Summary: As a result of FEMA-1203-DR-CA in 1998, floodwater damaged six of eight erosion control structures extending from the south bank of the Santa Clara River. Damage Survey Report (DSR) 21068 was prepared on September 22, 1998, for $1,968,659 to repair flood damages and make improvements to the six groins. The groins were damaged three years earlier in the FEMA-1044-DR-CA event, but the Ventura County Flood Control District (District) elected not to perform the repairs. FEMA placed DSR 21068 in suspension pending receipt of documentation establishing the condition of the groins just prior to 1203-DR. On January 12, 2001, FEMA removed DSR 21068 from suspension and found it ineligible because the District had not submitted the requested documentation.
In the first appeal letter dated February 2, 2001, the District stated that although the groins were not repaired after the 1044-DR event, the structures were functioning during the FEMA-1046-DR-CA disaster a few months later. The District revised the proposed scope of work by eliminating the improvements. The District also submitted maintenance records from 1992 to June 2001. The Regional Director denied the first appeal because the maintenance records did not establish pre-disaster condition of the groins.
The District stated in the second appeal that the groins were 100 percent functional during and after the 1044 and 1046 events and submitted two aerial photographs of the groins taken on March 25, 1995 and March 8, 1998.
Issues: 1) Do the aerial photographs establish the pre-disaster condition of the facility? 2) Does the Districts failure to repair damages to the facility after FEMA-1044-DR preclude federal assistance for repair of damages incurred from FEMA-1203-DR?
Findings: 1) No. The aerial photographs do not demonstrate the structural integrity or the extent of maintenance of the groins just prior to 1203-DR; however, the absence of devastating floods in the intervening years implies that the facility was structurally intact. 2) No. The damage caused by the FEMA-1044 event was 1/10 the amount of damage caused by the FEMA1203-DR event. The appeal is approved in the amount of $294,590.