BRIC’s inaugural application development period came to an end and potential BRIC projects are currently being evaluated by the National Technical Review (NTR) team comprised of mitigation subject matter experts who review each eligible project for cost-effectiveness and engineering feasibility. The review process will take several months meaning eager applicants and sub-applicants will not know their project’s status until July 2021 – approximately one month before the new grant cycle starts again, with the release of the Notice of Funding Opportunity (NOFO) for Fiscal Year 2021.
First, you need to know that BRIC 2021 could be a significant amount of funding. In a recent New York Times article, Michael Grimm, FEMA’s acting deputy associate administrator for disaster mitigation, said the “agency’s initial estimates suggested that as much as $3.7 billion could be available for the program.” Mr. Grimm also noted that more than $3.7 billion could be forthcoming as COVID could impact the estimate and raise it to $10 billion. With the potential for billions in BRIC funding, state, tribal and local governments need to be proactively scoping projects to determine which are the most competitive for the BRIC program.
Since high impact, large scale infrastructure and neighborhood-scale projects take time to successfully develop, we wanted to jump right in with our debriefing or “deBRICing” from the 2020 grant cycle – what worked well, what may need reevaluation, and how to better prepare your potential project for BRIC in 2021.
What worked well?
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 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. Moreover, the increase in project funding caps boosted the potential for high-impact infrastructure projects with cost estimates that traditionally exceeded the previous PDM caps. Some additional benefits included,
- A streamlined application process with 100 percent digital submission through FEMA GO.
- The qualitative scoring criteria awards points for evaluating future conditions, leveraging partnerships, and obtaining public support through community outreach.
- Incentives in the technical scoring criteria:
- For nature-based solutions with applicants and sub-applicants eligible to receive an additional 10 points for inclusion in project proposal;
- For communities with robust building codes and standards with applicants and sub-applicants eligible to receive a total of 35 points for 2015/ 2018 code adoption and a Building Code Effectiveness Grading Schedule (BCEGS) rating between 1-5; and,
- For small, impoverished communities in the technical scoring criteria with applicants and sub-applicants eligible to receive five additional points on the technical scoring criteria, in the hopes of promoting their participation in the program.
- Period-of-performance (POP) extension for complex projects provides additional flexibility for applicants and sub-applicants if the project’s schedule justified the need for expansion beyond the traditional 36-month POP.
- Removal of time constraint for pre-award costs provides a pathway for FEMA-selected projects to have their initial design work and feasibility studies reimbursed, if the procurement is compliant with applicable federal regulations.
What needs reevaluation?
While BRIC provided an overall more substantive mitigation investment, there are areas in its policy and implementation that would benefit from further review and analysis. Areas for reevaluation include,
- Increasing the Capability and Capacity Building (C&CB) funding from $600,000 per applicant. FEMA should consider increasing the C&CB project scoping allocation and making a larger initial investment in BRIC’s early years to build and fund potential future projects. This would help communities build a future pipeline of shovel ready projects. Given COVID-19 and its impact on local match availability, many sub-applicants simply cannot invest in initial preliminary work needed for BRIC projects. This is further compounded in States that do not have HMGP Advance Assistance (AA) funding available.
- Receiving additional guidance from FEMA on project phasing. While not included in the NOFO, FEMA did allow for phased projects to be submitted. A phased project has a scope of work that meets FEMA eligibility requirements, but whose complexity requires additional studies and design development to get the subapplication to the point where a full eligibility determination can be made. Additional guidance from FEMA on project phasing and when to phase a project (what level of design development or environmental analysis) could save communities time and resources on application development.
- Extending the small, impoverished community designation. Small, impoverished communities have a reduced non-federal match, but many of these communities, who stand to benefit from mitigation activities, lack the institutional capacity or resources to implement BRIC grants. They may not have the resources to navigate the complexities of BRIC, the Benefit Cost Analysis (BCA), and the rigorous subapplication process. Currently, a small, impoverished community needs to be the subapplicant to receive the reduced non-federal cost share amount. FEMA should extend the small, impoverished community designation to the project benefitting area or project activity area to allow for more flexibility and equity in program participation.
- Clarifying what constitutes an “overmatch.” The technical scoring criteria included five additional points for increased non-federal cost share (“overmatch”); however, FEMA should clarify what constitutes an overmatch. For example, is 26 percent, or one percent over the required non-federal share, sufficient to receive the points or should the increased non-federal cost share be more substantial. In addition, FEMA should provide guidance on how to calculate management costs when applicants and sub-applicants overmatch.
- Implementing technical updates to the FEMA GO system. While FEMA GO allows for a full digital submission, users experienced numerous issues with the software. Key feature improvements for next year include enabling deletion of draft sub-applications and files; making a downloadable PDF of the full sub-application available; and updating the cost estimate tab so that 100 percent of management costs are captured in the federal cost share.
Preparing for BRIC 2021
Primed with the lessons from the inaugural BRIC application cycle, it is important to start evaluating your potential BRIC projects for FY21 now. To do so, we recommend the following:
- Establish a BRIC working group comprised of diverse stakeholders. Suggestions include public works, parks and recreation, housing and economic development, utility managers, project and grant managers, and city managers. All of these stakeholders can collectively help identify potential projects. Additionally, they can collaborate and help gather basic data needed to evaluate the project through the use of existing Hazard Mitigation Plans, local and regional planning documents, planning studies, feasibility studies, capital project plans, new budgetary need requests, and climate adaptation resources.
- Be proactive in identifying mitigation activities and developing well-documented subapplications. Take advantage of pre-award costs to start project identification and planning now.
- Develop an early screening process to evaluate projects and determine their scope. This process should account for project eligibility, feasibility, cost-effectiveness, environmental and historic implications, and overall competitiveness. In this way, you may avoid committing resources to advanced design, engineering and application development for a project that is ultimately not cost effective or not a viable proposal for BRIC. As a part of this process, it is also important to identify what critical infrastructure or buildings and populations are being protected by this project and to what degree. Additionally, you must consider environmental and historic consultations, prepare project cost estimates, and develop BCAs. This will help as the project matures towards submission. Additional factors to consider include the likelihood of achieving the intended implementation outcome, potential duplication of programs (DOP), the project’s shovel-readiness, agency capacity to support the project through completion, and local match availability.
- Procure support early in the process to maximize the project scoping opportunity. It is important to understand and follow the Federal Procurement and the Conflict of Interest requirements (2 CFR 200) if consultants are being utilized. Failing to properly procure consultant support can jeopardize the pre-award reimbursement if the project is selected.
So, now that you have been deBRICed, we extend an opportunity for you to learn more about our experiences with BRIC 2020 and our recommendations for BRIC 2021. We will continue to highlight the lessons learned from the inaugural year of BRIC and to discuss how state and local entities can better prepare themselves for the upcoming BRIC funding opportunity. If you are interested in this opportunity, please sign up to receive more details below.
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.
Amelia Muccio is the Director of Mitigation at Hagerty Consulting and a subject matter expert in disaster recovery. With over 15 years of experience in public health, disaster preparedness, mitigation, and financial recovery, Amelia has helped clients obtain $5 billion in federal funds after major disasters, including Hurricane Sandy, the California Wildfires, and Hurricane Harvey.
Vanessa Castillo is a 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.
Millie Starliper is a mitigation and recovery consultant with experience in science and technology, policy, and FEMA mitigation programs. Over the past 6 years, Millie has contributed her expertise in grant management, application development, and project implementation to projects totaling more than $100 million on behalf of state and local governments, private nonprofits, and private sector businesses.