PA Digest, at 48, provides that “[s]pecial services[,] which are not required on every restoration project, include engineering surveys, soil investigations, services of a resident engineer, and feasibility studies. These services must be specifically described and must be shown to be necessary for completing the eligible scope of work.” The Applicant did not provide sufficient documentation to show the services of resident engineers were necessary.

Summary Paragraph Between April 30, 2010 and May 18, 2010, severe rainstorms, tornadoes, and straight-line winds impacted Nashville-Davidson County. The rainstorms caused the Cumberland River to overflow and submerge the hot house building located at the Applicant’s Metropolitan Water Services Biosolids Facility. Floodwaters submerged the building, damaging electrical components found in and near the building. FEMA subsequently prepared Project Worksheet (PW) 5524 documenting necessary repairs to a transformer, an instrument panel, two variable frequency drives, and a second transformer located outside the building. The PW did not document resident engineering costs and partially disallowed Direct Administrative Costs (DAC). On June 3, 2011, the Applicant submitted its first appeal requesting $18,161.18 and arguing FEMA made errors in estimating DAC and resident engineering costs. In a letter dated May 2, 2012, the FEMA Region IV Regional Administrator (RA) denied the appeal, finding that the the work associated with the hot house did not need the services of resident engineers, and the activities claimed as DAC actually involved procurement and payment activities that amounted to project management costs not DAC. On July 24, 2012, the Applicant submitted a second appeal based solely on resident engineering costs. The documentation provided with the Applicant’s second appeal submission was insufficient to show the services of resident engineers were necessary to complete work on the hot house.

Stafford Act § 406 (a)(1)(A), 42 U.S.C. § 5172. PA Digest, at 48. PA Guide, at 57.