The project application did not meet FEMA's cost-effectiveness requirement and relocated the function within the floodplain. The overall project benefit-cost ratio (BCR) was calculated from the two BCA module runs as before mitigation damages minus after mitigation damages which equals $4,347,316. Total benefits divided by total project cost of$26,000,000 results in a benefit cost ratio of 0.16. The determination was that the proposed project is not cost effective. In addition, the letter states that under HMGP, a relocation project is considered an acquisition of the structure and underlying real property for the purpose of creating open space, relocation of the structure and conversion of the property to deed restricted open space uses in perpetuity. The relocation of existing structures must be to areas outside of the SFHA or local regulatory floodplain, outside of any regulatory erosion zones and in conformance with any other applicable State or local land-use regulations.The second level appeal does not contain new or substantive information that would provide grounds for overturning the decision made at the Region.