For emergency protective measures to be eligible, the applicant is responsible for showing the work is required due to an immediate threat resulting from the declared incident. FEMA may only provide assistance in response to COVID-19 declared events that is provided in accordance with a COVID-19 specific policy. Air disinfection may be eligible in limited circumstances in accordance with FEMA’s Air Disinfection Memo. The Applicant has not demonstrated that the claimed costs for the replacement of the HVAC system are associated with eligible cleaning and disinfection measures outlined under the O&O Policy, the Air Disinfection Memo or any of FEMA’s other COVID-19 policies. Further, the HVAC replacement work goes beyond the emergency protective measures authorized in FEMA’s O&O Policy.

The claimed HVAC replacement costs are not associated with eligible emergency protective measures implemented in response to the COVID-19 pandemic. Therefore, this appeal is denied.

Stafford Act § 403(a)(3). 44 C.F.R. §§ 206.223(a)(1) and 206.225(a). PAPPG, at 19, 57. O&O Policy, at 2, 4-5; Air Disinfection Memo, at 1-2; Work Eligible Policy, at 3; Eligible Emergency Protective Measures, at 1-2. St. Johns Country Day School, FEMA-4486-DR-FL, at 3.