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2012-1760-Minutes for Meeting August 03,2012 Recorded 8/27/2012COUNTY NANCYUBLANKENSHIP,FCOUNTY CLERKDS CJ ~41Z-1160 COMMISSIONERS' JOURNAL 08/27/2012 8;41;43 AM II II I) I~~~IIIII~IIII I ~II 2 1 - B0 Do not remove this page from original document. Deschutes County Clerk Certificate Page Deschutes County Board of Commissioners 1300 NW Wall St., Suite 200, Bend, OR 97701-1960 (541) 388-6570 - Fax (541) 385-3202 - www.deschutes.or MINUTES OF MEETING - FEMA GRANT PROGRAM DESCHUTES COUNTY BOARD OF COMMISSIONERS DeArmond Room, Deschutes Services Building FRIDAY, AUGUST 3, 2012 Present were Commissioners Anthony DeBone, Alan Unger and Tammy Baney. Also present were Erik Kropp, Interim County Administrator; Mark Pilliod, County Counsel; Joe Studer and Ed Keith, County Foresters; and Katie Lighthall of Project Wildfire. Also present were John Jackson and Ken Fahlgren of Crook County; Nick Strader of Representative Greg Walden's office; Susanna Julber of Senator Merkeley's Office; and Wayne Kinney of Senator Ron Ryden's office. By conference call, present were General Mike Caldwell, Deputy Director of State Affairs, Oregon Military Department; Martin Plotner, Deputy Director, Office of Emergency Management; and John Ketchum, Keno Fire Chief, representing Klamath County. Chair DeBone opened the meeting at 9:05 a.m. The purpose of the meeting was to review and address issues with three FEMA grants, and the FEMA grant program in general. Joe Stutler explained that there have been ongoing issues with three FEMA grants. The purpose of the meeting is to get support from the participating counties and some understanding from the agencies, to work towards problem solving. He provided copies of documents including a memo dated August 3, 2012, plus the National Wildland Fire and Cohesive Strategy document. There have been a number of administrative and legislative barriers that indicate change must happen to implement the strategy much more efficiently. He hopes this is the correct path forward. Minutes of FEMA Meeting Friday, August 3, 2012 Page 1 of 8 Pages He then referred to his memo and the historical prospective. (A copy is attached for reference) Erik Kropp asked how the 10:1 ratio for sweat equity work came about. Mr. Stutler explained that the owners do the work, and put out the debris or take it to a specified site. They review properties and found that on average there is about 10 cubic yards to each treated acre, whether pine or juniper. This generates about 100,000 yards per year. They cannot be there to monitor each and every property owner while they do this work. It is not physically or economically possible. Wayne Kinney with Senator Wyden's office asked why the fiscal branch of the agency is objecting, when this does not seem to be a fiscal issue. Mr. Stutler stated that they had a problem with the ratio. For two years documentation was submitted under this protocol, and it was certified as the standard and well-tracked. Under the environmental compliance part, they wanted three different environmental assessments; but this money could be spent better elsewhere. They are no closer to implementing the 20120 grant and it needs to be implemented this federal fiscal year. He added that this is such a hot potato for FEMA, Region 10 has to be approved by Washington, DC. It is hard to deal with a bureaucracy, especially at two administrative levels. He just wants to protect communities and create jobs. Mark Pilliod asked if Region 10 questions the overall volume gathered through sweat equity, and whether it is the ratio or the volume. Mr. Stuller replied that the program side of FEMA feels the work was done well and that they overachieved. The environmental side had a problem at first with the footprint, but are now okay with this. The fiscal side does not seem to look at anything but the ratio. Mr. Kinney asked if this was the first time this was used. It seems that the fiscal office is rejecting the process that was approved by others at FEMA. Mr. Stutter said yes, and evidently the rules don't fit. Mr. Stutter said the main support was from OEM. Commissioner Baney noted that this all still required reporting, which was submitted, well-documented and accepted over a long time. Minutes of FEMA Meeting Friday, August 3, 2012 Page 2 of 8 Pages Mr. Studer said that this issue was addressed in December and things moved a bit, but were still bogged down. To make this work, they need to do something different to get a different outcome. The National Wildland and Cohesive Strategy group was tasked to come up with a list of barriers and some immediate solutions. The documents list 36. (He referred to the document at this time) He said the main issue is working with an agency that has expertise and the ability to deliver. It has been suggested that part of the grant be given to State of Federal agencies with the appropriate expertise and NEPA authority; they could implement the strategy. This idea has broad traction with the partnership council. The U.S. Forest Service and Interior agencies have been contacted and both would take these grants and move them; all that is needed now is FEMA's approval to do so. This will help the County and this area avoid a system that is broken. It is probably impossible to successfully deal with the FEMA system. It needs to be in the hands of people who understand wildland fire issues. He is seeking the agreement of the three counties who have the same target and need these dollars, to use a different grant agent. Deschutes County is still the principal county, working with Crook and Klamath, and the 2010 grant needs to get moving. He suggested obligating the block grant to one of the federal agencies. They have existing agreements of this kind and can move funding around. It would be for just the 2010 grant, with the counties doing the work. FEMA still needs to be accountable to close out the 2007 and 2008 grants. Mr. Kinney stated this would be an easy one to push. However, they don't know the ins and outs of transferring this over, or how fast it would move. He wants to be sure the money gets here. Mr. Studer asked General Caldwell if he had anything to add. General Caldwell said they would continue to try to resolve the issues, as he feels the work done has been outstanding. He is frustrated with FEMA and thought that the trip to Washington DC to meet with them would help. Resources are short, though, and there will soon be a new director of the OEM, Marty Plotner. Mr. Plotner concurred. The OEM does not get compensated for administration. He can't speak to the techniques and negotiations of the grants, but per the OEM, performance ended in May 2007 and they have until the end of August this year to submit the final documents. They are missing just the specific document relating to owner/match contributions. His office drafted a letter than should go out soon to FEMA. This should close and reconcile the 2007 grant. Minutes of FEMA Meeting Friday, August 3, 2012 Page 3 of 8 Pages Mr. Stutter asked what documentation is missing. Mr. Plotner said that they need to capture the match, a cover sheet showing the time and hours contributed by the property owners. Mr. Stutter stated that the agreement was at the beginning, with 4,000 or more property owners, it would be impossible to document each one. They agreed years ago to the 10:1 ratio. People take the debris to the disposal sites and grinding is done. They have no clue where it all came from. There is no way to know whether someone did, for instance, 1.3 acres and four hours of work. They generated over 80,000 cubic yards of debris in just one year. Commissioner Baney added the goal was how much acreage. They are not able to quantify how much came from each, but can quantify the amount of land that was treated. Mr. Stutter said that there were before and after aerial photos showing the difference. The work was done on thousands of addresses. General Caldwell stated that they took the photos, estimated the tonnage, and submitted this with information on how many properties there were, and figured out how much it takes to clear an acre of land. Mr. Plotner said that this is part of the standstill. This would provide documentation showing the work was done. Nick Strader of Representative Walden's office said he doesn't understand, this was the same information they got six months ago. The concept was to work outside the box, create dumping stations, etc. Now this is all being rehashed. General Caldwell stated they should force them to approve or deny. There is visual evidence and the work is innovative. They might need to go to the federal delegation. Mr. Stutter said that this is the first time the OEM requested this. Four years ago the coalition was told they had overachieved. They reached an agreement on the 10:1 ratio and reported every quarter. FEMA's environmental and program administrators said it was acceptable. He asked if the request for more documentation is coming from the fiscal branch. Mr. Plotner said fiscal, and to show them something that gives tangible evidence. The issue is FEMA and the County are waiting for this. They should be able to close out 2007, due the end of August. Minutes of FEMA Meeting Friday, August 3, 2012 Page 4 of 8 Pages Commissioner Baney said that there is still $78,000 owed to the County. There were actually three site visits. So why are they left holding the bag after having done more with less, and providing a lot of documentation. If everyone leaves this room now, it will be the same thing. They need to call in the delegation to prop this up. Another series of paper pushing may not help. She views the OEM as a partner, but they need a new vehicle and need to move this forward. Mr. Plotner said regarding 2007 to provide snapshots and totals so they can close it out. General Caldwell noted that they were satisfied with the visual evidence and site visits, and they more than met requirements. Mr. Studer said that he sees the sides as not being in agreement. They have given the maps to the OEM and FEMA, have had site visits and attended numerous meetings. He can again send what has already been sent if it will help to make the case. Nick Strader asked if there was a lack of documentation or if the parties disagreed regarding the 10:1 ratio. Mr. Studer stated that they all agreed eventually. They have been moving forward on this premise all this time. Mr. Plotner said that they are looking for documents to close out 2007. For 2008, the performance period ends on September 20, 2012. The scope of work revision has not yet been determined by FEMA for the out of scope work. He needs a support statement regarding the environmental buckets, and a final determination from Region 12 or national. This was the environmental part. Commissioner Baney stated that this involved private property with sidewalks, homes and roads; why is it missing the categorical exclusion piece? Regarding NEPA, they have 54 documents guiding the work that was done. This all goes towards the federal guidelines for categorical exclusion. Mr. Plotner said that each grant and year under the current statute requires the same process. He believes there is an easy position with the legislators. It was submitted and they are waiting for a determination. General Caldwell asked that since this involves private land, are they required to do a NEPA. Mr. Stutler responded that since this uses federal funds, it requires some level of NEPA be followed. NEPA was completed on the other lands. Minutes of FEMA Meeting Friday, August 3, 2012 Page 5 of 8 Pages FEMA has not given itself exclusions to make sense of low-risk work on the ground. There were three environmental assessments for three counties, using sweat equity for minor work. There would be a $300,000 bill if they had to use contractor to do this, and they had it done for 1/10 of the cost. But FEMA is still stuck on 2007 and 2008, and they can't move forward on 2010. Commissioner Baney said that FEMA at their Washington, DC office offered support for 2010 to protect communities. They said that it could go forward. Mr. Kinney asked if the 2007 grant initially required individual monitoring. Mr. Plotner said this started in 2008. Mr. Stutler added that they said they would monitor this, but it became clear within a few months that it was not possible. OEM agreed to the 10:1 ratio. FEMA environmental and program agreed as well, for 2008 but not 2007, but fiscal has not. Mr. Strader asked if they will release funds for 2010 if 2008 is not resolved. Mr. Studer stated that the funds can be obligated and then they can get moving. It has been two years. It can't be implemented as it has been in the past. It is not possible to do this level of monitoring. The only way it will work is to use a block grant through an agency with NEPA authority and wildland fire experience. If the U.S. Forest Service were handling this, OEM would not have to be involved. Commissioner Baney said she thought after the Washington, DC meeting that the issue was resolved. Susanne Julber of Senator Merkeley's office asked how this would be monitored. Mr. Stutler said that the counties use sweat equity and overachieved. The pre- disaster mitigation model used by FEMA has no way of recognizing overachievement. You are penalized for doing better. Commissioner Baney stated that you have to fit the work into buckets, and there is no flexibility. They have done what was asked, covered the NEPA documents and have been trying to protect communities. This needs a new direction. Mr. Studer noted that they agree the counties did their due diligence to solve the problem. They need to change the rules. There are two receptive agencies able to do the work through a block grant. This needs to be obligated for this federal fiscal year. If the three counties agree on this, it needs to be pursued. Minutes of FEMA Meeting Friday, August 3, 2012 Page 6 of 8 Pages General Caldwell agreed that this is not an OEM thing, forest grants. Mr. Plotner said he would like to see forestry work on this instead. Thus far it has been an exercise in futility. He will call Senator Wyden on Monday and insist on help. The delegation is part of the team. John Jackson of Crook County said that he has gone from excitement to do something good for the communities to wondering if there is too much liability. They have worked on this for three years. Mr. Studer asked if he supports moving the block grant to another agency and bypassing the OEM. General Caldwell noted that it is the smartest thing and makes the most sense. The snapshots will be helpful and can be submitted for 2007. He will talk with them on the rest next week. He feels the USDA or the USFS should be involved in the future. Mr. Jackson said Crook County was okay with this change. Mr. Studer noted that Deschutes County supports it. They should move forward with delegation support. John Ketchum of Klamath County indicated he has to get permission for a change like this. They want to understand the requirements and funding level. Mr. Studer said he'd be in touch with the details. The 10:1 ratio won't be an issue for the USFS or the BLM. They need to get the funds obligated quickly, and close out the others. The conference call ended at this point. Mr. Studer said that he has been working since March on one piece of paper; he just got it from the OEM today and it is still wrong. FEMA in inconsistent and unreasonable. The OEM does not use sweat equity or deal with wildland fire issues. The only valid records are those provided by Deschutes County. Mr. Jackson stated that they are arbitrarily holding 2010 hostage due to 2007 and 2008. Given the amount of time and the issues, FEMA should be embarrassed. Ms. Julbert asked if there was an appeal packet given to FEMA. Commissioner Baney said that they had a meeting with them in Washington DC and then another meeting in February, but have nothing in writing from them. Mr. Studer stated that they revised the scope of work for 2007 four times; three times for 2008; and two or three times for 2010. The last 2010 update had an issue with maps, but all of those were GIS based. There was a difference of 17 acres out of thousands, but it was a big deal for FEMA. Minutes of FEMA Meeting Friday, August 3, 2012 Page 7 of 8 Pages They really have to do this through a block grant process with another agency. If FEMA will agree to the block grant concept, the USFS will work with the Department of Forestry and progress can be made. They can't make process with FEMA. He just wants to see that the funds are obligated. Mr. Kinney stated that they are being punished for doing more than what was required. To approach the USFS and FEMA on this is appropriate. Mr. Stutter said he will close the loop with Klamath County, set up a time to outline who the contacts are at the Department of the Interior, and get the right authorities involved to move funds. This agency has already agreed to take this on. Mr. Kropp asked who the media should speak with. Commissioner Unger suggested they speak to Mr. Stutter on behalf of the counties. The legislators will handle their own media contacts. Being no further discussion, the meeting adjourned 10:30 a.m. DATED this -Z -21 Day of hL4-~ 2012 for the Deschutes County Board of Commissioners. Anthony DeBone, Chair Alan Unger, Vice Chair ATTEST: (Jboi~-IS2 Tammy Baney, Commissioner Recording Secretary Minutes of FEMA Meeting Friday, August 3, 2012 Page 8 of 8 Pages Z Z 0 t^ W V1 W J a v a m E co v a N - r O N ' M C ~ 00 Q z z V 4^ W V1 Q W a UCo 00 bo c 'o I~ I v G c 0 m 0 v v ro v IL d ~e m m .O co a~ a m rnZ) ai ~6 ~ .r i ~Co ~Y ~10 3) a(U n= Y W V a) y ~Y Y C w 0 -7) a~ C _ ((a a v rOn E C O C O 41 0 a> v W a) a> Q. Q O O A ~C .N v CL ch o C E :c L C ~ = co rd C O Y E Q Y w U aD Q M N C t D n T C c Y N 7,, C U E O ZN V TmY cv U ~ O 4l rn o Y v _ '---c nQ Z ;a Nmg (A ~-a V)nmELL o 0 o (nnG 0 3 m C ai 0 d E Y Y Q LL U) Ca is 3 z v Y v ~O cn ^ c L -D D Q) ^ c Y ~ c rn 3: 2L) ~ X ~4 0 Y of W~ Q M Ad a Y ~ Q W E 7 0 N CL C? m .C a N C0 0 m v v N ~ C 0 N a, O N D a . - ro C E ? 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C 4- s C O 4- (A W O1 -p ' --Z, V~ 41 L LL O co s Q 01 p d N vi u vu1 LL } = L. t Q 13 Ch w -0 w C -C c 0 f- a= C c- o o L. ti 3 W -0 N CL W -p CL q~ V) 13 CL O } 4- O o s d rOi d o s N N X O1 D V! i N N M s c I N ~ ~p N A ~ LU O 00 00 cc) ' v ~ ~ so o o , MEMORANDUM DATE: August 3, 2012 TO: Deschutes County BOCC; Crook County BOCC; Klamath County BOCC; Senators Ron Wyden and Jeff Merkley; Congressman Greg Walden; Mark Pilliod, Deschutes County Legal Counsel, Erik Kropp, Interim Deschutes County Administrator; Ed Keith, Deschutes County Forester FROM: Joe Stutler, Deschutes County Forester, Retired RE: FEMA/OEM Pre-Disaster Mitigation Grants for Deschutes, Crook and Klamath Counties The purpose of this memorandum is to clearly state the problems and offer a solution to the ongoing issues with the three pre-disaster mitigation grants awarded the counties. Historical perspective: See attached timeline for all details. 2007 Grant received for Deschutes and Crook counties - award amount $1.3 million. Counties implemented for two years. 1,200 acre target, 3,627 acres actually treated. $171,620 residual value and Deschutes County still owed $4,705 against grant. 2008 Grant received for Deschutes and Crook counties - award amount $1.1 million. Counties implemented for one year. 2,000 acre target, 2,957 acres actually treated. $401,823 residual value and Deschutes County still owed $75,987 against grant. 2010 Grant: Deschutes, Crook and Klamath counties notified of award of this third grant in May 2010. 11,141 acres proposed treatments in three counties with total value of $3,931,300. Grant awarded but not received. FEMA and OEM will not proceed with the environmental assessment until the issues with 2007 and 2008 grants are totally resolved and agreement is reached on how to monitor acres treated under the 2010 grant. Deschutes and Crook counties implemented the first two grants (2007 & 2008) for over two years, until mid-September, 2010. The counties had two field reviews by OEM during this time period. During the third field review (September 2010) the issue was raised by FEMA that Deschutes County was working outside of the environmental footprints for both grants. The counties immediately voluntarily stopped all work to resolve the issues. After 1 '/2 years of attempting to resolve the issues with the first two grants, assistance was received by the Oregon congressional delegation which brought all parties back together in January, 2012. This meeting resulted in the development of environmental "buckets" by FEMA to illustrate work performed inside and outside FEMA's environmental footprint. Since that January meeting, no decisions have been made by FEMA or OEM to resolve these issues and award the 2010 grant. August 3, 2012 current status: • 2007 Grant: Revised Scope of Work completed (07 Scope of Work revised four times, frankly because the standards kept changing), FEMA and OEM reviewed all financial records and found $100 discrepancy that Oregon OEM will cover; FEMA Region 10 Financial Division is still disputing the soft match calculation of 10 cubic yards equals 1 acre treated (a standard used for two years during implementation). Still no resolution although both the program and environmental divisions of FEMA Region 10 have cleared this grant but still without formal documentation. • 2008 Grant: Revised Scope of Work completed (revised three times, again with changing standards); NO ACTION from OEM or FEMA other than the initial meeting in January to establish environmental "buckets" which Deschutes County does not support as being the only way to document environmental compliance. The soft match calculation metric will again be a contentious issue with the financial division of FEMA. FEMA will claim based on the environmental buckets that Deschutes County will owe approximately $100,000 for work completed outside of the FEMA environmental footprint. Deschutes County did in fact work in Jefferson County (within 3 miles of the Deschutes County boundary) and the amount spent for the work and reimbursed under the grant is Deschutes County's mistake. • 2010 Grant: Scope of Work revision resubmitted for the third time based on additional requests from FEMA. The heart of the issue is FEMA wants a level of on-ground monitoring for the Sweat Equity fuels treatments that is cost prohibitive. It is physically and financially impractical for county staff to monitor every private landowner who chooses to contribute to the program and FEMA is insisting this standard be in place, discarding the 10 cubic yard equals 1 acre of treatment standard used for the other two grants. Additionally, Oregon OEM has requested of FEMA to reopen the 2010 Grant allowing the agency to receive addition monitoring and grant administration funding. Oregon OEM has stated that if that does not occur, OEM will turn down the 2010 Grant, leaving the three counties without the opportunity to implement the grant and this important fuels mitigation work. Problem Statement: It is clear that neither Oregon OEM nor FEMA are adequately staffed with qualified people to understand and implement wildland fire mitigation projects. It is also clear that the FEMA model for mitigation of natural hazards does not fit with cost effective and efficient "on the ground" wildland fuels treatment. Even with assistance from the congressional delegation last year to bring the parties together to resolve the issues, the facts remain that a preponderance of process, federal and state bureaucracy, and other work priorities have yielded little results other than additional paper work. Within FEMA there are at least three divisions (program, environmental and fiscal) that have not consistently agreed on grant compliance/success for the last two years, thus creating a mountain of bureaucracy and process. OEM has two people to administer all the grants in the State of Oregon, and freely admit that they are understaffed and not qualified to administer a wildland fire mitigation grant. Another compelling reason to solve this issue is unless the money for the 2010 grant can be positively obligated to the counties during this federal fiscal year (September 30, 2012), there is a high likelihood the money will be withdrawn. Solution: During the past two years, a wide range of federal, state, local government, NGO's and private citizen stakeholders have worked diligently to develop the National Wildland Fire Cohesive Strategy, a requirement of the FLAME Act of 2009. One immediate observation during the development of the three phases of the Cohesive Strategy was the removal of current administrative and legal barriers which prevent or hamper the implementation of the three national goals of the Cohesive Strategy which are: • Create and maintain fire resilient landscapes; • Create and maintain fire adapted communities; and • Integrate wildland fire response based on sound risk management. A specific outcome revealed during the creation of Phase II and III was the recognition of the administrative barriers with FEMA pre-disaster mitigation grants and lack of technical expertise to administer and implement the grants. The solution to these issues is for FEMA to provide block grants to federal and state agencies that have the technical expertise, grants management and skills to provide wildland fuels mitigation on private lands to expedite the implementation of the Cohesive Strategy. Specifically Deschutes, Crook and Klamath counties are requesting the following from the congressional delegation: 1. Request FEMA to obligate the dollars for the 2010 grant utilizing existing agreements with either the Forest Service or Interior Agencies i.e. BLM. Transfer the full grant amount to those agencies with wildland fuels experience and authority to complete NEPA, and have them administer the grant. Targets for accomplishment will remain the same. This effort demonstrates an immediate success opportunity for implementing the Cohesive Strategy and over the course of the grant period will create or maintain at least 85 jobs in the counties. 2. Request FEMA to officially close out the grants from 2007 and 2008 and reimburse Deschutes County the outstanding amounts owed. 3. The counties are requesting these actions be completed before the federal fiscal year ends on September 30, 2012. Joe Studer Deschutes County Forester, retired Attachment Deschutes/Crook County FEMA Pre-Disaster Mitigation Timeline August 1990-Awbrey Hall Fire, destroyed 37 homes and burned over 3,000 acres along and inside the City of Bend. Awareness of the wildland fire issues came to the forefront of agencies and the public. August 1996-Skeleton Fire burned 19 homes and burned approximately 18,000 just east of Bend and from those two landmark fires the FireFree Program was created in 1997. 1999-Based on the availability of a Project Impact Grant available from FEMA, a Project Impact Committee was formed in Deschutes County to carry on the efforts with FireFree. November 1, 1999-Deschutes County was one of 200 communities identified in the US to receive a Project Impact Grant for defensible space, implement the FireFree Program and provide other wildland fire mitigation. 2001-Project Impact name change to Project Wildfire, followed by a county ordinance officially creating the organization. October 2005-Deschutes County first became aware of FEMA pre-disaster mitigation grant opportunities. December 2005-Deschutes County attended a two day training session on completion of the grant application hosted by OR OEM. January 2006-Deschutes County/ Crook Counties complete respective all-hazard plans with wildland fire being the number one priority for activities. January 2006-Deschutes/Crook Counties submitted an application for pre-disaster mitigation grant; since there was not a model to complete the Benefit Costs Analysis (BCA) for wildland fire mitigation, Deschutes County hired a contractor to assist with developing an acceptable model and BCA ratio for the grant application. May 2006-Counties notified were not successful with the grant application and encouraged to re- apply. November 2007-The Pre-Disaster Mitigation Grant Program opens. February 2007-Deschutes/Crook Counties submitted an application for pre-disaster mitigation grant for $1.3 million for both counties which would treat 1,200 acres and provide approximately $258,000 of soft match through sweat equity or property owner contributions, 2007 PDM. May 2007-Deschutes County received confirmation that grant application was successful and would be contacted further for information on completing the environmental assessment (EA) with a FEMA Contractor and the intergovernmental agreement between the county and OR OEM. November 2007-Deschutes/Crook Counties met with FEMA contractor (URS Corporation) to discuss the application, environmental concerns, issues and project scope. The Counties were asked for numerous GIS products, previous environmental assessment efforts, cultural information, riparian and other wetlands inventory data, Community Fire Plans and T&E species information. December 2007-Deschutes/Crook counties submitted an application for pre-disaster mitigation grant; this would be the third application and for the amount of $1.1 million and for which 1,000 acres would be treated and $390,000 of soft match. January 2008-Draft EA was shared to both counties for comment (along with the public) and both counties provided comments to the draft, frankly the draft was generic in scope and counties asked for corrections where obvious errors. March 2008-Final EA was completed and posted in both counties for public comment. May 2008--Counties received word that were again successful with the pre-disaster mitigation application and the same process as before would be followed, 2008 PDM. April 2008 tbru May 2008-comments from the '07 EA were reviewed, the Finding of No Significant Impact and Decision Memo from FEMA was completed. June-July 2008---Intergovernmental agreement (IGA) between Deschutes County and OR OEM were completed, along with an IGA between Deschutes and Crook Counties. August 2008---Counties began work on the '07 grant. October-December 2008-----1St quarterly report was submitted to OEM for accomplishments for both counties. November 2008-Counties began working with FEMA contractor (URS Corporation) on '08 Grant, with one face to face meeting on completing the EA process. Counties discuss the application, environmental concerns, issues and project scope. The Counties were asked for numerous GIS products, previous Environmental Analysis efforts, cultural information, riparian and other wetlands inventory data, Community Fire Plans and T&E species information. January-December 2009-Counties reported quarterly (4) on accomplishments for '07 Grant. Jan-July 2009-- Comments from the '08 EA were reviewed, the Finding of No Significant Impact and Decision Memo from FEMA was completed, along with IGA with OR OEM and Crook County. July 2009-Field visit from OEM to review counties work and address reimbursement turnaround times. July 2009-Deschutes County reports 1,200 acre exceeded on '07 Grant from both counties. September 2009-Counties began work on '08 Grant. December 2009-Deschutes/Crook/Klamath Counties submitted a pre-disaster mitigation grant application for $3 million, 3,000 acres treatment and approximately $1 million of soft match for all three counties. January-December 2009-Counties complete quarterly reports for both '07 and '08 grants. January-May 2010-Counties continue work on both grants. May 2010-Field visit for both counties and both grants from OEM. May 2010-Counties notified that was again successful with the pre-disaster mitigation grant application and we would follow the same process as before, 2010 PDM. June 2010-While completing the quarterly report, County Forester noticed that Deschutes County has erroneously reported accomplishments from all grant activities in Deschutes County, including FEMA grants. At that point, the acres and soft match were recalculated to the correct acre and soft match totals for the '07 and '08 grants and submitted. January-December 2010-Counties complete quarterly reports for both '07 and '08 grants. July 2010-Counties notified by FEMA contractor (URS Corporation) to begin the EA work with '10 grant, initially were asked to send in GIS shape files for the project areas and were subsequently never contacted again. September 2010-Field visit by OEM and FEMA, after the visit Deschutes/Crook Counties were informed by FEMA representative that since acres and soft match had been far exceeded the grant totals, FEMA wanted to deem both grants complete and recover the remaining grant values. Discussions at the time occurred about the possibility of a scope of work revision for both grants and there was agreement to do so. For the '07 grant from September 2008 thru April 2010, the counties submitted five reimbursement requests for $655,551.37 and were reimbursed for our work. For the '08 grant from April 2010 thru August 2011, the counties submitted five reimbursement requests for $471,212.43 and were reimbursed for our work. October 2010-Letter from Deschutes County formally requesting Scope of Work revisions for both grants, requests went to OEM to FEMA R-10. December 2010-Deschutes County received a "stop-work-order" for both grants. December 2010Deschutes County sends OEM and F.CMA all federal NEPA completed for the project areas for both grants. Additionally Deschutes County specifically identified all Forest Practices Act applications for the same project areas. January 2011-Meeting with FEMA R-10, OEM-OR and Deschutes/Crook Counties in Salem to discuss Scope of Work and environmental footprint. At this meeting counties met with the environmental compliance and grant performance personnel from FEMA, provided a revised Scope of Work, reviewed all other NEPA completed by both other federal agencies and state agencies and provided maps of all. January 2011-Deschutes/Crook revised Scopes of Work to FEMA/OEM for both grants; additionally revised the 2010 Grant application, and because FEMA had a "new" policy for wildland fire management for the Pre-Disaster Mitigation Grants, counties also amended the '08 and '10 grants to be in compliance with this requirement. February 2011-After the meeting with FEMA and OEM, revised the scopes of work again for the 07', `08' and 2010 grants. March 2011-OEM forwards letter to FEMA requesting scope of work changes. April 2011-FEMA again sends letter requesting Scope of Work changes for '07-'08 grants with new specifics. May 2011-OEM request an extension for '07 grant and that extension is agreed to by FEMA. May 2011-FEMA sends a letter stating that Deschutes County had worked out of the environmental footprint and "suggesting" that the County must either re-pay the money or have that amount deducted from the forthcoming 2010 grant. July 2011-Deschutes County appeals the financial liability letter from FEMA and offers a solution; there is $715,000 remaining grant value, $328,000 (Deschutes County figures) liability, call Grants 07' and 08' "mitigation provided", utilize the remaining grant value for 08' Grant to accomplish new work, complete EA for 2010 Grant Scope of Work and to include any new work areas in 08' and move forward. August 2011-OEM-OR letter to FEMA requesting consideration of work completed as good and mitigation complete. September 2011-FEMA R-10 decision letter to "re-coup" funding. October 2011-FEMA R-10 letter to OEM-OR on their "decision." November 2011--OEM-OR letter to Deschutes County regarding FEMA's letter. November 2011-Conference call with Deschutes, Crook, OEM, General Caldwell and Congressional Delegation to develop a path forward. November 2011-Letter from Deschutes County to OEM, stating we appeal the decision. December 2011-Letter from Deschutes County to OEM stating reasons we appeal the decision. January 2012-Commissioner Baney, County Forester Joe Stutler met with FEMA Headquarters Staff to present the issues and reach a resolution. 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