On August 12, 2022, the Federal Emergency Management Agency (FEMA) released the Notice of Funding Opportunities (NOFO) for the Building Resilient Infrastructure and Communities (BRIC) and Flood Mitigation Assistance (FMA) programs. Given the increased severity and frequency of severe weather and disasters, communities nationwide are contemplating what solutions are available to help them become more resilient – the BRIC and FMA programs are two potential solutions. This blog post will focus on the BRIC program, with additional content on FMA later this week.
For FY 2022 BRIC funding, $2.3 billion has been set aside, with just over $2.1 billion available for the national competition. The maximum project cap is still $50 million (per project); however, the state allocation which includes Capability & Capacity Building (C&CB) has doubled from $1 million to $2 million. BRIC’s priorities for FY 2022 are:
- Mitigation to public infrastructure and disadvantaged communities, as referenced in Executive Order (EO) 14008;
- Incorporating nature-based solutions (NBS);
- Emphasis on projects designed to reduce carbon emissions;
- Enhancing climate resilience and adaptation; and,
- Increased funding to entities that facilitate the adoption and enforcement of the latest published editions of building codes.
A Multi-Pronged Approach for Equity
Increased Technical Assistance
This year, BRIC is seeking to equal the playing field by addressing inequities in the subapplication process – where mitigation projects are ultimately constructed. This is being addressed in several ways; the first being the expansion of the non-financial Direct Technical Assistance (TA). FEMA has increased this opportunity to at least 40 communities (doubled from last year). The outcome of this assistance is to help disadvantaged communities in the early stages of mitigation planning and help them develop future, high-quality grant subapplications. By increasing the amount of non-financial Direct TA, FEMA is helping build a pipeline of future BRIC projects within participating disadvantaged communities.
Additional Support for Disadvantaged Communities
BRIC, aligned with the Biden Administration’s Justice40 Initiative, seeks to prioritize assistance that benefits disadvantaged communities. To quantify this vulnerability, BRIC uses the Centers for Disease Control and Prevention (CDC) Social Vulnerability Index (SVI) tool to identify disadvantaged communities. Areas with an SVI score greater than or equal to 0.6 are considered disadvantaged. This year, the BRIC program modified its Economically Disadvantaged Rural Community (EDRC) technical evaluation criteria to include awarding 15 points to any community with a CDC SVI of 0.6 to 0.79. This helps to expand the communities that can receive points for these criteria even though they may not meet the limited EDRC definition (3,000 individuals and average per capita annual income that does not exceed 80 percent of the national per capita income). This change should make disadvantaged communities more competitive through the scoring process.
Additionally, due to limited capacity and funding, the BRIC subapplication poses a challenge for disadvantaged communities. Developing a high quality subapplication is a time intensive process which favors well-resourced subapplicants. This year, FEMA is allowing entities to apply on behalf of EDRCs. States, local governments, special districts, etc. will need a letter from the EDRC authorizing the applicant/subapplicant to submit the subapplication on their behalf, and the applying entity will be entitled to the 90 percent federal cost share (instead of 75 percent). This change allows for more resourced entities to apply the higher federal share and help communities that do not have the resources to navigate the complexities of the BRIC subapplication process.
Benefit Cost Analysis Support for Socially Vulnerable Communities
For years one and two, phased projects were competitive in BRIC. The first year, 12 of the 22 competitive mitigation projects were phased. For large-scale infrastructure, most jurisdictions do not have shovel ready projects sitting on the shelf. For disadvantaged communities, design, and environmental and historic preservation (EHP) can pose significant financial barriers to shovel readiness. To further assist disadvantaged communities, subapplicants with a phased project and an SVI score greater than 0.80 will receive assistance from FEMA for the preliminary Benefit Cost Analysis (BCA). While more guidance is needed from FEMA on this, we understand this to mean that FEMA will assist a disadvantaged community with their subapplication BCA. If the subapplication does not yield a cost-effective phased project, FEMA will not select a project for funding (e.g., a project with a benefit cost ratio over 1.0). Given that the BCA is traditionally one of the greatest hurdles in the Hazard Mitigation Assistance (HMA) program, this assistance to disadvantaged communities could be a substantive boost for the success of their subapplication.
Combating Climate Change
The other key initiative in BRIC this year is a stronger emphasis on confronting climate change. Two new focuses in BRIC 2022 are:
- Consideration of the amount of carbon emissions generated by the hazard mitigation project(s); and,
- Utilization of available data to consider the effects of climate change, including but not limited to high winds and continued sea level rise; duration and intensity of precipitation events; and exposure and sensitivity to extreme temperatures on heat, drought, and wildfire.
The NOFO also encouraged the use of environmentally friendly construction practices when completing BRIC hazard mitigation projects.
To be competitive as a climate adaptive project, the subapplication should also highlight:
- Nature-based solutions to climate impacts (sea level rise, drought, more precipitation, more frequent storms);
- Recognition of future conditions (climate, demographic, population, land use changes); and,
- Ancillary benefits (water/ air quality, habitat creation, energy efficiency, economic opportunity, reduced social vulnerability, reduced carbon emissions, cybersecurity, cultural resources, public health, mental health).
Where Funding, Equity, and Climate Change Align
It is okay to admit that many were unsure how BRIC would assist communities build resilience after the results of year one – 22 competitive project selections; only two of which were small, impoverished communities. Yet, the unprecedented $2.3 billion in funding for FY 2022, combined with the multiple layers of changes for equity, and a renewed emphasis on climate adaptive projects; BRIC 2022 is a true opportunity to help communities, including disadvantaged communities, take advantage of mitigation funding. This is the program and now is the time – “Carpe Diem” (Seize the day), mitigators!
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.