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Non-Arterial Areaways (NAA)
Appeal Brief
Appeal Letter
Appeal Analysis
Citation: FEMA-1361-DR-WA, City of Seattle, Non Arterial Areaways 906, 907 and 1403
Cross
Reference: Pre-disaster design, Hazard Mitigation
Summary: Non-Arterial Areaways (NAA) 906, 907 and 1403 were damaged in the Nisqually Earthquake Disaster of 2001. NAAs were constructed following the Great Seattle Fire of 1889. Streets and sidewalks were elevated eleven feet by constructing foundation walls from the old street level. The City of Seattle objected to FEMAs repair scope of work which called for epoxy injection as a means of restoring structural capacity to pre-disaster condition. FEMA engineering publications 306 and 308 find that epoxy injection to be an appropriate repair method for structural repairs of this nature. FEMAs estimate of repairs totaled $116,113.75 (PW 1844).The Citys first appeal, filed on November 8. 2002, argued that FEMAs repair method (epoxy injection) was a cosmetic repair that would not return the structural strength of the areaway walls to their pre-disaster condition. The Citys first appeal requested additional funding of $396,832.40 for the cost of filling the areaway voids with a lightweight engineered fill. The Regional Director denied the Citys first appeal.The City filed its second appeal on August 21, 2003, which included a total estimated cost of $412,573.38.
Issues: 1. Are the repair methods on PW 1844 adequate to return the NAAs to their predisaster condition?2. Is the scope of repairs on PW 1844 adequate to return the NAAs to their predisaster condition?3. Does the use of lightweight engineered fill, as proposed by the City, eligible as cost-effective hazard mitigation?
Findings: 1. Yes.2. No. Adjustments in the scope of work are required.3. No.
Rationale: 44 CFR § 206.226(e) and (f)
The Non-Arterial areaways (NAAs) were constructed in the Pioneer Square area of Seattle, between 1889 and 1893, following the Great Seattle Fire of 1889. The street elevation level in this area was raised approximately 11 feet by construction of foundation walls elevated above the old streets. These walls extend approximately 3 feet below the old street levels and are supported by pilings. These walls were built as foundation walls for the streets and sidewalks. These walls, approximately 2 feet thick, (cantilevered retaining walls) provide lateral support for the earth fill beneath the street, and vertical support for the City's sidewalks. This created an enclosed area consisting of the foundation wall, the sidewalk as a ceiling, the old street cobblestone or brick as a floor, and the adjacent building as the other wall. There are public utility systems, water mains, sewer, gas and electric lines which run throughout the areaways with sidewalk manhole cover access. The reference documents indicate that the NAAs were not used by the owners of the adjacent building for storage or other purposes and that the walls were not maintained.
The Nisqually Earthquake of February 28, 2001, resulted in damage to the NAAs. On October 9, 2001, FEMA Region X issued PW 1844, which included the damage assessment to NAAs 806, 906, 907, 910, 1403, 1601, 1901 and 5000. The scope of work included in selected sections removal of broken bricks, cleaning up and replacement and relaying of bricks, cleaning up concrete cracks and repairs by epoxy injection and cementatious grout, repair of mortar line cracks and pointing, and shotcrete. The total cost including miscellaneous items was estimated and obligated at $116,113.75. FEMA inspectors noted pre-disaster damage to the walls including cracking due to age, settlement and possibly previous earthquakes.
First Appeal
On November 8, 2002, the City of Seattle (Applicant) submitted its first appeal to the State of Washington, requesting additional funds in the amount of $396,832.40 for NAAs 906, 907, and 1403. The appeal requested that the damage assessment and repair methodology be reassessed and that filling the areaways with engineered, lightweight fill be authorized instead of the repair methodology detailed in the PW. The State of Washington forwarded the Applicants first appeal to FEMA on January 2, 2003, with a recommendation for additional funding in the amount of $96,871.76. The amount of funding was reduced from that recommended by the City based on the costs of recent, similar work and a reduction in the scope of repair for NAA 1403. The State submitted additional information to FEMA on March 11, 2003, based on correspondence from FEMA dated January 14, 2003.
In a letter dated June 11, 2003, the Director of FEMA Region X denied the appeal in its entirety. The response stated that the alternative repair methodology was not cost effective when compared to the repair costs estimated by FEMA and that additional repair costs beyond those in PW 1844 were not substantiated.
Second Appeal
The Applicant submitted its second appeal to the State of Washington on August 21, 2003. The appeal again dealt with NAAs 906, 907, and 1403 and estimated a total cost of repair of $412,573.38.
· The Applicant again asserted that FEMAs proposed repairs for the NAAs were inadequate to return the damaged NAAs to their pre-disaster function because of the structural nature of the damage.
· The Applicant also argued that the use of lightweight engineered fill is the most cost-effective and least cost repair method.
·
· The Applicant requested that the its engineering firm Parsons Brinckerhoff Quade and Douglas damage assessment and repair recommendations, which were attached to the Citys letter, be used to revise PW #1844 for NAAs 906, 907, and 1403.
The State of Washington transmitted the Applicants second appeal to FEMA in a letter dated October 14, 2003. The State emphasized the following points in its transmittal letter:
· The description of damages and estimated costs in the PW were inaccurate.
·
· The PW incorrectly categorized the work as Category E (buildings) versus Category C (roads).
·
· The quantity of repair was underestimated.
·
· The method of repair is inconsistent with the publications FEMA 306 and FEMA 308.
·
· The cost to rebuild or replace the walls exceeds the cost of filling the areaways.
·
· Filling the areaways with lightweight, engineered fill is innovative and has been used to repair similar damaged areaways under the jurisdiction of the Federal Highway Administration within the City.
·
· Filling the areaways provides permanent hazard mitigation, as compared to repairing the NAAs as described in the PW.
·
Current Status of Areaways Repairs
During a May 26, 2004, meeting with the State of Washington, the City and its consultant, Parsons Brinckerhoff Quade and Douglas, FEMA was advised that the areaways in question have been filled with lightweight concrete as proposed by the Citys consultant. FEMA was advised on June 1, 2004, that the actual cost for filling NAA 906, 907 and 1403 was $252,049.57.
Appeal Issues
While the Applicant and State raise a number of issues in their second appeal submittals, they can be summarized as follows:
· Are the methods of repair as outlined in the PW adequate to return the NAAs to their predisaster conditions?
· Is the scope of repairs as outlined in the PW adequate to return the NAAs to their predisaster conditions?
· Does the use of lightweight, engineered fill as proposed by the City qualify as cost effective hazard mitigation?
DISCUSSION
Due to the structural engineering issues in question, FEMA requested technical advice from its contractor, Fluor Daniel, Inc., as provided for in 44 CFR § 206.206 (d). The following discussion reflects that firms technical advice.
The primary argument of the Applicants second appeal is that the repair methods outlined in the PW are not adequate in method or scope to return the NAAs to their pre-disaster condition, and that FEMAs own publications, FEMA 306 and FEMA 308, support this position.
The cited FEMA publications are guidelines and do not prohibit the repair method outlined in the PW. The scope of work for repair was reviewed. Repair of the unreinforced masonry walls by grout injection will return the walls to the pre-disaster condition. However, based on a review of the project scope and items requiring repair, the cost estimate was revised to include additional items such as temporary facilities and purchase of used bricks, as well as the repair of more cracks. The total revised cost for the three NAAs is estimated to be $85,319. The States contention that the PW miscategorized the work as Category E versus Category C is not germane, because the categorization of the work does not impact the estimated repair cost.
Filling the NAAs with lightweight structural fill as a repair method is structurally superior to repairing the NAAs to restore them to their predisaster condition through grout injection as funded in the PW. It is also superior in terms of hazard mitigation, but it is not a cost-effective repair method when compared to repair of the walls by grout injection: $252,049 vs. $85,319.
CONCLUSION
The appeal for $252,049.57 is denied. However, the Applicant will be granted the difference between the total estimated repair cost ($85,319) and the original PW amount ($64,998), which is $20,321.
Appeal Brief
| Desastre | FEMA-1361-DR |
| Applicant | City of Seattle |
| Appeal Type | Second |
| PA ID# | 033-63000-00 |
| PW ID# | 1844 |
| Date Signed | 2004-10-01T04:00:00 |
Cross
Reference: Pre-disaster design, Hazard Mitigation
Appeal Letter
September 29, 2004
Ms. Donna J. Voss
Deputy State Coordinating Officer
Emergency Management Division
State of Washington
MS: TA-20 Building 20
Camp Murray, Washington 98430-5122
RE: Second Appeal City of Seattle, PA ID# 033-63000-00
Non-Arterial Areaways (NAA), FEMA-DR-1361-WA,
Project Worksheet (PW) 1844
Dear Ms. Voss:
This is in response to your October 14, 2003, letter forwarding the referenced second appeal on behalf of the City of Seattle (Applicant). The applicant appealed the damage description and repair scope of work in PW 1844. Additionally, the analysis of your staff and the Applicants consultant concludes that filling the NAAs is the preferred solution and less costly than the repair described in the PW. The Federal Emergency Management Agency (FEMA) was advised on June 1, 2004, that the actual cost for filling the NAAs was $252,049.57.
A structural engineer not involved in the original work reviewed the submitted documentation for FEMA. His determination was that the NAAs could have been structurally repaired at less cost than filling them. The quantity of repair and cost of repair were reevaluated by an estimator not involved in the original work. The cost of repair was determined to be $85,319 compared to $64,998 in the original PW. Therefore, the Applicant is entitled to an additional $20,321 for repair of the NAAs, as explained in the enclosed analysis. The appeal is partially granted. By copy of this letter I am requesting our Region X office to prepare a revised PW.
Please inform the Applicant of my decision. My determination constitutes the final decision on this matter as set forth in 44 CFR §206.206.
Sincerely,
/S/
Daniel A. Craig
Director
Recovery Division
Emergency Preparedness and Response
Enclosure
cc: John Pennington
Regional Director
Region X
Ms. Donna J. Voss
Deputy State Coordinating Officer
Emergency Management Division
State of Washington
MS: TA-20 Building 20
Camp Murray, Washington 98430-5122
RE: Second Appeal City of Seattle, PA ID# 033-63000-00
Non-Arterial Areaways (NAA), FEMA-DR-1361-WA,
Project Worksheet (PW) 1844
Dear Ms. Voss:
This is in response to your October 14, 2003, letter forwarding the referenced second appeal on behalf of the City of Seattle (Applicant). The applicant appealed the damage description and repair scope of work in PW 1844. Additionally, the analysis of your staff and the Applicants consultant concludes that filling the NAAs is the preferred solution and less costly than the repair described in the PW. The Federal Emergency Management Agency (FEMA) was advised on June 1, 2004, that the actual cost for filling the NAAs was $252,049.57.
A structural engineer not involved in the original work reviewed the submitted documentation for FEMA. His determination was that the NAAs could have been structurally repaired at less cost than filling them. The quantity of repair and cost of repair were reevaluated by an estimator not involved in the original work. The cost of repair was determined to be $85,319 compared to $64,998 in the original PW. Therefore, the Applicant is entitled to an additional $20,321 for repair of the NAAs, as explained in the enclosed analysis. The appeal is partially granted. By copy of this letter I am requesting our Region X office to prepare a revised PW.
Please inform the Applicant of my decision. My determination constitutes the final decision on this matter as set forth in 44 CFR §206.206.
Sincerely,
/S/
Daniel A. Craig
Director
Recovery Division
Emergency Preparedness and Response
Enclosure
cc: John Pennington
Regional Director
Region X
Appeal Analysis
BackgroundThe Non-Arterial areaways (NAAs) were constructed in the Pioneer Square area of Seattle, between 1889 and 1893, following the Great Seattle Fire of 1889. The street elevation level in this area was raised approximately 11 feet by construction of foundation walls elevated above the old streets. These walls extend approximately 3 feet below the old street levels and are supported by pilings. These walls were built as foundation walls for the streets and sidewalks. These walls, approximately 2 feet thick, (cantilevered retaining walls) provide lateral support for the earth fill beneath the street, and vertical support for the City's sidewalks. This created an enclosed area consisting of the foundation wall, the sidewalk as a ceiling, the old street cobblestone or brick as a floor, and the adjacent building as the other wall. There are public utility systems, water mains, sewer, gas and electric lines which run throughout the areaways with sidewalk manhole cover access. The reference documents indicate that the NAAs were not used by the owners of the adjacent building for storage or other purposes and that the walls were not maintained.
The Nisqually Earthquake of February 28, 2001, resulted in damage to the NAAs. On October 9, 2001, FEMA Region X issued PW 1844, which included the damage assessment to NAAs 806, 906, 907, 910, 1403, 1601, 1901 and 5000. The scope of work included in selected sections removal of broken bricks, cleaning up and replacement and relaying of bricks, cleaning up concrete cracks and repairs by epoxy injection and cementatious grout, repair of mortar line cracks and pointing, and shotcrete. The total cost including miscellaneous items was estimated and obligated at $116,113.75. FEMA inspectors noted pre-disaster damage to the walls including cracking due to age, settlement and possibly previous earthquakes.
First Appeal
On November 8, 2002, the City of Seattle (Applicant) submitted its first appeal to the State of Washington, requesting additional funds in the amount of $396,832.40 for NAAs 906, 907, and 1403. The appeal requested that the damage assessment and repair methodology be reassessed and that filling the areaways with engineered, lightweight fill be authorized instead of the repair methodology detailed in the PW. The State of Washington forwarded the Applicants first appeal to FEMA on January 2, 2003, with a recommendation for additional funding in the amount of $96,871.76. The amount of funding was reduced from that recommended by the City based on the costs of recent, similar work and a reduction in the scope of repair for NAA 1403. The State submitted additional information to FEMA on March 11, 2003, based on correspondence from FEMA dated January 14, 2003.
In a letter dated June 11, 2003, the Director of FEMA Region X denied the appeal in its entirety. The response stated that the alternative repair methodology was not cost effective when compared to the repair costs estimated by FEMA and that additional repair costs beyond those in PW 1844 were not substantiated.
Second Appeal
The Applicant submitted its second appeal to the State of Washington on August 21, 2003. The appeal again dealt with NAAs 906, 907, and 1403 and estimated a total cost of repair of $412,573.38.
· The Applicant again asserted that FEMAs proposed repairs for the NAAs were inadequate to return the damaged NAAs to their pre-disaster function because of the structural nature of the damage.
· The Applicant also argued that the use of lightweight engineered fill is the most cost-effective and least cost repair method.
·
· The Applicant requested that the its engineering firm Parsons Brinckerhoff Quade and Douglas damage assessment and repair recommendations, which were attached to the Citys letter, be used to revise PW #1844 for NAAs 906, 907, and 1403.
The State of Washington transmitted the Applicants second appeal to FEMA in a letter dated October 14, 2003. The State emphasized the following points in its transmittal letter:
· The description of damages and estimated costs in the PW were inaccurate.
·
· The PW incorrectly categorized the work as Category E (buildings) versus Category C (roads).
·
· The quantity of repair was underestimated.
·
· The method of repair is inconsistent with the publications FEMA 306 and FEMA 308.
·
· The cost to rebuild or replace the walls exceeds the cost of filling the areaways.
·
· Filling the areaways with lightweight, engineered fill is innovative and has been used to repair similar damaged areaways under the jurisdiction of the Federal Highway Administration within the City.
·
· Filling the areaways provides permanent hazard mitigation, as compared to repairing the NAAs as described in the PW.
·
Current Status of Areaways Repairs
During a May 26, 2004, meeting with the State of Washington, the City and its consultant, Parsons Brinckerhoff Quade and Douglas, FEMA was advised that the areaways in question have been filled with lightweight concrete as proposed by the Citys consultant. FEMA was advised on June 1, 2004, that the actual cost for filling NAA 906, 907 and 1403 was $252,049.57.
Appeal Issues
While the Applicant and State raise a number of issues in their second appeal submittals, they can be summarized as follows:
· Are the methods of repair as outlined in the PW adequate to return the NAAs to their predisaster conditions?
· Is the scope of repairs as outlined in the PW adequate to return the NAAs to their predisaster conditions?
· Does the use of lightweight, engineered fill as proposed by the City qualify as cost effective hazard mitigation?
DISCUSSION
Due to the structural engineering issues in question, FEMA requested technical advice from its contractor, Fluor Daniel, Inc., as provided for in 44 CFR § 206.206 (d). The following discussion reflects that firms technical advice.
The primary argument of the Applicants second appeal is that the repair methods outlined in the PW are not adequate in method or scope to return the NAAs to their pre-disaster condition, and that FEMAs own publications, FEMA 306 and FEMA 308, support this position.
The cited FEMA publications are guidelines and do not prohibit the repair method outlined in the PW. The scope of work for repair was reviewed. Repair of the unreinforced masonry walls by grout injection will return the walls to the pre-disaster condition. However, based on a review of the project scope and items requiring repair, the cost estimate was revised to include additional items such as temporary facilities and purchase of used bricks, as well as the repair of more cracks. The total revised cost for the three NAAs is estimated to be $85,319. The States contention that the PW miscategorized the work as Category E versus Category C is not germane, because the categorization of the work does not impact the estimated repair cost.
Filling the NAAs with lightweight structural fill as a repair method is structurally superior to repairing the NAAs to restore them to their predisaster condition through grout injection as funded in the PW. It is also superior in terms of hazard mitigation, but it is not a cost-effective repair method when compared to repair of the walls by grout injection: $252,049 vs. $85,319.
CONCLUSION
The appeal for $252,049.57 is denied. However, the Applicant will be granted the difference between the total estimated repair cost ($85,319) and the original PW amount ($64,998), which is $20,321.