According to the PA Guide; the owner of a facility is responsible for determining the extent of damage. Surveys for damage are not eligible for PA funding. However; when damage to an inaccessible structure or structural component is evident based on other observations; FEMA may pay for inspections to determine the extent of damage and method of repair. The Applicant contractor inspected 290 manholes for damage and did not limit its assessment to determining the extent of damage or method of repairs for inaccessible structures where damage was evident. This assessment constitutes an ineligible damage survey. The PA Guide states that costs for an engineering evaluation to determine the type and extent of repairs necessary to return a facility to its predisaster condition and costs of basic engineering and design services normally performed by an architectural-engineering firm on complex constructions projects are eligible for reimbursement. All costs must be reasonable and necessary to perform the eligible work.The Applicant has not demonstrated that the appealed costs were required as part of an engineering evaluation to determine the type and extent of necessary repairs. This type of engineering evaluation would not have been reasonable or necessary for the complexity of repairs described in this PW SOW – cleaning and spraying damaged manholes without significant variation between repairs.

HeadnotesAccording to the PA Guide; the owner of a facility is responsible for determining the extent of damage. Surveys for damage are not eligible for PA funding. However; when damage to an inaccessible structure or structural component is evident based on other observations; FEMA may pay for inspections to determine the extent of damage and method of repair. The Applicant’s contractor inspected 290 manholes for damage and did not limit its assessment to determining the extent of damage or method of repairs for inaccessible structures where damage was evident. This assessment constitutes an ineligible damage survey. The PA Guide states that costs for an engineering evaluation to determine the type and extent of repairs necessary to return a facility to its predisaster condition and costs of basic engineering and design services normally performed by an architectural-engineering firm on complex constructions projects are eligible for reimbursement. All costs must be reasonable and necessary to perform the eligible work.The Applicant has not demonstrated that the appealed costs were required as part of an engineering evaluation to determine the type and extent of necessary repairs. This type of engineering evaluation would not have been reasonable or necessary for the complexity of repairs described in this PW’s SOW – cleaning and spraying damaged manholes without significant variation between repairs.