Debris Removal – Mud, Silt, and Sediment – Contract Procurement – Reasonable Cost

Debris

HEADNOTES

Per 44 C.F.R. § 13.36(b)-(i), applicants seeking reimbursement under the Public Assistance Program must comply with Federal procurement requirements. Applicant did not comply with Federal procurement requirements with regard to contracting debris monitoring services. According to the PA Guide, at 41, FEMA may determine a cost to be reasonable based on: historic documentation for similar work, average costs for similar work in the area, published unit costs from national cost estimating databases, and FEMA cost codes. Applicant conceded the Regional Administrator was correct to calculate reasonable cost by assessing costs incurred for eight similarly situated parishes.

CONCLUSION

: The Applicant’s claim, that its project management consultant’s work included debris-related, non-monitoring services that went above and beyond those of “debris monitors” is unsubstantiated by the administrative record. The work at issue was debris monitoring. The Regional Administrator erred in the calculation of reimbursable hours for debris monitoring.

AUTHORITIES

and Second Appeals

Debris Removal – Mud, Silt, and Sediment – Contract Procurement – Reasonable Cost