44 C.F.R. § 206.223(a)(1) requires an item of work be required as the result of the emergency or major disaster event. The Applicant has demonstrated that trimming was necessary to clear vegetation for equipment access and crew safety to complete the eligible conductor replacement scope of work. 2 C.F.R. §§ 215.44(b)-(c), 215.45, 215.48 establish procurement and contract requirements such as socioeconomic contracting goals, documentation requirements, and contract provisions. FEMA’s PA Guide places limitations on the use of time and materials contracts and requires a “not to exceed” provision. The Applicant used a time and materials contract without the required contract provisions.The Applicant also failed to provide documentation to show compliance with procurement regulations.

: The Applicant did not follow Federal procurement standards prescribed in 2 C.F.R. Part 215. Specifically, the Applicant did not use a suitable contract type with required contract provisions, provide procurement documentation, perform a cost or price analysis, and demonstrate positive efforts were made to utilize small businesses, minority-owned firms, and women’s business enterprises.

44 C.F.R. § 206.223(a)(1). 2 C.F.R. §§ 215.44(b)-(c), 215.45, 215.48, 215.62. OMB Circular A-122. PA Guide, at 53. PA Debris Management Guide, at 99 -100. Clarke Electric Cooperative, FEMA-1737-DR-IA, at 1.