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Venice, Florida - Hurricane Information Center Construction in the Venice Public Library

Appeal Brief Appeal Letter Appeal Analysis

Appeal Brief

ApplicantFlorida Division of Emergency Management
Appeal Type2nd
Date Signed1997-05-12T00:00:00
1st Appeal
• Issue
o The City of Venice applied under disaster declaration DR-982-FL for a grant under HMGP for the purpose of defraying the construction cost of a Hurricane Information Center (HIC). FEMA Region IV denied approval, and the City of Venice appealed. Region IV denied the appeal.
• Reason for Denial
o The proposed HIC construction did not meet the minimum eligibility requirements of the HMGP provided in 44 CFR 206.434, requiring that a project solve a problem independently or constitute a functional portion of a solution, and substantially reduce the risk of future damages.
• Reference(s)
o 44 CFR 206.434 Eligibility;   44 CFR 206.440 Appeals
2nd Appeal
• Issue
o The subapplicant submitted the 2nd appeal based on the argument that the HIC construction was eligible for funding under HMGP.
• FEMA Findings
o The 2nd appeal decision was to uphold the 1st appeal.
o The rationale for the decision was that the project failed to meet the critical eligibility requirements of the HMGP, because the HIC did not solve a problem independently and substantially reduce the risk of future damages. However, FEMA HQ referred the Applicant to Florida’s 5% Initiative funding under the HMGP as a potential option for funding.
o Reference(s):  44 CFR 206.434 Eligibility;   44 CFR 206.440 Appeals

Appeal Letter

Federal Emergency Management Agency
Washington, D.C. 20472
MAY 12 1997
 
Mr. Joseph F. Myers
Director, Division ofEmergency Management
Department of Community Affairs
2470 Centerview Drive
Tallahassee, Florida 32399
 
Attention: Charles Speights, Florida State Hazard Mitigation Officer
 
Dear Mr. Myers:
 
This letter responds to a second appeal filed on behalf of the City of Venice, Florida for a grant under the Hazard Mitigation Grant Program (HMGP). The grant was requested to defray the cost of constructing a Hurricane Information Center (HIC) in the Venice Public Library. The State of Florida's project number is 982.0012. The grant application was submitted after disaster declaration
FEMA-982-DR-FL.

Unfortunately, I must deny the grant because the proposed project does not meet the critical eligibility requirements of the HMGP. To be eligible for a grant under the HMGP, the HIC must solve a problem independently, and substantially reduce the risk of future damages. Projects that merely identify or analyze hazards or problems are not eligible.
 
Funding under HMGP remains available. You have the option of proceeding with the project using Florida's five percent initiative funding. FEMA Region IV staff are available to assist you and the City of Venice in identifying suitable alternative risk reduction measures for the Venice community. If you have any questions, please contact Bob Shea, Director of the Program Implementation Division at (202) 646-3619. We look forward to working with you on this matter.
 
Sincerely,
 
Richard W. Krimm
Executive Associate Director
Mitigation Directorate
 
Enclosure

 

Appeal Analysis

Issue 1: The project does not meet the eligibility requirements as stated in 44 CFR 206.434 (b)(4) and (b)(5) (I-V). The HIC does not solve a problem independently, or substantially reduce the risk of future damages. Projects that merely identify or analyze hazards or problems are not eligible.

The HIC does not solve a problem independently as defined in 44 CFR 206.434 (b)(4). The HIC is primarily geared towards public awareness, identifying potential hazards and informing residents on methods of risk reduction. It does not directly implement the mitigation measures it advocates. As with all public awareness campaigns, the HIC relies on the inconstant participation of the general public to implement recommended mitigation measures. In addition, the Hurricane Information Center will contribute to the dissemination of information to the public about methods of preparing for emergencies in the City ofVenice, however, it would not prevent or reduce recurring damages as defined under HMGP 44 CFR 206.434 (b) (5) (I-V).

Issue 2: Although the proposed project is in conformance with the 409 State Hazard Mitigation Plan, it must still meet other eligibility requirements under 44 CFR 206.434 (b)(l).

A State may include educational programs or materials in their State Hazard Mitigation Plan that may have benefits that are not easily quantified or which fall outside the eligibility guidelines for projects funded through the HMGP. These projects may be funded through other sources, including the HMGP 5% initiative. Projects that are considered for HMGP funding must contribute to the development of a long-term comprehensive mitigation program corresponding with the State Hazard Mitigation Plan and meet the eligibility requirements of the HMGP.

Issue 3: The Venice Integrated Neighborhood Emergency System (VINES) component of the proposal is geared towards emergency response, not mitigation.

The HIC would also house an early warning system, VINES, which is geared towards emergency response, not mitigation. It is unclear where the funds to house VINES are being derived from. Within the context of HMGP, mitigation measures are those projects that, over the long term, reduce the risk of repetitive loss and hardship so that the cost of response and recovery will be less in the future. Warning systems are not long-term solutions to the problem of hurricane damage. Projects such as this are more appropriately funded under the 5% initiative of the HMGP.

 

Last updated August 19, 2014