Use case
Put a line from your scope of work next to the policy that governs it. PAPPAIA answers targeted questions about eligible permanent work, codes and standards, and 406 mitigation — with document, section and page cited for verification.
Citations checked against current published sources 2026-09-04
"Our engineer wants to elevate the replacement electrical panel and swap in submersible pumps. Which of that is code-required restoration, which is 406 mitigation, and what does the policy actually say about each?"
Paste a scope line and ask what governs it. Permanent work restores a facility to its pre-disaster size and capacity — as originally built or later modified — and its pre-disaster function. Not the capacity you happened to be running at the time of the incident. The governing text: 44 CFR § 206.201(i) and (j), § 206.226(k)(1), and PAPPG v5.0 Amended, Chapter 8, Section I (PDF pp. 171-172).
Paste a damage line and the matching scope line and ask what the PAPPG requires. The scope of work must be completely described and correspond directly to the cause of damage. Descriptions should be specific to the damaged elements and defined in quantifiable terms — length, width, depth, capacity — and descriptive ones — brick, asphalt, timber deck. FEMA does not fund repair of damage caused by deterioration, deferred maintenance, failure to protect the facility from further damage, or negligence. PAPPG v5.0 Amended, Chapter 9, Section I (PDF p. 231); Chapter 4, Section II.B.1 (PDF pp. 67-68).
Paste the code or standard your engineer cited and ask what the eligibility test requires. A code-triggered upgrade is eligible only if the code applies to the type of repair or restoration required, is appropriate to the pre-disaster use, is reasonable and in writing and formally adopted and implemented on or before the declaration date (or is a legal federal requirement), applies uniformly, and was enforced while in effect. 44 CFR § 206.226(d); PAPPG v5.0 Amended, Chapter 8, Section II.C (PDF p. 175). FEMA's consensus-based codes, specifications and standards carry separate identification and verification requirements (PDF pp. 173-174).
Paste the proposed measure and ask where the code line falls. Upgrades required to meet an eligible code or standard are part of restoration work, not mitigation. Only the portion above the code requirement is evaluated as 406 mitigation, and it must reduce future damage to the damaged portion(s) of the facility. Three cost-effectiveness paths: 15 percent of eligible repair cost, an Appendix J measure at up to 100 percent, or a BCA. Mitigation attaches to permanent work Categories C-G only. PAPPG v5.0 Amended, Chapter 8, Section III (PDF pp. 182-184); Appendix J (PDF pp. 316-320); 44 CFR § 206.226(e).
Paste your repair estimate and your replacement estimate and ask how the 50 percent rule reads them. The rule compares estimated repair cost against estimated replacement cost at pre-disaster size, capacity and function. The repair numerator covers disaster-related damage only and excludes site work, soft costs, contents, hazard mitigation measures, emergency work, selective demolition beyond what the repair requires, and upgrades to undamaged elements not directly tied to the method of repair. 44 CFR § 206.226(f); PAPPG v5.0 Amended, Chapter 8, Section VI (PDF pp. 211-212).
Illustrative example — the kind of answer this produces, not a captured transcript. Split it at the code line. Upgrades required to meet an eligible code or standard are restoration work, not mitigation; only the portion above the code requirement is evaluated as 406 mitigation (PAPPG v5 Ch. 8 Sec. III, PDF p. 182). Submersible pump replacement, elevating electrical panels, and generator quick-connects are all listed in Appendix J (PDF p. 318), so they clear cost-effectiveness at up to 100 percent of eligible repair cost before insurance reductions — no BCA required. One gate: 406 mitigation attaches to permanent work Categories C-G only, never to a Category B claim.
Sources
PAPPAIA retrieves the passages of your document most relevant to the question you ask and puts them next to the governing policy. Attach one document at a time. It answers targeted questions — it does not read a file end to end, compare several files against each other, or tell you what your scope of work leaves out.
Free while PAPPAIA is in public preview. Answers are grounded in cited policy sources and include exact references for independent verification. General information, not legal or grant-compliance advice.
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