BRIC FY 2022 Notice of Funding Opportunity: Targeting Equity and Climate Change

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.

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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.

Increasing Access and Equity to FEMA’s Enhanced Flood Mitigation Assistance Program

The Flood Mitigation Assistance (FMA) Program is the Federal Emergency Management Agency’s (FEMA) primary grant program for addressing flood risk to vulnerable National Flood Insurance Program (NFIP) properties. The recently signed Infrastructure Investment and Jobs Act (2021) (IIJA) appropriated $3.5 billion to the National Flood Insurance Fund for the FMA program. This breaks down to $700 million over the next five years, starting with fiscal year 2022. This is a significant investment on FEMA’s behalf to provide funding to reduce the number of properties currently at risk of flooding and reduce the number and value of future claims to the NFIP.

In addition to the funding, FEMA is challenged to consider if the dollars are truly reaching the most vulnerable communities and how the additional funding will ultimately reduce their risk. The highest priorities for FEMA should be streamlining and improving the program, continuing to add benefit for disadvantaged communities, as well as an enhanced focus on climate adaptive projects. If these priorities are addressed, FEMA may see a more equitable FMA program that flourishes in benefit of disadvantaged, flood-prone communities nationwide.

History of FMA funding

As a result of the Biggert-Waters Flood Insurance Reform Act of 2012, the primary source of funding for FMA has been NFIP premiums. As such, the primary goal of the FMA program has been to award projects with the greatest potential to maximize savings to the NFIP principally through mitigation projects that protect or remove Severe Repetitive Loss (SRL) and Repetitive Loss (RL) properties from flood hazards. FEMA uses the SRL list as its primary source of eligibility information, despite this list being fraught with inconsistencies and outdated information.

Repetitive Loss (RL): A property that has incurred flood related damage on two occasions, in which the cost of the repair, on the average, equaled or exceeded 25 percent of the market value of the structure at the time of each such flood event.

Severe Repetitive Loss (SRL): A property that has had four or more separate NFIP claims payments have been made with the amount of each claim exceeding $5,000 (including building and contents), and with the cumulative amount of claims payments exceeding $20,000; or two or more separate claim payments (building payments only) where the total of the payments exceeds the current value of the property.

As reported by the Department of Homeland Security, Office of Inspector General (OIG) in 2020, $1.09 billion was allocated in FMA grants from 2013 to 2019. Since 2013, demand for this funding source has exceeded available funds (Figure 1). In 2020, FMA received $477 million in applications, more than double the amount allocated, which demonstrates an increased need for mitigation dollars that were, until this point, not made available for flood ravaged communities. Additionally, the report found that, on average, FMA projects took 2.7 years to complete from the date of application submission. For a household whose home is no longer habitable, 2.7 years is unacceptable.

Figure 1 FMA Applications compared to Available Funding (2013-2020)

This figure was adapted from a DHS OIG Report (OIG-20-68, 2020), p. 5

Types of projects historically funded by FMA

The primary objective of the FMA program is to reduce or eliminate flood risk to SRL and RL properties by providing mitigation funding opportunities to address these vulnerabilities. To further incentivize the mitigation of these properties, the FMA program covers 100 percent of costs for the mitigation of SRL properties and 90 percent of costs for the mitigation of RL properties. Individual flood mitigation measures—largely property acquisitions and structure elevations are the majority of the projects funded under FMA. Between 2013 and 2019, the FMA program invested $328 million in the acquisition of real property and $428 million in the elevation of private structures. Other project types received substantially less funding (Figure 2).

Figure 2 FMA Federal Share by Project Type (2013-2019)

Where are FMA funds allocated?

States with the highest number of NFIP properties, and especially SRL and RL properties, receive the most FMA funding historically. From 2013 to 2019, Texas, Louisiana, and New Jersey received the most FMA funding (Figure 3), which is consistent with the location of SRL properties. One of the outliers is Mississippi, which has a high number of SRL properties, but reports no FMA funding in those years. Which brings us to a challenge of the FMA program – why are some communities, with demonstrable need, underrepresented in the distribution of FMA grants?

Figure 3 FMA Federal Share Awarded by State (2013-2019)

Figure 4 Total Number of SRL Properties by State (as of March 2019)

FMA Program Obstacles

Application Submission and Project Cost Effectiveness

To begin with, the complexity of the grant application process and significant resources needed at the local government level to develop those applications discourage many communities from applying. These challenges contribute to either state or local decisions not to pursue FMA and their ability to be successful in obtaining funding.

FEMA’s FMA program, as with the Building Resilient Infrastructure and Communities (BRIC) and Hazard Mitigation Grant Program (HMGP) grants, requires a very thorough and complex application to be submitted for the national competition, most of which is hard for communities to navigate on their own.

The FMA application also involves a Benefit-Cost Analysis (BCA) to evaluate if the risk reduction benefits of the project outweigh the costs to implement the project (e.g.,, buyout, elevate or otherwise mitigate the at-risk buildings). FEMA has taken steps to streamline cost-effectiveness by making revisions to the value of pre-calculated benefits. Pre-calculated benefits simplify the BCA for many individual flood mitigation projects by providing a standard value for benefits rather than requiring the community to conduct a full BCA.

Paperwork Overload

Another challenge to participation in the program is the burden to individual property owners. For example, the documentation burden can be significant since some of the households may not have NFIP documentation readily available. Further, property owners can be subject to prohibitive upfront or out-of-pocket costs—especially for elevation projects. This is acutely true in communities with socioeconomic disadvantages and in areas that have experienced repeated flood events. Elevation projects will often require the property owner to obtain property surveys, design plans, elevation certificates, and other technical information that must be submitted during the application process. In addition to documentation collection, as noted by the 2020 OIG report, property owners are often subject to a long waiting period before their home is purchased or mitigated.

Ultimately, property owners depend on the willingness and ability of state and local officials to participate in the FMA program. Without assistance to local jurisdictions to prepare project applications, mitigation of these at-risk properties and communities will continue to be slow and inequitable.

Closing the gap: Getting funding to communities in need

With the bump in funding that FMA is receiving through the IIJA, will necessary funding reach those communities that have been left out or underrepresented in the program? Mitigation across flood prone American communities is only going to become more urgent as the impacts of climate change worsen. These impacts will impact disadvantaged communities in disproportionate ways so the more we invest today, the better. Mitigation saves $6 on average for every $1 spent on federal mitigation grants.

With the Biden Administration’s Justice40 Initiative (Executive Order 14008), the FMA FY2021 program intends to prioritize projects that benefit disadvantaged communities. The FMA Notice of Funding Opportunity for FY21 grants includes additional scoring points for Project Scoping and Community Flood Mitigation Projects that benefit disadvantaged communities (as measured by the Centers for Disease Control and Prevention (CDC) Social Vulnerability Index).

In addition to the changes from the Justice40 Initiative, the IJIA expanded the federal cost share to 90 percent for a property that 1) is located in a census tract with a CDC SVI score of not less than 0.5001 or 2) serves as a primary residence for individuals with a household income of not more than 100 percent of the applicable median income.

To utilize this new funding in the most equitable way, several key areas can be improved to further the goals of the FMA program.

FEMA can provide communities accurate NFIP and SRL data more readily.
FEMA can incentivize homeowner participation by streamlining the application review and award process.
States can improve their subapplicant outreach to reduce ineligible or non-competitive projects and improve the viability of FMA subapplications submitted.
FEMA, state, and local governments can make equitable choices in prioritizing projects (e.g., prioritizing primary residences over secondary or income properties).

What’s next?

Interested states and communities should prepare for this upcoming funding by beginning outreach to communities to understand need and level of interest in participation and to provide technical assistance if needed. Additionally, states that have received FMA funding in the previous year can apply for FMA’s Technical Assistance program which provides funding to states to maintain a viable FMA program over time

As with the BRIC program and HMGP, FMA offers funding for Project Scoping activities. The funding caps are $300,000 for individual flood mitigation projects (e.g., acquisitions, elevations, mitigation reconstruction) and $900,000 for community flood mitigation projects. For individual flood mitigation projects, a community could apply for Project Scoping to conduct homeowner outreach, identify priority project areas, develop a Benefit-Cost Analysis, assist homeowners with documentation collection, and develop a complete FMA application. A similar strategy applies to project scoping for community flood mitigation projects.

Conclusion

As our climate continues to change, the importance of this funding cannot be overstated; and by ensuring all communities in need receive this funding, we are collectively buying down our risk to future disaster impacts. Furthermore, reducing or eliminating current barriers to entry into the program will help ensure funding reaches those who need it most, when they need it.

Vanessa Castillo is a mitigation and planning consultant with 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 Hazard Mitigation Grant Program (HMGP) for Colorado’s largest disaster.

Lauren Dozier is a Senior Managing Associate and a subject matter expert (SME) in disaster recovery. Lauren has spent the past 11 years in preparedness, mitigation, and FEMA Public Assistance (PA). Her knowledge and experience of financial recovery has assisted communities nationwide to recover from and prevent future disasters.

Amelia Muccio is the Director of Mitigation at Hagerty Consulting and a SME 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.

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Flooded with FEMA Mitigation Funding: Can We Spend It?

Earlier this month, the Biden Administration announced an unprecedented commitment of $3.46 billion of the Federal Emergency Management Agency’s (FEMA) Hazard Mitigation Grant Program (HMGP) funding for the 59 major disaster declarations for COVID-19. The top ten recipients are:

COVID-19 FEMA HMGP Allocations

Recipient	Total
Texas	$666,134,283
California	$484,383,864
New York	$378,128,107
Florida	$185,056,086
New Jersey	$148,647,976
Washington	$113,424,988
Massachusetts	$110,760,576
Maryland	$93,289,392
Georgia	$78,691,416
Louisiana	$78,005,056

Additionally, the Administration announced $1 billion for the Building Resilient Infrastructure and Communities (BRIC) program and $160 million for the Flood Mitigation Assistance (FMA) program. The nearly $5 billion of funding is to assist states, territories, and tribes to maximize their investment in mitigation, address the growing climate change crisis, and prioritize underserved communities.

HMGP is a statewide competitive grant program while BRIC and FMA are nationally competitive grant programs.

	Flood Mitigation Assistance (FMA)	Building Resilient Infrastructure & Communities (BRIC)	Hazard Mitigation Grant Program (HMGP)
Purpose	FEMA managed, State administered program and not directly tied to a disaster declaration; reduce NFIP claims	FEMA managed, State administered program and not directly tied to a disaster declaration; high-impact, neighborhood scale projects	State administered program and directly tied to a disaster declaration; break cycle of repetitive losses
Cycle	Annually	Annually	Post-Disaster
Local Match	0%, 10%, or 25%	At least 25% or 10% for economically disadvantaged rural communities	25%
FY 2021 Funding (Federal Share)	$160M Nationwide Nationally Competitive	$1B Nationwide Nationally Competitive	$3.46B for COVID-19 State Competitive

HMGP

FEMA announced all 59 states, tribes, and territories that received a major disaster declaration in response to the COVID-19 pandemic will be eligible to receive 4 percent of those disaster costs to invest in mitigation projects that reduce risks from natural disasters. Though the dollar amounts vary, the overall intent of the HMGP funding is clear – develop innovative mitigation projects that reduce the impacts of climate change.

BRIC

Earlier this week, FEMA released the Notice of Funding Opportunity (NOFO) for BRIC 2021. Based on lessons learned from the inaugural grant cycle, FEMA made some integral changes to the program to incorporate not only high-impact, neighborhood scale infrastructure projects, climate change, and increased emphasis of nature-based solutions, but, increasing and restructuring the funds to address the most vulnerable populations through the Justice40 Initiative. This initiative mandates that 40 percent of the BRIC funding benefit disadvantaged communities.

FEMA will distribute up to $1 billion through the BRIC program using the following approach:

State/ Territory Allocation: $56 million (up to 1 million per applicant). All 50 States, the District of Columbia, and U.S Territories may apply under the State/Territory Allocation. This includes Capability and Capacity Building (C&CB) activities (project scoping, partnership, building codes, and planning).
Tribal Set-Aside: $25 million, and all federally recognized Tribal Governments may apply under the Tribal Set Aside.
National Competition for Mitigation Projects: Approximately $919 million and any funds that are not awarded from the State/Territory Allocation will be re-allocated to the national competition.

FMA Program

FMA provided annual funding to eligible states, local communities, tribes, and territories to reduce or eliminate the future risk of flood damage to structures insured under the National Flood Insurance Program (NFIP). The $160 million is distributed through the FMA program by allotting the funds in five categories:

Up to $10 million: Project Scoping – funding for developing community flood mitigation projects or individual mitigation projects.
Up to $70 million: Community Flood Mitigation Projects to address community flood risk projects on a larger scale.
At least $80 Million: For technical assistance; flood hazard mitigation planning; and individual flood mitigation projects.

The Growing Mitigation Backlog

While these three funding streams (HMGP, BRIC and FMA) are providing communities with an unprecedented mitigation opportunity, how quickly should communities expect to have funding in hand and a shovel in the ground?

We analyzed FEMA’s Open Data Set for HMGP funding from 2010 to 2021 and only a little more than half of all awarded projects have been implemented and closed out. Much of the funding that was originally allocated for HMGP has not been spent which means that projects are either not being implemented, being deemed ineligible, or extremely delayed. In total, over $9 billion dollars in previously allocated HMGP funding remains unspent. Moreover, when examining the time spent from award to closeout, over 1,200 projects took over five years to be implemented.

FEMA Dataset HMGP Allocations 2010-2021
Total Number of HMGP Projects Awarded	9433
Total Dollar amount of HMGP Projects	$11,242,345,406.79
Total Number of Open (Approved) HMGP Projects	4411
Total Dollar Amount of Open HMGP Funding	$9,258,651,730.99
Total Number of Closed HMGP Projects	5022
Total Dollar Amount of Closed HMGP Funding	$1,983,693,675.80

This analysis reflects a grant program that is complex and complicated. While funding may be allocated, it does not necessarily demonstrate that projects are being implemented and/or constructed in a timely manner. FEMA’s mitigation funding is meant to save lives and protect critical infrastructure, which are urgent priorities that need quicker mitigation interventions. Furthermore, climate change is a pressing problem that requires a timely mitigation response. Yet, the fact is, we are still implementing and spending funding from legacy disasters including Hurricanes Katrina (2005) and Sandy (2012). Accordingly, this new mitigation funding, while incredibly helpful and needed, will tack on billions more in funding to an already significantly backlogged system.

How Can the This Funding Be Expedited?

To spend the funding quicker, it would require a commitment and change at every level of government and to the Hazard Mitigation Assistance (HMA) program.

Subapplicants

Subapplicants should thoroughly analyze projects for potential pitfalls, including potential Duplication of Programs (DOP) issues; Benefit-Cost Analyses (BCAs) which are reliant on questionable benefits to be cost-effective; as well as Environmental and Historic Preservation (EHP) considerations which may delay or render the project infeasible. Subapplicants should be transparent regarding any easements, public opposition, or other obstacles which may not be readily apparent in the subapplication materials so applicants can fully assess, evaluate, and subsequently inform subapplicants on the project’s viability. To accomplish these goals, subapplicants should consider taking the following steps:

Meet with your State Hazard Mitigation Officer (SHMO) and participate in State sponsored mitigation outreach and webinars.
Engage stakeholders and partners in advance of project development including the community for needed project buy-in; include securing a project champion to assist the project from beginning to end – project scoping to closeout.
Utilize pre-award costs to scope out potential mitigation projects including the development of planning and feasibility studies.
Frontload projects with detailed environmental and historic preservation (EHP) analyses including desk reviews for natural and cultural resources.
Submit credible subapplications (including a well-documented BCA), otherwise the State or FEMA may need to phase your project or send requests for information (RFIs) which can impede progress.
Fully utilize management costs to successfully implement your awarded project.

Applicants

Applicants play a key role in providing technical assistance and support to subapplicants as they navigate these complex and resource intensive programs. Applicants who can provide proactive and ongoing support to subapplicants as they scope, apply for, and manage awarded grant funding, greatly increasing the subapplicant’s chances of successfully implementing and closing out the project. Some important steps Applicants can take include:

Establish a continuous mitigation outreach program that engages partners during blue skies, as well as, during disasters.
Educate subapplicants on the State’s mitigation priorities which includes publication of state-sponsored mitigation materials to educate and inform subapplicants applying for funding.
Utilize Advance Assistance funding to build a pipeline of future shovel ready projects or to address gaps in the program (e.g., create a BCA for heat mitigation).
Conduct project scoping calls with subapplicants interested in the HMA program and/or have a potentially eligible mitigation project.
Utilize the Notice of Intent (NOI)/Letter of Intent (LOI) (screening process) to weed out ineligible projects.
Consider establishing a global match funding strategy to assist economically disadvantaged subapplicants who may lack the needed local match funding.
Perform detailed programmatic, feasibility, cost-effectiveness, and EHP reviews of the subapplications before sending them to FEMA.
Inform subapplicants of procurement requirements outlined in 2 CFR 200 as procurement violations are one of the most common reasons FEMA deobligates funding.
Fully utilize management costs to build capacity and to provide robust support to subapplicants.

FEMA

Update the current 2015 HMA Guidance to reflect the new reality of mitigation and resiliency efforts and community needs.
Re-evaluate cost effectiveness policies considering equity, climate change priorities, and the need to provide more quantitative approaches for ancillary benefits such as carbon sequestration, watershed protection, and water quality improvement.
Expand guidance and eligible activities for other mitigation activities including drought, heat, and wildfires.
Expand direct technical assistance (TA) to States and subapplicants (feasibility and cost-effectiveness support); consider a special TA outreach and subapplication development track that targets economically disadvantaged communities.
Gain efficiencies in the RFI process to help streamline the post-subapplication submission.
Establish more programmatic agreements for EHP review for multiple project activities.
The BCA is proving to be an insurmountable and inequitable obstacle for resource constrained subapplicants and innovative climate adaptive projects (inherent equities and outdated methodologies), FEMA should consider reducing the discount rate to a more relevant rate to relieve this burden.
Invest in mitigation personnel to develop the next generation of mitigation subject matter experts (SMEs) capable of reviewing/evaluating subapplications and BCAs and can support subapplicants and applicants as they implement this program.

The Way Forward

Communities, and specifically mitigation practitioners, have an opportunity to plan, design, and construct vital infrastructure and community mitigation projects given this new infusion of mitigation funding. The burden though, lies with helping streamline the current processes, and assist one another to succeed in implementing current and future projects in a timelier manner so that we can truly thwart the impacts we all face given the ever-present and growing threat of climate change.

Amelia Muccio is the Director of Mitigation at Hagerty Consulting and a SME 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.

Lauren Dozier is a Senior Managing Associate and a subject matter expert in disaster recovery. Lauren has spent the past 11 years in preparedness, mitigation and Public Assistance (PA). Her knowledge and experience of financial recovery has assisted communities nationwide to recover from and prevent future disasters.

Want to know more about FEMA mitigation programs?

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The Results Are In: Inaugural BRIC Grant Selections and What Comes Next

On Thursday, July 1, 2021, the Federal Emergency Management Agency (FEMA) announced the selection the subapplications for the $700 million being made available in fiscal year 2020 (FY20) for Building Resilient Infrastructure and Communities (BRIC) and Flood Mitigation Assistance (FMA) grant programs. These competitive programs provide funding to states, tribes, territories, and local governments for eligible mitigation activities – ultimately aimed at reducing disaster losses and protecting life and property from disaster-related damages.

In its inaugural funding cycle alone, BRIC increased the nation’s investment in pre-disaster mitigation to $500 million and the individual project cap to $50 million – a dramatic increase from the $4 million cap for mitigation projects and $10 million cap for resilient infrastructure projects under the PDM program. BRIC, unlike its predecessor, the legacy FEMA Pre-Disaster Mitigation (PDM) program, provides more meaningful and significant funding opportunities for high-impact infrastructure and community-based projects.

In total, 22 BRIC projects were competitively selected this cycle and the projects chosen are from nine states plus the District of Columbia (D.C.), totaling $377.7 billion. Hagerty assisted several applicants and subapplicants with their BRIC projects in FY20, ultimately helping submit nearly $1 billion of BRIC subapplications for FEMA review. Based on this experience, below are some of our key takeaways and lessons learned from BRIC this year as well as recommendations that are applicable during the next funding cycle.

Key Takeaways

The Success of Climate and Code Adoption

In the era of climate change, we should be pleased that 18 of the 22 competitive BRIC projects selected by FEMA included nature-based solutions into their mitigation projects. In fact, nature-based solutions, part of the technical scoring criteria, appears to be one of if not the most influential factor in project selection.

Second to nature-based mitigation, the competitive projects selected are from Applicants that have adopted the 2015 or 2018 versions of the International Building Code and the International Residential Code. Most, but not all, of the Applicant localities have a Building Code Effectiveness Grading Schedule (BCEGS) rating at or below 5, likely indicating that the chosen subapplicants have a similar BCEGS ratings; however subapplicant BCEGS rating are confidential. In the technical scoring criteria, subapplicants could receive up to 35 points for robust code adoption measures; accordingly, those with stronger building codes excelled during the selection process.

Small, Impoverished Communities

Additionally, we know BRIC funding is on the rise with the hope of providing greater support to small, impoverished communities. Last May, FEMA announced that $1 billion will be made competitively available under the BRIC program in 2021, with 40 percent being dedicated to supporting small, impoverished communities. Notably, this cycle, only two competitive projects selected by FEMA were designated as small, impoverished communities. The funding for these two projects totals approximately $24.7 million, or 7%, of the $377.7 million competitively available; yet, FEMA has signaled that the next round of BRIC funding will place greater focus on equity and disadvantaged communities.

What Comes Next?

All BRIC applications and associated projects were adjudicated into three categories: selected for further review, not selected, or did not meet Hazard Mitigation Assistance (HMA) requirements (ineligible). Wondering what this means and what to do next?

Selected for further review

Competitive mitigation projects, selected for further review, will likely be notified about the upcoming grant award once FEMA has completed the associated and required Environmental and Historic Preservation (EHP) review. Depending on the FEMA Region, EHP review and project approval can often be a lengthy process.

Not selected

Subapplicants with projects that were not selected should consider resubmitting in the next BRIC funding round or in the next available Hazard Mitigation Grant Program (HMGP) funding opportunity. If the project did not include green infrastructure or nature-based mitigation, subapplicants should evaluate if these features can be added to the project’s scope. It is sensible to assume that nature-based mitigation will be critical again in next year’s BRIC selection process.

Did not meet HMA requirements (ineligible)

If the project was deemed ineligible, subapplicants can contact their State Hazard Mitigation Officer (SHMO) and request the project’s National Technical Review (NTR) memo. This memo will assist in highlighting the eligibility, feasibility, and cost-effectiveness issues identified by the NTR and FEMA. Based on the memo’s findings, subapplicants can decide if the project can be fixed and resubmitted in the BRIC 2021 cycle.

BRIC 2021 and Beyond

The BRIC 2021 Notice of Funding Opportunity (NOFO) will likely be out next month and, given the tight turnaround, it is unlikely that many components of the program will change drastically. As applicants and subapplicants continue to scope potential projects for BRIC 2021, they should consider the following to best position projects for success.

Eligibility, feasibility, and cost-effectiveness. Eligible, feasible, and cost-effective projects are a recipe for HMA success and should not be deemed ineligible by FEMA.
Focus on nature-based solutions. Submit projects that have, at a minimum, a green/gray nexus or components of nature-based mitigation features. More information on how to incorporate these features can be found here.
Maximize the technical and qualitative scoring rubrics. This will help ensure that your project is competitive.
Give your project a descriptive title. This is the first thing a reviewer likely reads and encourages them to take a deeper dive.
Obtain and analyze your BCEGS rating. If your current BCEGS rating is over a 5, contact ISO to determine ways to lower the rating.
Establish public-private partnerships. These can help provide an increased local share match making your project potentially more favorable upon review.
Consider project phasing. Submitting the most credible project possible is important; therefore, if your project is in a preliminary design phase, consider submitting a phased project proposal. 12 phased projects were selected in BRIC 2020.
Advocate for your local jurisdiction. If your local jurisdiction has adopted the 2015/2018 IBC/IRC code and the State has not, reach out to your SHMO and/or FEMA Region to discuss if an exception can be given and the 20 points can be awarded for your subapplicant project(s).

Additionally, FEMA just announced their 2021 BRIC and FMA Program Webinar Series which begins on July 28 and will continue throughout October. During these sessions, FEMA will bring subject-matter experts and partners together to provide technical information, best practices, tools, and resources regarding these grant programs. The webinars are designed for leaders in states, local communities, tribes, and territories, as well as private sector entities, private non-profit organizations, and individuals interested in learning more about the BRIC and FMA grant programs and strategies for how to apply for them. All sessions will be recorded and posted to FEMA’s YouTube channel.

Conclusion

While this year’s BRIC competitive grant funding selections were limited to nine states and D.C., we need to remember it was the inaugural grant cycle for this promising funding stream. All that worked in support of BRIC projects – FEMA, States, tribes, subapplicants, and mitigation practitioners alike – learned valuable lessons during the process. Now, it is important to harness those lessons learned to include creating a more equitable approach to improve the resilience of communities. As we face the impacts of climate change and acknowledge that climate change is disproportionately impacting underserved communities, we need to ensure that moving forward, this critical funding stream is obtainable for all.

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The Secret to Mitigation Success: Management Costs

Anyone who has applied for Hazard Mitigation Assistance (HMA) grants knows application submission is only half the battle. Administering and implementing the grant successfully can be even more challenging. As with all federally funded programs, there are fiscal and compliance requirements that must be met to prevent jeopardizing grant recoupment. Document retention, file management, procurement, and expenditure tracking can all be heavy lifts for both states and local jurisdictions. Additionally, managing the actual project to meet all program requirement – i.e. project timelines, budget, and cost share – can be burdensome if the right resources are not in place.

What are management costs?

Historically, the Hazard Mitigation Grant Program (HMGP) offered each grant recipient (State, Territory, or Federally Recognized Indian Tribes) 4.89 percent of their HMGP total to manage the grant itself. The recipient had the option to pass down a percentage of management costs to their sub-recipients at the local level; however, most opted not to because the 4.89 percent was already not enough to manage the program themselves at the recipient level.

With the passage of the Disaster Recovery Reform Act (DRRA) in October of 2018, recipients are now eligible for up to 10 percent of the total HMGP amount for management costs. Not only did the DRRA benefit the recipient, but it also provided sub-recipients the opportunity to apply for up to five percent of their total project costs for management costs. The management costs are reimbursable to both the Recipient and Sub-recipient at 100 percent federal share, meaning there are no out-of-pocket costs for the applicable State or local jurisdiction.

Grant Management through Management Costs

Management costs are designed to be utilized by grant recipients and sub-recipients to manage the HMA grant itself versus managing the actual project (e.g., project management). This helps curtail the financial burden associated with grant management at the state and local level, thereby ensuring more effective and efficient grant management and successful mitigation projects reaching completion in a more fiscally responsible and timely manner.

Examples of Eligible Management Costs include:

Application development, including the benefit-cost analysis (BCA),
Preparing quarterly reports,
Processing payments,
Relevant training and site visits,
Preparing closeout documentation, and
Staff salary or consultant costs directly related to performing the activities listed above.

FEMA BRIC Program Technical Assistance: Source

Management Costs and BRIC

With the Federal Emergency Management Agency (FEMA) Building Resilient Infrastructure and Communities (BRIC) Program application period now open, proper grant management is even more important as these complex projects may be higher in dollar value. Applicants (states) and sub-applicants selected for BRIC funding are also eligible for 10 percent and 5 percent management costs, respectively; however, applicants must apply for management costs in a separate application. Sub-applicants should include management costs in the application as a line item in the budget and describe how the funds will be spent in the scope of work.

Hagerty Can Help

Our professionals are experts in navigating the pre- and post-disaster funding world with significant experience applying for, managing, and closing out mitigation grant programs for our clients. Management costs can be used to pay for our expertise at no cost to the applicant or sub-applicant.

We are available to talk about your recovery needs, including how to get the right people in the room and access all funding available through federal grant programs. To learn more, contact Hagerty’s Mitigation Team.

LISTON CONRAD is a Senior Recovery Manager at Hagerty Consulting with experience in the implementation of FEMA mitigation and Public Assistance (PA) programs along with housing and infrastructure programs funded through Community Development Block Grant – Disaster Recovery (CDBG-DR). With over 10 years’ experience in the disaster recovery environment, Liston has assisted the states of Mississippi, Colorado, North Carolina, Texas, and California navigate the complexities that disasters bring, including Wildfires, hurricanes and extreme Floods.

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.

Mitigation’s “Green New Deal”: Nature-Based Solutions

Currently, two tropical systems are eyeing the United States (U.S.) Gulf Coast for near simultaneous landfall this week. In the West, California is dealing with significant drought, extreme heat, and escalating wildfires. Each year, storms and fires continue to intensify – both in frequency and magnitude. The impacts of climate variability and disaster activity further highlight the need for nationwide investments in resilience – including a holistic, sustainable approach to hazard mitigation – to reduce continued disaster-related damages and loss.

Nature-Based Solutions

Nature-based solutions may be used in sustainable planning, design, environmental management, and engineering practices to incorporate a community’s natural features, landscape, or processes into the built environment to create a more resilient environment. The overarching goal of these projects is to provide more value to communities by mitigating hazards while also creating ecosystem benefits. This can ultimately improve a community’s quality of life and make it more attractive to new residents and businesses.

Nature-Based Solutions are categorized by both location and scale:

Watershed and Landscape – These typically include large-scale practices that require long-term planning and coordination, including projects with interconnected systems of natural areas and open space. Examples: land conservation, greenways, wetland restoration and protection, stormwater parks and floodplain restoration
Neighborhood or Site – These practices can often be built into a site, corridor, or neighborhood without requiring additional space. Examples: rain gardens, vegetated swales, green roofs, rainwater harvesting, permeable pavement, tree canopy, tree trenches, and green streets.
Coastal Areas – Projects that stabilize the shoreline, reduce erosion, and buffer the coast from storm impacts to support coastal resilience. Examples: coastal wetlands, oyster reefs, dunes, waterfront parks, and living shorelines

Integrated Approach to Hazard Mitigation

Planning and carrying out nature-based solutions can require an integrated approach to hazard mitigation. Since nature-based solutions provide a variety of co-benefits, a single project may be eligible for many different private, state, and federal grant programs. It is important to assess what types of nature-based projects would benefit your community, then identify available public funding opportunities, to include both federal and private investment. Additionally, pooling resources may be a cost-effective way to integrate nature-based solution practices into planned or ongoing capital improvement projects including creating or improving roads, streetscapes, stormwater management projects, parks, and parking areas. Throughout this process, cost savings may also be realized as nature-based solutions cost less than alternative investments – often lessening the necessity of standalone infrastructure projects and further reducing the expense of rebuilding and repairs after a disaster.

Nature Based Solutions in BRIC

In the Federal Emergency Management Agency’s (FEMA) recent Building Resilience Infrastructure and Communities (BRIC) Notice of Funding Opportunity (NOFO), the agency encourages communities to consider environmentally friendly, green infrastructure solutions as eligible project types. While nature-based solutions have many hazard mitigation benefits, they can also enhance resilience by helping a community meet its social, environmental, and economic goals.

In FEMA’s BRIC NOFO, the agency outlines two evaluation criteria for BRIC projects: technical criteria (all or nothing scoring) and qualitative criteria (gradient scoring scales). The technical criteria specifically promote sustainability, giving sub-applicants the potential to secure an additional 10 points when proposed projects include nature-based solutions. In addition, if a project addresses infrastructure and has an increased non-federal cost share due to private investment or other pooled state, local, or private resources, a sub-applicant may earn an additional 25 points. As written, we think the use of nature-based solutions provides applicants a competitive advantage for BRIC funding prioritization. This critical funding will provide leaders across the country with a more integrated way to mitigate against the impacts of disaster; while also encouraging communities to invest in our nation’s long-term sustainability, security, and strength.

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.

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Sara Harper is a civil engineer and certified floodplain manager with experience in the implementation of the FEMA mitigation programs. Before joining Hagerty, she was a project manager for Dewberry Engineers Inc., managing environmental and historic preservation compliance task orders for FEMA Region IX. Prior to Dewberry, she was a water resources engineer working on complex water systems in California, Oregon and Nevada for local, state, and federal interests.

Building a Pipeline of Shovel-Ready Mitigation Projects: BRIC’s Focus on Capability and Capacity Building

Disasters cause substantial damage and disrupt socioeconomic activities in ways that we cannot fully measure. It is difficult to predict when disaster will strike your community next, but it is possible to prepare for it. To successfully enable large-scale infrastructure and mitigation projects, the Federal Emergency Management Agency’s (FEMA’s) new Building Resilient Infrastructure and Communities (BRIC) program, required a mechanism to create a steady pipeline of eligible, shovel-ready projects. Capability and Capacity Building (C&CB) – a new project type eligible for funding under FEMA’s BRIC program— does just that.

According to FEMA, the BRIC program seeks to fund effective and innovative projects that will reduce risk, increase resilience, and serve as a catalyst to encourage the whole community investments in mitigation. To support this goal, BRIC sets $600,000 in C&CB funding aside – per eligible applicant – to enhance mitigation expertise, knowledge, and practice at the state and local level. Eligible expenditures can include building code activities, partnerships, project scoping, mitigation planning, and planning-related activities. This funding is designed to result in a resource, strategy, or mitigation product that will ultimately reduce or eliminate risk and damage from natural hazards.

In the recent BRIC Notice of Funding Opportunity (NOFO), FEMA offers a broad definition of C&CB project eligibility. This will enable greater flexibility for states and local communities as they look to fund the development of mitigation solutions under the BRIC program as well as other federal mitigation programs, such as FEMA’s Hazard Mitigation Grant Program (HMGP), Flood Mitigation Assistance (FMA), and HMGP Post Fire. Given that BRIC is expected to be a significantly larger grant program than PDM; C&CB funding provides the necessary seed funding to jump start development of future projects and it appears FEMA is willing to provide the space for communities to appropriately identify their needs and do so.

UnSplash: Scott Graham

Additionally, when endeavoring on a new mitigation or infrastructure project, public awareness is key to highlighting the co-benefits of the project, such as environmental and economic impacts. Therefore, FEMA allows for up to 10 percent of a C&CB activity or mitigation project to be used for public awareness and education, such as: brochures, workshops, and videos.

C&CB projects will not require a Benefit-Cost Analysis (BCA). Generally, projects will be subject to a 75 percent federal, 25 percent state and local cost share; however, impoverished communities may be eligible for an increased federal cost share of up to 90 percent. While the $600,000 per applicant maximum award may not provide all the funding required to analyze, coordinate, design, and engineer a jurisdiction’s large infrastructure project, it is the first step in the process of building greater capacity to do so.

The BRIC application period opens on September 30, 2020 and closes on January 29, 2021; however, BRIC project applications will take a significant amount of time and resources to complete. We encourage potential applicants and sub-applicants to begin their planning efforts as soon as possible.

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 C&CB project. Therefore, our professionals can help at little-to-no additional cost.

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The Building Blocks of BRIC: Investing in Our Infrastructure

America’s infrastructure is in dire need of repair. One out of every five miles of highway pavement is in poor condition; and, one in nine bridges in the United States (U.S.) is rated structurally deficient. Moreover, the average age of the nation’s 614,387 bridges is over 50 years old. The American Society of Civil Engineers (ASCE) estimates that by 2025, “aging and unreliable” infrastructure will cost American businesses $7 trillion in lost revenue. In addition, large scale disasters further exacerbate America’s aging infrastructure, especially critical infrastructure.

Critical infrastructure is defined as the assets, systems, and networks essential to societal and economic functions. In 2017, after heavy rainfall, 180,000 California residents were evacuated due to spillway damage at the Oroville Dam. The following year in California, aging PG&E hardware broke loose during heavy winds and resulted in the 2018 Camp Fire. On the East Coast, New York City is still recovering from Hurricane Sandy in which more than 8 million customers lost power and more than half a million homes were destroyed, resulting in more than $65 billion in damages.

For decades, short-term or minimal repairs have served as band aids that keep our aging bridges, tunnels, subways, and electrical grids in operation – but this is not a cost-effective long-term solution.

Tyler Nix: Source

Investing in our infrastructure and lifelines

The Federal Emergency Management Agency’s (FEMA’s) Building Resilient Infrastructure and Communities (BRIC) program creates an annual funding opportunity to make critical investments in infrastructure systems and create system-wide improvements that will help communities withstand the impacts of more frequent and severe natural disasters. BRIC replaces the Pre-Disaster Mitigation (PDM) program and refocuses mitigation efforts on strengthening core infrastructure sectors, such as water and wastewater, transportation, energy, communications, public health and several others. BRIC’s funding structure will enable high-impact investments with a focus on public infrastructure and critical services and facilities.

As outlined in FEMA’s Notice of Funding Opportunity (NOFO), eligible applicants states, territories and federally-recognized tribes may submit an unlimited number of mitigation project subapplications, each valued up to $50 million in federal share (75 percent of total project cost). This is a significant increase from the $10 million federal share cap under FEMA’s PDM Resilient Infrastructure program in 2019. Moreover, the BRIC NOFO creates a $600,000 state/territory and tribal set-aside for Capability- and Capacity-Building which includes project scoping activities. This set-aside alone is a crucial funding source for communities that have identified weaknesses in their infrastructure systems but require financial assistance with the technical studies, engineering, and alternatives analyses needed to support project development.

The technical criteria identified in the BRIC NOFO further solidifies the program’s prioritization of public infrastructure projects and focus on bolstering community lifelines – systems that enable continuous operation of critical government and business functions within a community. A project that addresses infrastructure and mitigates risk to one or more community lifelines may earn up to 35 points of 100 points enumerated under the Technical Evaluation Criteria for the National Competition.

BRIC NOFO: Source

A time for action

Now is the time for communities to invest in their future. Events such as the collapse of the Interstate 35W Bridge in Minneapolis in August 2007 stand as stark reminders of the need to invest in aging public assets and the potential consequences of decades of neglect. These are the systems and lifelines that transport communities, provide potable water to families, support health networks, ensure local and global communication, and power homes, schools, and other critical services.

Eligible applicants should start planning how they will promote the BRIC program to potential subapplicants. This includes developing solicitations for project applications (i.e. a Notice of Interest or Intent), publishing fact sheets and training material, and hosting webinars to review programmatic requirements and priorities. Interested subapplicants should review recent feasibility and planning studies to identify potential BRIC projects. Read more on identifying and screening projects on Hagerty blog on BRIC.

The BRIC program will provide communities with a funding source to proactively address deficiencies in their public infrastructure and community lifeline systems. Timely investments to rehabilitate infrastructure with an objective of creating a “resilient community” can result in an even higher return on investments. As John Roome, the World Bank’s Senior Director of Climate Change noted, investing in resilient infrastructure is not about spending more, but about spending better.

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.

Policy Analysis: Implementing BRIC in a COVID-19 World

As the response to COVID-19 continues to evolve, we are facing an unprecedented challenge nationwide. There are 56 active Presidential Disaster Declarations (all 50 states, five territories, and Washington DC) related specifically to the pandemic. Almost 1.2 million Americans are known to be infected and 68,000 have died (though the actual total numbers could be drastically higher). In some parts of the country, our healthcare system is on the brink of being overwhelmed, as hospitals report critical equipment shortages and face challenges balancing other medical care with COVID-19 treatment needs. Meanwhile, healthcare workers nationwide are suffering widespread layoffs, pay cuts, and furloughs as non-emergency and elective healthcare visits have been delayed or canceled. Without a viable vaccine or herd immunity, the country may be socially distancing to varying degrees for the better part of the next two years.

While heavily entrenched in organizing and implementing the nation’s response, the Federal Emergency Management Agency (FEMA) is being pressed by elected officials to allow for Hazard Mitigation Grant Program (HMGP) funding to be used for the COVID-19 Disaster Declarations. Using HMGP funding in this way would mark a paradigm shift – opening up funding beyond the program’s typical historic focus of floods, tornadoes, and earthquakes.

Though it may seem off-topic to consider long-term resilience in an immediate time of crisis, it is prudent to utilize a disaster event – no matter the hazard – as an opportunity to build back in ways that reduce future risk. Proactive investments to rehabilitate impacted communities while simultaneously mitigating risk increase the activities’ return on investment not only for natural hazards, but that which we face today. While the Hazard Mitigation Assistance (HMA) Program typically funds flood, tornado, wildfire, and earthquake project types, the current pandemic response underscores the mitigation funding opportunities for hardening or retrofitting of critical facilities, infrastructure, or other community assets vital to responding effectively to COVID-19 or similar infectious disease outbreaks.

In addition to these ongoing considerations related to HMGP and COVID-19, on April 10, 2020, FEMA released its draft policy for the new Building Resilient Infrastructure and Communities (BRIC) policy for public comment. The policy describes the new program which would supersede the existing Pre-Disaster Mitigation (PDM) Program as a major funding opportunity focused on investing in and strengthening the nation’s mitigation capabilities in order to protect communities and infrastructure. FEMA is accepting comments during a formal comment period ending on May 11, 2020.

The new grant program’s funding will be connected directly to expenditures made under Presidential Disaster Declarations. Given the scale of the COVID-19 pandemic and response, the annual funding for BRIC in 2021 could reach unprecedented levels. Communities seeking to leverage those funds can lean in by identifying and developing cost-effective and conceptually eligible projects to submit for funding through BRIC.

Annual Funding Amount

In addition to enacting various modifications to the program design and requirements, the Disaster Recovery Reform Act of 2018 (DRRA) authorizes FEMA to set aside up to six percent of total estimated disaster expenses associated with each Presidential Disaster Declaration to fund the BRIC Program. These funds will go into the National Public Infrastructure Pre-Disaster Mitigation Fund (NPIPDM), with the annual contributions fluctuating based on the number and cost of disasters in the prior year. Then, on an annual basis, FEMA will assess the total amount available in the fund and determine the total amount available through BRIC each year.
FEMA estimates that the annual contributions to the NPIPDM will be between $300-$500 million. This represents a significant increase in both projected amount available annually and the stability of annual award amounts. In contrast, PDM Program annual funding was determined by Congressional appropriations.

Notable Aspects of the Proposed Policy

There is no explicit mention of Advanced Assistance projects in the draft policy, which have been used in recent years to support the development of technically feasible, eligible, and cost-effective projects through PDM and HMGP. However, the draft policy does identify “Capability- and Capacity-Building Activities” as an eligible use of assistance. The functional design of this eligible use of assistance is ambiguous, but it may – in part – support a similar project pipeline for communities. Seed funding to develop future projects is critical to the success and longevity of BRIC.
The draft policy states that all projects planned to address structures in the Special Flood Hazard Area are contingent upon the jurisdiction participating in the National Flood Insurance Program (NFIP) and the property owner obtaining (if not already possessed) and maintaining flood insurance for the life of the structure. This requirement, which was notably not part of the PDM Program, would preclude mitigation projects from eligibility, regardless of the cost-benefit of the individual projects.
The draft policy includes (non-financial) technical assistance “to promote the program, identify potential projects, develop and review applications and mitigation plans, and provide training on grants management.” The specific nature of this technical assistance (availability, scope, request process, etc.) is not yet clear. Providing communities with clear guidance on strong resilient planning opportunities, such as developing, adopting, and implementing more modern or more resilient building code or enacting flood damage prevention ordinances, helps communities best integrate traditional planning with resilience-building.
Applicants may request Periods of Performance (POP) beyond 36 months at the time of application for “highly complex projects.” According to the draft policy, specific criteria for receiving approval for an extent POP will be detailed with other program implementation materials. This timeline represents increased flexibility and can help increase the viability of some larger or more interconnected projects.

How Hagerty Can Help

At Hagerty we have the expertise, passion, and commitment to assist you with FEMA hazard mitigation funding streams. Hagerty can assist communities to take advantage of the BRIC Program and help communities to further develop their projects into BRIC applications. Please reach out to Amelia Muccio to walk through the process and any mitigation projects that you might be considering. Please find more information about the BRIC funding in Hagerty’s overview below:

April Geruso is the Director of Resilience at Hagerty Consulting and a subject matter expert in preparedness, pre-disaster recovery planning, cost recovery, and community resilience. With nearly 15 years of experience in emergency management, April has led long-term recovery and resilience activities for disasters totaling $7.5 billion in damages, including recovery from the 2018 wildfires and hurricanes, and 2019 catastrophic flooding. She has also led pre-disaster recovery planning for multiple state and local governments, established protocols for cost recovery activities in New York City post-Hurricane Sandy, and consulted for federal planning efforts as a recovery expert. Prior to joining Hagerty, April served as the Deputy Director of Planning for the City of Philadelphia’s Office of Emergency Management, where she coordinated oversight and implementation of all City of Philadelphia emergency plans.

Michael Levkowitz is a Managing Consultant with Hagerty Consulting’s Preparedness Division with strategic expertise in mitigation planning and funding. Michael has served in a variety of roles supporting local, state, tribal, and federal agencies with hazard mitigation and long-term recovery planning, emergency preparedness, and risk communication. Following the 2019 disasters in Nebraska, Michael began supporting long-term recovery planning and the administration of HMGP funds in the state. Prior to joining Hagerty, Michael served as the Mitigation Strategist for Washington State Emergency Management Division, where he led the state’s effort to maintain and implement its Enhanced Hazard Mitigation Plan and support local jurisdictions and tribal communities in developing and adopting local and tribal hazard mitigation plans.

You can review our overview of BRIC Funding at:

Hagerty’s BRIC Funding Overview

You can review our Previous Blog Post at:

BRIC by BRIC – FEMA Invests in Pre-Disaster Mitigation

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A Multi-Pronged Approach for Equity

Increased Technical Assistance

Additional Support for Disadvantaged Communities

Benefit Cost Analysis Support for Socially Vulnerable Communities

Combating Climate Change

Where Funding, Equity, and Climate Change Align

Hagerty Can Help

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HMGP

BRIC

FMA Program

The Growing Mitigation Backlog

How Can the This Funding Be Expedited?

The Way Forward

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Key Takeaways

What Comes Next?

BRIC 2021 and Beyond

Conclusion

MISCELLANEOUS project types

Mitigation to Migration

All-Hazards Adaptability

Flexibility for Future Conditions

Expedited Funding Opportunities

Recommendations for 2020 and Beyond

Nature-Based Solutions

Integrated Approach to Hazard Mitigation

Nature Based Solutions in BRIC

Investing in our infrastructure and lifelines

A time for action

How Hagerty Can Help

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