o Dodge County, Nebraska, submitted an application through Nebraska Emergency Management Agency for HMGP funding of a river bank reconstruction and stabilization project on the west side of the Elkhorn River. The project was not approved, and a 1st level appeal was denied by Region VII.
• Reason for Denial
o Region VII found that the proposed project did not meet the cost-effectiveness requirement of the HMGP.
o 44 CFR 206.434 HMGP Eligibility; 44 CFR 206.440 Appeals
o Dodge County submitted a 2nd appeal to overturn the Region VII 1st appeal denial. The applicant had provided a benefit-cost analysis that did not address essential elements of benefit-cost analysis, such as flooding recurrence probabilities and present value calculations. An upper bound benefit cost analysis was done by FEMA, generating a benefit-cost ratio of 0.57, indicating that the project was not cost effective.
• FEMA Findings
o The 2nd appeal decision upheld the 1st appeal denial.
o The rationale for the 2nd appeal decision was that the grant application did not meet the cost-effectiveness eligibility requirement of the HMGP.
o Reference(s): 44 CFR 206.434 HMGP Eligibility; 44 CFR 206.440 Appeals