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Second Appeal Brief
PA ID# 093-30550-00; Town of Gramercy
PW ID# 16158; Hazard Mitigation Proposal
Citation: FEMA-1603-DR-LA, Town of Gramercy, Hazard Mitigation Proposal – Water Intake Piping-Hazard Mitigation Proposal, Project Worksheet (PW) 16158
Reference: Hazard Mitigation
Summary: On September 23, 2005, high winds caused a ship moored on the Mississippi River to strike and damage a water intake structure and protective dolphin pile owned by the Town of Gramercy (Applicant). FEMA approved $383,958 under
PW 16158, for replacement of the dolphin pile, repair of the water intake structure, and a Hazard Mitigation Proposal (HMP). The HMP, estimated at $49,860, proposed to install a stronger protective sheathing around the water intake pipe. The Applicant requested approval of a second HMP under the same PW, estimated at $342,000, to install four new protective monopiles as a protective barrier to supplement the existing dolphin pile. FEMA denied the second HMP, because the four additional piles did not exist prior to the event, and the HMP was not directly related to the damaged elements of the facility. The Applicant submitted a first appeal requesting approval of the installation of the four monopiles as an HMP, stating that the proposal is cost effective and recommended by the Town engineer. The Regional Administrator denied the first appeal on December 16, 2008, stating that Section 406 mitigation must apply only to damaged elements of the facility and that the proposed new monopiles did not exist prior to the event. On April 2, 2009, the Applicant submitted a second appeal with a revised HMP requesting five monopiles at a cost of $563,913. On August 18, 2009, the Director of the Public Assistance Division met with the Applicant to discuss the appeal. FEMA requested that the Applicant provide a cost benefit analysis of the HMP project and the Applicant provided one on August 19, 2009.
Issue: Is the installation of new protective piles eligible as a section 406 hazard mitigation project?
Finding: No. The proposal is not cost effective.
Rationale: Disaster Assistance Policy DAP9526.1, Hazard Mitigation Funding under Section 406 (Stafford Act)