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Second Appeal Brief
PA ID# 117-99117-00; Washington Parish
PW ID# Project Worksheet 3384; Leaners and Hangers
Parish, Leaners and Hangers, PW 3384
Leaners, hangers, debris, reasonable costs,
Washington Parish (Applicant) contracted for debris removal services after Hurricane Katrina and submitted a request for reimbursement to FEMA. The request included reimbursement of $150 to $800 to remove leaners of various sizes and $200 to $400 to remove each dangerous hanger. FEMA reviewed information the Applicant submitted and determined that the requested costs for removing leaning trees and dangerous hanging limbs were unreasonable. FEMA subsequently prepared PW 3384 for debris removal from public and private property that reflected the reduced costs for above items. On first appeal, the Regional Administrator developed a Reasonable Cost Matrix that contained the highest prices FEMA paid in Louisiana for various debris removal activities. The Regional Administrator used the Reasonable Cost Matrix to increase the amount of reimbursement for leaners and hangers. However, the approved amounts for leaners and hangers were less that what the Applicant requested.
In the second appeal, the Applicant submitted volumes of information to support its claim that its costs were reasonable and that FEMAs Reasonable Cost Matrix was flawed. The Public Assistance Division Director met with the State and Applicant on April 17, 2008, to discuss the appeal. The Applicant submitted supplemental information on
May 19, 2008.
Are the requested costs for leaners and hangers reasonable?
OMB Circular A-87, Cost Principles for State, Local and Tribal Governments