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Second Appeal Analysis
PA ID# 083-69070; City of Santa Barbara
DSR ID# 12255; Roof Replacement
As a result of a March 10, 1995, storm, the roof on the Santa Barbara Airport hanger building 309 was damaged by high winds. The hanger is a wood frame building with wood siding and a composition roof over wooden arch trusses. Sections of the rolled composition roof were torn from the building and strewn about the surrounding area damaging adjacent windows. Immediately after the storm, a contractor was brought in to patch the roof at a cost of $3,032. The work, identified as temporary by the subgrantee, consisted of applying new composition roofing over the damaged areas. The Federal Emergency Management Agency (FEMA) prepared damage survey report (DSR) 12255 (Category E) for $16,942 to fund the replacement of the entire composition roof, the completed temporary repairs to several damaged roof sections and replacement of 12 window panes.
The FEMA reviewer concluded that the only damage to the roof consisted of the loss of roof composition sheets on approximately a 500 square-foot (SF) roof area. The FEMA reviewer found no justification to provide funding for a complete replacement roof. The completed repairs of the roof, replacing 500 SF of composition sheeting, was considered to be a permanent repair and sufficient to restore the roof to pre-disaster condition. Additionally, the reviewer determined that an additional $504 was eligible for replacement of 12 window panes. On that basis, the funding for a complete replacement roof was denied. The DSR was approved for $3,536.
With a March 25, 1996, letter, the State transmitted the subgrantee's January 10, 1996, letter, appealing the denial of work items from DSR 12255. The subgrantee believed that the replacement of the entire roof should be eligible for funding on the basis that the completed repairs were temporary and were only intended to safeguard the building and its contents from greater losses and were not intended to restore the roof to pre-disaster condition. The State considered the temporary repairs as "emergency work" and recommended that a Category B DSR should be prepared for the completed repairs. The Regional Director denied the subgrantee's first appeal stating that there was no justification for replacement of the entire roof.
With a February 10, 1997, letter, the State transmitted the subgrantee's November 13, 1996, second appeal of DSR 12255. The subgrantee noted that the damage to the roof was more extensive than originally documented in the DSR and described in the City's first appeal. The subgrantee stated that most of the roofing material was torn from the building in huge sections. Therefore, the State requested that a Category B DSR be prepared to address the emergency repair costs and additional funding to permanently restore the entire roof. The only additional information provided by the State was a copy of the bid proposal for $40,970 that was submitted for replacing the entire roof. The subgrantee proceeded with replacing the entire roof.
The primary issue of this appeal is the extent of repairs needed to restore the roof to pre-disaster condition. The damage description written in the DSR indicates that the damages to the roof are limited to several composition sheets only. Specifically, both FEMA and OES inspectors described the damages to the roof as "several sheets of roofing on the south side of the arch." In addition, sketches included with the DSR show roofing blown off in only one specific location.
The subgrantee maintained that there would have been no way to properly seal the roof had the old roof sections that remained, many of them partially torn from the building, been kept in place. The subgrantee also noted that the damage to the roof was more extensive than originally documented in the DSR and that most of the roofing material was torn from the building in huge sections. However, there is no documentation in the DSR indicating that the damages are that extensive. The subgrantee has not provided any additional evidence indicating that any other section of the roof was damaged or needed replacement. Therefore, the approved scope of work is the only required repair to the roof to restore it to its pre-disaster condition. FEMA's determination to approve the roof repairs rather than to fund the replacement of the roof was appropriate.
Based on a review of the provided information, the appeal is denied. There is no indication that the completed temporary repairs would not adequately restore the pre-disaster condition and function of the roof.