OMB Circular A-122; Attachment A A(3) provides that a cost is reasonable if; in its nature or amount; it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur costs. Other factors affecting costs must be considered when testing for reasonableness. Per the PA Guide; FEMA can establish reasonable costs using average costs for similar work.The Applicant demonstrated that it incurred higher costs in order to complete the eligible scope of work in difficult terrain; documented actual costs appropriately; and acted prudently.The Applicant actual costs fall within the range allowed by FEMA for similar work in the same disaster.Pursuant to 44 C.F.R. 206.223(a)(3); an applicant must be legally responsible for work for it to be eligible. The Applicant did not demonstrate legal responsibility for providing its employees with water; ice; and personal equipment.

PA Guide; at 40-41.HeadnotesOMB Circular A-122; Attachment A § A(3) provides that a cost is reasonable if; in its nature or amount; it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur costs. Other factors affecting costs must be considered when testing for reasonableness. Per the PA Guide; FEMA can establish reasonable costs using average costs for similar work.The Applicant demonstrated that it incurred higher costs in order to complete the eligible scope of work in difficult terrain; documented actual costs appropriately; and acted prudently.The Applicant’s actual costs fall within the range allowed by FEMA for similar work in the same disaster.Pursuant to 44 C.F.R. § 206.223(a)(3); an applicant must be legally responsible for work for it to be eligible. The Applicant did not demonstrate legal responsibility for providing its employees with water; ice; and personal equipment.