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Third Appeal Summary
PA ID# 019-92012; Charleston County School District
DSR ID# N/A; Project Management Costs
PURPOSE: Respond to third appeal submitted by the Charleston County School District
DISCUSSION: Hurricane Hugo hit South Carolina on September 21, 1989, causing extensive damage to the State. Damage survey reports were prepared following the disaster, and funding for disaster-related expenses were provided accordingly. On October 26, 1994, the State Public Assistance Program issued guidance to applicants stating that their entities may be entitled to additional funding, including various project management expenses. Accordingly, the Charleston County School District submitted a request for additional FEMA funding for costs accrued during disaster-related work. The costs were denied based on various program issues. The State forwarded the applicant's first and second appeals with transmittal letters dated July 18, 1997 and December 1, 1997. The primary issue of the appeals is that some costs were not reviewed by FEMA using the same criteria as previous claims for PMCs for other applicants. The determination of ineligibility was upheld in the first and second appeal responses on the basis that the applicant's costs were not directly associated with an emergency or restoration project and much of the costs were covered by the applicant's administrative allowance. In addition, the Executive Associate Director assured the applicant that each of the supplemental funding requests was evaluated based on its own merit. The third appeal, transmitted by the State's May 26, 1998 letter, is a reiteration of the first and second appeals and no new information has been provided. Some of the requested costs were accrued performing eligible recovery work. However, the applicant did not request reimbursement for these costs until approximately six years after the disaster declaration which is well beyond the regulatory time frame. The remaining costs are not associated with an eligible project.
RECOMMENDED ACTION: Sign the letter denying this appeal.