Summary Paragraph Between May 25, 2008 and August 13, 2008, severe storms and heavy rains caused the Iowa River to overflow and flood The University of Iowa’s (Applicant) campus. These floodwaters inundated the lower levels of the Applicant’s music building and the first floor of its theatre building. FEMA subsequently prepared Project Worksheet (PW) 5246, documenting costs to install and lease 22 modular mobile facilities. In April of 2014, the project went through closeout, at which time FEMA denied $1,008.00 in premium pertaining to a builder’s risk policy, stating premium paid to insure temporary facilities was not eligible for reimbursement. In a June 16, 2014 letter, the Applicant submitted its first appeal and requested the previously denied $1,008.00. On February 18, 2015, the FEMA Region VII Regional Administrator (RA) made a request for additional information. In an undated response the Applicant amended the amount it seeks to $924.00. The Applicant’s first appeal submission attempted to distinguish and clarify the nature of two separate policies—builder’s risk and property. The Applicant argued that the builder’s risk premium is an allowable and allocable expense of preparing the site and installing the temporary facilities. The RA, through a letter dated April 3, 2015, denied the appeal, primarily determining builder’s risk premium was an increased operating expense. In a letter dated June 2, 2015, the Applicant submitted its second appeal, again requesting funding for $924.00 in builder’s risk premium. The Applicant, through its submission, argues it is not seeking funding for premium pertaining to its property policy and points to Part D of the CEF, where contractor’s insurance is included as a project cost. Authorities and Second Appeals Stafford Act § 403(a)(3)(D), 42 U.S.C. § 5170b(a)(3)(D). 44 C.F.R. § 206.223(a)(1), (3). 44 C.F.R. § 13.22. OMB Circular A-21, Attachment A (C)(2)(b) and (C)(4)(a). PA Guide, at 54-55, 73, 105, 123. Headnotes Pursuant to 44 C.F.R. § 206.223(a)(3), an eligible applicant must be legally responsible for the work. The Applicant sufficiently demonstrated that it is legally responsible for installing temporary facilities and obtaining the builder’s risk policy. OMB Circular A-21, Attachment A (C)(2)(b) provides that allowable costs must be allocable to the PA grant. The Applicant provided inadequate documentation to demonstrate that the $924.00 portion of builder’s risk premium is allocable to the project and consequently it is not a direct result of the disaster. The Applicant’s documentation shows the installation project occurred during the 2008-2009 policy term. Premium for this coverage cannot be allocated to payment for the 2009-2010 policy. The Applicant asserts the existence of a payment in arrears arrangement, however the Applicant provided no documentation of such.