A Timely Solution Needed for Hazard Mitigation Funding
If time waits for no one, neither do hurricanes and other natural disasters. In the wake of Hurricane Fiona, The Washington Post highlighted the untimeliness of resiliency efforts for Puerto Rico. Essentially, the Federal Emergency Management Agency (FEMA) allocated $3 billion for hazard mitigation projects after Hurricane Maria but only five percent of the available post-Hurricane Maria funds have been obligated. The article cited the cumbersome management of the funds at the federal and local level as a reason for slowing down the progress.
Sadly, the Washington Post reporting comes as no surprise to mitigation practitioners. The FEMA Hazard Mitigation Assistance (HMA) program post-subapplication/application submission process is fraught with delays and frustration. For a program that intends to provide funding to reduce the long-term risk to people and properties and break the cycle of repeated damage, the urgent need for these mitigation projects is overshadowed by an opaque federal review process, numerous Requests for Information (RFI), and subsequent subapplication/application revisions.
Managing the Request for Information (RFI) Process
The purpose of the RFI is for the subapplicant to provide their state and FEMA additional information that may not have been included in the original subapplication/application. Typically, additional information is needed to further evaluate the proposed project’s eligibility, feasibility, cost-effectiveness, and environmental and historic preservation (EHP) impacts. The RFI is intended to be a tool that helps to expedite the data gathering process, but in its current use, it is an impediment that drastically slows down the grant award process.
Case in point, Puerto Rico. The initial Hazard Mitigation Grant Program (HMGP) Letters of Intent (LOIs) were due in the fall of 2019 – two years after Hurricane Maria; yet, over the last three years, these potential hazard mitigation projects have been asked repeatedly for additional information through the RFI process. This untimely process likely had real world impacts following Hurricane Fiona. It seems plausible that the Hurricane Maria backup power projects, if funded, could have lessened the impacts associated with the island-wide power outrage. Not to mention, the infrastructure projects—roads, electrical grid, and water supply systems—that are stuck in a bureaucratic black hole awaiting funding.
Ongoing RFIs are not just slowing down FEMA post-disaster hazard mitigation funding. The FEMA Building Resilient Infrastructure and Communities (BRIC) pre-disaster mitigation program has identified for further review 75 competitive mitigation projects from Fiscal Year (FY) 2020 and FY 2021. As BRIC enters its third year with the opening of the FEMA GO portal on September 30, there is no information available to suggest these 75 projects have been issued grant awards. While BRIC can select $50 million high-impact infrastructure projects in disadvantaged communities, the process from FEMA selection, RFI, and grant award is significantly lagging. This lag time could mean that these projects are not in place to protect communities from the next disaster.
Streamlining the Review Process
One potential way to decrease the protracted review time is to tailor the RFIs to the subapplication/application type (project scoping versus project and phased versus shovel ready projects). Phased projects offer FEMA a strategy to conditionally approve a proposed project in which the first phase (Phase I) requires the subapplicant(s) to prepare technical and environmental reports and data including final site selection, design, engineering studies, permitting, and a refined Benefit-Cost Analysis (BCA). Phase I documentation must be reviewed and approved by FEMA before funding is awarded for the second phase (Phase II) construction and implementation. Since the studies performed by the subapplicant(s) in Phase I will result in a full eligibility, feasibility, cost-effectiveness, and EHP compliance review by FEMA, the initial review for phased projects should be expedited and not require years of RFIs. The goal of this approach should be to get mitigation grants awarded and allow communities to get started on the technical body of work needed to support the implementation of critical mitigation projects.
Investing More in Project Scoping Activities
Another option is to increase the HMGP, BRIC, and Flood Mitigation Assistance (FMA) project scoping funding. Substantial investments for future mitigation projects are needed now and many jurisdictions do not have the seed funding for the studies, plans, and designs. Applicants have $2 million this year for BRIC project scoping activities. This is an increase from the $600,000 in FY 2020, but the need is larger than the current opportunity.
The review timeline for project scoping subapplications—which involve no or minimal groundbreaking for technical studies—should be fast tracked. The subapplication/application must be eligible and comply with Hazard Mitigation Guidance, but a high-level screening, rather than a tedious year-long review, is more appropriate for this type of activity. The quicker the project scoping funds can be awarded; the quicker communities can begin the long-term recovery process. Delays to this funding will ripple through the mitigation program—resulting in less high-impact mitigation projects and less protection to communities that need it the most.
Mitigation practitioners need to be acutely aware that issuing RFIs while intended to be helpful can, and often do, result in harmful delays. The post-subapplication/application submission process needs to reexamine the lengthy review times, including the RFI process. Mitigation efforts are time sensitive and should be about protecting the people and communities behind the projects. At the end of the RFI process are real communities and associated impacts, like Salinas, Puerto Rico, that cannot wait another five years for mitigation funding.
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.
Vanessa Castillo is a Deputy Director of Mitigation at Hagerty Consulting and has extensive experience in the implementation of the FEMA mitigation programs. Before joining Hagerty, she was a Mitigation Specialist with the state of Colorado, where she contributed her expertise to the successful implementation of more than $65 million in the Hazard Mitigation Grant Program (HMGP) for Colorado’s largest disaster.