For the distribution of food to be considered an eligible emergency protective measure under the COVID-19 emergency, the applicant is responsible for demonstrating that the work and costs were incurred to respond to an immediate threat as a result of COVID-19 emergency. The Applicant has not demonstrated that the costs for the supplies for its food service are eligible emergency protective measures in response to COVID-19. Increased costs of operating a facility or providing a service are generally not eligible, even when directly related to the incident. The Applicant incurred additional costs to provide a meal to a child, or to make a meal available, which is an increased operating cost, not eligible for PA.

The Applicant has no demonstrated that the the cost incurred was an eligible emergency protective measure in response to COVID-19 emergency. The Applicant additional costs to provide a meal to a child, or to make a meal available, is an increased operating cost, not eligible for PA, even when directly related to the incident. Therefore, this appeal is denied.

Stafford Act § 403(a)(3). 44 C.F.R. § 206.223(a)(1), 206.225(a)(3)(i). PAPPG, at 19, 63. Fact Sheet, Coronavirus (COVID-19) Pandemic: Eligible Emergency Protective Measures, at 1. Coronavirus (COVID-19) Pandemic: Purchase and Distribution of Food Eligible for Public Assistance, at 3.