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Emergency Relief Manual
Chapter VI - Project Procedures and Requirements
General
Once the FHWA Division Administrator has made a finding that emergency or catastrophic conditions justify ER funding, the State should submit promptly a program of projects for repair of damage to the Federal-aid highways. Projects should be individually justified. If sufficient information is available when the Damage Survey Summary Report is submitted, the first program of ER projects may be incorporated into the Damage Survey Summary Report itself, or it may accompany that report, even though a finding has not yet been made. In any case, the program of projects should be submitted within three months after the disaster finding by the FHWA Division Administrator.
A program of projects is to be submitted to the FHWA Division office regardless of the Division office's role in project oversight on Federal-aid projects.
Fund Management
After the FHWA Division Administrator makes an affirmative finding on a State's request for ER, the Division requests an allocation of ER funds from the FHWA Headquarters Office of Program Administration. The initial allocation, generally based on the amount of anticipated obligations for the current fiscal year, could be less than the amount requested depending on the availability of ER funds. Headquarters allocates additional ER funds on an as-needed basis upon request by the Division Office, provided funds are available.
Near the end of each fiscal year (about September 15), FHWA Headquarters will coordinate with Division Offices to identify unobligated balances of ER funds that will not be needed through the end of the following fiscal year. Such funds will be withdrawn for allocation to States in need of ER funding. At the beginning of the following fiscal year, ER allocations are made, to the extent possible, to cover any backlog of need for the entire fiscal year based on the estimates submitted by the Division Offices. This practice is intended to avoid accumulating a large balance of allocated but unobligated ER funds and helps manage available funds nationwide as effectively as possible.
Federal Share
The Federal share for the repair of Federal-aid highways is established by law. It varies depending on the nature of repairs, when the work is accomplished, and the Federal-aid route being repaired.
For the costs associated with restoring essential traffic, minimizing the extent of damage, or protecting the remaining facility which are incurred in the first 180 days after the occurrence of the disaster, the Federal share is 100 percent.
For the costs of permanent restoration work, and the costs of all repairs incurred after the first 180 days, the Federal share is based on the type Federal-aid highway that is being repaired. For Interstate highways, the Federal share is 90 percent. For all other Federal-aid highways, the Federal share is 80 percent. The Federal share can be increased based on the "Sliding Scale" rates in States with high percentage of Federally owned public lands. The Federal share is 100 percent for all work done on roads on Federal lands.
Preparation and Submission of Programs
A program of ER projects should be prepared by the State. The program of projects should:
- Indicate the natural disaster or catastrophic failure and the time of its occurrence.
- Relate the damage to that described in the damage assessment reports prepared and/or detailed damage inspections.
- Describe proposed permanent repairs or replacements on a site-by-site basis (although sites may be lumped by route and county for program purposes).
- Include supporting material indicating the suitability and economy of upgrades or betterments including relocation proposed for participation with ER funds. For some projects it will be necessary to complete additional design work in order to develop justification for added protective features. When betterments are contemplated, the State or local agency should contact the Division Administrator so that further project development is accomplished with FHWA involvement.
- Identify emergency repairs.
Approval of Programs and Project Authorizations
The Division Administrators have authority to approve programs of projects that are located on the Federal-aid highways.
Temporary operations including emergency repairs, and preliminary engineering, including consultant work, may proceed without prior authorization. This work need not be authorized retroactively; however, the need for such work must subsequently be approved by the FHWA as part of a program of projects. Permanent restoration work shall not be performed prior to FHWA authorization unless performed as part of emergency repair.
Advancing Projects During ER Program Funding Shortages
When ER funds are not available for allocation to the States to cover either additional funding needs on previously approved ER events or funding needs for new disaster requests awaiting action by the Division Administrator, ER funding requests received in Headquarters are recorded and held by the Office of Program Administration pending action by Congress to replenish the ER accounts through a supplemental appropriation.
Recognizing that quick congressional action is not always possible, the following options could be used to fund or advance ER projects on an interim basis.
Previously Approved ER Events
For an event that the Division Administrator has previously found eligible for ER funding, requests to fund additional work for that event could be handled under one, or some combination, of the following:
Option 1 - Use of Unobligated ER Funds From Other ER Events In The State
This option could be available to a State that has several on-going ER-funded events. Although ER funds are allocated to a State based on funding requests for a specific event, using unobligated ER funds from a previously approved event to respond to ER needs on another approved event is usually acceptable unless the ER funding source is limited by law to a specific event. For the most part, ER funding sources are available for any ER event. For example at the time of this Manual's 2003 update, ER funding identified by appropriation codes 098, 09G, 09L, 09N, 09Q, 09T, 09X, and 09V could be used on any approved ER event.
It should be noted that Headquarters does not track the amount of ER funding used on a specific event through the fund allocation process. Instead, regardless of the funding source, ER funds used on a specific event are tracked through obligations entered in the Fiscal Management Information System (FMIS) using an appropriate disaster code assigned to the event by FHWA's Office of Program Administration. Disaster codes are discussed further below.
Option 2 - Use of Regular Federal-aid Highway Funds
Regular Federal-aid highway funds, appropriate for the type of Federal-aid highway (National Highway System [NHS] or Surface Transportation Program [STP]), can be used. Regular Federal-aid funds must comply with the obligation limitation in effect for that class of funds used.The Federal share would be that appropriate for the ER work being authorized. Under this option, the letter of authorization should indicate that the project will be converted to ER funding when ER funding becomes available, at which time the regular Federal-aid funding, and the accompanying obligation limitation, will be released from the project.
This option can be used for both emergency repairs to restore essential traffic as well as permanent repairs. This option has the advantage of allowing immediate Federal reimbursement for costs that are being incurred. Further, it provides a means of securing FHWA authorization of the permanent repair activities so that they may proceed. A disadvantage is that use of regular Federal-aid funding sources will likely require the use of obligation limitation until the project can be converted to ER funding.
Option 3 - Use of Advance Construction (AC)
Although 23 U.S.C. 115 does not contain authority to advance construct ER funds, it does designate several other Federal-aid funding sources that can be used for advance construction. Thus, a project advance constructed under any of the funding sources designated in Section 115 could later be converted using ER funds. For example, an ER type project can be authorized as an advance construction STP project and later converted to an ER project as ER funds become available. An authorization under this option should be made following the general guidance for advance construction of Federal-aid. The letter of authorization should confirm the State's intention to convert the project to ER funds.
This option can be used in those instances needing prior FHWA authorization of permanent repair work. This option has the advantage of providing a means of securing FHWA authorization of the permanent repair activities so that they may proceed. Further, it does not use obligation limitation. However, a State must have adequate funding resources of its own to proceed with the project until it can be converted to ER funding.
ER Events Awaiting a Division Administrator Finding
When a potential ER event has occurred, the State is empowered to undertake immediate emergency repairs to restore essential traffic service and to prevent further damage to Federal-aid highway facilities. Properly documented costs will later be reimbursed once the Division Administrator makes a formal finding that the event qualifies for funding under the ER program.
However, if a delay in the Division Administrator's formal finding will likely delay the orderly progression of both temporary and permanent repairs, it might be preferable to proceed with ER activities using Options 2 or 3 above, subject to the following requirements:
The State's formal request for ER funding, along with an acceptable Damage Survey Summary Report has been submitted to FHWA Division Office. Various methods for developing State requests are discussed in Chapter III.
Division staff managing the ER program has reviewed the ER request and recommends that it be approved, excepting any questionable or ineligible ER activities.
FHWA letter of authorization under Options 2 or 3 will stipulate that any use of ER funding on the project is subject to the Division Administrator's formal finding that the event qualifies for funding under the ER program.
Options 2 or 3 should be limited to specific events where the delay in securing a formal finding is lengthy and is delaying repair efforts. Any Division Office authorization of work prior to the Division Administrator's formal finding should be coordinated with the Office of Program Administration.
Use of Option 1 is not acceptable when there is a delay in the Division Administrator's formal finding. Under no circumstances can ER funding from any source be used on an event until the Division Administrator's finding has been made.
General Comments
Prior to FHWA authorization of permanent ER repairs using regular Federal-aid funds or the advance construction process, it is strongly recommended that the Division Office review the activities and project features to be funded to assure their eligibility before starting construction.
Project Oversight
ER projects for permanent repairs should be processed following regular Federal-aid procedures. ER projects the same as or sufficiently similar to regular Federal-aid projects subject to the 23 U.S.C. 106 oversight exceptions can also be administered under these exceptions, subject to the following two conditions:
Any betterments to be incorporated into the project and for which ER funding is requested must receive prior FHWA approval.
The FHWA reserves the right to conduct final inspections on all ER projects. The Division Administrator has the discretion to undertake final inspections on ER projects as deemed appropriate.
Combined Federal-Aid And Emergency Relief
When the State or applicant decides not to replace a damaged facility in-kind and proposes work in excess of the work eligible for ER funds, a combined project may be programmed using ER funds to the extent eligible. Other Federal-aid funds may be used for the additional work. Separate programming is required for each class of funds with appropriate cross-referencing.
Construction Start Deadline (Time Extensions)
ER funds are allocated to assist the States and other agencies or organizations in conditions of emergency. Consequently,after approval of programs and allocation of funds, all projects should be completed promptly. Failure to advance an approved ER project to completion within a reasonable period of time could result in withholding of funding for that project. Emergency opening work should be accomplished within one month of accessibility to the site under normal circumstances.
Unless there is satisfactory justification for project delay to warrant its retention, projects for permanent repairs that have not advanced to construction obligation by the end of the second fiscal year following the year in which the disaster occurred cannot be authorized. Justification for such delay and request for time extension must be submitted to the FHWA Division Administrator for approval. Time extensions are granted in one-year increments. Such delays may be caused by the need for extensive environmental evaluation, litigation, or complex right-of-way acquisition.
In certain situations the delay of permanent work may be as much as two to three years. Permanent restoration work, for example, could be deferred to permit study of a serious slide condition, thereby allowing sufficient time to adequately design a permanent correction.
FHWA as the Construction Agency
State or local agencies may request the FHWA to accomplish repairs, reconstruction, or relocation of sections that are on the Federal-aid highways. The emergency operations to restore essential traffic should be handled by the State or local agency. In any event, where such situations are anticipated, a letter of request should be prepared by the State or local agency through the State to the Division Administrator expressing the desire to have the FHWA perform the work. The Division Administrator should promptly forward any such request to the Federal Lands Highway Division Engineer along with his/her recommendations, and arrange for a joint field inspection by the two offices, the local agency, and/or the State.
Project Designations and Numbering
All ER-funded projects on a Federal-aid highway (not on a Federal road) shall be designated with the prefix "ER". ER projects located on Federal Roads use the prefix letters "ERFO" (Emergency Relief Federally Owned). Combination projects designated "ER-ERFO" may be used where portions of a project on a Federal-aid highway are also located on a Federal road.
The State may designate the project numbering system to be used for each project resulting from a natural disaster or catastrophic failure. Where an existing "ER" series has been established, the State may continue the sequence of the established series of project numbers for several individual improvements, with separate agreement numbers for individual improvements.
Projects may be numbered to conform to the system established for other Federal-aid projects. For the project number, enter seven digits (four digits for Route number and three digits for agreement number) preceded by the prefix ER.
Disaster Code
Division offices should be prepared to readily identify obligations by appropriation and by disaster. The Fiscal Management Information System (FMIS) provides a disaster number entry, which should be carefully entered to ensure that legislated limits on obligations for a particular disaster are not exceeded.
The disaster number is assigned at the time of the finding. This number should be shown as part of the disaster identification on the program. It consists of the fiscal year of the initial damage, followed by the sequence number (based on the number of disasters submitted by a State) of the disaster. Thus, the first disaster submitted by a State where the event began on or after October 1, 2002, would be shown as "02-1," with any subsequent eligible disasters submitted during the FY 2002 following in sequence as "02-2," etc.
Item number 42 in the FMIS should be completed as follows: The Disaster Code (five digits) should be used. The first four digits represent the fiscal year assigned to the event, e.g., 2002 or 2003, etc. Enter as the fifth digit the sequence number assigned to the disaster. For example, the first disaster approved in a State for FY 2003 would be coded 20031.
Construction Contracts /Force Account
Permanent repair and reconstruction work, not accomplished as emergency repairs, must be done by a competitive bid contract method unless the State demonstrates some other method is cost effective as described in 23 CFR 635.204.
Emergency repair work may be accomplished by the contract, negotiated contract, or transportation agency force account method as determined by the transportation agency as best suited to protect the public health and safety.
Emergency Repairs
Work shall be undertaken by the advertised contract method where feasible. The FHWA may approve a waiver of the advertising requirement if State or local law authorizes such procedures, and the contract method chosen is suitable for the proposed corrective work. Public agencies may perform force account work but are not permitted to compete for solicited or negotiated contracts.
Force Account
The term force account means the direct performance of highway construction work by a State transportation agency, a county, a railroad, or a public utility company by use of labor, equipment, materials, and supplies furnished by them and used under their direct control. Since the National Guard does not fall under any of the above-mentioned categories, ER funds cannot be used to pay for National Guard services on a force account basis.
Due to the emergency character of the work, State and local forces and/or negotiated equipment rental contracts may be used to perform a considerable portion of the emergency repairs. In accordance with 23 CFR 635.204(b), a formal finding for force account work for emergency repairs is not required.
Solicited Contract
A solicited contract may be warranted due to the emergency character of the work. The State may contact a reasonable minimum number of contractors by telephone to solicit equipment rental, labor, and materials bids for a specific amount of work. 23 U.S.C. 112(c) requires that a sworn statement of non-collusion to restrain of free competitive bidding must accompany the contractor's bid submittal. A summary showing how the solicitation was conducted, who was contacted, and the responses by the contractors must also be prepared.
Negotiated Contract
A negotiated contract provides for performance of a certain amount of work after a contractor has been selected. Usually such contracts include compensation for "move-in and move out" costs and/or a percentage of cost based on actual cost of equipment, labor, and materials. If one contractor acts as the prime contractor, there may also be an additional percentage of actual cost included for supervision of the other contractors' equipment on the job, similar to a subcontracting agreement.
If a negotiated contract is used for ER repairs, neither the sworn statement required by Section 112(c) of Title 23 nor the cost effective finding required by 23 CFR 635 is required.
Permanent Repairs
Permanent repair and reconstruction work, not accomplished as emergency repairs, must be done by contract awarded by competitive bidding unless the State demonstrates some other method is cost effective as described in 23 CFR 635.204. The contracting agency must assure an opportunity for free, open, and competitive bidding, including adequate publicity of the advertisements or call for bids. However, in certain cases, ER construction projects can be accelerated using other contracting techniques described below.
Techniques to Accelerate Projects
Innovative contracting procedures available to accelerate ER construction projects include cost-plus-time bidding, commonly referred to as A+B method, lane rental, and design-build contracting, and they are discussed below. Other methods such as abbreviated plans, shortened advertisement period for bids, and incentive/disincentive clauses are commonly used to accelerate ER construction projects, also discussed below. Contracting agencies must comply with 23 CFR Part 636 when using the design-build delivery system to provide for the permanent repairs of a damaged facility.
Cost-Plus-Time Bidding
Cost-plus-time bidding, more commonly referred to as the A+B method, involves time, with an associated cost, in the low bid determination. Under the A+B method, each bid submitted consists of two components:
The "A" component is the traditional bid for the contract items and is the dollar amount for all work to be performed under the contract.
The "B" component is a "bid" of the total number of calendar days required to complete the project, as estimated by the bidder (calendar days are used to avoid any potential for controversy which may arise if work days were used).
The bid for award consideration is based on a combination of the bid for the contract items and the associated cost of the time, according to the formula:
(A) + (B x Road User Cost / Day)
This formula is only used to determine the lowest bid for award and is not used to determine payment to the contractor.
The contract incorporates a disincentive provision that assesses road user costs to discourage the contractor from overrunning the time "bid" for the project. In addition, the contract should include an incentive provision to reward the contractor if the work is completed earlier than the time bid.
For critical projects that have high road user delay impacts, the A+B Method can be an effective technique to significantly reduce these impacts. This technique has successfully been used on an ER project to replace a damaged freeway bridge in a large urbanized area.
Lane Rental
Like cost-plus-time bidding, lane rental concept encourages contractors to minimize road user impacts during construction. The contract incorporates a lane rental fee assessment based on estimated cost of delay or inconvenience to the road user during the rental period. The fee is assessed for the time that the contractor occupies or obstructs part of the roadway and is deducted from the monthly progress payments.
The bidding proposal includes the lane rental fee rates in dollars per lane per time period, which could be daily, hourly, or fractions of an hour. Neither the contractor nor the contracting agency gives an indication as to the anticipated amount of time for which the assessment will apply and the low bid is determined solely on the lowest amount bid for the contract items.
The rental fee rates depend on the number and type of lanes closed and can vary for different hours of the day. For example, the peak travel periods between 6:30 AM and 9:00 AM and 3:00 PM and 6:00 PM might have an hourly rental fee of $2,000 for closing one lane, while a lane could be closed at any other time at a rental fee of $500 per hour.
Lane rental encourages contractors to schedule their work to keep traffic restrictions to a minimum, both in terms of duration and number of lane closures. The lane rental concept has merit for use on projects that significantly impact the traveling public; major urban area projects are prime candidates for this approach.
Design-Build
The design-build concept allows the contractor maximum flexibility for innovation in the selection of design, materials and construction methods. With design-build procurement, the contracting agency identifies the end result parameters and establishes the design criteria. The prospective bidders then develop design proposals that optimize their construction abilities. The submitted proposals may be rated by the contracting agency on such criteria as design quality, timeliness, management capability and cost, and these criteria may be used to adjust the bids for the purpose of awarding the contract.
By allowing the contractor to optimize its work force, equipment, and scheduling, the design-build concept offers greater opportunities for innovation. However, along with the increased flexibility, the contractor must also assume greater responsibility. Extended liability insurance or warranty clauses may be used to ensure that the finished product will perform as required.
From the contracting agency's perspective, the potential timesavings are a significant benefit. Since the design and construction are performed through one procurement, construction can begin before all design details are finalized. For example, pile driving could begin while bridge lighting is still being designed. Because both design and construction are performed under the same contract, claims for design errors or construction delays due to design errors are not allowed, and the potential for other types of claims is greatly reduced.
Federal-aid funds may participate in design-build contracts when approved and awarded using competitive bidding procedures. For further details, refer the final rule published in the December 10, 2002 Federal Register.
The design-build method of contracting provides an alternative to the traditional design-bid-build contracting method, but it should only be used for projects that fit the design-build process. The contracting agency must adequately define the scope of work prior to the request for proposals. A design-build project should have sufficient scope and complexity to allow for a strong creative design component. Relatively small or simple projects such as roadway resurfacing or minor roadway widening projects do not provide significant design components, and are not ideal projects for design-build. The design-build method assists in expediting project delivery. It is not intended to provide a means for quick obligation of funds or to compensate for insufficient State personnel resources.
Abbreviated Plans and Shortened Advertisement Period for Bids
The FHWA Division Administrator may approve abbreviated plans, provided all essential information necessary to describe the work to be accomplished and to determine the reasonableness of unit prices for contract or force account work have been provided. Also, the time period for advertisement of bids may be shortened; however, a State may also need to suspend its own rules and regulations covering advertisement periods.
Short List of Qualified Contractors
Another technique that has been used successfully to accelerate contract bidding and award involves using a short list of qualified contractors to bid on a project. For example, a minimum of three bidders may be selected based on the following: early willingness to respond, type of work, prior demonstrated ability to move swiftly, availability, staff and equipment, and having previously worked in the area. Generally, a contractor awarded a contract as low bidder on one project is not included in the short list of qualified contractors for the next project; however, the unsuccessful bidders are.
Contract Requirements
As already noted, permanent repair and reconstruction work not accomplished as emergency repairs must be done by a competitive bid contract method unless the State DOT demonstrates some other method is cost effective as described in 23 CFR Part 635.204. When permanent repair work not accomplished as emergency repairs is performed under a contract awarded by a local public agency, all Federal contract provision requirements outlined or referred to in 23 CFR Part 633A shall be met.
Davis-Bacon Act
Davis-Bacon wage rates on Federal-aid construction contracts apply for all ER contracts. This provision cannot be waived by the FHWA. Davis-Bacon Act requirements may be waived only by executive order of the President, ref. 40 U.S.C. 276a-5, which states, "In the event of national emergency the president is authorized to suspend the provisions of 276a to 276a-5 of this title."
Buy America
The FHWA's "Buy America" regulations (23 CFR Part 635.410) apply to all Federal-aid highway construction projects that permanently incorporate either iron or steel. A State may request that these provisions be waived if "the application of those provisions would be inconsistent with the public interest" (23 CFR 635.4109(c)(1)(i)).
Disadvantaged Business Enterprises (DBE)
The normal DBE requirements are applicable to the Emergency Relief funded projects.
Americans With Disability Act (ADA)
The FHWA operates under the ADA regulations issued by the Department of Justice (DOJ). According to DOJ, no waivers from these regulations are possible. The governing statute and DOJ regulations make no provision or exception for emergency relief situations. The ADA accessibility guidelines issued by DOJ, however, do provide guidance concerning temporary structures.
Convict Labor
The convict labor prohibition in 23 U.S.C. 114 applies to ER projects. Convict labor cannot be used in ER construction projects.
Environmental Considerations:
Repair projects under the ER program must comply with the requirements of the National Environmental Policy Act (NEPA) of 1969. Emergency repairs to restore essential travel, minimize the extent of damage, or protect remaining facilities are normally classified as categorical exclusions under 23 CFR 771.117(c)(9), as are ER projects to restore permanently the existing facility in-kind at the existing location, ref. 23 CFR Part 771.117(d). However, if impacts to protected or otherwise sensitive or high-value resources are possible, advance coordination with the appropriate local, State, and Federal resource agencies should be closely considered to avoid or minimize project delays or shutdowns.
On occasion, an ER project that includes a betterment, whether or not eligible for ER funding, may require further NEPA review. Although on the surface a project may appear to qualify for a categorical exclusion, certain betterments may need either an environmental assessment (EA) to determine whether or not the project will cause significant environmental impacts, or an environmental impact statement (EIS) if significant impacts are predicted. This is illustrated by the following example:
Project Betterment Requiring Environmental Evaluation
When repairing a section of roadway inundated and seriously damaged by floodwaters, it was determined that a grade raise could be economically justified for ER funding. Raising the grade of the roadway will require small amounts of additional right-of-way from adjacent wetland areas. In addition, in future flood events, the higher roadway grade could impound additional water and flood other upstream areas. As a result of the project's potential impact on wetlands and future flooding patterns, further evaluation was necessary to determine the appropriate level of NEPA documentation.
The NEPA project development process provides the final Federal-aid highway project decision, occasionally including a facility on new location. As noted above, ER projects to construct replacement facilities may require environmental assessments or environmental impact statements, depending on the potential level of impacts to resources, the value of the resources, and what, if any, legal protections apply to the resources. However, even replacement facilities constructed at the existing location of the damaged facility may require extra environmental evaluation beyond that needed for a routine categorical exclusion. These situations are illustrated by the following examples:
Replacement at New Location
A roadway was permanently submerged by water backing up behind a naturally created dam, and it has been determined replacement of the inundated highway facility at its existing location is neither practical nor feasible, and various alternate locations may be available to relocate this section of highway. The NEPA process documents consideration of appropriate project alternatives and their potential impacts and determines that the preferred alternative is replacement of the old facility on a specific new location or site. Although a categorical exclusion can be used if circumstances merit, early environmental coordination may determine that an EA or an EIS is necessary to do this.
Replacement at Existing Location
An existing bridge over a river has been damaged beyond repair but can be replaced with a bridge of comparable width and length at the same location. However, this section of river contains critical habitat for a Federally listed endangered species, which would be seriously impacted during the scheduled construction period. As a result of this potential impact, the project decision could not be categorically excluded, and additional NEPA evaluation and documentation was necessary.
Design Standards
Reconstruction of damaged roadway and bridge facilities must meet adequate standards, including appropriate safety features. Reconstruction of extensively damaged facilities, including betterment projects when adequately justified, should meet the current applicable design standards. Replacement of roadway facilities other than bridges is limited to the existing number of lanes and surface type. Bridges may be replaced with a facility that meets current geometric and construction standards required for the type and volumes of traffic that such a facility will carry over its design life.
State Emergency Manual
An important element of emergency procedures is the State's emergency operation plan. Since Federal-aid funds are not available for maintenance and State maintenance personnel will handle much of the emergency operations, the State's instructions should be carefully reviewed. It may be appropriate to supplement the State's instructions with portions of this manual, for example, Chapter V, Disaster Assessment and Damage Survey Summary Report and Chapter II, Eligibility of Damage Repair Work
