Insurance
Appeal Brief
Appeal Letter
Appeal Analysis
Appeal Brief
| Disaster | FEMA-1909 |
| Applicant | Nashville Electric Service |
| Appeal Type | Second |
| PA ID# | 000-UHCTF-00 |
| PW ID# | (PW) 5573 |
| Date Signed | 2018-07-02T00:00:00 |
Conclusion: The administrative record confirms that Nashville Electric Service’s (Applicant) insurance coverage was exhausted and no additional insurance proceeds were available for the costs reinstated in Project Worksheet (PW) 5573, Version 1. Accordingly, the project’s insurance deduction should be adjusted to reflect actual insurance proceeds received rather than anticipated insurance proceeds.
Summary Paragraph
From April 30 to May 18, 2010, floods from the disaster inundated the Applicant’s West Service Center (Facility), which required significant cleanup work as a result. In PW 5573, FEMA documented eligible cleanup and direct administrative costs, less a reduction for anticipated insurance proceeds and parking lot cleanup costs it found ineligible. On April 8, 2011, the Applicant appealed the denial of $255,562.63 in cleanup costs. FEMA granted the appeal on May 1, 2014, explaining that the reinstated costs were subject to further insurance review. An insurance review addendum dated May 2, 2014, explained that a $250,000.00 reduction for anticipated insurance proceeds would be applied to the reinstated costs because the Applicant did not show it exhausted its coverage for land and water contaminant cleanup under the Metropolitan Government of Nashville and Davidson County (Metro) insurance pool. FEMA prepared PW 5573, Version 1 on January 30, 2015, to reinstate the approved costs and apply the additional insurance reduction. On May 21, 2015, the Tennessee Emergency Management Agency forwarded a notice of the subgrant’s closure to the Applicant. The Applicant appealed on June 29, 2015, requesting that the project’s insurance reduction be adjusted to reflect actual proceeds received rather than anticipated proceeds. It stated it was not reimbursed for all damage and costs reported in the insurance claim because: (1) Metro allocated insurance pool settlement funds based on the approved PW amounts as of October 2011 (when Metro finalized the claim), and (2) the approved amount for PW 5573 did not include the cleanup costs of $255,562.63 on appeal in October 2011 because FEMA did not adjudicate the appeal until May 2014. The FEMA Region IV Regional Administrator (RA) denied the appeal on September 1, 2017, citing to Metro’s report of the final settlement paid as the basis for finding the Applicant did not pursue all insurance coverage available for its reinstated cleanup costs. On second appeal, the Applicant argues the RA erred in relying on Metro’s settlement report because the report provided no information on the claim it submitted to the insurance carrier.
Authorities
- Stafford Act § 312(a).
- 44 C.F.R. § 206.250(c).
- DAFS9580.3, at 2.
- RRP9525.3, at 2.
- PA Guide, at 119, 120, and 22.
Headnotes
- DAFS9580.3 explains that an applicant must seek out and maximize its potential insurance benefits, and advise FEMA of its insurance recoveries. According to 44 C.F.R. § 206.250(c), FEMA deducts actual and anticipated insurance recoveries from otherwise eligible costs. The PA Guide states that FEMA generally reimburses the difference between the eligible costs and insurance proceeds when project costs exceed a policy’s limits or sublimits for certain hazards such as flood.
- The record confirms: (1) the Applicant reported its parking lot cleanup costs to the insurer in its insurance claim; (2) its land and water contaminant cleanup coverage was subject to the policy’s Flood Zone A sublimit; and (3) no additional insurance proceeds were available under that coverage for the costs reinstated in Version 1 because the Facility is in Flood Zone A, and the policy’s Flood Zone A sublimit was exhausted.
Appeal Letter
Mr. Patrick Sheehan
Director
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204-1502
Re: Second Appeal – Nashville Electric Service, PA ID 000-UHCTF-00, FEMA-1909-DR-TN, Project Worksheet (PW) 5573 – Insurance
Dear Mr. Sheehan:
This is in response to a letter from your office dated October 30, 2017, which transmitted the referenced second appeal on behalf of Nashville Electric Service (Applicant). The Applicant is appealing the U.S. Department of Homeland Security’s Federal Emergency Management Agency’s (FEMA) reduction of $250,000.00 for anticipated insurance proceeds in Project Worksheet (PW) 5573, Version 1, and requests that FEMA adjust the insurance reduction for PW 5573 to reflect actual insurance proceeds received instead of anticipated insurance proceeds.
As explained in the enclosed analysis, I have determined: (1) the Applicant’s insurance coverage was exhausted and no additional insurance proceeds were available for the $255,562.63 in parking lot cleanup costs reinstated in PW 5573, Version 1, and (2) the insurance reduction for PW 5573 must be adjusted to reflect actual insurance proceeds received rather than anticipated insurance proceeds. Accordingly, I am granting this appeal. By copy of this letter, I am requesting that the Regional Administrator take appropriate action to implement this determination.
This determination is the final decision on this matter pursuant to 44 C.F.R. § 206.206, Appeals.
Sincerely,
Jonathan Hoyes
Director
Public Assistance Division
Enclosure
cc: Gracia Szczech
Regional Administrator
FEMA Region IV
Appeal Analysis
Background
From April 30 to May 18, 2010, severe storms, flooding, straight-line winds, and tornadoes caused damage throughout Nashville and Davidson County, Tennessee. As a result, up to nine feet of floodwater inundated areas of Nashville Electric Service’s (Applicant) West Service Center (Facility).
On February 23, 2011, FEMA documented the Applicant’s claim for $695,798.51 in costs to de‑muck and disinfect seven flood-damaged structures at the Facility in Project Worksheet (PW) 5573. After reviewing the entire claim, FEMA approved $359,880.72 in costs for cleanup work and $1,888.12 in direct administrative costs, but deemed $334,029.67 of the Applicant’s other costs ineligible. The disallowed amount included $255,562.63 in costs to clean and decontaminate the Facility’s parking lot.[1] After reviewing the Applicant’s flood coverage under the Metropolitan Government of Nashville and Davidson County (Metro) insurance pool, FEMA also applied a $359,880.72 reduction for anticipated insurance proceeds.[2] A commercial policy with Factory Mutual Insurance Company (FM Global) provided flood coverage for all insurance pool locations, which all shared the following policy coverage limits: (1) a flood coverage limit of $100,000,000.00, (2) a flood coverage sublimit of $5,000,000.00 for facilities located in areas designated as Flood Zone A,[3] and (3) a coverage limit of $250,000.00 for land and water contaminant cleanup, which was also subject to the policy’s flood limit and Flood Zone A sublimit.[4]
On April 8, 2011, the Applicant appealed FEMA’s decision to disallow $255,562.63 in parking lot cleanup costs.[5] FEMA granted the appeal on May 1, 2014, but noted that the reinstatement of those costs would be subject to further insurance review.[6] An addendum to the project’s initial insurance review entered in the Emergency Management Mission Integrated Environment (EMMIE)[7] on May 2, 2014, explained: (1) the parking lot cleanup costs granted on appeal “were reported to the [A]pplicant’s insurance carrier,” and (2) an additional anticipated insurance proceeds reduction of $250,000.00 would be applied to PW 5573 because the documentation on file did not establish the FM Global policy’s coverage limit of $250,000.00 for land and water contaminant cleanup had been exhausted. [8] On January 30, 2015, FEMA approved PW 5573, Version 1, to reinstate the $255,562.63 in costs granted on appeal, but applied an additional insurance reduction of $250,000.00.
On March 12, 2015, the Applicant contacted the Tennessee Emergency Management Agency (Grantee) to inquire whether an error occurred in reinstating the $255,562.63 in costs granted on appeal after noticing that only $5,562.63 in additional costs were obligated for Version 1.[9] The Grantee responded explaining that FEMA applied an additional insurance reduction to Version 1, and recommended the Applicant notify the Grantee if it did not receive those insurance proceeds.[10] On March 16, 2015, the Applicant contacted Metro to request reimbursement for the $250,000.00 in additional anticipated insurance proceeds that FEMA applied to PW 5573, Version 1.[11] Metro responded on April 1, 2015, explaining that no additional settlement funds were available to the Applicant because the insurance pool’s flood insurance claim was finalized in October 2011.[12]
In a letter dated April 30, 2015, the Applicant informed the Grantee that it pursued all insurance benefits available through the Metro insurance pool, but received no insurance proceeds for the parking lot cleanup costs reinstated in PW 5573, Version 1. Accordingly, the Applicant requested that FEMA adjust the project’s insurance reduction to reflect actual insurance proceeds received rather than anticipated insurance proceeds. On May 21, 2015, the Grantee received a notification letter from FEMA regarding the closure of the Applicant’s subgrants.[13] The letter directed the Grantee to notify the Applicant that FEMA had closed out the subgrants, and to advise the Applicant of its right to appeal that action. The Grantee forwarded that notification to the Applicant with a letter dated May 21, 2015.[14]
First Appeal
On June 29, 2015, the Applicant appealed FEMA’s closure of its subgrants, and requested that FEMA adjust the insurance reduction for PW 5573 to reflect actual insurance proceeds received of $359,880.80 rather than anticipated insurance proceeds of $609,880.72.[15] The Applicant explained that it submitted an insurance claim reporting all damage and costs to Metro and FM Global, but the final settlement received did not reimburse all reported costs. The Applicant attributed the low settlement amount to Metro’s methodology for allocating settlement funds to the insurance pool members. For instance, the Applicant stated that Metro based its allocation of settlement funds on the PW amounts approved by FEMA as of October 5, 2011,[16] which did not include the Applicant’s $255,562.63 in appealed parking lot cleanup costs because FEMA did not adjudicate the appeal until May 1, 2014.[17] The Grantee transmitted the Applicant’s first appeal to FEMA with a recommendation letter dated June 30, 2015.[18]
On March 11, 2016, FEMA issued a Final Request for Information (RFI) to advise the Applicant the appeal would likely be denied due to a lack of documentation demonstrating it submitted an insurance claim for its parking lot cleanup costs to FM Global, or exhausted the $250,000.00 in insurance coverage limit described in FM Global’s letter dated August 9, 2010.[19] FEMA also requested that the Applicant provide its Proof of Loss for all locations and damages included in PW 5573, and any other information supportive of its appeal.
The Applicant responded in a letter dated March 30, 2016, stating that it only received actual insurance proceeds of $359,880.88 for PW 5573.[20] The supporting documentation attached with the Applicant’s Final RFI response included: (1) photographs of insurance claim documentation the Applicant submitted to Metro and FM Global in two three-ring binders; (2) Metro’s Forensic Accounting and Claims Services (FACS) Report dated September 28, 2011; (3) the Applicant’s Proof of Loss documents for claims under its Standard Flood Insurance Policy with the National Flood Insurance Program (NFIP); (4) a spreadsheet itemizing the anticipated insurance proceeds applied and actual proceeds received for PW 5573; and (5) proof of the payments it received from FM Global settlement funds and its Standard Flood Insurance Policy carrier.
On September 1, 2017, the FEMA Region IV Regional Administrator (RA) denied the Applicant’s first appeal.[21] The RA concluded the Applicant’s documentation did not establish that it pursued all available insurance coverage. The RA also cited to Metro’s FACS Report as support for finding that the Applicant’s insurance claim did not include the $255,562.63 in parking lot cleanup costs reinstated in Version 1, and was based on $361,768.84 in costs FEMA approved for PW 5573, Version 0, rather than the total costs incurred to complete all work.
Second Appeal
In a letter dated October 23, 2017, the Applicant appeals the RA’s first appeal decision, and requests that FEMA reinstate the $250,000.00 insurance reduction applied in PW 5573, Version 1.[22] On second appeal, the Applicant argues that FEMA incorrectly applied the additional insurance reduction because all Metro insurance pool settlement funds have been exhausted, and there are no additional insurance proceeds to anticipate. The Applicant also contests the RA’s findings that it only submitted an insurance claim for $361,768.84 in costs documented in Version 0, and did not submit an insurance claim for $255,562.63 in costs reinstated in Version 1 to clean and decontaminate the Facility’s parking lot.[23] While the RA cited to Metro’s FACS Report as support for those findings, the Applicant emphasizes that the FACS Report only accounts for the final amount of settlement funds allocated to insurance pool members by Metro, and it provides no information regarding the Applicant’s actual insurance claim. The Applicant also notes that the FACS Report was created by Metro, not the Applicant.[24] Lastly, the Applicant explains it submitted a 129-page insurance claim package to Metro and FM Global in August 2011, which included the same documentation provided to FEMA during project development that fully described each item of work and substantiated $695,798.51 in costs.[25] The Grantee transmitted the Applicant’s second appeal to FEMA with an attached recommendation letter dated October 30, 2017.[26]
Discussion
FEMA is prohibited from providing assistance that would duplicate benefits received from any other program, insurance, or any other source.[27] In addition, insurance proceeds should be an applicant’s first avenue for disaster assistance, and FEMA funding is intended to supplement assistance from other sources.[28] Accordingly, an applicant for Public Assistance (PA) funding must seek out and maximize all potential benefits from its insurance policies, and provide FEMA with information pertaining to its insurance recoveries.[29] After reviewing a project’s insurance information, FEMA determines whether the settlement appears proper in terms of the policy provisions, and then reduces the grant amount by actual insurance proceeds received and the amount of proceeds that can be reasonably anticipated from the insurance policy.[30] When project costs exceed an insurance policy’s limits or sublimits for certain hazards such as flood or earthquake, FEMA generally reimburses the difference between the eligible costs and insurance proceeds.[31]
The information contained in the administrative record supports the Applicant’s assertion that it included the parking lot cleanup costs in its original insurance claim. For instance, the addendum to the project’s initial insurance review dated May 2, 2014, stated that the parking lot cleanup costs reinstated in Version 1 “were reported to the [A]pplicant’s insurance carrier” according to FM Global’s letter dated August 9, 2010.[32] In that letter, FM Global explained that it was notified of a possible claim “at the [Applicant’s] West Service Center” under the policy’s coverage for land and water contaminant cleanup, and that this coverage was subject to the flood limit and Flood Zone A sublimit.[33] While the letter did not indicate it would need additional information regarding the contaminant cleanup claim at the Applicant’s Facility, it did ask Metro to advise of any other possible claims within the policy’s land and contaminant cleanup coverage.[34] In addition, the record supports the Applicant’s assertion that the FACS Report does not provide information about its entire insurance claim. For example, the FACS Report only accounted for $1,128,584.00 of the Facility’s flood damage, but the documentation attached with FM Global’s letter dated August 9, 2010, included $28,449,423.00 of the Facility’s estimated flood damage.[35]
The administrative record also demonstrates the Facility was subject to the FM Global policy’s $5,000.000.00 Flood Zone A sublimit, rather than the policy’s total flood limit of $100,000,000.00. The project’s initial insurance review identified the Facility as a location “in FEMA flood zone shaded-X” with insurance proceeds anticipated under the FM Global policy’s $100,000,000.00 flood coverage limit.[36] However, the administrative record confirms that the Facility is located in Flood Zone A, and is subject to the $5,000,000.00 Flood Zone A sublimit. For example, Flood Insurance Rate Map (FIRM) Panel Number 47037C0211F,[37] the FIRMette for PW 5573 dated August 27, 2010, the Special Consideration Questions form for PW 5573 dated August 27, 2010,[38] and the Standard Flood Insurance Policy declarations received by FEMA on June 3, 2010,[39] all confirm that the Facility is located in Flood Zone A.[40] In addition, the documentation enclosed with FM Global’s letter dated August 9, 2010, contains 15 flood zone location entries that verify the Facility is situated in Flood Zone A.[41]
The project’s insurance review addendum dated May 2, 2014, added an additional insurance reduction to PW 5573 based on a finding that the documentation on file did not show the Applicant’s coverage limit for land and water contaminate cleanup under FM Global policy had been exhausted.[42] However, the administrative record confirms that the policy’s land and water contaminant cleanup coverage was subject to the policy’s Flood Zone A sublimit, which was exhausted prior to the approval of PW 5573, Version 0, in February 2011.[43] According to FM Global’s letter dated August 9, 2010, the insurance pool’s total flood claim for all Flood Zone A locations (estimated at $103,675,457.83)[44] was “far in excess of the [Flood] Zone A $5,000,000.00 limit.”[45] Prior to approving Version 0, FEMA also completed insurance reviews for 61 other PWs in the Metro insurance pool, which all confirmed the FM Global policy’s Flood Zone A sublimit had already been exhausted.[46] Metro’s email dated April 1, 2015, also stated that no additional insurance proceeds were available to the Applicant because the flood claim was closed in October 2011, and all FM Global settlement funds had already been allocated.[47] Therefore, no additional insurance coverage was available for the costs reinstated in Version 1 because the Facility and the policy’s land and water contaminant cleanup coverage were subject to the Flood Zone A sublimit, which had already been exhausted.
Conclusion
The administrative record confirms the Applicant’s insurance coverage was exhausted and no additional insurance proceeds were available for the $255,562.63 in parking lot cleanup costs reinstated in PW 5573, Version 1. Accordingly, the project’s insurance reduction must be adjusted to reflect actual insurance proceeds received instead of anticip
[1] Project Worksheet 5573, Nashville Electric Service, Version 1 (Feb. 23, 2011).
[2] EMMIE Subgrant Application Workflow History, Reviewer Comment No. 4 (Feb. 18, 2011).
[3] Flood Zone A locations include any location “designated by [FEMA] as subject to a flood frequency up to and including the 100 year frequency,” or any of the nine locations named in Appendix C. Factory Mut. Insurance Co., Policy No. JD042, at Appendix C (June 18, 2009) [hereinafter FM Global Policy]; see also Letter from Gen. Adjuster, Factory Mut. Ins. Co., to Ins. & Claims Manager, Metro. Gov’t of Nashville & Davidson Cty., at 2 (Aug. 9, 2010) [hereinafter FM Global Letter].
[4] FM Global Policy, at 3–4, 5; FM Global Letter, at 2, 5.
[5] Letter from Chief Fin. Officer, Nashville Elec. Serv., to Alternate Governor’s Authorized Representative, Tenn. Emergency Mgmt. Agency (Apr. 8, 2011). The support documentation attached with the appeal included a copy of PW 5573 and the Applicant’s contract documentation and invoices to substantiate its $255,562.63 in requested parking lot cleanup costs.
[6] Letter from Reg’l Adm’r, FEMA Region VI, to Interim Dir., Tenn. Emergency Mgmt. Agency (May 1, 2014).
[7] EMMIE is FEMA’s internet-based grants management system.
[8] EMMIE Subgrant Application Workflow History, Reviewer Comment No. 20 (May 2, 2014).
[9] Email from Controls & Compliance Manager, Nashville Elec. Serv., to Pub. Assistance Specialist, Tenn. Emergency Mgmt. Agency (Mar. 12, 2015, 10:06 AM).
[10] Email from Pub. Assistance Specialist, Tenn. Emergency Mgmt. Agency, to Controls & Compliance Manager, Nashville Elec. Serv. (Mar. 16, 2015, 11:43 AM).
[11] Email from Controls & Compliance Manager, Nashville Elec. Serv., to Fin. Manager, Metro. Gov’t of Nashville & Davidson Cty. Office of Mgmt. and Budget (Mar. 16, 2015, 3:20 PM).
[12] Email from Fin. Manager, Metro. Gov’t of Nashville & Davidson Cty. Office of Mgmt. and Budget, to Controls & Compliance Manager, Nashville Elec. Serv. (Apr. 1, 2015, 10:30 AM).
[13] See Letter from Pub. Assistance Branch Chief., FEMA Region IV, to Deputy Comm’r, Tenn. Emergency Mgmt. Agency (Apr. 28, 2015) (displaying a stamp confirming the Grantee received the letter on May 21, 2015); see also id., at Attachment (listing the “Subgrantee Status” as “Closed 04/27/2015).
[14] See Letter from Vice President, Nashville Elec. Serv., to Dir., Tenn. Emergency Mgmt. Agency (Jun. 29, 2015) (confirming the Grantee’s letter dated May 21, 2015, was received by the Applicant on June 3, 2015).
[15] Letter from Vice President, Nashville Elec. Serv., to Dir., Tenn. Emergency Mgmt. Agency (June 28 2015).
[16] This is the date Metro finalized the Applicant’s flood claim.
[17] Support documentation attached with the Applicant’s appeal included: (1) an appeal timeline; (2) Metro’s Forensic Accounting and Claims Services (FACS) Report dated September 28, 2011, which itemized all FM Global settlement funds received by the Applicant; (3) the Applicant’s email correspondence with Metro and the Grantee regarding its insurance proceeds for PW 5573; (4) the Applicant’s appeal dated April 8, 2011, challenging FEMA’s denial of $255,562.63 in parking lot cleanup costs in Version 0; and (5) FEMA’s appeal response dated May 1, 2014, granting the Applicant’s appeal for those costs.
[18] Letter from Alternate Governor’s Authorized Representative, Tenn. Emergency Mgmt. Agency, to Reg’l Adm’r, FEMA Region IV (June 30, 2015).
[19] Letter from Recovery Div. Dir., FEMA Region IV, to Deputy Comm’r, Tenn. Emergency Mgmt. Agency, and to Vice President, Nashville Elec. Serv. (Mar. 11, 2016); FM Global Letter, at 5.
[20] Letter from Vice President, Nashville Elec. Serv., to Pub. Assistance Branch Chief, FEMA Region IV (Mar. 30, 2016). The insurance proceeds received included: $182,789.00 in Standard Flood Insurance Policy coverage under a separate insurance carrier and $177,091.88 in FM Global settlement funds.
[21] FEMA First Appeal Analysis, Nashville Elec. Serv., FEMA-1909-DR-TN, at 3–4 (Sept. 1, 2017).
[22] Letter from Vice President, Nashville Elec. Serv., to Alternate Governor’s Authorized Representative, Tenn. Emergency Mgmt. Agency (Oct. 23, 2017) [hereinafter Applicant’s Second Appeal].
[23] See id., at 2 (citing to FEMA First Appeal Analysis, Nashville Elec. Serv., FEMA-1909-DR-TN, at 3 (Sept. 1, 2017).
[24] According to metadata from the electronic version of the FACS Report, the Finance Manager for Metro’s Office of Management and Budget created the FACS Report on October 5, 2011, at 1:32 PM.
[25] Applicant’s Second Appeal, at 2–3.
[26] Letter from Alternate Governor’s Authorized Representative, Tenn. Emergency Mgmt. Agency, to Assistant Adm’r, FEMA Office of Recovery Directorate (Oct. 30, 2017).
[27] The Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988, Pub. L. No. 93-288, § 312(a), 42 U.S.C. § 5155(a) (2007).
[28] FEMA Response and Recovery Directorate Policy RRP9525.3, Duplication of Benefits-Non Government Funds, at 2 (July 24, 2007).
[29] FEMA Disaster Assistance Fact Sheet DAFS9580.3, Insurance Considerations for Applicants, at 2 (May 29, 2008); Public Assistance Guide, FEMA 322, at 120 (June 2007) [hereinafter PA Guide].
[30] 44 C.F.R. § 206.250(c) (2009); PA Guide, at 119.
[31] See id. at 122 (providing the following examples of uninsured losses that may be eligible for PA funding: (1) an applicant’s reasonable deductible in its first claim for FEMA assistance, (2) depreciation, i.e., the difference between FEMA eligible costs and final loss valuations used by insurers, and (3) costs exceeding an insurance policy’s limits or sublimits for certain hazards such as flood or earthquake).
[32] EMMIE Subgrant Application Workflow History, Reviewer Comment No. 20 (May 2, 2014).
[33] FM Global Letter, at 5.
[34] Id. (emphasis added).
[35] These estimates were based on inspections performed by FM Global and Metro.
[36] EMMIE Subgrant Application Workflow History, Reviewer Comment No. 4 (Feb. 18, 2011).
[37] Flood Insurance Rate Map Panel No. 47037C0211F (Apr. 20, 2001).
[38] FEMA Form 90-120 for PW 5573 was uploaded in EMMIE on February 18, 2011.
[39] See Flood Policy Declarations, The Hartford Standard Flood Insurance Policy No. 87043381132009 (displaying a receipt stamp confirming FEMA received it on Jun 3, 2010).
[40] Each of these sources identify the Facility as a location in Flood Zone AE, which constitutes Flood Zone A location under the FM Global policy because it is subject to a 100 year flood frequency. See FM Global Policy (defining Flood Zone A as any location “designated by [FEMA] as subject to a flood frequency up to and including the 100 year frequency,” or any of the nine locations named in Appendix C); see also FM Global Letter at 2.
[41] FM Global Letter, at Attachment.
[42] EMMIE Subgrant Application Workflow History, Reviewer Comment No. 20 (May 2, 2014).
[43] FM Global Policy, at 3–4, 5; FM Global Letter, at 2, 5.
[44] FM Global Letter, at Attachment.
[45] Id. and 3.
[46] The insurance reviews for the following PWs under FEMA-1909-DR-TN all confirm the coverage limit for locations in Appendix C/Flood Zone A was exhausted: 1908, 2531, 2592, 4721, 4886, 4953, 5170, 5171, 5172, 5181, 5199, 5323, 5324, 5325, 5353, 5363, 5370, 5386, 5405, 5440, 5477, 5482, 5483, 5487, 5488, 5489, 5490, 5495, 5496, 5497, 5501, 5502, 5505, 5506, 5510, 5518, 5522, 5523, 5524, 5531, 5533, 5534, 5543, 5548, 5549, 5550, 5567, 5569, 5570, 5571, 5574, 5575, 5579, 5580, 5585, 5586, 5590, 5591, 5593, 5596, and 5597.
[47] Email from Fin. Manager, Metro. Gov’t of Nashville & Davidson Cty. Office of Mgmt. and Budget, to Controls & Compliance Manager, Nashville Elec. Serv. (Apr. 1, 2015, 10:30 AM); Email from Metro. Gov’t of Nashville & Davidson Cty. Office of Mgmt. and Budget, to Controls & Compliance Manager, Nashville Elec. Serv. (Oct. 5, 2011, 9:26 AM).
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