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Second Appeal Letter
PA ID# 000-ULBOG-00; Electric Membership Corporation (REMC)
PW ID# 833; Geographic Information System (GIS)
February 8, 2005
Dr. Kenneth B. Taylor, Director
North Carolina Division of Emergency Management
4716 Mail Service Center
Raleigh, North Carolina 27699
RE: Second Appeal Roanoke Electric Membership Corporation (REMC),
PA ID # 000-ULBOG-00, Geographic Information System (GIS),
Dear Dr. Taylor:
This is in response to your letter dated August 11, 2004, which transmitted the referenced second appeal on behalf of Roanoke Electric Membership Corporation. REMC requests a reconsideration of the Acting Regional Directors denial of its application for funding to update its GIS database.
In the Fall of 2002, REMC undertook a project to deploy a GIS database designed to replace the outdated paper mapping system. The GIS database was in pre-deployment testing and training when Hurricane Isabel damaged REMCs distribution poles, lines and associated equipment in 2003. During the power restoration process following Hurricane Isabel, numerous changes to the electric system were made that were not documented by the usual work order process. As a result of these undocumented changes, REMC submitted a project worksheet requesting reimbursement of costs of returning the GIS to its pre-disaster condition. This work included updating the GIS database to reflect the changes made to the distribution system after Hurricane Isabel. The Federal Emergency Management Agency (FEMA) denied the request because it considered the cost to be increased operating expenses.
REMC submitted a first appeal to FEMA Region IV, stating that the GIS database is directly related to overall management of the electrical distribution system and the cost of updating the database should be eligible. The Acting FEMA Regional Director denied the first appeal, because the cost of updating the GIS is considered an increased operating cost. REMC submitted a second appeal to FEMA in a letter dated June 18, 2004. REMC believes that the Acting FEMA Regional Director did not properly apply FEMA eligibility policies to its analysis of the damaged facility in responding to the first appeal request.
On January 25, 2005, management of REMC and representatives of the National and North Carolina Rural Electric Cooperatives Associations met with staff of the headquarters Recovery Division to discuss this second appeal. The REMC GIS database and its uses were described and discussed in detail. The information provided to us at the meeting has been carefully considered in our evaluation of the appeal.
All disaster-related costs that an eligible applicant incurs are not necessarily eligible for reimbursement under the Public Assistance Program. Eligible work includes debris removal, emergency protective measures and the repair and restoration of damaged facilities. Updating the GIS database does not fit in any of the above categories of eligible work. Therefore, there is no basis for reversing the Acting Regional Directors decision on the first appeal. Accordingly, the second appeal is denied.
Please inform the Applicant of my decision. My determination constitutes the final decision on this matter as set forth in 44 CFR §206.206.
Daniel A. Craig
Emergency Preparedness and Response
cc: Mary Lynne Miller
Acting Regional Director
FEMA Region IV