proposed to be protected by the project and the distance between the project area and the structures.
• Property address(es) of each structure involved in the mitigation project. This includes the street name and number; city, county or parish; state; and ZIP code. A post office box number is not an acceptable address. If the address provided does not match with the structure(s) to be mitigated, provide photos or a site map with the structure(s) footprint(s) identified.
• Structure-specific details: If the project is protecting multiple structures, this information must be provided, with supporting documentation, for each structure. Provide the following information about the existing structure(s):
  • For hazardous fuels reduction and defensible space projects, a list of the type of structures to be protected (e.g., residential, police station, hospital).
  • Property-level rating of wildfire risk for each home or community and the scale used to measure the rating levels (if applicable).
  • For ignition-resistant construction projects, in addition to the structure type, the following information about each structure:
    • Year the structure was built.
    • Description of the structure type (e.g., elementary school, government building).
    • Description of the construction type (e.g., wood framed, masonry/brick, concrete or steel).
    • Structure information, including the size of the structure and number of stories.
    • The average number of occupants residing in each structure.
    • Description of the foundation.
    • Photographs of the structure to be protected by the wildfire mitigation project. Provide a descriptive caption explaining what each photo shows, the direction it was taken and the side of the structure shown (e.g., “east side of structure, looking west”).

All subapplications must include an activities description referencing industry standards or project plans and specifications and a schedule for completing the activities.

The project narrative must identify the proposed mitigation action and structures to be mitigated, including a description of the proposed activities and a clear explanation of how the project will mitigate risk. The project narrative must include key milestones and correspond with the design information, project schedule and budget.

The following items should be included in the project narrative:

• The wildfire hazard being mitigated, including previous wildfires, damage history and the future potential wildfire risk of the project area(s).
• A rationale for effectiveness. Eligible wildfire mitigation projects must demonstrate mitigation of the risk from wildfire to residential and non-residential buildings and structures, including public and commercial facilities. Projects must be in a Wildland Urban Interface, be adjacent to or intermingled with the built environment, and provide protection to life and the built environment from future wildfires.
• Quantification of the project area where the wildfire mitigation will occur (e.g., 100 acres of fuels reduction) or quantify the area for each type of treatment as it relates to the projected structures (e.g., a 30-foot buffer of defensible space around each identified structure).
• For hazardous fuels reduction projects, a description of the treatment plan or landscaping plan for all vegetation that would be removed or affected by the project for each project site. This should include a description of the types of vegetation that would be removed, the method of removal (e.g., herbicide, hand tools, bulldozer), and the overall goal of the vegetation removal (e.g., decrease vegetation density, remove ladder fuels, create a level and vegetation-free site).
• If vegetation will be planted, details about the types of vegetation and the method of planting.
• A description of the distance from the treatment site to protected structures. A hazardous fuels reduction project could protect numerous structures that are within the treatment area, and the risk reduction for the target community or buildings must be demonstrated in the scoping narrative and supporting documentation.
• For defensible space projects, a description of the proposed defensible space activities for each property. Describe the treatment plan or landscaping plan for all vegetation that would be removed. In addition, describe any other facilities to be addressed, such as propane tanks, wood decks or fences, and the method of mitigation. Provide the treatment radius around each structure receiving mitigation.
• For fire-resistant materials projects, proposed conceptual designs, project plans and specifications. Fire-resistant materials projects are required to include a defensible space component as part of the application, or each property owner must have previously created defensible space and agrees to maintain it.
• A description of how the project conforms to current codes and best practices. FEMA urges the community or any entity implementing wildfire mitigation to use the materials and technologies that are in accordance with International Wildland Urban Interface Code, FEMA, Fire Administration and the NFPA Firewise recommendations, whenever applicable.
• A description of the equipment that will be used for the project. Include the likely maximum use of this equipment on at least an annual basis. If available, include details about known or planned restrictions to the construction equipment such as seasonal or daily restrictions.
• A description of all potential construction debris, including vegetation, that could be generated by the project. Provide details on the method of disposal of vegetation (such as grazing, chipping or mulching, or hauling to an off-site location) and construction debris, including potential locations and the legal status of disposal sites (whether the site is a licensed landfill).

Subapplications must include detailed line-item costs in the project budgets for each mitigation item provided in the scope of work. Well-documented project budgets contain quantities, unit costs and a source for each unit cost. Lump-sum estimates are not acceptable. The assistance of a licensed engineer, architect or contractor (wildfire expert) may be required to help develop the project cost.

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.

Allowable costs are costs that are necessary and reasonable for the proper and efficient performance and administration of the federal award. They may include but are not limited to:

• Engineering services for design, structural feasibility analysis, geotechnical assessments and budget preparation.
• Project administration and construction management.
• Soil sampling.
• Permit costs.
• Surveying and inspection.
• Labor costs.
• Management costs (refer to Part 13).
• All construction activities.
• List of equipment, including cost for each item.
• Debris removal and disposal costs (e.g., hauling, chipping).
• Erosion control.
• List of construction materials, including unit cost for each item.

A cost per structure must be provided for defensible space and ignition-resistant construction projects, and a cost per acre must be provided for hazardous fuels reduction projects.

Maintenance costs should reflect the costs associated with mitigation being maintained for the entire project useful life. Maintenance costs will vary, depending on project type, geographic location, climate and vegetation type. For example:

• Defensible space: Grassland vegetation was mowed and forested vegetation was removed within a 100-foot radius of the structure. At a minimum, to maintain the project effectiveness, the grassland regrowth must be mowed on a consistent basis (dependent on geographic location and precipitation) throughout the one-year project useful life. The forested regrowth must be hand trimmed at least every three years throughout the 20-year project useful life.
• Hazardous fuels reduction: 150 acres of dense forested vegetation was thinned out by pruning the forested canopy. To maintain effectiveness, the forested regrowth must be hand trimmed at least every three years throughout the 20-year project useful life.
• Ignition-resistant construction: Brush was removed within a 100-foot radius of the structure to create the required defensible space, and a fire-resistant roof was put on the structure. At a minimum, to maintain the project effectiveness, the brush regrowth must be trimmed on a consistent basis (dependent on drought conditions) throughout the four-year project useful life. Minimal roof maintenance should be required within the 10-year project useful life.
• Flash flooding prevention measures: Contour log felling was completed for a width of about 500 feet perpendicular to a slope denuded by wildfire. The logs were staked in place to prevent them from rolling downhill. Soil was tamped between the logs and the ground surface to prevent water from eroding under the logs. A trench approximately 1-foot deep was dug on the uphill side of each log to catch debris. To maintain project effectiveness, the debris trenches must be cleared annually until vegetation on the slope is re-established (about three years).

The basic steps in implementing an approved HMA wildfire project are:

1. Pre-construction (carry out design process; site assessments, seek technical consultant; prepare cost estimate; obtain construction permits, including requirement environmental permits; hire construction manager/contractor).
2. Coordinate with appropriate state, local tribal and territorial agencies and private nonprofits as appropriate.
3. Clear/prepare site for construction activities.
4. Construct/implement/install mitigation measures included in the project.
5. Achieve substantial completion.
6. Complete inspections and obtain certificate of occupancy (if required).
7. Complete monitoring and maintenance.

Post-award monitoring helps ensure subapplicants/subrecipients are achieving the objectives of the federal award consistent with the performance goals and milestones described in the subaward. To assist the recipient in monitoring wildfire projects, the following milestone information or events should be included in Quarterly Progress Reports:

• If the subrecipient is acquiring contract support, the subrecipient should report when the request for proposal is completed, when the contract is out for bid, when the bid period closes, when proposals are reviewed, when the contractor is selected and the date of the kick-off meeting.
• Describe the current status including a summary of:
  • Recent progress and planned work.
  • Risks identified or changes from the milestones/deliverables submitted with the scope of work (e.g., financial concerns, coordination issues with state or local governments and utilities, project management or contracting issues, legal disputes, and significant changes impacting construction activities or timelines such as delays due to weather, materials, procurement or labor issues).
• When construction has started, is substantially complete or completed.
• Any other milestones that have been identified in the subapplication or agreed to or are required by the recipient.

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.^[471] 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 procedures, closeout of wildfire projects generally includes:

• Property site inventory listing of all properties mitigated.
• Final inspection report with the name of the inspector and date of inspection. The report must include the following:
  • A narrative of all the components of the project that were completed and verification that the scope of work was completed and is consistent with activities identified in the scope of work.
  • Photographs of the project area(s) with clear labels.
  • A map of the project area(s) with accurate latitude/longitude to the nearest sixth decimal place.
• Clearly labeled photographs of the project site before and after mitigation. Photos should confirm the scope of work is completed.

In addition, the closeout of wildfire mitigation projects includes submitting an operations and maintenance plan to FEMA for review prior to project closeout. In the operations and maintenance plan, the recipient must confirm the plan is consistent with the HMA Guide, meets or exceeds local codes, and is in conformance with appropriate fire-related codes.

At a minimum, the operations and maintenance plan must include all the following information:

• Information demonstrating the completed wildfire project will be maintained to achieve the proposed hazard mitigation.
• A description of the post-closeout maintenance activities that will be undertaken to maintain the project area(s) or site(s).
• The period of time the community is committing to maintain the area and/or project site, which must be consistent with the project useful life in the BCA.
• The department and job position that will be responsible for maintaining the project after the construction has ended.
• Estimated costs for annual maintenance of the project.
• The schedule for implementation of the maintenance activities.