Under 44 C.F.R. § 13.30(d)(1), applicants or grantees must obtain prior approval from FEMA to revise a project’s SOW. The Applicant did not submit a request to FEMA change the SOW before performing the work. The PA Guide at 111 requires an Applicant to obtain prior approval for an improved project. The Applicant did not submit a request for an improved project before performing the work.

The Applicant changed the SOW by failing to return the culverts to the predisaster condition and did not receive prior approval from FEMA for that change, nor submit a request for an improved project before the work was

Stafford Act § 406. 44 C.F.R. §§ 13.30, 13.43, 206.203, 206.206, PA Guide, at 29, 33, 79, 110, 111, 127, 128, 140. Mo. Dep’t of Natural Res., FEMA-4012-DR-MO, at 4-5. Vill. of Waterford, FEMA-4020-DR-NY, at 3. Plymouth Twp., FEMA-4030-Dr-PA, at 6-7. Clean Water Act §§ 1251-1387.