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Second Appeal Summary
PA ID# 037-91XXX; Los Angeles County Various Departments
DSR ID# Multiple; Emergency Work Documentation Deadline
Citation: FEMA-1008-DR-CA, Los Angeles County Various Departments
Cross-reference: Emergency Work, Time Limitations
Summary: Due to the exceptional nature of the extensive damage resulting from the January 17, 1994, Northridge earthquake, FEMA extended the emergency work period two years beyond the maximum time extensions authorized to the grantee, by establishing a cut-off date of January 1, 1997, for the completion of emergency work. The Disaster Recovery Manager set a deadline of April 30, 1997, for the submittal of emergency work documentation with the intent of expediting the granting of federal disaster assistance and close out of the Public Assistance program. The DRM warned that if documentation had not been received by the deadline, FEMA would proceed to close out emergency work DSRs based on the best documentation available.
On June 20, 1997, the State forwarded a first appeal to FEMA on behalf of multiple departments of Los Angeles County (County). The applicants claimed that the documentation deadline ran counter to established FEMA policy and was an unreasonable requirement considering the magnitude of their emergency recovery program. On October 1, 1998, the Disaster Recovery Manager denied the applicant's appeal because time extensions are granted on a project by project basis when sufficient justification is provided to FEMA/OES.
In the second appeal letter, the applicants reassert that the deadline for emergency work documentation is a departure from FEMA policy, and it is an unreasonable deadline for actual cost documentation submittal. The County invites OES and FEMA to meet to discuss a reasonable plan for the submission of emergency work documentation for the County's approximately 300 emergency work projects.
The current status of the applicant's 263 emergency work DSRs is as follows:
- 102 of the DSRs are associated with small projects, which are reconciled by OES.
- 161 DSRs are associated with large projects and fit into one of three situations,
- 34 are associated with Grant Acceleration Program (GAP) projects,
- 50 are associated with FEMA's Seismic Hazard Mitigation Program for Hospitals program
- 77 DSRs are associated with projects that are currently in the P-4 close-out process.
Issues: Are the 11 applicants eligible for a comprehensive time extension for submission of emergency work documentation?
Findings: No, a blanket time extension for the 11 applicants is not warranted.
Rationale: The Northridge Long-Term Recovery Area, OES, and the County have developed a reasonable plan for closing out the applicants' emergency work projects.