FEMA may provide Public Assistance (PA) funding to an eligible PNP that provides noncritical but essential services only if it has applied for a disaster loan from the SBA. When the PNP cannot accept the terms of the loan, and the SBA therefore denies the loan, such as where the PNP does not meet a collateral requirement, PA funding is limited to the costs that would not have otherwise been covered by the loan. The Applicant could not offer collateral for the SBA loan; therefore, its PA funding is limited to the costs the loan would not have covered.

There are no costs the SBA loan would not have been able to cover because the loan would have met the Applicant’s PA funding needs. As such, the Applicant’s appeal is denied.

Stafford Act § 406, 42 U.S.C. § 5172. 13 C.F.R. § 123.202, 44 C.F.R § 206.226(c)(2). PAPPG, at 46, 57-58.