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Roof Replacement

Appeal Brief Appeal Letter Appeal Analysis

Appeal Brief

DisasterFEMA-1046-DR
ApplicantCity of Santa Barbara
Appeal TypeSecond
PA ID#083-69070
PW ID#12255
Date Signed1997-10-14T04:00:00
Citation: FEMA-1046-DR-CA; City of Santa Barbara; DSR 12255

Cross-Reference: Eligible repair, Total replacement

Summary: As a result of a March 10, 1995, storm, the roof on the Santa Barbara Airport hanger building 309 was damaged by high winds. Sections of the rolled composition roof were torn from the building and strewn about the surrounding area damaging adjacent windows. Damage survey report (DSR) 12255 was prepared for $16,942 to fund the replacement of the entire roof, the completed repairs, and replacement of 12 window panes. The Federal Emergency Management Agency (FEMA) concluded that damage to the roof consisted of the loss of roof composition sheets on approximately a 500 square-foot area. Because the roof damage was limited to a small portion of the total roof area, the completed repairs were considered permanent. FEMA approved funding for the completed repairs and replacing the 12 windowpanes. The subgrantee believed that the replacement of the entire roof should be eligible for funding because the repairs were made only to safeguard the building and its contents from greater losses and not to restore the building to pre-disaster function. The Regional Director denied the subgrantee's first appeal, stating that there was no justification for replacement of the entire roof. With a second appeal, the State requested that a Category B DSR should be prepared for the temporary patching, which it considers "emergency work," and maintains that there is no way to repair the roof without replacing the entire existing roof.

Issues: Should FEMA fund the replacement of the entire roof?

Findings: No. Damage to the roof is limited to approximately five percent of the total roof area. There is no justification to support the replacement of the entire roof.

Rationale: Only work to restore eligible facilities on the basis of the design of such facilities as they existed immediately prior to the disaster is eligible. (44 CFR 206.226)

Appeal Letter

October 14, 1997

Mr. Gilbert Najera
Governor's Authorized Representative
Governor's Office of Emergency Services
74 North Pasadena Avenue, West Annex, 3rd Floor
Pasadena, California 91103

Dear Mr. Najera:

This letter is in response to your February 10, 1997, submittal of the City of Santa Barbara's second appeal of damage survey report (DSR) 12255 under FEMA-1046-DR-CA. The DSR was prepared to cover the expenses involved with repairing the roof of hanger building 309 and replacing 12 window panes that were damaged as a result of flying debris. The subgrantee is requesting additional funding to replace the entire roof.

As explained in the enclosed analysis, I have determined that the approved scope of work was adequate to restore the pre-disaster condition and function of the roof. The subgrantee has not established that the replacement of the entire roof is warranted. Therefore, I am denying this appeal.

Please inform the applicant of my determination. The applicant may submit a third appeal to the Director of FEMA. The appeal must be submitted through your office and the Regional Director within 60 days of receipt of this determination.

Sincerely,
/S/
Lacy E. Suiter
Executive Associate Director
Response and Recovery Directorate

Enclosure

Appeal Analysis

BACKGROUND
As a result of a March 10, 1995, storm, the roof on the Santa Barbara Airport hanger building 309 was damaged by high winds. The hanger is a wood frame building with wood siding and a composition roof over wooden arch trusses. Sections of the rolled composition roof were torn from the building and strewn about the surrounding area damaging adjacent windows. Immediately after the storm, a contractor was brought in to patch the roof at a cost of $3,032. The work, identified as temporary by the subgrantee, consisted of applying new composition roofing over the damaged areas. The Federal Emergency Management Agency (FEMA) prepared damage survey report (DSR) 12255 (Category E) for $16,942 to fund the replacement of the entire composition roof, the completed temporary repairs to several damaged roof sections and replacement of 12 window panes.

The FEMA reviewer concluded that the only damage to the roof consisted of the loss of roof composition sheets on approximately a 500 square-foot (SF) roof area. The FEMA reviewer found no justification to provide funding for a complete replacement roof. The completed repairs of the roof, replacing 500 SF of composition sheeting, was considered to be a permanent repair and sufficient to restore the roof to pre-disaster condition. Additionally, the reviewer determined that an additional $504 was eligible for replacement of 12 window panes. On that basis, the funding for a complete replacement roof was denied. The DSR was approved for $3,536.

First Appeal
With a March 25, 1996, letter, the State transmitted the subgrantee's January 10, 1996, letter, appealing the denial of work items from DSR 12255. The subgrantee believed that the replacement of the entire roof should be eligible for funding on the basis that the completed repairs were temporary and were only intended to safeguard the building and its contents from greater losses and were not intended to restore the roof to pre-disaster condition. The State considered the temporary repairs as "emergency work" and recommended that a Category B DSR should be prepared for the completed repairs. The Regional Director denied the subgrantee's first appeal stating that there was no justification for replacement of the entire roof.

Second Appeal
With a February 10, 1997, letter, the State transmitted the subgrantee's November 13, 1996, second appeal of DSR 12255. The subgrantee noted that the damage to the roof was more extensive than originally documented in the DSR and described in the City's first appeal. The subgrantee stated that most of the roofing material was torn from the building in huge sections. Therefore, the State requested that a Category B DSR be prepared to address the emergency repair costs and additional funding to permanently restore the entire roof. The only additional information provided by the State was a copy of the bid proposal for $40,970 that was submitted for replacing the entire roof. The subgrantee proceeded with replacing the entire roof.

DISCUSSION
The primary issue of this appeal is the extent of repairs needed to restore the roof to pre-disaster condition. The damage description written in the DSR indicates that the damages to the roof are limited to several composition sheets only. Specifically, both FEMA and OES inspectors described the damages to the roof as "several sheets of roofing on the south side of the arch." In addition, sketches included with the DSR show roofing blown off in only one specific location.

The subgrantee maintained that there would have been no way to properly seal the roof had the old roof sections that remained, many of them partially torn from the building, been kept in place. The subgrantee also noted that the damage to the roof was more extensive than originally documented in the DSR and that most of the roofing material was torn from the building in huge sections. However, there is no documentation in the DSR indicating that the damages are that extensive. The subgrantee has not provided any additional evidence indicating that any other section of the roof was damaged or needed replacement. Therefore, the approved scope of work is the only required repair to the roof to restore it to its pre-disaster condition. FEMA's determination to approve the roof repairs rather than to fund the replacement of the roof was appropriate.

CONCLUSION
Based on a review of the provided information, the appeal is denied. There is no indication that the completed temporary repairs would not adequately restore the pre-disaster condition and function of the roof.
Last updated February 4, 2020