When snow assistance is authorized, PA funding for snow related activities is limited to a continuous 48-hour period. The Applicant’s existing contracts spanned the 2016-2018 snow seasons. PA funding is limited to costs incurred during the designated 48-hour period of March 14-15, 2017. Costs must be adequately documented to be allowable under federal awards. The Applicant’s documentation fails to specify incurred contract expenses tied directly to plowing its roads during the designated 48-hour period. Section 705(c) of the Stafford Act bars FEMA from recovering obligated funds to a state or local government if: (1) the payment was authorized by an approved agreement specifying the costs; (2) the costs were reasonable; and (3) the purpose of the grant was accomplished. As all three conditions are met, FEMA may not recoup the previously awarded funds.

The Applicant has not demonstrated that its contract costs are directly tied to snow removal on county roads during the designated 48-hour period. However, Section 705(c) of the Stafford Act prohibits FEMA from recouping the $45,798.23 in contract costs already obligated under PW 715.

Stafford Act § 705(c). 44 C.F.R. § 206.227. 2 C.F.R. § 200.403(g). PAPPG, at 22, 81-82, 140, 144-145. FP 205-081-2, at 4-7.