Section 428 - Alternate Procedures

Where recovery, resilience, and precision intersect: FEMA Public Assistance (PA), Hazard Mitigation, and Documentation.

Applicants and their subrecipients have the opportunity to pursue alternative projects that go beyond simply restoring damaged facilities or infrastructure to their pre-disaster state. This provision empowers applicants to use allocated funds in ways that best support their unique recovery goals, enhance long-term resilience, and strengthen future preparedness. The flexibility this provides makes it possible to tailor project administration to each community’s needs.

In collaboration with FEMA, our team, and the professional architects and engineers working on your behalf, we develop thorough plans, specifications, and cost estimates for reconstruction. These are based on Applicant-signed Damage Descriptions and Dimensions (DDD) and pre-disaster design requirements, fully aligned with current codes, specifications, and standards. Additionally, repairs and new constructions that require upgrades—per federal, state, and local regulations—are eligible for funding if they meet all established criteria.

This collaborative and strategic approach ensures that your recovery efforts are both compliant and optimized for long-term impact.

Determination memos and appeals are your responsibility

When disagreements arise on Section 428 projects, FEMA’s current resolution method involves issuing determination memos during the project formulation process. We manage this process on your behalf by crafting a compelling rebuttal to the determination memo and seamlessly uploading it through the grants portal. These memos lay the groundwork for any formal appeal or arbitration, ensuring a strong position from the outset. While projects involving determination memos and appeals may extend the timeline to obligation, our expertise helps navigate these challenges effectively, so you can secure the best possible outcome.

Repetition and reworked projects are inevitable.

When FEMA’s quality assurance and quality control teams challenge the DDD or SOW, they send it back for revisions, creating further delays and risking the project’s ability to meet the critical 18-month obligation deadline.

We handle this process for you. We respond to determination memos promptly and decisively, grounded in policy and procedure, backed by extensive supporting documentation. Our approach keeps your project on track and reduces the risk of costly delays.

Section 428 projects need the right resources, and you must account for cycle time.

The average length of time to order and perform individual site inspections—as well as prepare and input a DDD, SOW, and CE—is burdensome, time-consuming, and varies with the size of the project.

Collaboration and agreement are required at each step of the project formulation process for Section 428 projects.

Negotiating a final SOW can be very time-consuming.

We represent you for each step.