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Second Appeal Summary
PA ID# 037-91036; Los Angeles County Internal Services Department
DSR ID# DSR 08975; Central Cogeneration Plant
Citation: FEMA-1008-DR-CA, Los Angeles County Internal Services Department,
Central Cogeneration Plant, DSR 08975
Project Management Costs
The Northridge earthquake on January 17, 1994, damaged the Central Cogeneration Plant. Large Project Closeout DSR 08975 reduced eligible funding by $14,316 for failure to document eligible costs. In addition, FEMA treated $11,196 in Architectural and Engineering (A&E) construction administration costs as project management soft costs. On October 5, 2007, the Applicant submitted its first appeal requesting a permit fee, A&E construction administration costs, and the additional repair costs (de-obligated due to lack of documentation) for a total of $27,751 (which includes $2,239 in project management costs). The Applicant stated that A&E services are critical to the construction of the project and the A&E contractor is responsible for inspecting, analyzing, and verifying that the construction work is completed as specified and is not performing project management functions. It stated that it could not provide auditable documentation of some disaster-related repair costs as they were completed as part of ongoing facility maintenance; however, the Applicant maintained that these should be eligible costs. The Deputy Regional Administrator partially approved the appeal on May 8, 2008, concluding: $30 for a permit fee and associated project management was eligible; the A&E construction administration costs were properly treated as project management soft costs; and the Applicant failed to document eligible repair costs. The Applicant filed its second appeal on June 23, 2008. The Applicant reiterated its position from the first appeal stating that the characterization of A&E construction administration costs as project management soft costs is inappropriate and stated that funding related to repair work should be obligated.
1. Are A&E construction administration costs eligible for reimbursement as
2. Did the Applicant provide documentation to support its claim for eligible repair costs?
Rationale: Cost Estimating Format for Large Projects Instructional Guide (CEF Guide), Version 2
(November 1998); 44 CFR §13.20.