DRRA Section 1206 Program Support for Floodplain Management

Project Overview

Since 2021, Hagerty has partnered with the City of Cape Coral, Florida, to support disaster recovery, mitigation, and planning efforts. Our work spans a variety of federal and state programs, including:

• Federal Emergency Management Agency (FEMA) Public Assistance (PA)
• FEMA Hazard Mitigation Grant Program (HMGP)
• United States (US) Department of Housing and Urban Development’s (HUD) Community Development Block Grant – Disaster Recovery (CDBG-DR)
• Federal Highway Administration’s Emergency Relief (FHWA-ER) Program
• The Resilient Florida Grant Program

In 2024, FEMA issued a compliance notice identifying deficiencies in the City’s floodplain management practices, such as incomplete permitting records and a lack of Substantial Improvement/Substantial Damage (SI/SD) determinations. The City faced the risk of probation and potential retrograde to Class 10 in FEMA’s Community Rating System, which would eliminate flood insurance premium discounts.

To address these urgent challenges, Hagerty developed a Substantial Damage Administrative Procedures (SDAP) plan and a Disaster Recovery Reform Act (DRRA) Section 1206 Protocol. Ultimately, these efforts were designed to strengthen documentation, improve inspection processes, enhance compliance with federal policy, and expedite reimbursement under FEMA’s PA program.

Understanding the Mission

The City needed to meet NFIP compliance deadlines while simultaneously managing ongoing recovery operations for Hurricanes Ian and Milton. At the same time, FEMA encouraged the use of DRRA Section 1206 to support eligible inspections and documentation activities. Hagerty was engaged to help Cape Coral establish internal processes that aligned with federal requirements, reduced the risk of NFIP probation, and supported reimbursement under FEMA’s PA program.

The Hagerty Approach

Post-Hurricane Ian Planning

Following FEMA’s compliance notice in early 2024, Hagerty developed a custom Section 1206 Protocol to guide eligible recovery activities under FEMA’s PA program. This framework:

• Clarified roles and responsibilities
• Outlined workflows for project management, vendor coordination, outreach, and documentation
• Positioned the City to demonstrate compliance and seek maximum reimbursement

In July 2024, FEMA formally requested an SDAP plan. Hagerty supported the City in adapting the SDAP template to fit Cape Coral’s organizational structure, including:

• Defining consistent processes for SI/SD determinations, permitting, and code enforcement
• Assigning roles across departments
• Establishing standards for activity tracking, document collection, and file organization

To ensure successful implementation during the 180-day Section 1206 reimbursement window, Hagerty also developed a Reporting Toolkit with templates for documentation tracking and a Media Toolkit with customizable public messaging to support consistent community outreach. These resources helped Cape Coral maintain audit readiness and remain on schedule with floodplain management goals.

Implementation During Hurricane Milton Response

Following Hurricane Milton’s landfall in October 2024 and the subsequent major disaster declaration, the 180-day window for Section 1206 reimbursement began in accordance with FEMA PA policy. Drawing on the preparedness measures developed post-Hurricane Ian, the City successfully implemented Hagerty’s protocols and toolkits to launch response operations. Hagerty provided direct support across key activities, including:

• Coordinating field inspections and SI/SD determinations in partnership with City officials
• Facilitating vendor coordination, documentation collection, and project tracking
• Organizing property-level closeout packages and maintaining audit-ready documentation using the Reporting Toolkit
• Deploying the Media Toolkit to support public outreach efforts

The Hagerty team also created a detailed project timeline, handled administrative tasks, and provided weekly reporting to support compliance.

Achieving Results

Throughout the 180-day DRRA Section 1206 period, Hagerty provided end-to-end program support, driving measurable outcomes across compliance, inspections, and public engagement, including:

• 1,700+ SI/SD inspections conducted in accordance with FEMA guidelines
• 200+ determination letters issued to affected property owners, enhancing transparency and regulatory compliance
• 1,900+ community outreach activities, including the distribution of printed materials and digital communications via social media posts
• 1,700+ closeout folders developed with supporting documentation, in accordance with the City’s SDAP and Reporting Toolkit

At the end of the reimbursement period, Hagerty delivered a formal Closeout Memorandum and a set of Standard Operating Procedures (SOPs) to support ongoing Section 1206 activities. These results reflect the City’s commitment to advancing floodplain management practices and building code administration efforts, with Hagerty serving as a strategic partner throughout the process.