Citation:         FEMA-1393-DR-FL, Collier County Public Services Division, Sand Replacement, Project Worksheets (PWs) 566 and 673

Cross-

Reference:     Improved Beaches, Work Eligibility

Summary:       Collier County Public Services Division (Applicant) maintains four beaches that have been nourished and determined eligible for Public Assistance (PA) permanent work funding. The beaches suffered erosion from several declared storms and multiple PWs were prepared to replace the eroded sand. In a first appeal submitted on behalf of the Applicant, the Grantee contended that FEMA prematurely closed the referenced PWs and did not account for the eligible costs of beach environmental and turtle monitoring following the completion of the projects along the mainland and Marco Island beaches. The Grantee also claimed that the FEMA-approved scopes of work for PWs 566 and 673 were insufficient and requested an increase of the scopes to reflect the actual amount of sand placed on the beaches during re-nourishment projects in 2006 and 2007. The Regional Administrator found that no adequate basis was provided for increasing the eligible amount of sand placement as the damages could not be directly attributed to Tropical Storm Gabrielle. However, he determined that the incurred environmental monitoring costs are eligible for reimbursement and partially approved the appeal. In the second appeal, the Applicant claimed that FEMA based the approved scopes of work on estimated volumes of sand loss from the beaches, rather than the actual quantity of sand required to restore the beaches and requested FEMA approve changes to the PWs’ scopes of work. The Applicant based their proposed volume of sand on a consultant’s report which apportioned the total sand loss from 2000 to 2006 between Tropical Storm Gabrielle (FEMA-1393-DR-FL), Hurricane Katrina (FEMA-1602-DR-FL), and Hurricane Wilma (FEMA-1609-DR-FL). However, this quantity of sand loss is not limited to disaster-related damage as the beaches eroded before, between, and after the declared incident periods. The second appeal approves overall eligible sand replacement cost for Tropical Storm Gabrielle in the total amount of $6,180,261.53.  In conjunction with previously approved funding, this results in a total net increase in funding of $1,167,097.52.  The second appeal also directs the Region to review PWs for the beaches under the Hurricanes Katrina and Wilma declarations.

Issue:              Has the Applicant demonstrated that the disaster-related damages caused by Tropical Storm Gabrielle exceed the quantities detailed in the scopes of work of the referenced PWs?

Finding:          No. The documentation submitted does not justify an increase in the approved scopes of work.

Rationale:       44 CFR §206.223(a)(1), §206.202(d)