From May 4 to June 21, 2015, severe storms caused flooding on the Subrecipient’s road network. The Kansas Division of Emergency Management (Recipient) prepared PW 414 to document Category C (roads) work to repair damage at nine sites. Estimated costs totaled $77,156.13. On May 31, 2016, FEMA notified the Subrecipient that the project was ineligible for PA funding, as the available documentation failed to show damage was a direct result of the disaster. The Subrecipient appealed on July 18, 2016. In the Final Request for Information, FEMA requested documentation related to site conditions, and asked for clarification of the damages recorded in the PW. In response, the Subrecipient argued that FEMA’s request for documentation was unrealistic, and the method for recording damage was decided by the project specialist. On April 7, 2017, the FEMA Region VII Regional Administrator (RA) denied the appeal. The RA found the Subrecipient failed to demonstrate damage was the direct result of the disaster. The RA also found costs ineligible due to discrepancies in the damage dimensions recorded in PW 414. On May 26, 2017, the Subrecipient submitted its second appeal for $77,156.13. The Subrecipient argues that FEMA’s documentation requirements are unrealistic, and denies responsibility for any discrepancies in the damage description. Authorities and Second Appeals Stafford Act § 406. 44 C.F.R. §§ 206.223(a)(1), 206.226. Public Assistance Guide, at 33. Vill. of Waterford, FEMA-4020-DR-NY, at 4. Arthur Cty., FEMA-4225-DR-NE, at 3. Headnotes Per 44 C.F.R. § 206.223(a)(1), to be eligible for funding, an item of work must be required as a result of the disaster. The PA Guide states that for facilities such as roadways and culverts, which require routine maintenance to maintain their designed function, it may be possible to review predisaster maintenance or inspection reports to verify the predisaster condition and assess eligible disaster damage. It is the subrecipient’s responsibility to demonstrate that damage is disaster-related. The Subrecipient provided predisaster budgets and material purchase invoices, which document a general program of routine predisaster road maintenance. However, neither the budgets nor the invoices document specific items of maintenance work, which would enable verification of predisaster conditions at the sites on appeal. The Subrecipient did not otherwise document the predisaster condition of its roads.