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Second Appeal Brief
PA ID# 087-99087-00; St. Bernard Parish
PW ID# 3757; Estopinal-Salles House
Citation: FEMA-1603-DR-LA; St. Bernard Parish, Estopinal-Salles House, PW 3757
Cross - Work Eligibility
Summary: The Estopinal-Salles House (facility), part of the Los Islenos Museum Complex in St. Bernard Parish (Applicant), sustained wind and flood damage caused by Hurricane Katrina. FEMA prepared PW 3757 for $15,005 to fund the repair of the facility. However, additional damage was later identified, and FEMA determined the replacement of the facility was eligible for funding at an estimated cost of $121,462. Subsequently, FEMA determined that the contract included work to “authentically reconstruct a historic replication … using construction methodology that was common in the 1780s.” As the facility was not eligible for inclusion in the National Register of Historic Places (National Register), FEMA concluded that the eligible replacement costs were limited to the costs to build a similar structure based on current codes and standards and using current construction methods. FEMA determined that the costs for bousillage insulation (mud and moss construction technique) and for heavy hand-hewn timber construction were ineligible because they were associated with the historic replication of the facility.
In its first appeal, the Applicant stated that the bousillage and heavy timber treated to resemble hand-hewn timber was necessary to restore the facility to its pre-disaster function as a museum exhibit. The FEMA Regional Administrator limited eligible costs to those for replacement using conventional construction methods.
The Applicant submitted its second appeal on November 2, 2010, reiterating that the bousillage and heavy timber treated to resemble hand-hewn timber is necessary to restore the pre-disaster function of the facility.
Issue: Is the installation of the bousillage insulation and heavy timber treated to resemble hand-hewn timber necessary to restore the pre-disaster function of the facility?
Finding: Yes. The facility is part of a collection that has historic and cultural significance, demonstrating residential construction practices of the Los Islenos colonists. The heavy timber installation is eligible; however, the bousillage was not visible prior to the event, so only conventional insulation installation is eligible.
Rationale: Disaster Assistance Policy DAP9524.6, Collections and Individual Objects, dated August 17, 1999