US. Department of Homeland Security
FEMA Region 6
800 Noeth Le
Denton, TX
FEMA
October 17, 2018
James Waskom, Director
Governor's Office of Homeland Security
and Emergency Preparedness
7667 Independence Blvd.
Baton Rouge, LA 70806
Re: DR-1603/1607-LA Office of Community Development
Unit Cost Guidance, Request for Guidance
Dear Mr. Waskom:
Per the Governor's Office of Homeland Security and Emergency Preparedness (GOHSEP) letter
to the Federal Emergency Management Agency (FEMA) dated July 12, 2018, and titled,
“Request for Guidance,” the State requested specific guidance regarding cost eligibility of the 27
homes that were attached to the letter. The State requested information on whether Hazard
Mitigation Grant Program (HMGP) grant funds should be used to reimburse these homeowners
the full amount of the grant or should HMGP grant funds have not been expended and the funds
should be deobligated, which would necessitate being recouped from the homeowners.
Our guidance is as follows: If a property was approved to be part of the pilot after the issuance of
the Unit Cost Guidance (UCG) on January 8, 2007, then the UCG should be utilized. Ifa
property was approved by FEMA for the pilot before the issuance of the UCG then the full cost
of the reconstruction should be examined for cost eligibility and cost reasonableness and
reimbursed as appropriate minus any duplication of benefits.
For reference, on January 8, 2007, FEMA issued a document in support of the HMGP
Reconstruction Grant Pilot for Hurricanes Katrina, Rita and Wilma guidance that was
introduced June 23, 2006. The document, Unit Cost Guidance (UCG) and Instructions for
Developing Unit Cost Estimates, established guidance and instructions for developing unit cost
estimates for projects submitted under FEMA’s HMGP Reconstruction Grant Pilot activities for
Hurricanes Katrina, Rita, and Wilma. The unit costs developed in this document are based on
foundation type and required elevation height, as well as for one and two-story structures. The
square foot cost data developed in this document are based on “R. S. Means Square Foot Costs
(2006)” for “an average quality of construction as defined by the guidance.” This document was
developed to ensure that HMGP funds were sufficient to provide for a structure based on
standard grade and standard quality materials.Mr. Waskom
October 17, 2018
Page 2
‘The UCG became the instrument that was used by FEMA and the State to determine cost
eligibility and the maximum amount allowed for properties involved in the Pilot Reconstruction
Program. FEMA has stated in the past, and reiterates in this letter, that GOHSEP should not
reimburse a homeowner for expenditures above the UCG as part of the Pilot Reconstruction
Program.
To reiterate our guidance: If property was approved to be part of the pilot after the issuance of
the UCG on January 8, 2007, then the UCG should be utilized.
Please find the March 1, 2013, letter to Mr. Stanley Cohn, signed by then FEMA Region 6
External Affairs Director Philip Beasley, attached for reference. That 2013 letter is replaced by
this letter, which should be used in its place.
If you have any further questions, please contact Sandra Keefe, Mitigation Division Director, at
(040) 898-5127 or sandra, keefe@fema.dhs.gov.
George A. Robinson
Regional Administrator
Attachment