FEMA cannot provide assistance for disaster-related losses that would duplicate benefits available to an applicant from another source, including insurance. When two or more entities agree to share risk under a contractual agreement, FEMA defines the agreement as an insurance pool. The policy with FCSRMC is a contractual agreement that indemnifies the Applicant in the event of loss by obligating FCSRMC to provide payment for damages. Consequently, FEMA’s reduction of funding under PW 3663 and PW 5563 was proper, as FCSRMC was responsible for reimbursing the Applicant’s costs to repair disaster-related damages, including the costs on appeal.

The terms of the Applicant’s agreement with FCSRMC demonstrate that it is an insurance pool. Approval of additional PA funding would constitute a duplication of benefits and is prohibited by the Stafford Act. The appeal is denied.

Stafford Act § 312. 44 C.F.R. § 206.250(c). PAPPG, at 40. FP 206-086-1, at 2, 8-9.