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Second Appeal Summary
PA ID# 037-70000; City of Santa Monica
DSR ID# 85560; Cabana Building
Citation: Appeal Analysis; Second Appeal; City of Santa Monica; California; FEMA-1008-DR-CA, PA 037-70000
Cross Reference: DSR 85560; Engineering and Design Costs; Cabana Buildings
Facts: Following the Northridge Earthquake, FEMA prepared DSR 99985 for $13,527 for the City of Santa Monica to fund various earthquake-related repairs to Cabana Buildings A and B. The DSR was found ineligible because the facilities were not in active use, per 44 CFR 206.226(I)(2). Later, the City submitted a request to FEMA to prepare another DSR for $35,000 to fund an architectural and engineering study of the damaged buildings. DSR 76054 was prepared as a supplement to DSR 99985. Upon review, DSR 76054 was found ineligible, per 44 CFR 206.226(I)(2). Based on additional documentation provided by the City, FEMA concluded that the Cabana Buildings were in active use at the time of the disaster and therefore, supplemental DSR 85560 was prepared for $13,527 to fund the repair of the buildings. This amount allowed $12,186 for repair costs, $366 (3% of repair costs) for construction inspection services, and $975 (8% of repair costs) for engineering and design services. During review, FEMA determined that the costs of engineering and design services were ineligible because the scope of eligible work does not warrant these services. Subsequently, DSR 85560 was approved for $12,553 to cover eligible repair and construction inspection costs. In the first appeal, the City claimed that the project required a formal bidding process and construction management, that FEMA reinstated similar costs as a result of the City's appeal of DSR 99769, and that Mr. Krimm's January 19, 1996, letter states that engineering and design and bid preparation costs are eligible. The Disaster Recovery Manager (DRM) denied the first appeal because the scope of work of DSR 85560 consists of repair of wall cracks and miscellaneous repairs, which does not justify the need for any engineering and design services, with the exception of construction inspection. In the second appeal, the subgrantee repeats the same arguments of the first appeal.
Issue: Does the nature of the work necessary to repair the disaster-related damage identified in DSR 85560 warrant engineering and design services?
Findings: No. The costs associated with those services are subject to evaluation for their reasonableness in relation to the work. The DRM believes that the costs are not reasonable. The subgrantee has not provided any compelling information substantiating that the engineering and design fees are warranted.
Rationale: 44 CFR 13.36