Repair vs Replacement

Repair vs Replacement

HEADNOTES

The comparison of repair costs with replacement costs results in a fraction that expresses repair as a percentage of replacement. The numerator of the fraction is the cost of repairing disaster-related damage only and includes costs associated with codes or standards upgrades that apply to the repair of the damaged elements only. For the Dock, the replacement of all 66 tie rods, wales and pile guides are not eligible for inclusion in the repair estimate because the report does not contain any information to indicate the damage was the result of the disaster. For the Boardwalk, the repair estimate improperly includes the cost for the replacement of 60 percent of the stringers, 100 percent of the decking and 50 percent of the handrails, which the report does not demonstrate were damaged as a result of the disaster.

CONCLUSION

The Applicant has not demonstrated the replacement of the Dock and Boardwalk is eligible under FEMA’s 50 percent rule. Therefore, the appeal is denied.

AUTHORITIES

Stafford Act § 406(a). 44 C.F.R. § 206.226(f). PAPPG, at 37-38, 96-97, 127, 129, 152.

44 C.F.R. § 206.226(f)
Repair vs Replacement