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Cities of Dublin and Pleasanton | Disaster Debris Management Plan | 2022 46 from private commercial property by a State or local government may be eligible for reimbursement only when such removal is in the public interest. To receive Public Assistance reimbursement for private property debris removal, an applicant at a minimum must provide FEMA with a right-of-entry agreement including a hold-harmless agreement and indemnification applicable to the project scope of work, photos documenting the condition of the property, a private property debris removal assessment establishing the scope of work, and documentation of an environmental and historic review, if appropriate. State and local governments must take reasonable steps to prevent a duplication of benefits and to verify that insurance coverage or any other source of funding does not exist for private property debris removal. When the debris removal is covered by insurance, insurance proceeds must be used as the first source of funding. Cal OES requires that local governments check homeowner insurance policies to determine coverage and to collect insurance proceeds to return to FEMA and the state. Cal OES also strongly suggests that right-of-entry documents include an explicit requirement that the property owner forward insurance proceeds to the applicant agency. If private property debris removal is authorized and considered for the Cities, the following documentation will be required by the state and FEMA:  Right-of-Entry (ROE) and Hold Harmless Agreements (HHA) – The City executes signed ROE and HHA documents with private property owners holding the federal government harmless from any damages caused to private property. A sample ROE/HHA agreement is in Attachment M  The jurisdiction may execute ROE and HHA forms prior to a disaster under the condition that the ROE and HHA forms do not reference a particular incident or disaster number. The sample ROE/HHA includes a stipulation that the property owner will report any insurance settlements paid to the property owner for debris removal to the jurisdiction , if the property had debris removed at government expense. This will aid the Cities in recouping costs of debris removal from private property  Photos – Photograph conditions of private property before debris removal and after completion of debris removal should be made to protect the interest of the Cities. The photos will support verification of the address of and scope of work on the property.  Private property debris removal assessment – The assessment will be a property-specific form to establish the scope of eligible work on the property. The assessment can be in the form of a map or work order, provided the scope of work can be clearly identified.  Documentation of environmental and historical review – Debris removal efforts on private property must comply with all review requirements under the California Environmental Quality Act (CEQA), and 44 CFR (specifically parts 9, Floodplain Management and Protection of Wetlands, and 10, Environmental Considerations). 3.5.2 Hazardous Trees Determining removal of hazardous trees and stumps is challenging. FEMA has established criteria to assist in making these determinations, using objective information that can be collected in the field. The following procedures align with the FEMA Public Assistance Program eligibility