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:

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