On August 19, NRECA filed comments with the Federal Emergency Management (FEMA) regarding their proposed fifth update to the Public Assistance Program and Policy Guide (PAPPG). NRECA’s overall impression is that FEMA’s proposed changes would improve the PAPPG. Although NRECA is generally supportive of FEMA’s proposed changes, we do see continued areas for improvement. The Federal Emergency Management Agency must fix programs and policies that create financial hardships for electric cooperatives and their communities struggling to recover from natural disasters. NRECA is encouraging FEMA revise the proposed PAPPG version 5 and address the following:

  • Explicitly identify broadband as an eligible critical communication / utility service.
  • FEMA should clarify that both emergency and permanent work is eligible for interest reimbursement.
  • Eliminate the “50% Rule and mixed-use Rules”.
  • FEMA create training videos for its staff in the field and publicly post them so that the recipients and subrecipients can also watch and learn.
Despite FEMA’s efforts to improve consistent implementation of its program across its 10 regions, its Consolidated Resource Centers, and countless Joint Field Offices, room for improvement remains.​

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