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Summary: Wind and wave action resulting from flooding during the 2005-2006 winter storms caused damage to a 2,000-linear foot-long by eight-foot high earthen berm depositing six to eight inches of berm material and silt into two aerator ponds and one settling pond located at a sewer treatment facility. FEMA prepared PW 2776 for $480,831, to restore the ponds to pre-disaster condition. Granton Community Services District (Applicant) requested additional funding for $1,496,573 for a hazard mitigation proposal to protect its facilities against a 100-year flood event. The Applicant proposed to construct a concrete floodwall around the wastewater treatment facility. FEMA denied the request because the proposed Hazard Mitigation Proposal (HMP) was not being performed in conjunction with the repairs of the damaged facilities. In addition, FEMA determined that building a wall around the entire facility was providing mitigation protection to more than the disaster-related damaged elements. The Applicant stated in its first appeal, submitted January 9, 2008, that FEMA mischaracterized the proposed HMP as a new facility. The Deputy Regional Administrator denied the first appeal re-affirming the initial determination. In its second appeal, the Applicant argues that it was not feasible to elevate the existing levees with fill material because raising the elevation would widen the base and encroach upon nearby creeks. In addition, the Applicant clarified that the HMP is for the construction of a four-foot tall concrete wall on top of the existing berm. The Applicant is not proposing to build a separate floodwall.
Issues: Is the construction of a four-foot tall concrete wall on top of the existing berm, as proposed by the Applicant, eligible as cost-effective hazard mitigation?
Findings: Yes.
Rationale: 44 CFR §206.226(e), Hazard Mitigation, Response and Recovery Policy 9526.1, Hazard Mitigation funding under Section 406, dated August 13, 1998.
Second Appeal Brief
FEMA-1628-DR
PA ID# 097-UGBU4-00; Granton Community Services District
PW ID# 2776; Hazard Mitigation
07/23/2009
Citation:FEMA-1628-DR-CA, Granton Community Services District, Hazard Mitigation, PW 2776PA ID# 097-UGBU4-00; Granton Community Services District
PW ID# 2776; Hazard Mitigation
07/23/2009
Summary: Wind and wave action resulting from flooding during the 2005-2006 winter storms caused damage to a 2,000-linear foot-long by eight-foot high earthen berm depositing six to eight inches of berm material and silt into two aerator ponds and one settling pond located at a sewer treatment facility. FEMA prepared PW 2776 for $480,831, to restore the ponds to pre-disaster condition. Granton Community Services District (Applicant) requested additional funding for $1,496,573 for a hazard mitigation proposal to protect its facilities against a 100-year flood event. The Applicant proposed to construct a concrete floodwall around the wastewater treatment facility. FEMA denied the request because the proposed Hazard Mitigation Proposal (HMP) was not being performed in conjunction with the repairs of the damaged facilities. In addition, FEMA determined that building a wall around the entire facility was providing mitigation protection to more than the disaster-related damaged elements. The Applicant stated in its first appeal, submitted January 9, 2008, that FEMA mischaracterized the proposed HMP as a new facility. The Deputy Regional Administrator denied the first appeal re-affirming the initial determination. In its second appeal, the Applicant argues that it was not feasible to elevate the existing levees with fill material because raising the elevation would widen the base and encroach upon nearby creeks. In addition, the Applicant clarified that the HMP is for the construction of a four-foot tall concrete wall on top of the existing berm. The Applicant is not proposing to build a separate floodwall.
Issues: Is the construction of a four-foot tall concrete wall on top of the existing berm, as proposed by the Applicant, eligible as cost-effective hazard mitigation?
Findings: Yes.
Rationale: 44 CFR §206.226(e), Hazard Mitigation, Response and Recovery Policy 9526.1, Hazard Mitigation funding under Section 406, dated August 13, 1998.

