The Debris Management Guide requires applicants to monitor debris removal operations to be eligible for Public Assistance funding. The Applicant did not monitor a majority of its debris drop off sites and did not employ qualified monitors at the remaining sites who met the policy requirements for debris monitors. 44 C.F.R. allows FEMA to take discretionary enforcement actions when the applicants materially fail to comply with terms of an award. The Applicant failed to provide documentation which would allow FEMA to determine whether the costs associated with the debris collection, removal, and monitoring were reasonable. The Applicant failed to properly procure multiple contracts and as such, the RA undertook a discretionary enforcement action and awarded no costs because FEMA could not determine whether the costs claimed were reasonable.

The Applicant did not comply with debris monitoring requirements or submit monitoring documentation which would allow FEMA to determine whether the costs claimed by the Applicant were reasonable. Further, the RA appropriately exercised his discretionary authority in denying all costs as an enforcement remedy for the Applicant’s material noncompliance with procurement requirements. Therefore, the second appeal is denied.

Public Assistance Debris Management Guide, FEMA 325, at 30, 66, 105, 106, 108-10. Public Assistance Debris Monitoring Guide, FEMA 327, at 1, 5, 19-22. Public Assistance Guide, FEMA 322, at 41, 53. Disaster Assistance Policy DAP 9580.203 44 C.F.R. §§ 13.36(f)(4), 13.43(a). OMB CIRCULAR-87, COST PRINCIPLES FOR STATE, LOCAL, AND INDIAN TRIBAL GOVERNMENTS.