PA ID# 000-U6PMC-00; Central Electric Cooperative
DSR ID# Project 239; Improved Project-Various Sites
Citation: FEMA-1620-DR-SD; Central Electric Cooperative
Cross- Reference: Codes and Standards; Eligible work
Summary: As a result of a severe winter storm on November 27 through 29, of 2005, FEMA prepared Project Worksheet (PW) 239 for $856,450 to repair 130 (PW incorrectly states 132) projects sites in Central Electric Cooperatives (Applicant) distribution system. The PW stated the Applicant requested an improved project. The Applicant subsequently stated that it did not request an improved project. Rather, it requested reimbursement for all costs incurred in repairing these sites (including the replacement of significant sections of conductors) in accordance with the Rural Utility Service (RUS) Bulletin 1724D-106. FEMA determined that the RUS Bulletin was not a code and standard pursuant to program regulations. FEMA did adjust the estimated amount of the project worksheet by $52,410 to reflect local unit costs of various components of the system. The Applicant submitted a first appeal in a letter dated January 23, 2007. The Region denied the first appeal in PW 239 Version 2 stating that the project remains an improved project with eligible costs capped as in Version 1. The Applicants second appeal is requesting funding for the upgrades based on the RUS bulletin.
Issues: 1) Should the scope of work be revised to comply with the scope of work associated with the Rural Utility Service (RUS) codes and standards?
2) Should the total project cost be increased to allow additional costs to upgrade to current Rural Utility Service (RUS) standards?
Findings: 1) No, the submitted codes and standards do not meet the criteria necessary to be included as eligible work.
2) No, the approved scope of repair in PW 239 will restore the system to its pre-disaster function, design, and capacity. Costs should not be increased to cover the cost of ineligible components of work. Rationale: Stafford Act Section 406(e); 44 CFR §206.223(a)(1); 44 CFR 206.226(d)