THE NEXT GENERATION OF BRIC PROJECTS

As the impacts and effects of climate change are realized, the needs to reduce hazard risks in communities across the country are rapidly multiplying.  The passage of the Disaster Recovery Reform Act (DRRA) in October 2018 has, and will continue to have, a transformative impact on the field of emergency management. Specifically, the DRRA has had a major impact on the Federal Emergency Management Associate (FEMA) Hazard Mitigation Assistance (HMA) programs through the introduction of FEMA’s new pre-disaster mitigation program, Building Resilient Infrastructure and Communities (BRIC). While BRIC represents an important step forward in providing a reliable source of mitigation funding to state, local, tribal, and territorial (SLTT) governments, the goal and intent of the program has exposed many underlying process and policy limits related to HMA programs.  Below we identify some mitigation challenges practitioners are facing across the country, as well as some items that FEMA may want to consider addressing as its programs continue to evolve to meet the quickly changing mitigation needs of our nation.

MISCELLANEOUS project types

As FEMA rolls out its first year of BRIC grants, state and local entities are busy developing eligible, cost-effective, feasible, and nationally competitive projects. FEMA encourages state and local entities to pursue activities that best address priorities in their community including projects that address climate change adaptation and resiliency.  At this time,  these activities are listed as miscellaneous/other in the FEMA Hazard Mitigation Assistance Guidance (2015) and they assist communities in “adapting to new challenges posed by more powerful storms, frequent heavy precipitation, heat waves, prolonged droughts, extreme flooding, higher sea levels, and other weather events.” As our country experiences historic wildfires, an unprecedented pandemic, and a hyperactive hurricane season, the miscellaneous/other activities likely offer the best opportunity to address the evolving risks we continue to see in 2020 as well as the conditions forecasted in decades to come. As communities seek to address their mitigation needs through more innovative means than those identified in FEMA’s 2015 HMA Guidance, it has become apparent that a highly flexible, malleable project type is needed which comports with BRIC’s stated goal of finding new ways to mitigate risk to infrastructure and reducing our collective risk to all-hazards.

FEMA Eligible Activities by Program: Source

Mitigation to Migration

As the climate changes, unmitigated sea level rise, extreme weather, and drought have created a need to relocate or migrate people and assets to a new, more stable location. In some instances, communities have already sought FEMA HMA grant funding to address this need. To address these evolving conditions, projects like managed retreat, infrastructure relocation, and wildfire buyout programs may be required.

Currently, FEMA HMA Guidance includes private property buyout project options for flood and landslide hazards; however, wildfire mitigation includes projects that are limited to hazardous fuels reduction, defensible space, and ignition resistant construction, but does not include the option for private property buyout. As we have seen this year, if megafires more frequently become gigafires, there could become a need to relocate communities and infrastructure to a more sustainable and fire safe landscape within of the Wildland Urban Interface (WUI). This is one example of the adaptability which will be required to mitigate anticipated hazards and changing conditions which will increase our resilience and reduce our nation’s long-term risks and exposure to these changing conditions.

All-Hazards Adaptability

During the COVID-19 pandemic, States on both the East and West coasts had to grapple with the need to open emergency shelters and surge healthcare facilities due to hurricanes and wildfires. While the FEMA HMA Guidance doesn’t allow for standalone pandemic mitigation projects, FEMA acknowledges in its recent Guide to Expanding Mitigation that public health co-benefits can be identified in structural mitigation projects. Given this guidance, projects with co-benefits or ancillary benefits related to a pandemic, but outside of the project’s primary risk reduction objective, could be included in the project’s scope. As outlined in the BRIC Qualitative Scoring other ancillary benefits include: “water/air quality, habitat creation, energy efficiency, economic opportunity, reduced social vulnerability, cultural resources, and mental health”.

Flexibility for Future Conditions

A multi-hazard approach to mitigation projects also contends with the reality that current and future mitigation must address the compounding effects of climate change on natural hazards. For example, to mitigate stormwater impacts, FEMA’s Nature-Based Solutions provides guidance on watershed, neighborhood, and coastal area project types. Many of these stormwater projects including greenways, permeable pavement, green roofs, and tree canopies can also be effective at mitigating extreme heat and the urban heat island effect. While projects that mitigate heat waves are listed as an eligible miscellaneous/other activity, how to quantify the impacts of this hazard in the FEMA benefit-cost analysis (BCA) tool remains undefined.

As an example, potential benefits (avoided losses) could explore how to quantify increased costs of healthcare, increased hospitalization, and increased energy use, as many residents of California experienced earlier this year.

To translate miscellaneous/other activities into quantifiable mitigation opportunities, the FEMA BCA toolkit needs to provide a more robust way to quantify the benefits of addressing these increasing hazards and future conditions. FEMA’s sea level rise policy has been in effect since 2013 and has helped evaluate how climate change considerations can be incorporated into HMA grants. FEMA recently updated its ecosystem service benefits in BCA policy to allow these benefits to be used regardless of the project’s benefit cost ratio (BCR). FEMA made “this change in recognition that the environment is an important component of a community’s resilience strategy”. Other BCA considerations to increase the cost-effectiveness of innovative, multi-hazard projects would be the development of new pre-calculated benefits, including additional environmental, social, and recreational benefit calculations/methodologies, and updating the outdated, assumptive models to account for future conditions.

Expedited Funding Opportunities

In some instances, there is a critical need for Applicants to quickly submit sub-applications to FEMA so they may review, approve, and award projects.  An example of this are property acquisitions and quick-implementation projects in the post-fire environment necessary to mitigate the impacts of erosion and debris upon people and property downstream of impacted watersheds.  In these instances, it is critical Applicants develop the ability to quickly identify these projects, assist communities with sub-application development as well as work with their FEMA counterparts to develop a system which quickly conveys these projects through the award process.  It is also critical that eligible applicants work closely with eligible sub-applicants pre-award to ensure that should this fast track process be implemented, local communities are able to quickly procure the necessary resources to implement the project in compliance with applicable federal regulations.

Recommendations for 2020 and Beyond

As the BRIC program and our mitigation needs evolve, the next generation of Hazard Mitigation Assistance Guidance will undoubtedly need to adapt to meet our future needs. To successfully do so, all mitigation partners and practitioners should work closely together to address the items identified below:

• Provide standardized implementation guidance for HMA projects across the FEMA regions to reduce the potential for conflicting approaches between regions.
• Expand eligible activities to better reflect current and future conditions and broadly market these so they are well known and utilized as appropriate – otherwise, miscellaneous/other will become a prevalent project type.
• Reconsider duplication of programs as large infrastructure projects may require extensive collaboration and funding from multiple Federal partners to ensure high-impact projects can be built.
• Revisit previously ineligible activities, such as prescribed burns, which might serve a critical wildfire mitigation role.
• Better define project-phasing best practices to provide unified guidance on the design development and level of detail needed in a BCA for phased projects. A common question is at what stage of design development does a project require phasing.
• Expand the current list of pre-calculated benefits and consider the use of pre-calculated benefits for property acquisition in high risk WUI areas and projects that incorporate one or more of the identified nature-based solutions.
• Expand traditional benefits in the FEMA BCA tool to streamline the valuation of ancillary benefits and future conditions (heat, drought, newly eligible activities under the Disaster Recovery Reform Act, etc.); identify best practices used by other Federal agencies to identify and quantify project benefits to include the Environmental Protection Agency (EPA), and US Army Corps of Engineers (USACE).
• Align FEMA programmatic guidance and BCA methodologies to support the projects identified in the FEMA Mitigation Action Portfolio. Currently, the FEMA MAP includes projects that are not funded by FEMA and do not use FEMA BCA methodologies. Many of these projects would likely be ineligible or not cost-effective using FEMA’s current HMA eligibility and application development mechanisms.

With further evolution of the Hazard Mitigation Assistance Program, governments and communities will be granted a better opportunity to develop the next generation of BRIC competitive projects – projects that make the most of limited mitigation funding by anticipating changes in our environment and being responsive to those future conditions.

Hagerty is here to 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, contact us.

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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.

Scott Baldwin is a Senior Mitigation Manager at Hagerty Consulting and a subject matter expert in natural hazard mitigation in both the pre and post disaster recovery environments.  With over 10 years of experience in FEMA’s Hazard Mitigation Assistance and Public Assistance (PA) programs, Scott has worked closely with states and communities in Colorado and California to identify, develop, and implement mitigation and recovery solutions tailored to meet their needs.

Vanessa Castillo is a mitigation and planning specialist with experience in the implementation of the FEMA mitigation programs. Before joining Hagerty, she was a planner with the City of Denver where she specialized in environmental compliance. Prior to Denver, 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 Hazard Mitigation Grant Program (HMGP) for Colorado’s largest disaster.