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Second Appeal Letter
PA ID# 059-22A8A-00; South Coast Water District
PW ID# 865; Water Pipeline Break
March 11, 2010
Governor’s Authorized Representative
California Emergency Management Agency
3650 Schriever Avenue
Mather, CA 95655
Re: Second Appeal– South Coast Water District, PA ID 059-22A8A-00, Water Pipeline Break, FEMA-1585-DR-CA, Project Worksheet (PW) 865-2
Dear Mr. McCarton:
This is in response to a letter from your office dated October 14, 2008, which transmitted the referenced second appeal for the South Coast Water District (Applicant). The Applicant is appealing the Department of Homeland Security’s Federal Emergency Management Agency’s (FEMA) decision to deny its request for a hazard mitigation project related to the damaged waterline.
As explained in the enclosed analysis, the benefit cost analyses that the Applicant submitted do not demonstrate that the project is cost effective. Acceptable cost benefit ratios are obtained only if the San Onofre Nuclear Generating Station is shut down by a failure of the Joint Transmission Main (JTM). While the Applicant made this assumption for the analyses, it did not provide any documentation from Southern California Edison to confirm that the power station had shut down when the JTM failed as a result of the declared event, or would in a future event. The Applicant also did not document that the approved scope of work was not technically feasible. Accordingly, I am denying this appeal.
Please inform the Applicant of my decision. My determination constitutes the final decision on this matter as set forth in 44 CFR §206.206, Appeals.
Elizabeth A. Zimmerman
Disaster Assistance Directorate
cc: Nancy Ward
FEMA Region IX