This is in response to a letter from your office dated November 5, 2018, which transmitted the referenced second appeal on behalf of Franklin County (Applicant). The Applicant is appealing the Department of Homeland Security’s Federal Emergency Management Agency’s (FEMA) denial of $174,102.64 in costs pertaining to the repair, removal, and replacement of several culverts. As explained in the enclosed analysis, I have determined that the work is ineligible for funding. The Applicant has not provided documentation to demonstrate that the claimed damages were the direct result of the disaster. Accordingly, I am denying this appeal. 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.