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Second Appeal Brief
PA ID# 245-04200-00; Augusta-Richmond County
PW ID# (PW) 299 ; Debris Removal – Vegetative – Support Documentation
Conclusion: Augusta-Richmond County (Applicant) did not provide adequate documentation on first appeal to account for the discrepancies between the debris hauled to and the mulch hauled from the Greenland DMS. Accordingly, the RA appropriately exercised her discretion in finding 78,229 CY of vegetative debris as eligible. However, $12,003.50 in funding that the RA reduced on first appeal to account for partial tailgated trucks will be restored because the reduction is duplicative.
From February 10, 2014 through February 14, 2014, a severe ice storm caused extensive damage to trees throughout Augusta-Richmond County, Georgia. FEMA prepared two Project Worksheets (PW) for debris removal. The Applicant claimed it hauled 499,313.40 cubic yards (CY) of debris to the Fairgrounds debris management site (DMS) and 146,657 CY to the Greenland DMS. Some of the Applicant’s truck load tickets did not reflect the claimed CY capacity. Additionally there was a discrepancy between the volume of debris hauled in and the volume of mulched vegetative debris hauled out of the DMS locations. As a remedy, FEMA applied the United States Army Corps of Engineers (USACE) Hurricane Debris Estimating Model to recalculate the debris volume and disallowed some of the Applicant’s claimed costs. On first appeal, the Applicant challenged the use of the USACE model. The Regional Administrator (RA) allowed all costs for the Fairgrounds DMS, but only a small increase for the Greenland DMS. On second appeal, the Applicant appeals only the costs associated with the Greenland DMS from PW 299. Although it indicated that it used mulch to stabilize both the Fairground DMS and Greenland DMS, the Applicant did not provide any documentation on first appeal supporting its contention regarding the Greenland DMS.
Authorities and Second Appeals
- 44 C.F.R. §§ 13.43; 206.224(a).
- Public Assistance Debris Monitoring Guide, FEMA 327 (Oct. 2010).
- Public Assistance Debris Management Guide, FEMA 325, Appendix B (July 2007).
- According to 44 C.F.R. §13.43(a), FEMA may disallow all or part of the cost of the activity or action not in compliance.
- The Applicant did not submit sufficient documentation on first appeal to adequately account for the discrepancy between the claimed debris hauled to the Greenland DMS and the mulch hauled from the site.