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Emergency Relief Program FAQs

To view a set of frequently asked questions, select a topic and category based on your interest area. Perform a word search or choose a topic from the list.

Answer:

The standard value of passenger time in the HMCE tool is pre-set at $15.58 per hour. Consistent with FEMA and DOT guidance, this represents one half of the average national wage, as reported by the Bureau of Labor Statistics. The value allows the HMCE tool to evaluate the benefits of avoided service outages or alternative services, as well as the cost of outages associated with project implementation.
Applicants have three options for this value:

  1. Use the standard value in the tool of $15.58 per hour, reflecting 50 percent of the national average wage rate.
  2. Adjust the value to account for regional differences, using regional wage information reported by the Bureau of Labor Statistics.

    Based on an analysis of the September 2013 BLS report “Employer Costs for Employee Compensation &mdash September 2013”, Historical Listings through September 2013, and National Compensation Survey data from 2010-2011 for applicable Census regions and combined statistical areas (CSAs, i.e. adjacent metropolitan areas), comparing regional average wage values to the regional average private industry wages resulted in the following adjustments:

    • Regional:
      1. New England (CT, RI, MA, ME, NH, VT): $18.38 per hour
      2. Mid-Atlantic (NY, NJ, PA): $17.59 per hour
      3. South-Atlantic (MD, DC, DE, VA, NC, etc.): $14.38 per hour
    • Combined Statistical Areas
    1. Boston-Worcester-Manchester (RI, MA, NH) CSA: $18.80 per hour
    2. New York-Newark-Bridgeport Mid-Atlantic (NY-NJ-CT) CSA: $19.40 per hour
    3. Philadelphia-Camden-Vineyard (PA-NJ-DE-MD) CSA: $17.86 per hour
    4. Washington-Baltimore-Northern Virginia (DC-MD-VA-WV) CSA: $18.25 per hour
    5. Adjust the value to account for regional differences as follows: Calculate one half of the average household income for the applicant’s service area, or for all public transportation users in the applicant’s service area, divided by the average household size for the population used.

Regardless of the approach selected, the same value must be used in all proposals submitted by a single applicant. If an applicant intends to use the third option, additional backup documentation is required, including copies of the applicable census tables, the calculations used, and a brief statement of why one of the other two options is not accurate or sufficient for the analysis. Other alternative approaches are not recommended.

Answer:

For all eligible force account and operating expenses, FTA will pay both straight and overtime labor costs.

Answer:

Given the unique eligibility criteria for the Category 1, 2, or 3 grants, FTA will only permit budget revisions that meet the below criteria with prior FTA approval.

  • Budget revisions will only be permitted to shift funds from an existing Category 2 Activity Line Item (ALI) when a cost-savings is realized to another existing Category 2 ALI, should there be a cost-overrun or need for additional funds.
  • Grantees will be required to submit documentation demonstrating the cost savings and cost over-run involved in the budget revision.

If the grantee experiences a cost-savings or determines it no longer needs the funds obligated in other ALIs in its Category 1, 2, and 3 grant, then the excess funds will be deobligated. Funds that are deobligated from the grant may be available for future obligation by the grantee, should the grantee have additional eligible recovery costs that cannot be funded by its pro-rated allocation or its insurance proceeds.

Answer:

Yes. However, apportioned resiliency funds cannot be used for design costs of projects unless the grantee has documented the availability of funding for the entire project, including construction.

Additionally, a grantee may not incur capital expenses for local priority resiliency projects until a project has received formal FTA approval granting pre-award authority for the project.

Answer:

No, applicants are not required to conduct a cost-benefit analysis to evaluate multiple alternatives for protecting a given asset, although this may be a useful step in selecting and identifying proposed projects for this competition.

As a part of the evaluation criterion “Protection of Most Vulnerable and Essential Infrastructure”, applicants should explain how and why a particular alternative was identified for this competition. This evaluation may use FTA’s HMCE tool, or may utilize a similar hazard-mitigation focused BCA process.

Answer:

It depends. Capital projects may not have a useful life of less than one year. “Resiliency projects” are defined as capital projects designed and built to reduce the vulnerabilities of a public transportation facility or system to future emergencies or major disasters likely to occur in the geographic area in which the public transportation system is located; or to projected changes in development patterns, demographics, or extreme weather or other climate patterns.

All resiliency projects must comply with FTA’s useful life requirements for capital assets. FTA’s useful life requirements state that a recipient must reimburse FTA for the remaining useful life of any asset that is disposed of prior to the end of its useful life.

Useful life is determined in accordance with the purpose of the project as well as the type of asset acquired. Since the purpose of a resiliency project is to protect other assets, the useful life of a resiliency project is tied to the lesser of the length of time that an asset (or its replacement) needs protection or the standard useful life of the purchased asset. For example, the useful life of a concrete flood barrier around a substation that is projected to be moved in five years is equal to five years. The useful life of movable equipment, such as modular flood barriers, should be determined by the grantee based on guidance in FTA Circular 5010.

Answer:

FTA will apply the same oversight and grant management/administration requirements that apply to recovery and local priority resilience projects, once awarded. Resilience projects must comply with all Federal planning requirements, including the TIP/STIP requirement; however, they will not require prior FTA approval or to be submitted as part of a program of recovery projects, as required for Hurricane Sandy recovery and local priority resilience work. As projects were evaluated and selected based on the submitted application, projects should be delivered in accordance with the schedule and scope identified in the application.

Answer:

As the specific purpose of a resiliency project is to add protective features to existing infrastructure to minimize damage from future emergencies or major disasters, a resiliency project typically includes a “substantial functional, location or capacity change." As such, FTA expects project sponsors to ensure such resiliency projects are included or appropriately referenced in the MPO’s metropolitan transportation plan as well as the TIP and STIP prior to incurring costs. Please reference FHWA and FTA’s joint planning rule (23 CFR 450.324) for TIP/STIP requirements. Project sponsors are also reminded they must comply with other applicable pre-award requirements (unless specifically waived), before incurring costs for these projects.

While 23 CFR 450.324 contains an exception for "emergency relief projects" that do not involve substantial functional, locational, or capacity changes be included in the TIP/STIP, FTA does not expect resiliency projects, particularly those funded from the local priority resiliency allocations and future competitive resiliency allocations, to qualify for the reason noted above and given most are not "emergency" in nature.

However, there may be some integrated resiliency elements or projects specifically tied to a recovery project and funded from a grantee's recovery allocation that do not include "substantial functional, location, or capacity changes". Project sponsors should review the additional planning FAQs for more information about this exception and the process for certifying if a project qualifies. What appropriate funding assumptions can be made to include projects funded under FTA’s Emergency Relief Program (ERP) in a TIP/STIP? Per FHWA/FTA’s joint planning rule, a project must be fully funded from “reasonably anticipated” fund sources to be included in the TIP/STIP. To meet the requirement of anticipated full funding, sponsors of ERP projects must identify all the funding sources for the ERP project including the federal funds that FTA has allocated from the ERP to individual project, any required non-federal match plus any other funds required to meet the total cost of the project. Project sponsors should not assume the availability of ERP funds for a specific project if Congress has not appropriated those funds to the ERP, or if FTA has not specifically allocated ERP funds to the specific project. Projects that have been allocated ERP funds from the Disaster Relief Appropriations Act by the Notice of Availability published May 29, 2013 can assume the ERP funds to be “reasonably available” to the project so that the project can be included in the TIP/STIP.

However, project sponsors cannot assume that any future funds that have not yet been allocated, particularly those that may be awarded on a competitive basis, are “ reasonably anticipated to be available” until FTA makes an allocation to a project. Once FTA makes an allocation, the project sponsor should work with the MPO and/or State to amend the TIP/STIP to include the ERP project, identifying all federal and other funds required to meet the full cost of the project. Project sponsors are urged to work closely with the MPO and States early to understand and plan for any TIP/STIP amendment procedures for project inclusion once FTA has allocated ERP funds. If my agency has incurred eligibility expenses, recovery and/or resiliency, in advance of having the project programmed in the Transportation Improvement Program (TIP) and Statewide Improvement Program (STIP), can they be reimbursed from my pro-rated allocations for recovery and local priority resiliency? It depends. Some grantees, in preparation for the 2013 hurricane season, have incurred costs on local recovery and resiliency projects prior to those projects being included in the Transportation Improvement Program (TIP) or the State Transportation Improvement Program (STIP). Inclusion in the TIP/STIP is a requirement for pre-award authority. Given the short time frame for completing these projects, FTA has determined that it will reimburse costs incurred for recovery and approved resiliency projects if those projects are in the TIP/STIP by November 1, 2013. However, grantees are reminded that the planning requirement is just one of the pre-award requirements. In order to be eligible for reimbursement, the project must have met other applicable federal requirements (e.g. NEPA, procurement) or had a waiver in place. Resiliency projects also require FTA approval prior to incurring costs to confirm eligibility.

Beyond November 1, the agency will need to determine if we will permit reimbursement of costs incurred that were not in compliance with the planning rule.

FTA also already published guidance in a previous Q&A about exceptions that may apply to recovery projects that do not involve substantial functional, locational, or capacity changes. If you have a recovery project that may qualify for this exception to the planning rule (23 CFR 450.324), please submit the request in writing to the FTA Sandy Office. (here)

Answer:

Yes, however each state administers its own HMGP funds and determines how those funds are spent, in accordance with FEMA requirements.

Answer:

Pre-construction activities (i.e. planning, NEPA review, preliminary engineering and design) are not required to be on the TIP and STIP prior to incurring costs to be eligible for potential reimbursement under pre-award authority. FTA considers these activities necessary to estimate the cost of a project for inclusion in the TIP and STIP.

All other project activities must be in the TIP and STIP prior to incurring costs.

FTA will determine the eligibility for reimbursement of pre-award activities once a grant is in development and the project has been included in the TIP and STIP.

Answer:

Yes, in the case of projects with scalable options or multiple independent sub-projects, it is permissible for an applicant to reallocate the funds associated with one or more specific sub-projects.  The remaining resilience funded sub-projects must have independent resilience utility, and may be identified based on their location or the specific proposed activity. Recipients are encouraged to identify why the particular sub-project has been chosen for reallocation, for example, if it has a lower benefit-cost balance than the remaining projects.

Answer:

Yes, as noted in the previous answer, it is permissible for a recipient to request the reallocation of a portion of a project’s proposed scope, provided that the remaining scope results in a viable project with an independent resilience benefit. In this case, the recipient should submit a revised project budget breakdown reflecting the reduced scope. 

Answer:

No, the HMCE analysis should always reflect the total project cost, as the analysis is based on the costs and benefits of the project to society, not to the Federal government. The application should clearly identify both the total project cost and the requested Federal funding amount.

Answer:

No. The only Federal funds that can be used in place of local share for the FTA Emergency Relief Program are funds, which by statute lose their federal identity and can be used as match for other Federal programs, such as Community Development Block Grant funds.

Answer:

No. Local priority resilience funds cannot be used to design projects that will be submitted as part of the competitive process.

However, the grantee has the following options for paying for these costs:

  1. FTA will extend pre-award authority for environmental work (to comply with NEPA) and design costs for these activities, permitting them to be eligible for reimbursement OR count towards your local match if the competitive resiliency project is selected.
  2. A grantee can use their FTA formula funds such as the Section 5307 funds to pay for these costs.
Answer:

No. Resilience projects must be designed to reduce damages and losses from extreme weather events and other disasters, not to protect assets from exposure to typical weather patterns and other environmental factors. If a project protects against a disaster, but also provides benefits in typical conditions, the application may present these and other ongoing benefits as reduced operations and maintenance costs over the project’s lifespan.

Answer:

Project administration costs are considered to be those necessary and reasonable administrative costs associated with the implementation of specific FTA approved capital project activities. Such costs may be direct or indirect. Direct costs must be supported with documentation to show the nature and amount of cost including time and attendance records for actual staff time charged to the activity. Indirect costs must be supported with a federally approved indirect cost allocation plan. Project administration costs should be budgeted separately or included in related capital activity line item budgets. Project administration costs are funded as capital costs. While project administration is an eligible capital cost, general program administration is not.

Project team resources may be funded up to a reasonable amount, which generally does not exceed 10 percent of the total capital costs of the project.

Answer:

The HMCE tool is designed to accurately interpolate between two or more events with increasing total damages and increasing recurrence intervals (RIs). So for a scenario where a 100-year event causes more damage than a 200-year event; the HMCE tool would not accurately interpolate between the events and would underestimate the actual project benefits. Therefore, to produce accurate results in the HMCE tool, we recommend the following:

  • If there are only the two known RI events, then input only the 100-year event as a known RI event and omit the 200-year RI event to avoid an undercounting of project benefits and explain your reasoning in the documentation.
  • If there are three more events including the two known RI events, then input all the events as unknown RI events and let the tool estimate the RIs and group the results.
Answer:

Yes, recipients may use transportation development credits as local match for grants under Section 5324.

Answer:

Yes, it can be assumed that certain assets would experience increased utilization during a 100-year storm event; however, data documentation must be provided to support this assumption indicating 1) the historical precedence for the assumption, 2) the estimated level of increased utilization, and 3) the basis for the estimated increase. In general, assumptions based on predicted behavior will require much more stringent documentation than for historic events.

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