FEMA’s BRIC Program: Second Annual Competitive Project Selections and the Unprecedented Funding Commitment for 2022
On August 1, 2022, we learned the outcome of the Federal Emergency Management Agency (FEMA)’s Building Resilient Infrastructure and Communities (BRIC) 2021 competitive mitigation project selections. Last year, the inaugural year, 22 competitive mitigation projects were announced from nine states plus the District of Columbia (D.C.) totaling $377.7 million. Of these 22 projects, 18 included nature-based solutions and all the competitive projects selected were from States that have adopted the 2015 or 2018 versions of the International Building Code (IBC) and the International Residential Code (IRC). Last year, FEMA faced criticism for the selections not being geographically diverse; for not funding smaller mitigation projects (projects under $1 million); and for funding not benefiting disadvantaged communities as only two of the 22 projects were in defined small, impoverished communities.
BRIC 2021 Adjudication
Competitive BRIC projects are adjudicated into four categories: identified for further review; not selected; not selected / not reviewed; or did not meet Hazard Mitigation Assistance (HMA) requirements (ineligible). Last year, we explained each of these categories in detail and what to do depending on your selection status. This year not selected / not reviewed is a new category and we anticipate that Applicants/ Subapplicants with projects in this category are unlikely to receive feedback from FEMA.
In 2021, the BRIC program had double the amount of funding from its inaugural cycle and the BRIC competitive funding expanded to 53 competitive mitigation projects from 18 states plus D.C. totaling $795.9 million. Additionally, all ten of the FEMA Regions received at least one competitive mitigation project this year — at some level addressing the lack of geographic diversity from the previous year. Additionally, in 2021, the average project dollar amount is $15 million — with the smallest being $189,000 and the largest at the program max of $50 million. Moreover, three selected projects are under $1 million which also addresses the concern that smaller mitigation projects were not funded in the previous year.
It also appears that an Applicant’s (State) building codes still played a large role in project selection. While two states received 2021 project selections with no adopted or Statewide residential codes in place (Wyoming and Wisconsin), the funding received by these two States only made-up 1 percent of the total available competitive mitigation funding available. Increasing equity also factored into the 2021 selections as the BRIC program is included in the Justice40 Initiative with the goal of prioritizing the delivery of benefits to disadvantaged communities. Per FEMA, approximately 49 percent of projects selected through the 2021 national competition will be delivered to communities that meet one or more Justice40 interim criteria.
Rising temperatures are endangering human health, agriculture, and our nation’s energy infrastructure. Heat waves are becoming more intense and more common and extreme heat can exacerbate drought, and hot, dry conditions can in turn create wildfire conditions; however, mitigating these hazards has not traditionally been a significant funding opportunity through FEMA’s Hazard Mitigation Assistance (HMA) program. The first year of BRIC included one competitive wildfire project funded and there were no heat or drought projects selected. In 2021, FEMA selected one wildfire (California); four drought (two projects in California, one in North Carolina, and one in Utah); and three extreme heat projects (one in California and two in New York). The expansion of funding to drought and extreme heat hazards in BRIC is a deliberate decision to make communities more resilient to climate change and extreme weather events.
Unprecedent funding for BRIC in 2022
On July 20, 2022, the Biden-Harris Administration announced that BRIC program funding would be an unprecedented $2.3 billion this year which is significantly increased from the $500 million in 2020, and the $1 billion in 2021. The Administration also expressed a clear focus on funding to help communities increase resilience to heat waves, drought, wildfires, floods, and hurricanes.
The upcoming 2022 Notice of Funding Opportunity (NOFO) is expected by mid-August. The NOFO will be posted on FEMA’s BRIC website when released. In preparation for the release of the NOFO, FEMA will kick off their 2022 Summer Engagement Series webinars on August 4, 2022. Interested applicants and subapplicants can register for the webinars here.
Our guidance from last year is still very relevant for success. BRIC is a highly selective and nationally competitive grant program. The overall success rate was 14 percent in 2021, up from the 4 percent for competitive projects in 2020. At a minimum, projects must be eligible, feasible, and cost-effective; and, to truly be competitive, projects must aim to maximize the program’s technical and qualitative scoring rubrics. Moreover, as established in previous years, nature-based solutions, future conditions, and building codes (International Building Code (IBC), International Residential Code (IRC), and Building Code Effectiveness Grading Schedule (BCEGS) ratings) are also important considerations for BRIC submissions. Additionally, including a public-private partnership can increase the project’s change of success. Lastly, with the Justice40 Initiative, examining the project benefitting area to determine if a disadvantaged community is being protected is a valuable focus for competitive mitigation projects.
As Vice President Harris said during her speech to introduce the 2021 project selections, “we are experiencing the climate crisis in real time.” Given this urgency, the greatest challenge we will likely experience in BRIC is putting the ‘bricks into BRIC’. With the BRIC 2020 competitive mitigation projects not yet awarded, there are long delays from project selection before the grant funding is awarded and the project is finally implemented. The unprecedented level of funding is exciting, but there is a significant lag time before funds reach the communities and shovels are in the ground. If this trend continues in future years, we may not be able to combat the climate crisis in time. It is imperative that BRIC continue the trends seen in 2021 and determine a path to enable more efficient award times for the projects the Agency identifies for further review.
Hagerty Can Help
While the cost share for this program is 75 percent federal and 25 percent non-federal, FEMA will provide 100 percent federal funding for management costs associated with the administration of a BRIC-awarded mitigation measure or project. Therefore, our professionals can help at little-to-no additional cost. Hagerty’s Mitigation Team are experts in navigating the pre- and post-disaster funding world. We are available to talk about your recovery needs, including how to access all funding available through federal grant programs. To learn more, please fill out the form below.
Amelia Muccio is the Director of Mitigation at Hagerty Consulting and a subject matter expert in disaster recovery. With over 15 years of experience in public health, disaster preparedness, mitigation, and financial recovery, Amelia has helped clients obtain $5 billion in federal funds after major disasters, including Hurricane Sandy, the California Wildfires, and Hurricane Harvey.