PA ID# 087-99087-00; County of Henrico
PW ID# Multiple PWs; Debris Removal-Reasonable Costs
Citation: FEMA-1491-DR-VA, County of Henrico, Multiple PWs
Cross Debris Removal, Reasonable Cost Reference:
Summary: The Commonwealth of Virginia was struck by severe weather caused by Hurricane Isabel on September 18, 2003. Multiple PWs were written to include $1,956,765 to cover the costs of removing hazardous stumps throughout the county. At project closeout, FEMA determined that the stump removal costs were not reasonable and de-obligated the funding. In response to the first appeal, FEMA approved the $498,065 for removing stumps 24 inches in diameter or larger on a per-stump basis. However, FEMA denied the Applicants request for removing stumps with 24¬¬-inch diameter or less on a per-stump basis. Rather, FEMA reimbursed for these costs on an equivalent cubic-yard basis. This resulted in a reduction of $1,464,576.
The second appeal, submitted on September November 7, 2007, argues that FEMA policy in force at the time of the disaster did not prohibit the removal of stumps of 24-inch diameter or less on a per-stump basis and the $1,464,576 should be allowed as a reasonable cost. Issues: Is the Applicant eligible for reimbursement for removing stumps 24 inches or less in diameter on a per-stump basis? Findings: No. Rationale: Office of Management and Budget Circular A-87 Cost Principles for State, Local and Tribal Government; 44 CFR §13.36(f);
44 CFR §206.224, FEMA 325, Debris Management Guide dated April 1999, Appendix F