For the distribution of food to be considered an eligible emergency protective measure under the COVID-19 emergency, the applicant is responsible for demonstrating that the work and costs were incurred to respond to an immediate threat as a result of the COVID-19 emergency. The Applicant has not demonstrated that the costs for the freezer rentals for its food distribution service are eligible emergency protective measures in response to COVID-19.

The Applicant has not demonstrated that it performed eligible emergency protective measures in response to the COVID-19 emergency. Therefore, this appeal is denied.

Stafford Act § 403(a). 44 C.F.R. §§ 206.223(a)(1), 206.225(a)(3)(i). PAPPG, at 19, 57, 63. FP 104-010-03, at 3 (Food Policy).