This is in response to a January 24, 2018 letter from your office, transmitting the referenced second appeal on behalf of the Applicant. The Applicant is appealing FEMA’s denial of $29,779,340.58, including a change to the scope of its improved project, an increase in estimated costs, Direct Administrative Costs (DAC) above those previously awarded, $1,000,000.00 in insurance proceeds for Law and Ordinance, which it argues should have been allocated to a different PW, and $299,732.61 asserted to be a mathematical error in implementing the first appeal determination in Version 3 of PW 1980. As explained in the enclosed analysis, I have determined that the Applicant failed to seek funding for additional work in a timely manner, and failed to justify its request for adjustments to the cost estimate. Regarding DAC, the RA took appropriate action in awarding costs capped at $155 per hour, as a remedy for the Applicant’s noncompliance with procurement regulations. It was also proper, in accordance with federal regulation, not to award travel costs or costs incurred during a period when no contract was in place. Additionally, the $1,000,000.00 in insurance proceeds for Law and Ordinance were appropriately applied to PW 1980. However, there was an inadvertent mistake in implementing the RA’s first appeal decision, and the insurance proceeds allocated in Version 3 of PW 1980 was greater than the RA determined in the first appeal. Accordingly, I am partially granting this second appeal so the total insurance proceeds can be corrected. Please inform the Applicant of my decision. This determination is the final decision on this matter pursuant to 44 C.F.R. § 206.206, Appeals.