Title 44 of the Code of Federal Regulations (44 C.F.R.) Part 13 (2007) established procurement requirements for local governments applicable at the time of the disaster. FEMA applied procurement standards for nonprofit entities found in 2 C.F.R. Part 215, in the first appeal analysis. However, the Applicant failed to comply with similar procurement standards found in 44 C.F.R. § 13.36. Appeals must contain documented justification supporting the applicant’s position. The burden to fully substantiate appeals with documented justification falls exclusively to the applicant. The available documentation related to costs under the BDR contract does not contain detail that would enable FEMA to evaluate its eligibility, and the Applicant did not provide an explanation of the documentation with its appeal letter.

The Applicant failed to comply with procurement standards applicable to local governments. Additionally, the Applicant has not provided information that would enable a reasonable costs determination. Therefore, this appeal is denied.

44 C.F.R. §§ 13.36, 13.43, 206.206(a). PA Guide, at 53, 113. Chambers Cnty., FEMA-1791-DR-TX, at 6-7.