44 C.F.R. 206.206(b) establishes two levels of appeal and specifically endows the RA with the sole authority to consider first appeals; and the Assistant Administrator for the Disaster Assistance Directorate with the sole authority to consider second appeals.FEMA denied the disputed costs in the original PWs and the RA upheld the denials on first appeal. Subsequent obligation and deobligation actions did not and could not vacate or overturn the RA first appeal decisions. Only the Assistant Administrator has the authority to overturn first appeal determinations. Stafford Act 423(a) and 44 C.F.R. 206.206(c)(1) provides an applicant with 60 days to submit an appeal. The Applicant submitted its second appeals 5 years after the RA denied the first appeals.44 C.F.R. 206.206(c)(2) provides the grantee with 60 days to forward an applicant appeal together with its written recommendation.

FEMA Recovery Policy FP 205-081-2; Stafford Act Section 705; Disaster Grant Closeout Procedures; at 2.Headnotes44 C.F.R. § 206.206(b) establishes two levels of appeal and specifically endows the RA with the sole authority to consider first appeals; and the Assistant Administrator for the Disaster Assistance Directorate with the sole authority to consider second appeals.FEMA denied the disputed costs in the original PWs and the RA upheld the denials on first appeal. Subsequent obligation and deobligation actions did not and could not vacate or overturn the RA’s first appeal decisions. Only the Assistant Administrator has the authority to overturn first appeal determinations. Stafford Act § 423(a) and 44 C.F.R. § 206.206(c)(1) provides an applicant with 60 days to submit an appeal. The Applicant submitted its second appeals 5 years after the RA denied the first appeals.44 C.F.R. § 206.206(c)(2) provides the grantee with 60 days to forward an applicant’s appeal together with its written recommendation.