Beginning on April 30, 2010, severe storms, tornadoes, heavy rains, high winds, flooding, and flash flooding affected the City of Clarksville. As a result, several buildings—collectively known as the Primary Clarifier Complex (Facility)—within the Clarksville Gas and Water’s (Applicant) wastewater treatment plant were inundated with floodwaters. Project Worksheet (PW) 5374 was prepared to reflect costs to replace or repair damage to the Facility. Upon review of PW 5374, FEMA determined that the Facility is located within a United States Army Corps of Engineers (USACE) flood easement which held harmless the United States Government from all losses resulting from flood. As such, FEMA determined that the repair work was ineligible for Public Assistance (PA) funding, and PW 5374 was obligated for zero dollars.
In its first appeal letter, dated June 24, 2011, the Applicant presented three issues. First, the Applicant asserted that the USACE easement did not contain an indemnification provision in favor of the United States. Second, the Applicant asserted that the Cost Estimating Format (CEF) omitted ancillary material and equipment costs and did not fully account for labor costs associated with work performed. Accordingly, the Applicant requested a revised scope of work and additional PA funding in PW 5374. Lastly, the Applicant requested additional funding for project management tasks and Direct Administrative Costs (DAC) associated with the Facility’s repair work.
On May 13, 2014, the Region IV Regional Administrator (RA) partially approved the first appeal finding eligible $22,039.85 for costs disallowed due to a USACE easement, project and construction management costs, and DAC. The RA denied funding associated with work items excluded from the scope of work in PW 5374 because the appeal’s supporting documentation made no distinction between work already accounted for in the CEF and the specific appealed scope addition or cost increase.
Through its June 30, 2014 second appeal, the Applicant requests $126,029.71 in additional PA funding for excluded work items. The Applicant claims $67,029.71 for six days of labor to complete work performed on the Facility that was not captured in the CEF for the original version of PW 5374. In addition, the Applicant requests $58,997.01 for the repair or replacement of data conduits, data cable installation, data cable terminations, instrumentation installation, instrumentation conduit installation, instrumentation cable installation, and instrumentation cable terminations throughout the Facility. The Applicant provides four supporting documents to substantiate its request for additional funding.
The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), Section 406, authorizes FEMA to make contributions to a local government to restore eligible facilities on the basis of the design of such facilities as they existed immediately prior to the disaster. Pursuant to Title 44 of the Code of Federal Regulations (44 C.F.R.) § 206.223(a), which implements that provision, an eligible item of work must be, among other things, required as the result of the disaster event. Typically, FEMA reimburses costs that can be directly tied to the performance of eligible work. The Applicant must substantiate eligible costs with adequate documentation.
The Applicant submitted four supporting documents related to PW 5374 with its second appeal. The first, Exhibit 1, is an undated and unsigned bulleted list of uncompleted items. The second document is the CEF attached to PW 5374 which reflects six days of labor performed by Shermco and Harlan Labor (Contractor). The third document provides names of laborers, dates they worked, and hours worked. The Applicant states this document demonstrates the difference between the PW estimate and the actual labor cost. Finally, the fourth document, Attachment C, lists various electrical components and equipment and their associated costs. These documents provide greater detail regarding the work items the Applicant wants included in the revised PW scope of work. However, without a detailed explanation demonstrating where the damage occurred within the Facility and how the work requested addresses damage caused by the disaster, these documents do not sufficiently meet the criteria required by 44 C.F.R. § 206.223 to support PA funding. Accordingly, FEMA cannot approve an expanded scope of work to include the Applicant’s requested items.
As required by 44 C.F.R. § 206.223(a), the second appeal does not provide the level of information necessary to make PA eligibility determinations regarding the Applicant’s requested work items. Specifically, the Applicant failed to demonstrate that the requested work was the result of the disaster. Accordingly, this appeal is denied.
 In the second appeal, there is a discrepancy in the Applicant’s requested amount. The Applicant requests a total of $126,029.71 in additional funding. However, the breakdown of the additional amount adds up to $126,026.72 (67,029.71 + $58,997.01).
 The Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988, Pub. L. No. 93-288, § 406, 42 U.S.C. § 5172 (2007).
 See 44 C.F.R. § 206.223(a) (2009).
 See generally, 44 C.F.R. § 206.228; see also Public Assistance Guide, FEMA 322, at 40 (June 2007).
 See OFFICE OF MGMT. & BUDGET, EXEC. OFFICE OF THE PRESIDENT, OMB CIRCULAR A-87, COST PRINCIPLES FOR STATE, LOCAL, AND INDIAN TRIBAL GOVERNMENTS (2004) (codified at 2 C.F.R. § 225).
 On October 7, 2014, FEMA sent a Request for Information (RFI) to the Applicant and Grantee requesting documentation connecting the labor logs provided with the second appeal to specific elements of PW 5374’s scope of work. FEMA provided examples of acceptable documentation, including but not limited to, a detailed list of all damaged elements beyond what is listed in the PW including documentation of the nature and extent of the damage, a detailed scope of work provided within bid documents; a breakdown of which organization—Allied Technical Services, Shermco Industries, Harlan, and Hazen and Sawyer—was responsible for which parts of the work completed; and documentation of work completed, such as a scope of work with percent-complete by task item. As of issuance of this appeal response, neither the Applicant nor the Grantee has submitted any documentation in response to the RFI.