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Second Appeal Brief
PA ID# 191-26880-00; City of Goldsboro
PW ID# 4314; Debris Monitoring
Citation: FEMA-1292-DR-NC; City of Goldsboro; Project Worksheet (PW) 4314; Debris Monitoring
Cross Reference: Debris Removal; Debris Monitoring; Reasonable Costs
Summary: Hurricane Floyd made landfall on September 16, 1999, leaving large amounts of debris across the City of Goldsboro, NC. The Applicant contracted the debris management responsibility including bid preparation and selection of contractors. Four PWs were approved to cover the debris removal costs, which totaled $738,496. PW 4314 was approved for $184,033 to cover the debris monitoring costs. During final inspection, the claimed amount of $322,660 for debris monitoring costs was determined not reasonable and therefore, not eligible. PW 4314 was approved in the amount of $188,295. This covered costs of direct labor of field staff (including fringe benefits), reimbursable expenses, and a three percent inspection fee intended to account for monitoring. The Applicant submitted a first appeal claiming actual monitoring costs were $329,166 and requesting an additional $140,871 be funded. It stated that the scope of the monitoring costs exceeded monitoring and included bid preparation, contractor selection and financial administration. The first appeal was denied on March 13, 2002, because the monitoring costs were approaching fifty percent of the actual removal costs and were determined unreasonable. The Applicant submitted a second appeal on May 22, 2002. Again the request is that an additional $140,871 be funded.
Issues: 1. Are the debris monitoring costs reasonable?
Findings: 1. Yes. The Applicants average unit costs including monitoring is less than the average calculated for a sample set for North Carolina.2.
Rationale: 44 CFR § 206.228