Last year's Hurricane Irene left a fire station in New York under 8 feet of water. Tthe 56-year old station had to be condemned. With minimal funds available, the fire department has to rely onto provide funding for a new fire station, according to the architect who wrote to tell me about the situation.
Technology and construction have changed greatly since the original station was built. But FEMA’s policy is to provide funding only for what it considers a “like-kind” replacement — meaning the new station can be no larger and no better than what it is replacing. So, it appears that the fire department is doomed to the same facility it started with, without adhering to new standards or recommendations for updated fire station design.
Alexander Greenberg, FEMA Region II public assistance branch chief, told the architect that, “A proposed code and standard can only be determined to be eligible if it meets all of the following criteria: It must
- Apply to the type of repair or restoration required; (Standards may be different for new construction and repair work)
- Be appropriate to the pre-disaster use of the facility;
- Be reasonable, in writing; and formally adopted and implemented by the State or local government on or before the disaster declaration date or be a legal Federal requirement applicable to the type of restoration; Design standards, guidelines, policies, industry practices, or other non-mandatory provisions are not acceptable.
In addition, it must be applied uniformly to all similar types of facilities with the jurisdiction of owner of the facility; and also, for any standard in effect at the time of the disaster, it must have been enforced during the time it was in effect.”
FEMA previously had published fire station design guidelines — Safety and Health Considerations for the Design of Fire and Emergency Medical Services Stations — through the . But according to Greenberg:
“FEMA Public Assistance does not recognize F A-168 [the prior FEMA publication] as a 'Standard' as defined by 44 CFR §206.221(i) and §206.226(d). Any upgrades requested by an applicant in order to adhere to the guidance found in this document are not eligible for FEMA funding as basic eligible work and cost under the 'Codes and Standards' criteria.”
But the fire department's previous design already is undersized. In fact, it:
- Violates NYS Code requirements for egress (exiting offices through corridors vs. through the apparatus bay)
- Lacks ADA accessibility
- Lacks ANSI clearances at doors, etc.
- Lacks code compliant stair to the mezzanine
- Lacks code minimum number of toilet fixtures
- Lacks safe clearance around trucks (no code reference for this)
- Violates NYS Energy Code implication regarding the thickness of exterior walls
- Possibly falls short of OSHA compliance
Some of the shortcomings listed here are based on codes and some are standards that Greenberg has stated will not be accepted. The new building will have to be larger than the existing and this will generate a debate with FEMA.
The New York fire department mentioned above has few financial resources beyond whatever FEMA provides. They need assistance developing an approach that will allow this project to proceed.
This is the same situation that fire departments in New Orleans area encountered when trying to rebuild fire stations that were destroyed by Hurricane Katrina. Chief Thomas Stone learned the hard lessons of dealing with FEMA when he tried to rebuild and restore 10 fire stations in St. Bernard Parish, La. Fire departments impacted by Hurricane Sandy now are going through the same process with FEMA.
What about some common sense in helping a fire department get back in service?