Appeal Brief | Appeal Letter | Appeal Analysis | Back
Second Appeal Brief
PA ID# 059-22A8A-00; South Coast Water District
PW ID# 865; Water Pipeline Break
Citation: FEMA-1585-DR-CA; South Coast Water District (Applicant)
Reference: Hazard mitigation; Permanent relocation; Improved Project
Summary: Heavy rainfall during the February 2005 winter storms triggered a landslide that damaged a section of the Joint Transmission Main (JTM) buried within an easement located at the bottom of the slide. The Applicant engaged the services of engineering consultants to assess the slope and provide recommendations for repair of the water main. The Applicant’s consultants identified several alternatives to repair the water main, including restoration of the landslide and reconstruction of the water main within the easement. Project Worksheet (PW) 865-2 was prepared in March 2008, at an estimated cost of $1,738,800 for work to stabilize the landslide and reconstruct the water main within the Applicant’s easement. The Applicant contends that this alternative, as well as two others proposed by its consultants, are technically infeasible as they do not remove the water main from the threat of damage by future landslides. Rather than stabilize the landslide and repair the water main along its current alignment, the Applicant’s plan is to relocate the water main along a different alignment, within the right-of-way of two city streets, which the Applicant contends is an appropriate and cost effective hazard mitigation project that removes the facility from the threat of future landslides. The Applicant states that the JTM is a main water supply for the City of San Clemente, South Coast Water District, state parks, Camp Pendleton Marine Corps Base, and the San Onofre Nuclear Generating Station.
Issue: Should FEMA grant the Applicant’s request to relocate the water main along an alignment within the right-of-way of city streets and fund the project at an estimated total cost of $3,530,000?
Finding: No. The cost effectiveness of the Applicant’s proposal relies on the assumption that the San Onofre Nuclear Generating Station will be shut down by a failure of the JTM. However, the Applicant did not provide any documentation from Southern California Edison to confirm that the power station had shut down when the JTM failed as a result of the declared event, or would in a future event.
Rationale: 44 CFR 206.226(e); 44 CFR 206.226(g); RR Policy 9526.1; RP9580.102; 44 CFR §206.203(d)(1)