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Debris Removal Costs
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Cross Appeal Format and Content, Reasonable Cost
Reference:
Summary: Debris generated by Hurricane Rita (FEMA-1606-DR-TX) was deposited throughout the City of Jasper (Applicant) and caused an immediate threat to public health and safety. The Applicant entered into a Time and Materials contract on September 26, 2005, for cleanup of the debris. The total invoiced amount from the contractor was $896,781.20 for the collection, hauling and disposal of 24,341.3 cubic yards of debris. FEMA determined the total costs to be unreasonable and obligated Project Worksheet Number 1010 on January 30, 2006, in the amount of $449,273.99 based on rates used by the Texas Department of Transportation (TDOT), including an additional 25 percent for overhead and profit. This reduced the eligible claimed amount by $322,149.50. FEMA also reduced the eligible amount by $125,357.70 for duplicated costs submitted by the contractor. On March 31, 2006, the Applicant submitted a first appeal stating that it provided additional cost information to substantiate the reasonableness and necessity of the debris removal costs. On May 17, 2006, FEMA denied the first appeal, stating that the Applicant did not include justification for reconsideration, and that the TDOT rates used in the reasonable cost comparison appeared to be appropriate. Therefore, additional costs for debris removal were not eligible. The Applicant filed a second appeal with FEMA on July 12, 2006, requesting reconsideration of the determination.
Issues: (1) Has the Applicant provided sufficient documentation to justify the additional costs of debris removal under the Time and Materials contract in lieu of TDOT rates?
Findings: (1) No. The Applicant provided no justification or supporting documentation regarding the reasonableness of costs.
Rationale: 44 CFR ยง206.206
Second Appeal Brief
FEMA-1606-DR
PA ID# 241-37420-00; City of Jasper
PW ID# Project Worksheet 1010; Debris Removal Costs
08/02/2007
Citation: FEMA-1606-DR-TX, City of Jasper, PW 1010, Debris Removal CostsPA ID# 241-37420-00; City of Jasper
PW ID# Project Worksheet 1010; Debris Removal Costs
08/02/2007
Cross Appeal Format and Content, Reasonable Cost
Reference:
Summary: Debris generated by Hurricane Rita (FEMA-1606-DR-TX) was deposited throughout the City of Jasper (Applicant) and caused an immediate threat to public health and safety. The Applicant entered into a Time and Materials contract on September 26, 2005, for cleanup of the debris. The total invoiced amount from the contractor was $896,781.20 for the collection, hauling and disposal of 24,341.3 cubic yards of debris. FEMA determined the total costs to be unreasonable and obligated Project Worksheet Number 1010 on January 30, 2006, in the amount of $449,273.99 based on rates used by the Texas Department of Transportation (TDOT), including an additional 25 percent for overhead and profit. This reduced the eligible claimed amount by $322,149.50. FEMA also reduced the eligible amount by $125,357.70 for duplicated costs submitted by the contractor. On March 31, 2006, the Applicant submitted a first appeal stating that it provided additional cost information to substantiate the reasonableness and necessity of the debris removal costs. On May 17, 2006, FEMA denied the first appeal, stating that the Applicant did not include justification for reconsideration, and that the TDOT rates used in the reasonable cost comparison appeared to be appropriate. Therefore, additional costs for debris removal were not eligible. The Applicant filed a second appeal with FEMA on July 12, 2006, requesting reconsideration of the determination.
Issues: (1) Has the Applicant provided sufficient documentation to justify the additional costs of debris removal under the Time and Materials contract in lieu of TDOT rates?
Findings: (1) No. The Applicant provided no justification or supporting documentation regarding the reasonableness of costs.
Rationale: 44 CFR ยง206.206