2019 FEMA Disaster Project

In the spring and summer of 2019, extreme storms and flooding caused significant damage to roads throughout the Cornland Special Road District. The flooding event occurred from April 29 through July 5, 2019. On July 9, 2019, a federal disaster was declared (FEMA-4451-DR-MO), making the district eligible for federal Public Assistance funding to repair damaged roads.

The project was administered jointly by FEMA (Federal Emergency Management Agency) and SEMA (Missouri State Emergency Management Agency). The district served as the subrecipient responsible for completing road repairs and submitting reimbursement claims. The federal disaster declaration for DR-4451-MO is publicly available on the FEMA website.

The 2019 flooding event was described in FEMA documentation as a lengthy extreme storm event in which floodwaters overtopped and scoured secondary roads throughout the district. Surface water flooding washed out road surfaces and bases, and filled roadside ditches with earth across multiple county roads. The district's gravel roads — which serve rural landowners throughout Bates County — sustained damage across at least five separate road segments totaling several miles of affected roadway. Two crossroad culverts in the north bottoms were also impacted.

The board's 2021 correspondence to landowners described the scale of the work: approximately 60 truckloads of gravel were spread on SW 1067 alone, and 10 loads on SW 2508, at a combined material cost of approximately $13,758.

When a federal disaster is declared, FEMA's Public Assistance (PA) program provides funding to help local governments repair or replace infrastructure damaged by the disaster. For road districts like Cornland, this means reimbursement for the cost of repairing flood-damaged roads, culverts, and drainage systems.

The program works on a reimbursement basis — the district must first spend its own funds to complete the repair work, then submit documentation to receive reimbursement. FEMA does not pay costs upfront. This requirement placed significant financial strain on a small district with limited reserves.

Under the standard Public Assistance cost-sharing arrangement, FEMA funds 75% of eligible project costs. The remaining 25% is the responsibility of the state or local applicant. In Missouri, SEMA (the State Emergency Management Agency) administers FEMA Public Assistance funds on behalf of the federal government and serves as the intermediary between FEMA and local subrecipients like the Cornland Special Road District.

SEMA — the Missouri State Emergency Management Agency — is Missouri's state-level emergency management organization, operating under the Missouri Department of Public Safety. When a federal disaster is declared in Missouri, SEMA serves as the Recipient, meaning it receives federal funds from FEMA and distributes them to local governments and organizations (called subrecipients) that suffered disaster-related damage.

For the Cornland Special Road District's 2019 flooding project, SEMA was the district's primary point of contact throughout the reimbursement process. All reimbursement requests, documentation, and correspondence were submitted to SEMA, which then reviewed and forwarded them to FEMA for approval. SEMA also conducted site inspections to verify that road repair work was completed in accordance with the approved scope of work.

Because FEMA reimburses costs after the work is completed, the district had to fund road repairs out of its own limited budget first, then apply for reimbursement. This process unfolded in five phases over several years.

The district would complete a portion of road repair work — grading, gravel, hauling, and labor — then compile receipts, invoices, expense summaries, and other supporting documentation. It would submit these to SEMA using standard forms (SEMA PA-7 and PA-8). SEMA would review the submission and forward eligible costs to FEMA. FEMA would award 75% of approved costs, and SEMA would withhold a portion of each payment until the project was declared complete. Upon project completion, SEMA released the retained funds, followed by the State of Missouri's 10% share of the project cost. Missouri Public Assistance grants are funded 75% federal, 10% state, and 15% local — the remaining 15% is the district's own responsibility and is not reimbursed.

The district's authorized representative throughout this process was Gary Anderson, who managed all five phases of reimbursement requests and the final closeout documentation.

This is the most common point of confusion in the project records, and it is worth setting out plainly before the tables below. Sites describe where the damage was. Phases describe when the district asked to be paid back. They are unrelated systems, and they do not line up with one another.

Sites — the geography, fixed at the start

A FEMA inspector visited the district on March 31, 2020 and documented the flood damage. He divided it into fifteen numbered sites, each one a stretch of road or a specific feature. Each site was recorded with GPS start and end coordinates, a length, a width, a depth, the volume of material needed, and the type of damage — road surface washed out, road base washed out, ditch filled with earth, or in one case a culvert to be cleaned.

Those fifteen sites became the project's Scope of Work — the definitive list of what FEMA agreed to pay for. The site numbers never changed after that. Site 07 meant the same stretch of CR 2487 in 2023 as it did in 2020. The full list, with maps and photographs, is in the Roads Repaired section further down this page.

Phases — the money, spread over three years

FEMA does not pay in advance. The district had to buy the gravel, pay the trucking, pay for the grading, and then apply for reimbursement afterward. A small road district cannot fund several miles of road restoration at once, so the work was done in stages as money allowed, over roughly three years.

Each time the district had completed and paid for a batch of work, it gathered up the cancelled checks, invoices and receipts, filled out SEMA Forms PA-7 and PA-8, and submitted a reimbursement request. Those submissions are the phases. There were five, between December 2020 and May 2023, plus a separate request covering administrative costs.

A phase is therefore not a place. It is a date range and a stack of paid bills. Phase 3 does not mean “the third site” or “sites 7 through 10” — it means everything the district had paid for since the last request was filed.

Why they do not line up

Because the two systems organize the same project along different axes:

A single load of gravel is a good illustration. It belongs to whichever site it was spread on, and to whichever phase the district happened to be in when it paid the invoice. Those two answers have nothing to do with each other. One site can appear across several phases if work there was done a little at a time; one phase almost always covers several sites at once.

The itemized request for Phase 3, submitted in December 2022, shows the pattern clearly. It lists fifteen payments totaling $20,095.90, grouped not by road but by the kind of expense: $3,390.00 in grading across seven checks, $9,906.37 in road rock across three, and $6,799.53 in rock hauling across five. Every line identifies a check number, a date, a payee, and an amount. None identifies a site.

^a The district's request letter of December 17, 2020 states $31,849.62. An internal summary later prepared by the district records $35,696.00 for Phase 1. The difference has not been reconciled from surviving records, and the letter is treated as the authoritative figure here.

^b $21,565.32 is the figure carried on the district's expense summary for this period. An internal summary records $21,525.00.

^c The cover letter accompanying this request states $14,615.54. The itemized request form enclosed with it states $14,215.54 and adds correctly to that figure across all seven line items. $14,215.54 is correct; the cover letter contains a transposition error.

^d An earlier version of this page dated this request May 17, 2023 and stated the amount requested as $6,484.10. Both were incorrect. $6,484.10 was the amount FEMA originally authorized on August 14, 2020, not the amount the district requested. The district's request letter is dated December 12, 2023 and asks for $4,850.00; it refers to the May 17, 2023 correspondence as a separate, earlier submission. FEMA amended the project downward by $1,770.91 on January 2, 2024, setting the final award at $4,713.19, which was paid in full on January 11, 2024.

The figures above can be checked independently against FEMA's own accounting. FEMA's Public Assistance Grant Summary (form P.5) dated January 3, 2024 records the final obligated amounts for both project worksheets, including two downward adjustments made after the work was inspected and closed out.

Two points are worth stating plainly, because they are easy to misread:

The project cost less than approved. FEMA originally obligated $129,682.00. The verified cost of the completed work was $94,263.71. The unused $35,418.29 was deobligated by FEMA and never paid to the district. A grant award is a ceiling, not a payment.

The March 2024 payment is the state's share, not a duplicate. Missouri Public Assistance grants are funded 75% federal, 10% state, and 15% local. The $9,426.37 received on March 6, 2024 is exactly 10% of $94,263.71 — the State of Missouri's contribution, paid after federal closeout.

The FEMA-funded road repairs covered three categories of eligible costs. The repairs addressed damage caused by floodwaters overtopping and scouring secondary roads throughout the district in Bates County.

One of the most challenging aspects of the FEMA Public Assistance program is that local governments must spend their own money first, then apply for reimbursement. For a small road district like Cornland with limited reserves, this created significant financial pressure over the multi-year life of the project.

In June 2020, the district calculated that it needed an additional $20,200 from landowners to meet FEMA's cost-sharing requirements. Each landowner's requested donation was calculated based on the relative productive agricultural value of their property. The following donations were requested and received:

Despite receiving only $4,170 of the $20,200 requested in donations, the district was able to complete the project through a combination of sources.

The district's existing bank balance provided a starting point — approximately $10,095 was available at the time the project began. Ongoing annual property tax distributions and CART fund income continued to flow into the district each year from 2019 through 2023, providing additional operating funds.

In 2021, Gary Anderson personally loaned the district $1,858 to help keep the project moving forward. This loan was repaid to him in September 2021.

The phased reimbursement structure also helped significantly. Because FEMA reimbursed 75% of eligible costs after each phase of work was completed, the district did not need to have the full project cost available at one time. The district would spend funds on road repairs, submit documentation to SEMA, receive a reimbursement payment covering 75% of those costs, and then use those funds to continue additional work. This cycle repeated across five phases over several years.

Finally, at project closeout, the actual verified cost of the completed work came in at $94,263.71 — significantly less than the original $129,682 approved amount. This meant the district's cost-sharing obligation was proportionally reduced, making the project financially achievable despite the shortfall in donations.

The following roads and sites were identified in FEMA Project Worksheet PW #570 as having sustained damage from the 2019 flooding. All roads are gravel, 24 feet wide, two lanes. The damage was caused by surface water flooding that washed out road surfaces, road bases, and filled roadside ditches with earth. Work was completed to restore each road to its pre-disaster condition.

Two sites require explanation

Site 13 (CR 3048) is not in the approved scope of work. FEMA's damage description for this project lists fifteen sites, including Site 13 on CR 3048, with GPS coordinates and quantities of 117.33 cubic yards of surface gravel and 117.33 cubic yards of base gravel. The approved Scope of Work, however, lists only sites 01–12, 14, and 15 — in both the original version and the awarded version. Site 13 appears in the damage description and not in the work FEMA approved for funding.

The district's own internal estimating and budget spreadsheets do carry Site 13 entries, coded to “Bob Chandler Lane,” totaling approximately $1,960. Whether any of those costs were included in a reimbursement request cannot be determined from vendor records, because no vendor invoice held by the district records a delivery location — the invoices state date, ticket number, product, tonnage, and price, but not the road. The district is unable to resolve this from its own files and has included it in its request to SEMA.

Site 15 was reported partially complete without documentation. FEMA's Project Note 3 for this project records that the district reported Site 15 as 10% complete, that no supporting documentation was present or provided, and that FEMA therefore estimated the entire site as work to be completed. Project Note 2 separately records that the district had calculated the wrong quantity of material for Site 15, and corrects it to 704 cubic yards. Both notes are FEMA's own; they are reproduced here rather than paraphrased.

Work outside the approved scope was excluded from the claim

The district's records show a consistent practice on this point. Where grading was performed on roads outside the fifteen approved sites, the hours were recorded on the invoice but entered at a rate of zero and excluded from the amount claimed for federal reimbursement. One invoice held by the district records forty-four hours of grader work, of which sixteen hours on two roads outside the approved scope were billed at zero and twenty-eight hours on approved roads were billed and claimed.

The reason was stated to the state at the time. In an email to SEMA dated April 19, 2022, the district's Authorized Representative wrote that some of the grading performed had been beyond the scope of work approved for reimbursement by FEMA and was not included in the amount requested, and that two hauling charges from August 2021 had been excluded on the same basis. The invoice and the email were produced independently and describe the same practice.

The project was formally closed out in September 2023 following a final inspection by SEMA on June 8, 2023, which confirmed all road repair work was complete. A final closeout payment of $17,674.45 was issued by SEMA in September 2023.

An earlier version of this page listed the status of this administrative project as unresolved. It has since been confirmed and is closed.

Project Worksheet #00961 was a Category Z administrative project, funded 100% federally, covering the cost of administering the road repair grant. It was originally approved on August 14, 2020 in the amount of $6,484.10. On January 2, 2024, FEMA amended the project downward by $1,770.91 — a routine adjustment reflecting actual administrative costs coming in below the original estimate.

The amended amount of $4,713.19 was received by the district on January 11, 2024 and appears on the January 2024 bank statement. Nothing further is owed to the district on this project.

In July 2026 the district located a USB storage device belonging to the former Authorized Representative, containing project material that had not previously been part of the district's paper files. The board is describing how this material was found, because records that arrive outside the ordinary filing system should be accounted for rather than simply used.

The device held 492 files — 144 PDF documents, 143 photographs, and 205 word processing and spreadsheet files. Roughly half of the office files proved to be backup or auto-recovered duplicates, leaving an effective total nearer 250 distinct documents. Every file was inventoried by name, folder, size, and modification date. All word processing and spreadsheet files were searched by content. All PDF documents were searched, and those containing no machine-readable text were identified for direct examination. All 143 photographs were examined for embedded camera and date information.

The review resolved several questions this page previously listed as open, and it raised others. Both are reflected above. Specifically, it produced the complete February 2022 submission to SEMA, the FEMA damage and determination report containing all fifteen site descriptions with coordinates, the January 2024 correspondence from SEMA's Recovery Division, the check image and invoices underlying the administrative cost project, and the district's 2022 letter to residents.

Two findings from that review are stated here because they are absences rather than documents, and absences are easily missed:

• No board minutes for any year from 2019 through 2024 appear among the 492 files. The only minutes present are dated May 2025, together with meeting notices from 2011 and 2013. This is consistent with the district's paper files and is addressed further on the Audit & Compliance page.
• No photograph on the device dates from 2021, 2022, or 2023 — the period of the restoration work and the June 2023 inspection. The photographs present are from the 2019 disaster period and from an earlier flood event in 2015. Completion photography exists as links to cloud-hosted albums referenced in a district document; the board is working to retrieve and preserve those originals before they become unavailable.

Material recovered from this device has been treated the same as any other district record. Where it conflicts with bank statements, the bank statements govern. Where it conflicts with documents held by FEMA, SEMA, or a vendor, those documents govern. Nothing on this page rests on the recovered material alone.

Nothing on this page rests on the district's word alone. Every figure can be traced to a source document, and most can be checked against records held by someone other than the district. Anyone wishing to inspect these records may request them from the district under the Missouri Sunshine Law.

The section above describes what the district can document. This section describes what it cannot. The board considers it more useful to state these gaps plainly than to leave them to be discovered.

Force account labor documentation

FEMA's closeout narrative states that the $50,710.14 force account labor claim was supported by signed timesheets, and that FEMA validated 100% of labor costs to confirm the hours were completed in accordance with the approved scope of work. That was a single determination made at closeout in 2023 covering the labor claim as a whole. It was not a phase-by-phase approval, and it should not be described as one.

The district has searched its records page by page — 727 pages across 21 scanned batches, plus all supplementary document sets — and has not located those labor records. Pages where scanning quality was poor were inspected visually rather than assumed blank, so this is a search result and not a limitation of the scans. The only timesheet document in district files is a management-time log kept by the former Authorized Representative for Category Z administrative costs under a separate project number. That is a different cost category and does not substantiate the force account labor figure.

One distinction should be stated precisely. FEMA's narrative uses the phrase "signed timesheets." The Missouri State Auditor, reviewing the same period, described the district as having maintained invoices showing hours worked at rates between $45 and $65 per hour. These may well describe the same physical documents — a contractor's signed invoice stating hours and an hourly rate would reasonably satisfy a closeout reviewer looking for labor support. The district is not in a position to assert which characterization is correct, and does not claim the distinction resolves anything. Either way, the underlying records are not in district files.

The December 26, 2022 reimbursement request to SEMA lists, by name, enclosures consisting of receipts from the individuals who performed grading work. That establishes the documents existed and were transmitted to the state. The district's own file copies were not retained. The board has requested the complete submission file from SEMA and the supporting Labor Item Record referenced in FEMA's closeout narrative, and will publish those records if they are produced.

A further check has since been possible. The February 22, 2022 reimbursement request to SEMA — the phase covering December 2020 through February 2022, which includes the period of the grading work — enumerates its nine enclosures by name in the cover letter. They are the two SEMA forms, an expense summary, trucking receipts, a rock purchase schedule, and four enclosures headed “Grading.” No timesheet appears in the index. The district has since recovered a copy of that complete submission and examined the grading enclosures directly: one is a printed invoice showing site codes, hours, and an hourly rate, and the remainder are handwritten invoices on standard pre-printed sales pads carrying fields for terms, description, price, and amount. They are invoices. The district makes no claim as to whether FEMA was entitled to treat them as satisfying a timesheet requirement; it states only what the documents are.

How $50,710.14 was categorized

The phase reimbursement requests the district holds are itemized primarily as road rock, hauling, and grading. FEMA's closeout instead reports three categories — contract work, force account labor, and materials — with force account labor at $50,710.14. The district does not currently hold the worksheet showing how costs were assigned among those three categories at closeout, and cannot independently explain the difference between its own line-item categories and FEMA's. The most likely explanation is that FEMA reclassified district-directed work at closeout, which is ordinary practice, but the board is not asserting that without the document. It has been requested along with the records above.

Two features of the district's records bear on this and are worth stating, because they may explain why no timesheets exist rather than merely restating that they do not.

First, the categories do not map onto one another in any traceable way. The district's expense summary groups its costs under headings of its own — “rock and hauling” and “grading” — and its grading heading includes a limited liability company and a neighboring township alongside individuals. Under FEMA's structure a contractor and another unit of government would fall under contract costs, not force account labor. Separately, the material purchased in the first two phases alone exceeds the entire materials figure reported at closeout for all five phases. Whichever way those differences are explained, the closeout figures were not derived from the district's records in a form the district can reproduce.

Second, the grading entries are recorded against equipment, not personnel. Every grading line in the district's expense summary carries an equipment designation — grader, grader blade, or tractor — at rates between $30 and $85 per hour. By contrast, the one document in district files that is unambiguously a force account labor timesheet, the Category Z management-time log, records personnel time at $21.76 per hour with a separate column for benefits. Those are two different kinds of rate. FEMA treats force account equipment as a cost category distinct from force account labor, evidenced by equipment usage records rather than personnel timesheets, and no equipment line appears in the closeout narrative.

The board is not in a position to determine whether the $50,710.14 is properly force account labor, force account equipment, or contract cost. Each carries a different documentation requirement. The district has put that question to SEMA in writing, together with its request for the Labor Item Record, and will publish the answer.

Phase 1 and Phase 2 itemized breakdowns

Itemized, line-by-line reimbursement requests survive for Phases 3, 4, and 5, each identifying check numbers, dates, payees, amounts, and cost categories. For Phase 1, the December 17, 2020 request letter and the SEMA PA-7 and PA-8 forms survive, but the itemization does not. For Phase 2, no itemization has been located.

An expense summary prepared by the district covering December 2020 through February 2022 provides payee-level detail for that period and is available on request. It is a district-prepared summary rather than a source record, and it exists in more than one revision with small differences between them.

Record of Expenditures, Sites 01 through 15

This document is listed as Enclosure 4 to the December 17, 2020 request letter. It has not been found in district files. The district cannot determine whether it was produced and later lost, or never produced.

Former Authorized Representative's email account

A substantial portion of the correspondence with SEMA and FEMA was conducted by email from an account the district does not currently have access to. Much of what the district holds from that channel exists only as printouts or forwarded copies of messages that originated in that account. The board will review that material and produce what is responsive if access is obtained.

A related source has been recovered and reviewed. See Source Records Recovered above.

Distinguishing FEMA work from routine maintenance

The district's ledgers and annual reports classify disbursements by type of work, not by funding source. They do not, on their face, distinguish payments made for FEMA project restoration from payments made for ordinary road maintenance. The documents that do make that distinction are the phase reimbursement request itemizations — and, as noted above, two of the five are missing.