When an applicant discovers a significant overrun related to the total final cost for all small projects, it may submit an appeal for additional funding within 60 days following the completion of its last small project. The work completion date is the date the Applicant completes all work associated with the approved scope of work, including meeting all compliance requirements. It does not include grant management activities such as site inspections. FEMA policy is clear that the work completion date does not include grant management activities such as site inspections. Alternatively, neither the Applicant nor the Recipient has demonstrated that the site inspection conducted on December 27, 2023 was either associated with PW 580’s approved SOW to replace the culverts and replace damaged road components or a compliance requirement for the grant. Therefore, the Applicant’s February 2, 2024 NSPO request was submitted more than 60 calendar-days after the work completion date of October 19, 2023.

The Applicant has not demonstrated it submitted its NSPO request within 60 days of work completion on its last small project. Therefore, this appeal is denied.

Stafford Act §§ 406(a)(1)(A), 422. 44 C.F.R. §§ 206.203(c)(2), 206.204(e). PAPPG, at 186, 196, 199.