Stafford Act § 403, as implemented by 44 C.F.R. § 206.223(a)(3), requires work to be the legal responsibility of the Applicant. The lease and proposal acceptance do not establish legal responsibility nor do they correspond to how service labor work was billed. 44 C.F.R. § 206.225(a) authorizes emergency protective measures necessary to eliminate or lessen immediate threats to life, public health, and safety, as well as threats of significant additional damage to improved property. 44 C.F.R. § 206.202(d)(i) provides that the PW identifies the eligible SOW. Generally, costs that can be tied to the performance of eligible work are eligible. Costs must also be found reasonable per OMB cost principles. The approved SOW encompasses equipment rentals and security costs. 44 C.F.R. § 206.203(c)(1), large project funding shall equal the Federal share of the actual eligible costs documented by the grantee. 44 C.F.R. § 206.205(b) explains the project closeout process for grant applicants to reconcile the difference between a project’s estimated and actual costs. FEMA is not permitted to award funding for large projects based on estimates. As such, final funding will be determined by actual costs incurred for eligible work and reconciled at closeout.

Stafford Act § 403. 44 C.F.R. §§ 206.202(d)(1)(i), 206.203(c)(1), 206.205(b), 206.223(a)(3), 206.225. OMB Circular A-87, att. (C)(1)(a) and (j). Public Assistance Guide, at 40, 109.