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Third Appeal Summary
PA ID# 071-59962; City of Redlands
DSR ID# 84886,06193 ; Civic Center Complex
PURPOSE: Respond to third appeal submitted by the City of Redlands for restoration of the Civic Center Complex.
DISCUSSION: Seismic activity associated with FEMA-0947-DR-CA resulted in damage to the City of Redlands' Civic Center Complex (Complex). FEMA prepared a DSR to cover replacement of broken windows in 1992. Approximately two years later, the subgrantee requested $24,600 to cover structural repairs of the walls and six (6) concrete columns in the sub-basement of the complex. In addition, the subgrantee submitted an HMP to upgrade 117 undamaged concrete columns. The HMP and supplemental request were determined ineligible due to regulatory timeframe limitations. Upon review of the first appeal, FEMA determined that the HMP was not cost-effective; however, a supplemental DSR was approved for $24,600. FEMA denied the subgrantee's second appeal for the HMP. In their third appeal, the subgrantee states that codes and standards require seismic upgrades to the 117 undamaged columns. Alternatively, the subgrantee asserts that FEMA should fund the project as an HMP. However, the seismic retrofit project requested by the subgrantee is not required by a code or standard. Therefore, the requested work is not eligible for permanent restoration funding. In addition, the elements (concrete columns) associated with the HMP are undamaged. As such, the seismic retrofit project is not eligible for hazard mitigation funding under Section 406 of the Stafford Act. Therefore, this appeal should be denied.
RECOMMENDED ACTION: Sign the letter denying the appeal