o FEMA's initial review of a HMGP subapplication for the City of St. Robert Community Safe Room found deficiencies of required information basic to determination of eligibility including inconsistencies with target population, travel considerations, site location and project budget considerations. Responses by the subapplicant to FEMA's requests for information did not adequately provide requested information, and FEMA denied the HMGP subapplication. The City appealed the decision, and FEMA denied the appeal.
• Reason for Denial
o FEMA Region VII based the denial of the 1st appeal on the determination that information and documentation required in order to proceed with review of eligibility, including that addressing inconsistencies with target population, travel considerations, site location and project budget considerations, was not provided.
o 44 CFR 206.434 Eligibility; Hazard Mitigation Assistace Unified Guidance (HMA Guidance), Part IX, C.4.1.2 - Population at Risk from Tornadoes, June 1, 2010; 44 CFR 206.440 Appeals
o The applicant filed a second appeal through Region VII, citing difficulties in processing the application due to changing requirements by FEMA concerning calculation of target population and lack of related timely responses by FEMA.
• FEMA Findings
o FEMA HQ denied the 2nd appeal, supporting Region VII’s decision to deny the 1st appeal.
o Rationale: Information and documention provided did not sufficiently address issues specific to: the travel time conideration of up to 1,364 occupants safely reaching the facility within five minutes of receiving a tornado warning and the additional risk to people having to cross a 4-lane highway enroute to the facility; and clear identification of the at-risk population that would utilize the safe room per HMA Guidance.
o Reference(s): 44 CFR 206.434 Eligibility; HMA Guidance, Part IX, C.4.1.2 - Population at Risk from Tornadoes; 44 CFR 206.440 Appeals