FEMA policy provides that an estimated PM fee is generally limited to 3 percent of construction costs if a contract is used, with an additional PM allowance at 1 percent of construction costs for the design phase. In addition, special services may be required for some projects. These services are estimated separately. The CEF provided by the Grantee correctly estimated additional PM costs, utilizing the general estimated percentages described above. The Applicant has not provided documentation justifying an increase in the capped amount of the improved PM project and has not shown that Resident Project Representative costs constitute “special services” that would be excluded from the estimated PM costs.

Based on the additional soft costs identified in the CEF that FEMA inadvertently omitted from PW 11235, FEMA finds $8,820,189.64 in PM costs are reasonable and will reinstate that funding. The Applicant has not provided documentation supporting its request for an additional $6.7 million in PM funding. Accordingly, the appeal is partially granted.

44 C.F.R. §§ 13.43(a)(2), 206.203(d)(1). PA Guide, at 79, 115, 116 (1999), at 110 (2007). Public Assistance Program and Policy Guide, FP 104-009-2, at 103 (Jan. 2016). RRP 9525.6, Project Supervision & Management Costs of Subgrantees, at 2 (Apr. 22, 2001). CEF for Large Projects Instructional Guide V2.1, at 11-1 (Sept. 2009). Omochumne-Hartnell Water Dist., FEMA-1624-DR-CA, at 6-7.