FEMA policy states that FEMA cannot provide PA funding for revenue lost as a result of the disaster, such as when states open a toll road and do not charge a toll, or when states waive the normal fee for ferry service to encourage alternate transportation after an incident. Here, the Applicant waived the tipping fees as a result of the disaster and now requests reimbursement from FEMA to recoup those lost costs. As the tipping fees represent revenue lost as a result of the disaster, they are ineligible for funding. 2 C.F.R. § 200.403(a) provides that in order to be allowable, costs must be necessary and reasonable for the performance of the federal award. Here, the Applicant already completed the substantive work by the time FEMA prepared the draft PW, prior to the Applicant’s hiring of Metric. In addition, the obligated PW (approved after Metric’s work) contained the same SOW and project costs as those included in the earlier draft PW. Therefore, the Applicant has not demonstrated the claimed DAC is associated with work that was either necessary or reasonable for the performance of PW 334.
The tipping fees represent loss of revenue, and are consequently ineligible for funding. In addition, because the Applicant has not demonstrated the claimed DAC pertains to work that was either necessary or reasonable for the performance of the federal award, those costs are also ineligible. Therefore, FEMA denies the request to adjust the approved funding of this small project.
2 C.F.R. §§ 200.403(a), 200.404(a). 44 C.F.R. § 206.224(a)(1). PAPPG, at 37-38, 41, 55-56, 139, 152. PAAP Pilot Program Guide for Debris Removal (Version 4), at 5. La. State Univ. Health Care Servs. Div., et. al., FEMA-1786-DR-LA, at 6; Chambers Cnty., FEMA-1791-DR-TX, at 7.