FEMA may provide PA funding for eligible work, but the costs must be necessary and reasonable to accomplish the work. The Applicant’s costs were reasonable and necessary, given the number of potential disaster survivors it may have had to shelter based on forecasts, the lack of available alternatives, and the need for enough rooms to be available at all times to ensure survivors who arrived unexpectedly and without notice could be sheltered.

FEMA finds that the Applicant established that its procurement of NCS was reasonable to address the needs of the incident, and that costs for those rooms were necessary and reasonable. The appeal is granted.

Stafford Act § 403(a). 44 C.F.R. § 206.225(a)(1). 2 C.F.R. §§ 200.403, 200.404. PAPPG, at 65. FEMA Policy 104-009-18, Version 2, at 1-4.