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Second Appeal Brief
PA ID# 117-27190-00; Town of Franklinton
PW ID# Project Worksheets 271 and 3672; Leaners and Hangers
Town of Franklinton, Leaners and Hangers, PWs 271 and 3672
Leaners, hangers, debris, reasonable costs,
The Town of Franklinton (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 and managing Temporary Debris Storage and Reduction Sites (TDSRS) were unreasonable. FEMA subsequently prepared PW 271 for debris removal from public property and PW 3672 for debris removal from private property that reflected the reduced costs for the 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, hangers, and TDSRS. 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 15, 2008.
Are the requested costs for leaners and hangers reasonable?
OMB Circular A-87, Cost Principles for State, Local and Tribal Governments