Guidelines for the Disaster Financial Assistance Arrangements - Interpretation Bulletin 10: Interface Fire Disasters
* Note the following references in the Guidelines: "province" always refers to provinces and territories.
Interpretation Bulletin 10 PDF (683KB) (as of June, 2023)
Issue
Guidance on the application of the DFAA as it pertains to fire disasters, including:
- the disaster period and affected geographical area;
- pre-emptive costs; and
- mitigation enhancements.
Definitions
- Defensible Space
- The area around a building in which vegetation, debris, and other types of combustible fuels have been treated, cleared, or reduced to slow the spread of fire to and from the building.
- Evacuation Alert
- A situation where proper authorities notify individuals that they may be in danger and should be prepared to evacuate the area should it become necessary.
- Evacuation Order
- A situation where proper authorities require individuals to leave at risk areas.
- Evacuation Rescind
- Evacuees are allowed to return to the area previously evacuated, having been advised that the danger has passed.
- Essential services
- A service, facility or activity that is or will be, at any time, necessary for the safety or security of the public.
- Essential goods and supplies:
- Any goods and supplies that are necessary for the health, safety and welfare of people, including, without limitation, the following:
- food, water and other beverages;
- fuel and gasoline;
- health care goods, pharmaceuticals and medical supplies;
- personal hygiene, sanitation and cleaning goods.
- Interface fire
- A fire that poses a threat to built-up areas (e.g., a threat to human life, private property, public infrastructure, critical infrastructure, etc.) and results in an evacuation, or property damage, or disruption of the delivery of essential goods and services.
Context
The DFAA are intended to address natural disasters resulting in extensive property damage or disruption of the delivery of essential goods and services. They do not apply to the fighting of forest, prairie, grass or wildfires, except where they pose a threat to built-up areas (e.g., a threat to human life, private property, public infrastructure, critical infrastructure, etc.) - and then primarily for pre-emptive actions, evacuation and damaged infrastructure restoration (Guidelines, Section 1.4).
Furthermore, public sector response costs for regular salaries, normal operating expenses, and emergency service costs related to routine emergency management functions (as opposed to incremental costs of responding to broader disaster consequences) are not eligible under the DFAA (Guidelines, Section 4.1.3).
Interpretations
Disaster period and affected geographical area
For the purposes of DFAA eligibility, the disaster period (including beginning and end dates) and the affected geographical area must be defined and accepted by the province and the Government of Canada (Guidelines, Section 2.1.3). These data points will inform the Order in Council, which when approved, declares the provincial emergency to be of concern to the Government of Canada, and authorizes the provision of financial assistance to the affected province.
When defining the disaster period and the affected geographical area, Public Safety Canada (PS) suggests referring to a list of the fire season’s evacuation alerts and orders.
- The start date for the disaster period generally correlates with the date of the earliest evacuation order on the list.
- There are exceptions where the evacuation alert date can be used as the start date for the disaster period. However, the province would need to confirm that the alert resulted in an evacuation, or property damage, or disruption of the delivery of essential goods and services. These cases will be reviewed by PS on a case-by-case basis.
- PS understands that in some remote regions, e.g., fly-in communities, orders or alerts may not be available as reference points. These cases will be reviewed by PS on a case-by-case basis.
- Conversely, the end date for the disaster period typically corresponds with when the latest evacuation order was rescinded by proper authorities.
- It is important to note that the disaster period should not include the dates prior to the disaster’s onset, where pre-emptive activities were ongoing (Guidelines, Section 3.2).
- In the Order in Council, the affected geographical area is defined as a list of census divisions wherein a community was evacuated, or sustained property damages, or experienced disruption of the delivery of essential goods and services during the defined disaster period. The province should at minimum include a list of community names in their records, or if time permits, a list of census divisions is preferable.
In order to support the submitted disaster period and affected geographical area, the province will need to provide records to substantiate the request. Records may include, but are not limited to:
- List of evacuation orders (date issued; date rescinded; affected communities);
- Situational reports;
- Geographical maps;
- News articles and social media snapshots;
- Satellite, thermal, or aerial imaging;
To the extent possible, provinces should organize their records per fire site (evacuation dates; with expenditures broken down by pre-emptive, response, and recovery cost categories) to facilitate the final audit.
Pre-emptive Costs
Costs for pre-emptive action (typically up to two weeks prior to the evacuation order for the fire site) may be eligible (Section 3.2.1). Examples of eligible expenses could include actions taken to increase the defensible space between public or private property and wildland, activities to temporarily increase the resiliency of structures, and evacuation planning activities, etc.
It is important to note that measures that were taken as a normal part of preparations to avoid or mitigate the effects of a “future fire” prior to its onset are not eligible. Furthermore, if for any reason the threatened disaster does not occur (e.g., the fire does not result in an evacuation, or damaged property, or disruption of the delivery of essential goods and services), any expenses incurred for pre-emptive measures would not be eligible (Guidelines, Section 3.2.2).
In order for the pre-emptive expense related to the fire to be eligible under the DFAA, the province will need to provide records to substantiate the claim. Records should include, but are not limited to:
- Evidence that the expense is related to the event;
- Evidence that the pre-emptive activities to which the expenses are related are separate from ongoing maintenance and other routine work;
- Evidence that the pre-emptive costs to protect the people and their property are above what the province could reasonably absorb on its own;
- Evidence that the danger was imminent (e.g., an evacuation order given by proper authorities, etc.); and
- Evidence that provincial expenditures have actually been paid out for the pre-emptive costs.
Mitigation Enhancements
Mitigation enhancements undertaken within the repair of damaged structures that were not insured or insurable could be eligible for cost-sharing under the DFAA. See Interpretation Bulletin 7: 15% Mitigation Enhancements for details. Examples of mitigation enhancements that could help reduce the structure’s vulnerability to future fire disasters could include using non-combustible materials when replacing damaged roofs, using fire-resistant siding when repairing damaged homes, etc.
In order to support the submitted mitigation project costs, the province will need to provide records to substantiate the request. Records may include, but are not limited to:
- Evidence that the infrastructure to which the enhancements were applied to was DFAA eligible (e.g., damage linked to disaster, infrastructure was not insurable, etc.);
- A reliable estimate of the repair of the damaged infrastructure to its pre-disaster condition (appraisal value);
- Evidence that the enhancement is reasonable/justifiable (e.g., engineer report confirming that the project will reduce the vulnerability of the damaged infrastructure to future natural disasters);
- Evidence that the project was not linked to routine maintenance, improvements/upgrades, or replacements of public infrastructure;
- Evidence that the project costs are not eligible for reimbursement/cost-sharing under another federal program existing at the time of the disaster; and
- Confirmation that the work was completed and paid for.
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