Pursuant to 44 C.F.R. § 206.204(e) and the PA Guide, if a cost overrun occurs during the execution of approved work, an applicant must submit a request for additional funding through the grantee as soon as the need for additional funding is discovered The Applicant immediately notified the Grantee of an overrun each time the Applicant’s contractor informed it that more debris was being removed than originally estimated. As such, the Applicant complied with federal regulation and policy by timely notifying the Grantee of the additional volume of debris removed resulting in a cost overrun. Pursuant to 2 C.F.R. § 225 Appendix A (C)(1), costs must be reasonable and necessary in order to be allowable. The Applicant demonstrated the use of pickups is reasonable and necessary for monitoring debris removal from ditches. However, the overtime FAL and the use of dozers and loaders, were not reasonable and necessary for simply monitoring debris removal.

Stafford Act §§ 403(a)(3)(A), 423. 2 C.F.R. § 225 Appendix A (C)(1)-(2). 44 C.F.R. §§ 206.204(e), 206.223(a)(1), 206.228(a). PA Program Appeal Procedures, at 13-14, 18. PA Debris Monitoring Guide, at 13. PA Guide, at 37, 42, 110, 140. DAP9580.203, Disaster Assistance Directorate Fact Sheet Debris Monitoring, at 1. RP 9525.7, Labor Costs – Emergency Work, at 1.