From May 4 through June 21, 2015, Spring Township (Applicant), located in Butler County, Kansas, experienced severe storms, flooding, straight-line winds, and tornadoes. Many of the Applicant’s gravel roads sustained damage as a result of the storms and flooding. The damages include scouring, loss of aggregate and ditches filled with debris. FEMA wrote Project Worksheet (PW) 123 in December 2015, to document damages to fifteen road sites. The PW’s SOW authorized the replacement of gravel to a depth between one and a half inches and two and a half inches. FEMA estimated the project would cost $102,005.75. However, prior to obligation, FEMA reviewed the project and determined it was ineligible because the Applicant failed to provide documentation to demonstrate the roads were properly maintained and the damages were the direct result of the disaster. The Applicant appealed, arguing it provided documentation that demonstrated the roads were maintained prior to the disaster and that the damages were a result of the disaster. The Applicant supplemented its appeal with an additional letter where it claimed it should be reimbursed $201,159.58 in actual costs, plus an additional $2,458.57 in direct administrative costs (DAC) for a total of $202,473.28. The Applicant also explained that it worked with the Recipient’s project specialist and re-wrote the entire PW. In doing so, the Applicant and Recipient changed the Damage Description and Dimensions and SOW fields of PW 123. The Applicant and Recipient changed the depth of gravel from one-half inch to an additional two to five inches and added two culverts. The Recipient supported the appeal, noting that almost all the same roads identified in FEMA’s original PW were also damaged in a 2013 disaster and were repaired shortly before the 2015 disaster. The administrative record contains no request for, nor approval of, a change in the SOW for PW 123. The Regional Administrator (RA) partially granted the appeal, finding the Applicant demonstrated adequate maintenance of the roads, and the damage to them was the result of the disaster. The RA also approved $2,383.13 in DAC. However, the RA determined the additional gravel and the inclusion of two additional culverts in the rewritten PW were not eligible for Public Assistance funds. The Applicant submitted a second appeal, seeking $94,389.17 for the placement of additional gravel and the repair of two additional culverts, as listed in the rewritten PW. The Applicant asserts it reported all of its damages to FEMA and provided all the requested documentation. The Applicant states the additional gravel and repairs of two culverts may have been omissions from the original PW, but they were not additional damages. Authorities and Second Appeals 44 C.F.R. §§ 13.30(d)(l), 206.202(d)(1)(ii). PA Guide, at 96, 139, 140. Nobles Cooperative Electric, FEMA-4112-DR-MN, at 2-3. Roseau Cty. Hwy. Dept., FEMA-1288-DR-MN, at 7. Headnotes 44 C.F.R. § 13.30(d)(l) requires applicants to obtain FEMA’s prior approval whenever a revision of the scope or objective of the project is anticipated. The Applicant has not demonstrated where it requested and received FEMA’s approval for a change in the original SOW for PW 123. 44 C.F.R. § 206.202(d)(1)(ii) requires applicants to identify and to report damage to FEMA within 60 days of its first substantive meeting with FEMA. The Applicant has not demonstrated it identified the need for additional gravel or repair of damaged culverts within 60 days of the kick-off meeting.