o The City of Murphysboro, Illinois applied for HMGP funding for construction of a new driveway to provide workers’ safe access to the local wastewater treatment plant. Severe and recurrent flooding of the current plant access road causes the plant to be in accessible, except by helicopter or boat, resulting in risk to the workers’ safety. The plant however is outside of the SFHA and has no history of flooding. FEMA Region V denied the request for HMGP funding, based on inadequate information in the application specific to actual road damages or damages to the plant, and the benefit cost analysis (BCA). The City appealed that determination. The appeal was supported by the State. Region V denied the appeal.
• Reason for Denial
o The appeal did not include new information on actual road damages or damages to the plant, nor a revised BCA. No loss of function was identified, since access to the plant was not fully prevented by flooding, and loss of function could not be considered in the BCA.
o 44 CFR 206.440 – Appeals; 44 CFR 79, 44 CFR 206.434 – Cost-effectiveness