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Second Appeal Letter
PA ID# 061-91021; Placer Union High School District
DSR ID# 23012 ; High School Gymnasium Roof Replacement
September 3, 1997
Ms. Nancy Ward
Governor's Authorized Representative
Governor's Office of Emergency Services
Post Office Box 239013
Sacramento, California 95823
Dear Ms. Ward:
This is in response to your letter dated March 19, 1997, to the Federal Emergency Management Agency (FEMA). With that letter, you forwarded a second appeal of damage survey report (DSR) 23012 under FEMA-1044-DR-CA on behalf of Placer Union High School District, requesting FEMA to pay the total costs associated with replacement of a single-ply roofing system. The amount requested is $7,108.
During the winter storms of 1995, the roof drains of Placer Union High School gymnasium became clogged, forming a six-inch pool of water on the roof. Subsequently, the single-ply roof separated from the roof membrane, flooding the gymnasium and other areas beneath the roof. Based on cost estimates from a qualified contractor to replace the roof, FEMA prepared DSR 23012 for $7,108. Upon review, FEMA reduced the DSR to $1,549 to reflect FEMA roof repair cost codes. In the first appeal, the Regional Director determined that it was appropriate to use contractor bids in lieu of the FEMA's cost codes. However, the first appeal was denied due to the presence of a warranty on the roof and possible duplication of benefits, pursuant to the Stafford Act, section 312 (c).
The two issues of this appeal are whether or not a duplication of benefits exists and should the original level of funding be reinstated. Upon review of the warranty documentation, it appears the warranty did not cover the type of damage that the roof sustained. Thus, I have concluded that there was no duplication of benefits. Further, pursuant to the Public Assistance Guide, it is appropriate to use contractor bids in lieu of FEMA cost codes when developing DSR cost estimates. Therefore, I am approving the second appeal and reinstating the level of funding to $7,108.
I have asked the Regional Director to take appropriate action to implement this decision. Please inform the applicant of my determination.
Lacy E. Suiter
Executive Associate Director
Response and Recovery Directorate