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Second Appeal Summary
PA ID# 000-92040; University of California, Santa Cruz
DSR ID# Multiple; Mobile Trailer Units
Citation: FEMA-0845-DR-CA; University of California, Santa Cruz; Mobile Trailer Units
Cross Reference: Disaster Related Damages, Codes and Standards
Summary: Numerous mobile trailer units used for classrooms at the University of California, Santa Cruz, suffered minor damage as a result of the Loma Prieta earthquake (FEMA-0845-DR-CA). The damage generally consisted of relative movement between the trailers and their foundation systems. DSRs (33) were prepared to relevel the trailers and tighten the tiedown straps, for a total cost of $9,814. No specific damage to the ground anchoring units was reported. The subgrantee requested that the anchoring system be reconstructed in accordance with current code requirements, estimated at a cost of $44,750. DSR 33880 was prepared to fund these efforts as hazard mitigation. The DSR narrative indicated that the subgrantee chose the hazard mitigation approach to avoid the eligibility of code upgrade work for the units that were not installed in compliance with the prevailing code at the time. Later review found that the hazard mitigation work was not cost-effective, and therefore not eligible. However, based on the subgrantee's representation that the work was in fact required by a current code, DSR 39068 was prepared to fund the anchoring reconstruction as permanent work ($109,787). Based on continued involvement with the project, and further review of the existing unit designs, FEMA determined that the Title 25 was a standard for new construction and did not require the existing foundation systems to be upgraded. This determination was upheld in first appeal. The subgrantee's second appeal again asserts that Title 25 does apply to this project, and suggests that the anchoring system itself was damaged during the disaster, thus requiring the upgrade per Title 25.
- Was the ground anchoring system damaged during the disaster?
- Does Title 25 require an upgrade of the anchoring system?
- No. Although the subgrantee suggests in the second appeal that the foundation units were damaged during the disaster, no previous reference regarding damages had been made. No specific data has been provided to support damages.
- No. The requirements of Title 25 applies to new construction, and does not mandate upgrading of foundation units relative to the scope of the eligible repair work (releveling of trailers and tightening of tiedown straps).
Rationale: 44 CFR 206.223 General Work Eligibility, 44 CFR 206.226(b) Standards