This is in response to a letter from your office dated July 20, 2018, which transmitted the referenced second appeal on behalf of the City of Norman (Subrecipient). The Subrecipient is appealing the Department of Homeland Security’s Federal Emergency Management Agency’s denial of $2,600,000.00 in costs pertaining to proposed upgrades due to codes and standards. As explained in the enclosed analysis, I have determined that the Subrecipient accepted 406 mitigation for permanent work, did not complete work within the regulatory six month timeframe for emergency work, and did not request a time extension; therefore, FEMA was correct in designating the PWs as Category C, Permanent Work for Roads and Bridges. Additionally, the Subrecipient has not demonstrated that its codes and standards apply to all similar facilities within its jurisdiction; therefore, they are not eligible upgrades. Accordingly, I am denying this appeal. Please inform the Subrecipient of my decision. This determination is the final decision on this matter pursuant to 44 C.F.R. § 206.206, Appeals.