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Second Appeal Summary
PA ID# 111-91042; Ventura Flood Control District
DSR ID# Multiple; Debris removal from various debris basins
Citation: FEMA-1044-DR-CA; Ventura County Flood Control District; Multiple DSRs
Cross Reference: Debris basins, Debris removal
Summary: The winter storms of 1995 caused flooding throughout Ventura County. DSRs 11373, 46587, 11372, 11388, 11389, 11376, 11398, and 11399 were prepared for debris removal from various debris basins in Ventura County. FEMA suspended the DSRs in May 1996 because the Ventura County Flood Control District did not complete the work within six months of the incident, indicating that the work was not in response to an immediate threat pursuant to 44 CFR 206.224. Following a first appeal, FEMA found that the subgrantee provided sufficient justification for the delays and prepared supplemental DSRs for debris removal. The total funding provided in these DSRs was $1,283,109. The subgrantee appealed the accuracy of the Region's calculations of eligible funding. The subgrantee stated that the Region determined the average annual debris potential (AADP) based on ten-years of maintenance data despite being provided with 30 years of maintenance data, and contended that all 30 years should be considered in calculations. The subgrantee also stated that the Region estimated debris deposition between cleanouts by multiplying the AADP by the number of years between cleanouts. The subgrantee contends that, because there is only significant precipitation six-months out of the year, debris deposition should be determined based on the number of wet seasons between cleanouts. This method results in a total of $1,421,425 requested by the subgrantee.
- Is ten-years worth of maintenance data sufficient for calculating AADP?
- Should debris deposition be based on wet seasons?
- Yes. Ten years is sufficient data for calculating AADP.
- Yes. Non-disaster debris amounts will be determined by multiplying the AADP by the number of wet seasons between the last pre-disaster aerial survey and the disaster declaration. Supplemental DSRs should be prepared to provide an additional $478,850 of funding.
Rationale: Determining AADP based on ten-years of data more accurately reflects current trends in debris deposition than 30-year data when considering changes in land use and climate. When determining non-disaster debris quantities it is reasonable to assume that no significant debris deposition occurs during months with little precipitation. Therefore, calculations for determining debris quantities should be based on the number of wet seasons experienced as opposed to years elapsed between aerial surveys and the disaster declaration.