Stafford Act § 312(a) prohibits applicants from receiving duplicate funding Site 3 was not covered in another PW, so there was no duplication of benefits. The PA Guide at 29-31 requires eligible work to be the direct result of a disaster, within the disaster area, and the applicant’s legal responsibility. Calling road repairs “excessive” was vague, these repairs could be funded if eligible. The PA Guide at 40 states costs are reasonable they would be incurred by a prudent person under the circumstances. The first appeal decision was unclear as to which costs were unreasonable and why. Under 44 C.F.R. § 206.223(a)(1), an item of work must be the direct result of a disaster to be eligible. The first appeal decision relied on pictures to verify disaster-related damage but did not seek other types of documentation. The Public Assistance Program Appeal Procedures at 14-15 requires the final RFI to explain the reason for a potential denial and request documents to support the appeal. The RFI did not explain what costs were unreasonable and why, and did not request information to support reasonableness. The RFI did not explain that the record lacked non-photographic documentation of disaster-related damage or request such documentation.

Stafford Act §§ 312(a), 406(e). 2 C.F.R. § 200.404. 44 C.F.R. § 206.223(a). PA Guide, at 29-31, 33, 40-41, 106, 140. Public Assistance Program Appeal Procedures, at 8, 13-15. Delaware Cty., FEMA-1930-DR-IA, at 6; Collier Cty., FEMA-1609-DR-FL, at 3; Tn. of Sandwich, FEMA-4097/4110-DR-MA, at 5; Ks. Republic Cty. Highway Dep’t, FEMA-4230-DR-KS, at 4.