Recent disasters are a stern reminder that preparedness is key to effectively managing and recovering from a major event. It is critical for America’s special districts to engage with fellow local special districts and general governments providing services in their communities to plan for and implement hazard mitigation projects – and then qualify for federal mitigation funding.
Investing district resources to harden critical infrastructure against a range of hazards may seem daunting and expensive; but, in some cases, it could be the best public investment to protect life and property as well as maintain quality of life. Studies show that every $1 spent to mitigate infrastructure against disaster saves $6 when the disaster happens. In other words – it’s six times more expensive to respond to/repair unmitigated infrastructure after disaster strikes.
Like federal post-disaster relief, federal resiliency funds are sourced from the Federal Emergency Management Agency (FEMA). The federal government has authorized several big-ticket programs offering 75-percent cost share, and as much as 90 percent for disadvantaged communities, to assist with mitigation needs. Application periods for hazard mitigation programs are open for a limited time on an annual basis, while others may open after a disaster has been declared.
But projects are required to be prioritized, documented, and approved in order to be eligible. This article shares highlights on those programs after providing a “quick start” guide for special districts interested in pursuing hazard mitigation needs. (We hope that’s everyone!)
Participation in a Hazard Mitigation Plan
Operators of public infrastructures must have their needs and projects listed on a FEMA-approved Hazard Mitigation Plan (HMP) to qualify for any significant federal hazard mitigation funds. Special districts can only accomplish this through collaboration with county governments during their HMP stakeholder engagement process, which occurs on a five-year basis for participating counties.
Before we dive in, a clarification. HMPs are not an emergency management plan, not crisis response protocols, nor are they mutual aid agreements. These are separate documents that special districts should have as a best practice.
HMPs are usually comprehensive documents that identify and detail the different hazards that may impact the communities leading to losses – ranging from tornadoes to winter storms, hurricanes to fires, floods, and more.
The document also identifies the critical and essential public infrastructure assets in the community. These elements are essential to everyday public operations as well as for emergency response and shelter in times of disaster. Examples include, but are certainly not limited to: fire stations, water wells, levees, drainage/flood control systems, medical facilities, lift stations, wastewater facilities, safe/community rooms, energy infrastructure, and more.
Where are the Active HMPs and What is the Process?
Special districts are most successful in the HMP planning process when tag teaming with fellow county and/or municipal governments, primarily due to the broad impacts a mitigation project can have beyond the district boundary as well as the economies of scale to plan all at once. For that reason, this article is based on the recommendation of districts joining a multijurisdictional process.
Understanding the status of a county or municipality’s HMP is central to districts’ planning and approach. Follow this link to an interactive map of jurisdictions across the country with active, pending, lapsed, or no plans. Notably, counties in the Southeast and the Plains are well covered; however, many communities across Arkansas, Montana, New Mexico, Texas, and in New England either have expired HMPs or have never had one. These communities are left without avenues to FEMA mitigation funding.
Districts interested in jumping aboard a plan should familiarize themselves with where their county or municipalities are in the process. For instance, special districts located in areas with HMPs near expiration should begin considering their mitigation needs and reaching out to their local disaster planning and emergency management agency. Accordingly, special districts in areas with an expired plan or in a locality where a plan has never been established are encouraged to educate county officials on the importance of the HMP and start the process. Otherwise, special district leaders in communities without an active HMP are encouraged to consider HMP development on their own and to lead the charge with fellow local governments, especially if services are provided in hazard-prone areas.
Simply put, how the process goes: Establishing HMPs begin with a stakeholder engagement process, then scoping and development of the document and included projects, followed by finalization. Local HMPs are sent to state disaster/emergency agencies for review before final FEMA approval. The cycle begins anew twice per decade.
Cover Your Assets: Be Proactive with Fellow Local Governments
It is unlikely that county officials responsible for the planning process understand special districts’ needs and how they fit into the mold of its multijurisdictional HMP. This is because special districts are almost always autonomous and are responsible for the maintenance and understanding of their own infrastructure (this is the point of an independent special purpose government).
For this reason, it is most important for special district managers and directors to stay in touch with their county or municipal emergency planning and operations officials. Doing so will position the district as a stakeholder in the hazard mitigation planning cycle. Not participating in a multijurisdictional process can prove to be more costly for a special district, potentially posing higher barriers to secure a HMP, and leading to loss of funding opportunities to protect the district.
Educating county and municipal emergency officials on the independent nature of special district governance is also imperative. For many multijurisdictional HMPs, counties inventory and include its own assets in unincorporated areas, such as roads or police services. Planners many not fully understand how an independent governing entity is responsible for separate infrastructure in the unincorporated area, which demands separate engagement. This is a common reason for districts being overlooked in the planning process.
Be ready for the process and know your infrastructure. Basically and essentially, special districts seeking to be part of a HMP must have an inventory of their critical facilities. Understanding where the infrastructure is located, its integrity, and its resilience factors should be identified. The risk profiles for each are important to setting county-wide priorities and setting the stage for future funding opportunities.
Understand the potential impacts of mitigation projects. A benefit/cost analysis, commonly referred to as a “BCA,” is the determination of how significant a project is in terms of “bang for the buck.” Special districts engaging with the HMP process are encouraged to work with county agencies to quantify the population, structures, property values, how many disasters have hit in years’ past, and how much time has passed since the last time the community received attention for its hazard mitigation needs. In other words –more people, structures, and property protected by critical infrastructure in need of mitigation equates to higher benefits for the cost, and thus a higher prioritization for the project to be funded in the future.
Districts cannot certify population figures alone. Special districts seeking to establish a HMP without a non-county or non-municipal partners may experience hurdles to determine the benefit/cost analysis of certain projects. This is because special districts are not federally recognized as a geographic unit of local government, and federal agencies are unable to certify population and household statistics. As a result, the federal government will not recognize the thousands of people an independent special district serves with its critical infrastructure services. In all, collaborating with county governments is a work around the issue and is a perk of engaging in multijurisdictional plans.
Understand the Impacts to your Community and Beyond
Location and community profile matter – especially in recent years. 40 Percent of federal infrastructure investments are required to flow toward disadvantaged and underserved communities as part of the Biden Administration’s “Environmental Justice 40” initiative, or “EJ40.” No disadvantaged community is the same, but the general characteristics are those that are socioeconomically distressed, have been disconnected due to major infrastructure projects (such as interstates), experience poor water quality, contend with air pollution, and are generally at risk of lesser health outcomes and lower quality of life due to the general environment, among other characteristics.
Notably, benefits of a special district-sponsored infrastructure project can be scored beyond the district’s boundaries. Example scenarios include:
- The benefit of a drainage district upgrading its flood control systems on a home or business upstream from its boundaries count toward the scoring of the district project.
- Downstream benefits of forest/watershed mitigation project are relevant to the project and properly scored.
- Few shelters or low transportation options may spur need for a community safe room, which could be placed in a park district or other district providing appropriate space.
Do you have a possible hazard mitigation project in mind that could benefit a disadvantaged community/ “EJ40 Community”? Use this interactive map to discover whether your community is federally considered to be a disadvantaged community.
Further, the Community Disaster Resilience Zones (CDRZ) Act (Public Law 117-225) requires FEMA to maintain a National Risk Index map categorizing the risk profiles of each Census tract based on risk to population, potential economic losses (factoring agricultural losses as well), and existing vulnerability and resiliency for infrastructure. In late 2023, FEMA designated 483 census tracts across the country as CDRZ, increasing prioritization, technical assistance options, and the federal cost-share of a project impacting the community to be as high as 90 percent. Click here for the map of CDRZ-designated Census tracts.
Finally, if a special district’s project is geared toward flood control, is in a flood plain, and has the potential to protect structures insured under a National Flood Insurance Program-backed plans, FEMA’s Flood Mitigation Assistance program could also be a good fit. Districts should explore this option, especially if they serve one of the 1,500+ communities participating in FEMA’s Community Risk Rating program.
Getting Ready for the Storm (and more): The Wish List Approach & Top Projects for Hazard Mitigation
A HMP is a statement of priorities deemed worthy of investment, and there is no limit on the number of projects or the extent to infrastructure that can be identified – but not every project gets funded over the five-year HMP timeframe, as grants are usually awarded based on risk profile. On the flipside, if a project or asset is not listed in an approved HMP, then FEMA cost-share is simply not an option. For this reason, it’s important to consider the HMP a “project wish list,” of-sorts.
According to FEMA, the top hazard mitigation projects by application and federal cost share include:
- Community safe rooms providing shelter from tornadoes, hurricanes, and other natural disasters.
- Elevating homes to allow flood waters to flow beneath.
- Flood risk reduction strategies that may include open space, stormwater systems, or other approaches to mitigate flooding for the community.
- Land stabilization and environmental restoration.
- Hardening public utilities and other critical infrastructure.
- Project scoping including engineering reports, environmental studies, feasibility studies, and benefit-cost analysis.
- Property acquisitions for the purposes of mitigation.
- Renovating buildings to comply with modern codes, as well as retrofitting budlings and non-structural facilities.
- Updating HMPs.
When to Access Funding Opportunities
Major federal programs requiring a HMP for project funding include:
- Hazard Mitigation Grant Program-Post Fire. Funding is allocated after a fire disaster declaration for the purposes of mitigation against future fire hazards.
- Pre-Hazard Mitigation Grant Program projects. The FY24 application process was open throughout June. Click here to read the Notice of Funding Opportunity to best understand this program.
- Building Resilient Infrastructure Communities (BRIC) projects, which open annually. FEMA awarded cost-share to 656 projects totaling $882.6 million in FY23.
- Safeguarding Tomorrow Revolving Loan Fund (available in only a handful of states) is modeled after the federal water and wastewater revolving loans. States must pass legislation establishing the fund to participate.
- Flood Mitigation Assistance projects, geared toward protecting building with National Flood Insurance Program-backed policies. Click here to review suggested actions to take now ahead of the upcoming FY24 application period.
Finally, congressional earmarks are another opportunity for special districts with a HMP-designated project. Special districts with active plans may request Community Project Funding on hazard mitigation projects listed on HMPs from their members of the U.S. House of Representatives and/or Congressionally Directed Spending from the U.S. Senators. This annual opportunity comes unreliably fast and furious, usually at some point in the spring, with some representatives and senators opening their application portals for as little as a week. Having projects ready, such as with a HMP, is among the best ways for districts to position themselves to act fast on earmark opportunities.
Learn more about how to develop a Hazard Mitigation Plan using FEMA’s most recent guide to local mitigation planning.
Click here for FEMA’s FAQ document: “Special Districts Participation in Mitigation Planning.”
Have questions? Would like to explore connecting with fellow special district on hazard mitigation needs? Contact Cole Arreola-Karr, AASD Executive Director, at cole@americasdistricts.org.