FEMA Hazard Mitigation: A First Step Toward Climate Adaptation

FEMA Hazard Mitigation: A First Step Toward Climate Adaptation

FEMA Hazard Mitigation: A First Step Toward
March 23, 2022
Climate Adaptation
Diane P. Horn
With the increasing severity and frequency of natural disasters, attributed at least in part to
Analyst in Flood Insurance
climate change, policymakers often view mitigation funding as a way to control disaster-related
and Emergency
spending. The importance of federal mitigation funding is illustrated by a recent study that
Management
looked at the impacts of 23 years of federal mitigation grants and found that for every $1 invested

by federal grant programs, society as a whole saved $6 due to reduced future losses.

FEMA has a lead role in guiding nationwide mitigation of extreme weather events, including
those resulting from the impacts of climate change. In particular, FEMA administers the federal government’s most
significant grant programs for pre-and post-disaster mitigation. FEMA has identified hazard mitigation as one of the main
ways in which the agency will enhance resilience to the effects of climate change and lead federal climate change adaptation
efforts.
FEMA funds mitigation measures through a number of programs:
 the Hazard Mitigation Grant Program (HMGP);
 the Building Resilient Infrastructure and Communities grant program (BRIC);
 the Flood Mitigation Assistance grant program (FMA);
 the STORM Act State Revolving Loan Program for Hazard Mitigation;
 Public Assistance (PA); and
 Individual Assistance (IA).
Three of these programs are available after a disaster (HMGP, PA, and IA), while the other three (BRIC, FMA, STORM Act)
provide pre-disaster mitigation funding for use before an event occurs or in anticipation of an incident. Historically, post-
disaster mitigation has received significantly more funding than pre-disaster mitigation. Between 1996 and 2019,
approximately $1.86 billion was awarded for FMA grants, $1.92 billion was awarded for PDM grants (the predecessor to
BRIC), and $22.4 billion was awarded in HMGP funding. Funding for pre-disaster mitigation has increased recently through
the Disaster Recovery Reform Act of 2018 (P.L. 115-24) and the Infrastructure Investment and Jobs Act (P.L. 117-58).
Increased funding for pre-disaster mitigation is more essential in the context of climate change, as many projected climate
impacts have yet to occur.
This report gives an overview of FEMA funding for mitigation, including issues related to equity, and suggests
considerations for Congress that may enhance FEMA’s support for hazard mitigation and climate adaptation.

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Contents
Introduction ..................................................................................................................................... 1
FEMA Hazard Mitigation Assistance .............................................................................................. 3
Post-Disaster Mitigation ............................................................................................................ 4
Hazard Mitigation Grant Program (HMGP) ....................................................................... 4
FEMA Public Assistance and Individual Assistance ........................................................... 6
Pre-Disaster Mitigation ............................................................................................................. 8
Building Resilient Infrastructure and Communities (BRIC) ............................................. 11
Flood Mitigation Assistance Grant Program (FMA) ........................................................ 17
STORM Act State Hazard Mitigation Revolving Loan Program ..................................... 19
Considerations for Congress.......................................................................................................... 21
Pre-Disaster vs. Post-Disaster Mitigation Funding ................................................................. 21
BRIC ................................................................................................................................. 22
Individual Assistance ........................................................................................................ 22
Public Assistance .............................................................................................................. 23
STORM Act ...................................................................................................................... 24
Hazard Mitigation Assistance and Equity ............................................................................... 24
Prioritizing Disadvantaged Communities ......................................................................... 24
Capacity Constraints ......................................................................................................... 25
U.S. Territories and Tribal Governments .......................................................................... 26
Funding Allocations .......................................................................................................... 27
Hazard Mitigation and Climate Adaptation ............................................................................ 28
Concluding Comments .................................................................................................................. 28

Figures
Figure 1. Hazard Mitigation Grant Program Funding for Major Disaster Declarations
Related to the COVID-19 Pandemic ............................................................................................ 6
Figure 2. Funding for Pre-Disaster Mitigation, FY1997-FY2021 ................................................. 10
Figure 3. BRIC FY2020 Applications ........................................................................................... 14
Figure 4. FMA FY2020 Applications ............................................................................................ 18

Tables
Table 1. FEMA Hazard Mitigation Programs .................................................................................. 4
Table 2. Pre-Disaster Mitigation Funding, FY1997-FY2021 .......................................................... 9
Table 3. BRIC FY2020 Applications Selected for Further Review ............................................... 16

Contacts
Author Information ........................................................................................................................ 28

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FEMA Hazard Mitigation: A First Step Toward Climate Adaptation

Introduction
Communities across the country are already experiencing the impacts of climate change.
Additionally, many extreme weather and climate-related events are expected to become more
frequent and more intense under climate change.1 The impacts of such events are estimated to
have already cost more than $1.0 trillion (in 2021 dollars) since 1980.2
Catastrophic events pose a financial threat both to society as a whole and to the federal
government, which has allocated increasing resources to disaster relief and recovery.3 In the
United States, as in many countries, this can be attributed to a combination of factors: rapid
expansion of population into areas that are susceptible to natural disasters, rising property values
in hazardous areas, and climatological and environmental changes. Nearly one-third of the U.S.
housing stock (about 35 million homes) is considered to be at high risk of a natural disaster,4 and
most homes in the United States have some risk of climate change-induced hazard events.5 For
example, in 2019, the Congressional Budget Office (CBO) estimated residential property losses
from hurricane and tropical storm-related flooding to be approximately $20 billion per year (in
2017 dollars).6
The Government Accountability Office (GAO) has found that the rising number of natural
disasters and increasing reliance on the federal government for response and recovery assistance
is a key source of federal fiscal exposure.7 GAO has suggested in several reports that two related
sets of actions—climate adaptation and pre-disaster mitigation—can enhance climate resilience
by reducing risk.8 GAO has also suggested that enhancing resilience to climate change could
reduce future damages from climate-related events, and recommended adjustments to natural or
human systems in response to actual and expected climate change, and through hazard mitigation
actions before a disaster.9

1 D.R. Reidmiller, et al., Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment,
U.S. Global Change Research Program, Volume II, Washington, DC, November 23, 2018, pp. 1-47,
https://nca2018.globalchange.gov/ (hereinafter Fourth National Climate Assessment).
2 The Public and Affordable Housing Research Corporation and the National Low Income Housing Coalition, Taking
Stock: Natural Hazards and Federally Assisted Housing, June 29, 2021, p. 4, https://preservationdatabase.org/wp-
content/uploads/2021/06/Taking-Stock.pdf.
3 See, for example, U.S. Government Accountability Office, Federal Disaster Assistance: Federal Departments and
Agencies Obligated At Least $277.6 Billion During Fiscal Years 2005 Through 2014, GAO-16-797, September 22,
2016, https://www.gao.gov/assets/gao-16-797.pdf; and CRS Report R45484, The Disaster Relief Fund: Overview and
Issues, by William L. Painter.
4 CoreLogic, “Risk Redefined: CoreLogic Climate Change Catastrophe Report Emphasizes Need to Address Increasing
Frequency of Hazard Events,” January 27, 2021, https://www.corelogic.com/press-releases/risk-redefined-corelogic-
climate-change-catastrophe-report-emphasizes-need-to-address-increasing-frequency-of-hazard-events/.
5 Saumi Shokraee et al., 2020 Climate Change Catastrophe Report, CoreLogic, January 28, 2021,
https://www.corelogic.com/downloadable-docs/2020-climate-change-catastrophe-report-17-ctr-0121-00.pdf.
6 Congressional Budget Office, Expected Costs of Damage from Hurricane Winds and Storm-Related Flooding, CBO
Publication 55019, Washington, DC, April 2019, p. 3, https://www.cbo.gov/system/files/2019-04/55019-
ExpectedCostsFromWindStorm.pdf.
7 GAO, Climate Change: A Climate Migration Pilot Program Could Enhance the Nation’s Resilience and Reduce
Federal Fiscal Exposure, GAO-20-488, July 6, 2020, pp. 1-2, https://www.gao.gov/assets/gao-20-488.pdf.
8 Ibid., and GAO, Climate Change: Selected Governments Have Approached Adaptation Through Laws and Long-
Term Plans, GAO-16-454, May 12, 2016, p. 4, https://www.gao.gov/assets/gao-16-454.pdf.
9 See, for example, GAO, High-Risk Series: An Update, GAO-15-290, February 11, 2015, pp. 67-70,
https://www.gao.gov/assets/gao-15-290.pdf; and GAO, Climate Change: Selected Governments Have Approached
Adaptation Through Laws and Long-Term Plans, GAO-16-454, May 12, 2016, p. 4, https://www.gao.gov/assets/gao-
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FEMA administers several of the federal government’s primary hazard mitigation programs,
making the agency a central part of the nation’s climate change adaptation strategy. While the
agency lacks a statutory mission to combat change directly, many of FEMA’s mitigation activities
are intended to reduce the impact of natural disasters, including those that may be exacerbated by
climate change.10 FEMA has identified hazard mitigation as one of the main ways that the agency
will address climate change.11 According to the FEMA Administrator, “Climate change is the
crisis of this generation. Combating it requires mitigating future risks and reducing impacts.”12
Adaptation, Mitigation, and Resilience
As a relatively new policy area, definitive terminology has yet to be established and definitions are not used
uniformly across federal agencies. For example, FEMA’s use of the term mitigation, or hazard mitigation, differs from
the terminology used by the U.S. Global Change Research Program (USGCRP).13 In general, the term adaptation is
used by climate change professionals and hazard mitigation is used by the emergency management community.14
Hazard mitigation has traditionally relied on analysis of historical events to characterize risk, whereas climate
adaptation employs predictions of future conditions, usually derived from global climate models, to characterize
risk.
Adaptation: adjustment in natural or human systems to a new or changing environment.
Resilience: the capacity to anticipate, prepare for, respond to, and recover from significant multi-hazard threats
with minimum damage to social well-being, health, the economy, and the environment.
Mitigation (USGCRP): measures to reduce the amount and speed of future climate change by reducing
emissions of heat-trapping gases or removing carbon dioxide from the atmosphere. This is also referred to as
greenhouse gas mitigation.
Mitigation (FEMA): any sustained action to reduce or eliminate long-term risk to people and property from
natural hazards and their effects.15
Mitigation measures can be funded by several FEMA programs: (1) any of the FEMA Hazard
Mitigation Assistance grant programs: the Hazard Mitigation Grant Program (HMGP), the
Building Resilient Infrastructure and Communities grant program (BRIC), the Flood Mitigation
Assistance grant program (FMA), and the State Revolving Loan Program for Hazard Mitigation;
(2) FEMA Public Assistance (PA) funding under Stafford Act Section 406; and (3) FEMA
Individual Assistance (IA) funding under Stafford Act Section 408 (see Table 1).
Although all mitigation activities are essentially preparation for the next disaster, FEMA
distinguishes between post-disaster mitigation funding, which is awarded after a specific incident,
and pre-disaster mitigation funding, which is awarded in order to reduce future damage from an
anticipated event. PA, IA, and HMGP are post-disaster funding, and require a form of disaster
declaration: an emergency declaration, a major disaster declaration16 from the President, or a Fire

16-454.pdf.
10 Congressional Budget Office, Budgetary Effects of Climate Change and of Potential Legislative Responses to It,
Report 57175, April 2021, p. 1, https://www.cbo.gov/publication/57175.
11 FEMA, 5 Ways FEMA is Tackling the Climate Crisis, November 9, 2021, https://www.fema.gov/blog/5-ways-fema-
tackling-climate-crisis.
12 FEMA, FEMA Announces Initial Initiatives to Advance Climate Change Resilience, October 28, 2021,
https://www.fema.gov/press-release/20211028/fema-announces-initial-initiatives-advance-climate-change-resilience.
13 U.S. Global Change Research Program, Glossary, https://www.globalchange.gov/climate-change/glossary.
14 GAO, Climate Resilience: A Strategic Investment Approach for High-Priority Projects Could Help Target Federal
Resources, GAO-20-127, October 23, 2019, p. 2, https://www.gao.gov/assets/710/702236.pdf.
15 FEMA, Hazard Mitigation Assistance Guidance, Washington, DC, February 27, 2015, p. 1, https://www.fema.gov/
sites/default/files/2020-07/fy15_HMA_Guidance.pdf.
16 For more information about disaster declarations, see FEMA, How a Disaster Gets Declared, https://www.fema.gov/
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Management Assistance Grant (FMAG) declaration.17 BRIC, FMA, and STORM Act funding
represent pre-disaster mitigation funding. Applicants can request funding from these programs to
reduce future risks without waiting for a disaster to occur.
The Department of Housing and Urban Development (HUD) Community Development Block
Grant Disaster Recovery authorities for disaster recovery (CDBG-DR) and its mitigation variant
(CDBG-MIT)18 and the Small Business Administration (SBA) Disaster Loan Program19 can also
fund mitigation activities. These programs may work cooperatively with FEMA programs, but are
outside the scope of this report.
FEMA Hazard Mitigation Assistance
Climate impacts include events that present immediate, acute, physical danger, such as major
storms and wildfires, or those causing incremental physical impacts over extended periods of
time, such as extreme heat, drought, and sea level rise (and associated coastal flooding.) Many
places are subject to more than one climate-related impact, such as extreme rainfall combined
with coastal flooding, or extreme heat coupled with drought and wildfire. A growing body of
evidence shows that the increasing frequency and intensity of weather-related disasters compound
one another.20 The compounding effects of these impacts may result in increased risks.
Given the increasing severity and frequency of natural disasters, as well as their potential to
increase cost and casualties, some policymakers have encouraged the use of mitigation funding in
order to reduce disaster-related spending. The majority of federal funding for both pre- and post-
disaster mitigation comes from FEMA through three programs: HMGP, BRIC, and FMA.
Together, these programs are collectively referred to as Hazard Mitigation Assistance (HMA).
Eligible applicants include state and local governments and federally-recognized tribes.
Individuals and businesses may not apply for HMA funding, but they may benefit from a
community application. Eligible activities differ for the three programs.21 Applicants must have a
FEMA-approved hazard mitigation plan at the time that HMA funding is obligated.22
The importance of federal mitigation funding is illustrated by a recent study that looked at the
impacts of 23 years of federal mitigation grants provided by FEMA, the Economic Development
Administration (EDA), and HUD, and found that for every $1 invested by federal grant programs,
society as a whole saved $6 due to reduced future losses. This is an average across four natural
hazards: riverine flooding (7:1), hurricane winds (5:1), earthquakes (3:1), and fires at the

disaster/how-declared; and CRS Report R43784, FEMA’s Disaster Declaration Process: A Primer, by Bruce R.
Lindsay.
17 For more information on FMAG declarations, see FEMA, Fire Mitigation Assistance Grants, https://www.fema.gov/
assistance/public/fire-management-assistance; and CRS Report R43738, Fire Management Assistance Grants:
Frequently Asked Questions, by Diane P. Horn, Katie Hoover, and Bruce R. Lindsay.
18 For more information on CDBG-DR and CDBG-MIT, see CRS Report R46475, The Community Development Block
Grant’s Disaster Recovery (CDBG-DR) Component: Background and Issues, by Joseph V. Jaroscak.
19 For more information on SBA disaster loans, see CRS Report R41309, The SBA Disaster Loan Program: Overview
and Possible Issues for Congress, by Bruce R. Lindsay.
20 Colin Raymond et al., “Understanding and Managing Connected Extreme Events,” Nature Climate Change, vol. 10,
no. 7 (June 2020), pp. 611-621.
21 FEMA, Hazard Mitigation Assistance Guidance, Washington, DC, February 27, 2015, p. 32-33,
https://www.fema.gov/sites/default/files/2020-07/fy15_HMA_Guidance.pdf.
22 Ibid., pp. 45-47. See also FEMA, Hazard Mitigation Planning, https://www.fema.gov/emergency-managers/risk-
management/hazard-mitigation-planning.
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wildland-urban interface (WUI)23 (3:1).24 The study also estimated that the federal government
spends an annual average of $10 billion on disasters through PA, IA, and other costs.25
Table 1. FEMA Hazard Mitigation Programs
Type
Program
Legislation
Funding
Post-disaster
HMGP
Stafford Act Section 404
Disaster Relief Fund (DRF)
Post-disaster
IA
Stafford Act Section 408
DRF
Post-disaster
PA
Stafford Act Section 406
DRF
Pre-disaster
BRIC
DRRA Section 1234, Stafford
6% set-aside from DRF
Act Section 203
Pre-disaster
FMA
National Flood Insurance Act
NFIP policyholders,
additional appropriation
from IIJA FY2022-FY2026
Pre-disaster
State Hazard
STORM Act, Stafford Act
Appropriation from IIJA
Mitigation Revolving Section 205
FY2022-FY2026
Loan Program
Notes: Robert T. Stafford Disaster Relief and Emergency Assistance Act (P.L. 93-288, as amended); Disaster
Recovery Reform Act of 2018 (DRRA, P.L. 117-58); Infrastructure Investment and Jobs Act (IIJA), P.L. 117-58);
Safeguarding Tomorrow through Ongoing Risk Mitigation (STORM) Act of 2020, P.L. 116-284.
Post-Disaster Mitigation
Hazard Mitigation Grant Program (HMGP)
The Hazard Mitigation Grant Program is authorized by the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (hereinafter the Stafford Act)26 Section 404—Hazard Mitigation27 and
is funded through the Disaster Relief Fund (DRF).28 HMGP’s key purpose is to ensure that the
opportunity to take critical mitigation measures is not lost during the reconstruction process
following a disaster. HMGP funding is available to all areas of a state, territory, or tribal lands
where it is requested by a governor or tribal chief executive following a major disaster declaration
or an FMAG declaration.
The level of HMGP funding available for a given disaster is based on a percentage of the
estimated total federal assistance under the Stafford Act for the declaration, awarded on a sliding
scale as a percentage of the estimated amount of total federal assistance for the disaster:

23 The wildland-urban interface (WUI) is the zone where structures and other human development meet or intermingle
with undeveloped wildland or vegetative fuels. See U.S. Fire Administration, Wildland Urban Interface (WUI),
https://www.usfa.fema.gov/wui/.
24 National Institute of Building Sciences, Natural Hazard Mitigation Saves: 2019 Report, Washington, DC, 2019, p.
37, https://www.nibs.org/files/pdfs/NIBS_MMC_MitigationSaves_2019.pdf.
25 Multi-hazard Mitigation Council, National Institute of Building Sciences, Natural Hazard Mitigation Saves, 2019
Report, Washington, DC, pp. 1-3, https://www.nibs.org/projects/natural-hazard-mitigation-saves-2019-report.
26 42 U.S.C. §§5121 et seq.
27 42 U.S.C. §5170c.
28 For more information on the Disaster Relief Fund (DRF), see CRS Report R45484, The Disaster Relief Fund:
Overview and Issues, by William L. Painter.
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 up to 15% of the first $2 billion of estimated aggregate amounts of disaster
assistance;
 up to 10% of amounts between $2 billion and $10 billion;
 up to 7.5% of amounts between $10 billion and $35.333 billion; and
 20% for any state with an approved Enhanced State Mitigation Plan29 in effect
before the disaster.30
HMGP funding initially goes to a state. States can use HMGP funds for any eligible activity for
any type of hazard and are not limited to the hazard or area for which the grant was awarded. For
example, funding allocated for flooding in one county could be used for wildfire mitigation in a
different county, as long as the activity is eligible. The decision is made by the state where the
funding can best be used, and decisions about allocating HMGP funds to subapplicants are made
by the state.31
HMGP Funding for COVID-19 Disaster Declarations
FEMA announced in August 2021 that HMGP funding will be available to all states, territories,
and tribes that received a major disaster declaration for the COVID-19 pandemic for 4% of
eligible relief costs (see Figure 1).32 This funding is not restricted to pandemic-related mitigation.
Four percent is a lower percentage than is usually awarded for HMPG, but the total funding of
$3.46 billion represents the largest amount of HMGP funding in a single fiscal year. (The largest
amount previously was $2.29 billion in FY2005.)

29 44 C.F.R. §201.5.
30 42 U.S.C. §5170c(a) and 44 C.F.R. §206.432(b).
31 Eligible subapplicants include state, territorial and local governments, federally-recognized tribes or tribal
organizations, and certain nonprofit organizations. Additionally, certain nonprofit organizations may apply for HMGP
funding. State agencies and federally-recognized tribes applying for HMGP funding must have a FEMA-approved
State or Tribal Mitigation Plan at the time of the presidential major disaster declaration and at the time the HMGP
funding is obligated. All subapplicants for HMGP must have a FEMA-approved Local or Tribal Mitigation Plan at the
time of obligation of grant funds.
32 FEMA, COVID-19 Disaster Declarations, August 20, 2021, https://www.fema.gov/disaster/coronavirus/disaster-
declarations.
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Figure 1. Hazard Mitigation Grant Program Funding for Major Disaster Declarations
Related to the COVID-19 Pandemic

Source: FEMA, Hazard Mitigation Grant Program Allocations for COVID-19 Declarations, August 20, 2021.
FEMA Public Assistance and Individual Assistance
Public Assistance
FEMA Public Assistance (PA) provides financial and direct assistance to subfederal governments
and eligible nonprofits when authorized following a Stafford Act emergency or major disaster
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declaration.33 PA may provide assistance for urgent emergency response activities (emergency
work) as well as long-term reconstruction (permanent work). On average, PA accounts for the
single greatest source of expenditures from the DRF, which supports the administration and
funding of Stafford Act assistance.34 Mitigation projects account for a fraction of these historical
obligations.35
Under current authorities, FEMA may provide PA for post-disaster mitigation measures on the
disaster-damaged components of eligible facilities, or when eligible, on the full extent of
replacement facilities (including alternate or improved projects that may significantly differ from
the original facility).36 In general, PA for mitigation can only fund measures affecting the
damaged components of facilities, which may result in partial funding for projects like whole-
facility elevation. Per federal regulations and agency policy, FEMA will only approve mitigation
measures determined to be cost effective.37
Additionally, FEMA may provide PA for subfederal governments to rebuild eligible facilities in
accordance with applicable building codes. The Disaster Recovery Reform Act of 2018 (DRRA)38
enhanced these authorities by authorizing FEMA to provide PA for the costs of reconstruction or
replacement in accordance with “the latest published editions of relevant consensus-based codes,
specifications, and standards that incorporate the latest hazard-resistant designs.”39
Individual Assistance—Individuals and Households Program
After a Stafford Act declaration, the President may authorize FEMA to provide various forms of
assistance, including assistance through the Individuals and Households Program (IHP), a form of
Individual Assistance (IA).40 The IHP is authorized under Stafford Act Section 408—Federal
Assistance to Individuals and Households.41 If approved, IHP assistance may provide financial
and/or direct assistance to eligible individuals and households. However, the IHP cannot

33 See CRS Infographic IG10021, How FEMA Public Assistance Works, by Erica A. Lee.
34 For more information on PA, see CRS Report R46749, FEMA’s Public Assistance Program: A Primer and
Considerations for Congress, by Erica A. Lee.
35 Ibid., p. 23.
36 See CRS Report R46749, FEMA’s Public Assistance Program: A Primer and Considerations for Congress, by Erica
A. Lee. Definitions of alternate and improved facilities may be found at FEMA, Public Assistance Program and Policy
Guide Version 4.0 (PAPPG 2020), June 1, 2020, p. 163, https://www.fema.gov/sites/default/files/documents/
fema_pappg-v4-updated-links_policy_6-1-2020.pdf.
37 44 C.F.R. §206.226(e); FEMA, PAPPG 2020, pp. 154-155, 242-246; FEMA, “Benefit-Cost Analysis,”
https://www.fema.gov/grants/ guidance-tools/benefit-cost-analysis; and
CRS Report R46749, FEMA’s Public Assistance Program: A Primer and Considerations for Congress, by Erica A.
Lee.
38 Division D of P.L. 115-254.
39 Section 1235(b) of DRRA, Division D of P.L. 115-254, as it amends §406(e)(1)(A) of the Stafford Act, P.L. 93-288,
as amended, 42 U.S.C. §5172(e)(1)(A); and CRS Report R45819, The Disaster Recovery Reform Act of 2018 (DRRA):
A Summary of Selected Statutory Provisions, coordinated by Elizabeth M. Webster and Bruce R. Lindsay, pp. 14-16.
40 42 U.S.C. §5174. See also 44 C.F.R. §206.110(a); and FEMA, Individual Assistance Program and Policy Guide
(IAPPG), v. 1.1, FP 104-009-03, May 2021, pp. 6, 41, https://www.fema.gov/sites/default/files/documents/fema_iappg-
1.1.pdf (hereinafter FEMA, IAPPG). For additional information on FEMA’s Individual Assistance (IA) program, see
CRS In Focus IF11298, A Brief Overview of FEMA’s Individual Assistance Program, by Elizabeth M. Webster.
41 42 U.S.C. §5174.
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compensate disaster survivors for all losses and it is not intended to make disaster survivors
whole again.42
Home Repair Assistance43 is one component of IHP assistance. The objective of Home Repair
Assistance is to make the disaster survivors’ home “safe, sanitary, or functional,” not to return the
home to its pre-disaster condition or to improve it.44 However, repairs may include hazard
mitigation measures that make the housing more resilient.45 Specifically, reasonable hazard
mitigation measures may be permitted, even if they improve upon a component’s pre-disaster
condition.46
FEMA’s regulations and guidance impose limitations on the mitigation assistance that may be
provided, including that it may only be awarded for disaster-damaged real property components
that existed and were functional prior to the declared disaster.47 Further, the amount of financial
assistance for housing—including mitigation measures—is capped in statute.48 Assistance for
housing-related needs may not exceed $37,900 (FY2022; adjusted annually),49 and the approved
mitigation measures are subject to this cap.
On June 10, 2021, FEMA announced an expansion of the mitigation assistance provided under
the IHP Home Repair Assistance program for disasters declared on or after May 26, 2021, to
“allow eligible homeowners ... [to] repair or rebuild stronger, more durable homes.” Per the
agency’s announcement, FEMA’s IHP Home Repair Assistance will fund the following specific
mitigation measures: (1) roof repair to withstand higher winds and help prevent water infiltration;
(2) elevating a water heater or furnace to avoid future flood damage; and (3) elevating or moving
an electrical panel to avoid future flood damage.50
Additionally, although hazard mitigation measures are intended to “reduce the likelihood of
future damage,” this assistance is not available until after a disaster has occurred and received a
presidential Stafford Act declaration.51
Pre-Disaster Mitigation
Funding for pre-disaster mitigation is a relatively new practice. Before 1997, federal hazard
mitigation funding was only available after a disaster, through HMGP and PA, and was intended
to ensure that the reconstruction process following a disaster addressed opportunities to include

42 42 U.S.C. §5174; 44 C.F.R. §§206.110-206.120; and FEMA, IAPPG, p. 41.
43 FEMA, Assistance for Housing and Other Needs, September 2, 2021, https://www.fema.gov/assistance/individual/
housing.
44 FEMA, IAPPG, p. 85.
45 FEMA, IAPPG, p. 86.
46 FEMA, IAPPG, p. 88.
47 44 C.F.R. §§206.111 and 206.117(a), (b)(2)(i), (b)(2)(iii), and (b)(2)(iv); and FEMA, IAPPG, p. 87.
48 42 U.S.C. §5174(h)(1); and FEMA, IAPPG, pp. 42, 85. For FY2022, the maximum amount of financial assistance
for housing is $37,900 and the maximum amount of financial assistance for other needs is $37,900 (DHS/FEMA,
“Notice of Maximum Amount of Assistance Under the Individuals and Households Program,” 86 Federal Register
63046, November 15, 2021, https://www.govinfo.gov/content/pkg/FR-2021-11-15/pdf/2021-24755.pdf (hereinafter
FEMA, “Notice of Maximum Amount of IHP Assistance”). It is adjusted annually to reflect changes in the Consumer
Price Index for All Urban Consumers published by the Department of Labor (42 U.S.C. §5174(h)(3)).
49 42 U.S.C. §5174(h)(1); FEMA, “Notice of Maximum Amount of IHP Assistance.”
50 FEMA, Hazard Mitigation Under the Individuals and Households Program, June 10, 2021, https://www.fema.gov/
fact-sheet/hazard-mitigation-under-individuals-and-households-program.
51 FEMA, IAPPG, pp. 85-86.
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mitigation measures. Congress first appropriated funding for FEMA pre-disaster mitigation in
1997, and FEMA used this funding to establish a pilot project called Project Impact.52 The
Disaster Mitigation Act of 200053 placed pre-disaster mitigation in the Stafford Act and created
the Pre-Disaster Mitigation Grant Program (PDM).54 In 2003, Congress further defined the PDM
program to explicitly require competitive grant awards, which represented the first time that
mitigation funding was awarded competitively.55
From FY1997 to FY2018, the funding available for pre-disaster mitigation was appropriated on
an annual basis. The amount of funding requested in grant applications exceeded the amount of
appropriated funds each year. For example, between 2003 and 2016, a total of $1.1 billion in
PDM funds was appropriated, while applicants requested a total of $3.2 billion.56
Funding for pre-disaster mitigation changed significantly with the passage of DRRA. Section
1234 of DRRA authorized a new source of funding for pre-disaster mitigation, the National
Public Infrastructure Pre-Disaster Mitigation Fund (NPIPDMF), which allows the President to set
aside from the DRF an amount equal to 6% of the estimated aggregate amount of funding
awarded under seven sections of the Stafford Act.57 The amount set aside in the NPIPDMF shall
not reduce the amounts otherwise available for the relevant sections of the Stafford Act.58
In FY2019, the PDM program was funded through the DRF as part of the transition to the new
funding model, and the BRIC program began in FY2020. Table 2 and Figure 2 show funding
levels for pre-disaster mitigation from FY1997 to FY2021.
Table 2. Pre-Disaster Mitigation Funding, FY1997-FY2021
Amount Appropriated
Fiscal Year
(in millions)
Program
1997
$2
Project Impact
1998
$30
Project Impact
1999
$25
Project Impact
2000
$25
Project Impact
2001
$25
Project Impact
2002
$25
Project Impact
2003
$150
PDM
2004
$150
PDM
2005
$100
PDM

52 FEMA, Building a Disaster Resistant Community, Project Impact Guidebook, 1997, https://training.fema.gov/hiedu/
docs/hazriskmanage/hazards%20risk%20mgmt%20-%20session%204%20-%20project%20impact%20guidebook.pdf.
53 P.L. 106-390.
54 42 U.S.C. §5133.
55 GAO, The Status of FEMA’s FY03 Pre-Disaster Mitigation Program, GAO-04-717r, April 25, 2004, p. 6,
https://www.gao.gov/assets/gao-04-727r.pdf.
56 PDM Fiscal Year 2017 Report to Congress, p. 4.
57 Stafford Act Sections 403 (essential assistance), 406 (repair, restoration and replacement of damaged facilities), 407
(debris removal), 408 (federal assistance to individuals and households), 410 (unemployment assistance), 416 (crisis
counseling assistance and training), and 428 (public assistance program alternative program procedures). See CRS
Report R45819, The Disaster Recovery Reform Act of 2018 (DRRA): A Summary of Selected Statutory Provisions, for
further details.
58 42 U.S.C. §5133(i)(3).
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Amount Appropriated
Fiscal Year
(in millions)
Program
2006
$50
PDM
2007
$100
PDM
2008
$114
PDM
2009
$90
PDM
2010
$100
PDM
2011
$49.9
PDM
2012
$35.5
PDM
2013
$25
PDM
2014
$25
PDM
2015
$25
PDM
2016
$100
PDM
2017
$90
PDM
2018
$235
PDM
2019
$250
PDM
2020
$500
BRIC
2021
$1,000
BRIC
Sources: CRS Report RL34537, FEMA’s Pre-Disaster Mitigation Program: Overview and Issues; FEMA, National Pre-
Disaster Mitigation Fund, Fiscal Year 2017 Report to Congress, September 1, 2017, p. 4, https://www.dhs.gov/
sites/default/files/publications/FEMA%20-%20National%20Pre-Disaster%20Mitigation%20Fund.pdf; and FEMA
Notices of Funding Opportunity for PDM and BRIC, FY2017 to FY2021.
Figure 2. Funding for Pre-Disaster Mitigation, FY1997-FY2021

Source: CRS Analysis of data in Table 2.
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FEMA’s expectation was that the NPIPDMF would receive $300-500 million per year on
average, based on historical disaster expenditures.59 The disaster assistance associated with the
COVID-19 major disaster declarations,60 however, has resulted in significant additional funding
for pre-disaster mitigation. As of February, 2022, $1.808 billion was set aside in the DRF for pre-
disaster mitigation.61
Building Resilient Infrastructure and Communities (BRIC)
FEMA introduced a new program, Building Resilient Infrastructure and Communities (BRIC),62
in FY2020 to replace the PDM program and award funding from the NPIPDMF. DRRA did not
require the creation of a new program. DRRA changed the funding mechanism for pre-disaster
mitigation; however, the statutory changes introduced in DRRA could have been incorporated in
the PDM program. The Association of State Floodplain Managers (ASFPM) adopted a resolution
about BRIC in which they noted that FEMA created a program with a significantly different focus
and priorities from the PDM program, despite the fact that Congress did not establish new
priorities for funding in DRRA.63
Any state that has had a major disaster declaration under the Stafford Act in the seven years prior
to the application start date is eligible to apply for BRIC funding. Any federally recognized tribe
that has had a major disaster declaration or is entirely or partially located in a state or territory
that has had a major disaster declaration in the seven years prior to the application start date is
also eligible. All states, territories, and recognized tribal governments are eligible for BRIC at
least through FY2026 due to the COVID-19 pandemic disaster declarations.64
BRIC FY2020
FY2020 was the first year of operation for BRIC. A total of $500 million was available in
FY2020 in three categories: (1) state/territory allocation: $33.6 million; (2) tribal set-aside: $20
million; and (3) national competition: $446.4 million. Applicants in FY2020 were able to submit
an unlimited number of mitigation project applications in category (3), each valued up to $50
million. The $50 million cap for an individual mitigation project in BRIC represents a significant
increase in pre-disaster mitigation funding; the largest amount available to an individual for PDM
activities in FY2019 was $10 million. Since the PDM program was established, two projects have

59 U.S. Congress, House Committee on Transportation and Infrastructure, Subcommittee on Economic Development,
Public Buildings, and Emergency Management, Disaster Preparedness: DRRA Implementation and FEMA Readiness,
Serial No. 116-17 (House Hearing), 116th Cong., 1st sess., May 22, 2019, p. 90, https://www.congress.gov/116/chrg/
CHRG-116hhrg40590/CHRG-116hhrg40590.pdf.
60 FEMA, COVID-19 Disaster Declarations, https://www.fema.gov/disasters/coronavirus/disaster-declarations.
61 FEMA, Disaster Relief Fund: Monthly Report as of February 28, 2022, Fiscal Year 2022 Report to Congress,
Washington, DC, February 7, 2022, p. 25, https://www.fema.gov/sites/default/files/documents/fema_drf-congressional-
report-month-feb_2022.pdf.
62 FEMA, Building Resilient Infrastructure and Communities (BRIC), https://www.fema.gov/grants/mitigation/
building-resilient-infrastructure-communities.
63 Association of State Floodplain Managers, Resolution Regarding the FEMA Building Resilient Communities and
Infrastructure (BRIC) Grant Program and Recommended Changes, December 1, 2021, p. 3, https://asfpm-
library.s3.us-west-2.amazonaws.com/ASFPM_Pubs/ASFPM_BRIC_Resolution.pdf (hereinafter ASFPM BRIC
Resolution).
64 Eligible applicants for BRIC funding include states, the District of Columbia, U.S. territories, and federally
recognized Indian tribal governments. Local governments and federally recognized Indian tribal governments are
eligible subapplicants.
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been awarded more than $4 million, and 280 projects (approximately 7%) have been awarded
more than $1 million.65
FEMA has discretion to set priorities annually for pre-disaster mitigation funding. The priorities
for FY2020 aimed to incentivize public infrastructure projects; projects that mitigate risk to one
or more lifelines;66 projects that incorporate nature-based solutions;67 and projects that encourage
the adoption and enforcement of the latest published editions of building codes.68
The most heavily weighted technical criteria in FY2020 related to building code activities,
reflecting FEMA’s emphasis on disaster resilience through strong building codes.69 Applications
that included mandatory building code adoption requirements were scored more favorably. BRIC
priorities also included a focus on future conditions, with applications evaluated on how the
project would anticipate future conditions, such as population and demographic changes, climate
change, and sea level rise. BRIC’s project evaluation criteria also included a number of measures
to support underserved communities.70
A new form of assistance introduced in BRIC is the provision of non-financial Direct Technical
Assistance71 for communities to build capacity and develop applications to support underserved
populations.72 FEMA has suggested that Direct Technical Assistance is especially important to
disadvantaged communities,73 and may help small jurisdictions in particular.74 In FY2020, FEMA
selected eight communities to receive non-financial Direct Technical Assistance, of which six are
small and impoverished communities and three are tribes.75
FEMA received 991 applications for BRIC in FY2020, the highest number received to date for
pre-disaster mitigation (see Figure 3). Fifty-three states and territories requested over $3.6
billion, from the $500 million available. Tribes submitted 62 subapplications requesting $20.2
million in funding. Five states submitted projects with over $200 million federal share each:

65 CRS analysis of OpenFEMA data set on Hazard Mitigation Assistance Projects – v2, https://www.fema.gov/
openfema-data-page/hazard-mitigation-assistance-projects-v2. Accessed November 21, 2021.
66 Lifelines are the most fundamental services in a community that enable all other aspects of society to function. They
include safety and security; food, water, and shelter; health and medical; energy; communications; transportation; and
hazardous material. See FEMA, Community Lifelines, https://www.fema.gov/emergency-managers/practitioners/
lifelines.
67 FEMA, Building Community Resilience with Nature-Based Solutions, May 2021, https://www.fema.gov/sites/
default/files/documents/fema_riskmap_nature-based-solutions-guide_2020.pdf.
68 FEMA, BRIC Building Code Activities, https://www.fema.gov/sites/default/files/documents/fema_fy21-bric-
building-code-activities-psm.pdf.
69 See FEMA, 2018-2022 Strategic Plan, Washington, DC, March 15, 2018, p. 14, https://www.fema.gov/sites/default/
files/2020-03/fema-strategic-plan_2018-2022.pdf.
70 DHS, Environmental Justice Annual Implementation Report FY2020, Washington, DC, pp. 11-12,
https://www.dhs.gov/sites/default/files/publications/dhs_fy20_ej_progress_report.pdf.
71 FEMA, FEMA Program Support Material: BRIC Direct Technical Assistance, https://www.fema.gov/sites/default/
files/documents/fema_fy21-bric-direct-technical-assistance-psm.pdf.
72 Department of Homeland Security (DHS), Environmental Justice Annual Implementation Report FY2020,
Washington, DC, pp. 11-12, https://www.dhs.gov/sites/default/files/publications/dhs_fy20_ej_progress_report.pdf.
73 FEMA, BRIC Direct Technical Assistance, https://www.fema.gov/sites/default/files/documents/fema_fy21-bric-
direct-technical-assistance-psm.pdf.
74 Leslie Kaufman, “Q&A: New Director Criswell Prepares FEMA for a Hot, Chaotic Future,” Insurance Journal,
September 24, 2021, https://www.insurancejournal.com/news/national/2021/09/24/633682.htm.
75 FEMA, “Building Resilient Infrastructure and Communities FY 2020 Subapplication Status,” https://www.fema.gov/
grants/mitigation/building-resilient-infrastructure-communities/fy2020-subapplication-status.
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California, New Jersey, New York, Texas, and Virginia; and 25 states submitted projects with $50
million or more federal share each.76
FEMA has not yet announced the funding awards for BRIC FY2020 but has selected 406
subapplications for further review,77 with 22 projects from 10 states selected for further review in
the national competition (see Table 3). Fifty-seven percent of the funding under review is in three
states: California (25.27%), Washington (16.16%) and New Jersey (15.49%).
Of the 991 subapplications received for BRIC, 98 (9.89%) were from small and impoverished
communities.78 Projects submitted by 46 small and impoverished communities were selected for
further review, amounting to $39.2 million in total project costs,79 about 7.84% of the overall
BRIC funding available. However, the majority of the projects submitted by small and
impoverished communities that FEMA selected were from the state and tribal allocations (36
from the tribal set-aside and eight from the state allocations), where funding was virtually
guaranteed for eligible projects. Only two projects from small impoverished communities were
selected for further review for competitively-awarded funding. This suggests that the small and
impoverished communities that submitted subapplications were less successful than the total
number would suggest, particularly in the competitive awards.
ASFPM analyzed the projects that were selected for further review for BRIC FY2020 funding
and concluded that more dollars and projects were selected for wealthier, greater-resourced
communities than for less wealthy communities with fewer resources. They also found an award
bias toward coastal communities vs. inland communities, with $474.6 million of projects selected
for coastal communities and $27.3 million for non-coastal projects. They noted that only one
competitive project was selected from a non-coastal state, and no competitive applications were
selected from FEMA regions 5, 6, 7, or 8.80

76 FEMA, Hazard Mitigation Assistance (HMA) Annual Grant Cycle Submissions Summary, March 17, 2021,
https://www.fema.gov/fact-sheet/hazard-mitigation-assistance-hma-annual-grant-cycle-submissions-summary.
77 An application which is listed as “identified for further review” is not a notification of award. This means that a
subapplication has met the requirements specified in the NOFO and the HMA Unified Guidance. At this time, the
applicants are required to work with a FEMA Regional Office to complete the pre-award activities for
subapplications. Regional Offices will also complete the Environmental and Historic Preservation (EHP) compliance
review for projects prior to award. See FEMA, Subapplication Status Descriptions, https://www.fema.gov/grants/
mitigation/subapplication-status-descriptions.
78 Note that from 2005 to 2019, small impoverished communities represented an average of about 6% of sub-
applications each year, so this constitutes a slight increase. See FEMA, “Hazard Mitigation Assistance (HMA) Annual
Grant Cycle Submissions Summary,” release, March 12, 2021, https://www.fema.gov/fact-sheet/hazard-mitigation-
assistance-hma-annual-grant-cycle-submissions-summary.
79 FEMA, Hazard Mitigation Assistance (HMA) Annual Grant Cycle Submissions Summary, March 17, 2021,
https://www.fema.gov/fact-sheet/hazard-mitigation-assistance-hma-annual-grant-cycle-submissions-summary.
80 FEMA Region 5 includes Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin. FEMA Region 6 includes
Arkansas, Louisiana, New Mexico, Oklahoma, and Texas. FEMA Region 7 includes Iowa, Kansas, Missouri, and
Nebraska. FEMA Region 8 includes Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming. See
FEMA, Regions, https://www.fema.gov/about/organization/regions.
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Figure 3. BRIC FY2020 Applications

Source: FEMA, Hazard Mitigation Assistance (HMA) Annual Grant Cycle Submissions Summary, March 17, 2021,
https://www.fema.gov/fact-sheet/hazard-mitigation-assistance-hma-annual-grant-cycle-submissions-summary.
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BRIC FY2021
A total of $1 billion is available for BRIC in FY2021 in three categories: (1) state/territory
allocation: $56 million; (2) tribal set-aside: $25 million; and (3) national competition: $919
million. Each state, territory, and tribe is eligible for at least $1 million in categories (1) or (2).
Applicants are again able to submit an unlimited number of mitigation project applications in
category (3), each valued up to $50 million.81 BRIC priorities for FY2021 are: (1) natural hazard
risk reduction activities that mitigate risk to public infrastructure and disadvantaged communities;
(2) projects that mitigate risk to one or more lifelines; (3) projects that incorporate nature-based
solutions; (4) projects that enhance climate resilience; and (5) projects proposed by applicants
who adopt and enforce mandatory tribal, territorial, or state-wide building codes based on the
latest published editions of building codes.82 BRIC received 782 applications requesting $4.16
million, and all states and territories applied for BRIC funding in FY2021.83
Infrastructure Funding for BRIC
The Infrastructure Investment and Jobs Act (IIJA)84 appropriated $1 billion for BRIC, with $200
million for each of FY2022 to FY2026. This funding is in addition to the 6% set-aside.

81 DHS, Notice of Funding Opportunity (NOFO), Fiscal Year 2021 Building Resilient Infrastructure and Communities,
pp. 6-7, https://www.fema.gov/sites/default/files/documents/fema_nofo-fiscal-year-2021-building-resilient-
infrastructure.pdf.
82 BRIC FY2021, p. 6.
83 FEMA, FEMA Receives Record-Breaking Amount in Requested Funding for Mitigation Grant Programs, February
4, 2022, https://content.govdelivery.com/accounts/USDHSFEMA/bulletins/309b032.
84 P.L. 117-58.
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Table 3. BRIC FY2020 Applications Selected for Further Review
National Competition
Number of Subapplications
Type of Project
Percentage of Total
Selected for Further
Applicant State
Federal Share
Federal Share
Review
California
$95,448,982.38
25.27%
4
3 flood control, 1 wildfire
mitigation
Washington
$61,041,509.98
16.16%
3
1 flood control, 1
saferoom/shelter, 1 relocation
New Jersey
$58,517,000.00
15.49%
2
2 flood control
District of Columbia
$38,560,817.00
10.21%
2
1 flood control, 1 utility and
infrastructure protection
South Carolina
$32,635,783.95
8.64%
1
utility and infrastructure
protection
Maryland
$31,924,193.00
8.45%
1
flood control
North Carolina
$23,692,990.54
6.27%
5
1 flood control, 1
floodproofing, 1 elevation, 1
relocation, 1 utility and
infrastructure protection
New York
$20,872,058.06
5.53%
2
2 flood control
Kentucky
$10,543,961.38
2.79%
1
flood control
Massachusetts
$4,484,673.00
1.19%
1
utility and infrastructure
protection
Total
$377,721,964.29
100.00%
22

Sources: CRS analysis of data provided by FEMA to CRS, July 28, 2021; and FEMA, Building Resilient Infrastructure and Communities FY 2020 Subapplication Status,
https://www.fema.gov/grants/mitigation/building-resilient-infrastructure-communities/fy2020-subapplication-status.
Notes: The type of project was identified from web sites for individual projects.
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Flood Mitigation Assistance Grant Program (FMA)
The Flood Mitigation Assistance (FMA) grant program is another pre-disaster mitigation funding
program operated by FEMA. The FMA program is funded entirely through revenue collected by
the NFIP.85 The FMA program awards grants for a number of purposes, including state and local
mitigation planning; the elevation, relocation, demolition, or flood proofing of structures; the
acquisition of properties; and other activities.86 FMA grants are only available to communities
which participate in the NFIP, to assist in efforts to reduce or eliminate flood damage to buildings
and structures insurable under the NFIP, particularly repetitive loss87 and severe repetitive loss88
properties. Eligible applicants for FMA funding include states, the District of Columbia, U.S.
territories, and federally recognized Indian tribal governments. Local governments and federally
recognized Indian tribal governments are eligible subapplicants for FMA grants.
A database of FMA grants that is available from FEMA indicates that approximately $1.86 billion
in projects was approved between 1996 and 2019.89 Demand for FMA grants has consistently
exceeded available funds. For example, $200 million was available for FMA in FY2020. FEMA
received 236 applications from 30 states and territories, the highest number received to date.
FEMA received requests with total proposed project costs exceeding $393 million in FY2020 (see
Figure 4)90 and requests for $534 million in FY2021. However, 26 states and territories did not
apply for FMA funding in FY2020, and 31 states and territories did not apply in FY2021.91
FEMA has not yet announced the funding awards for FMA FY2020 but has selected 117
subapplications for further review; 49 eligible projects were not selected due to lack of available
FMA funding.92 50% of the projects selected were for Louisiana and 27% for Texas.93

85 42 U.S.C. §4104c.
86 For additional information on the FMA Program, see 44 C.F.R. Part 78; FEMA’s website at https://www.fema.gov/
grants/mitigation/floods; and CRS Report R44593, Introduction to the National Flood Insurance Program (NFIP), by
Diane P. Horn and Baird Webel.
87 42 U.S.C. §4121(a)(7) defines repetitive loss structure as a structure covered by a contract for flood insurance that
(A) has incurred flood-related damage on 2 occasions, in which the cost of repair, on the average, equaled or exceeded
25 percent of the value of the structure at the time of each such flood event; and (B) at the time of the second incidence
of flood-related damage, the contract for flood insurance contains increased cost of compliance coverage.
88 Severe repetitive loss properties are those that have incurred four or more claim payments exceeding $5,000 each,
with a cumulative amount of such payments over $20,000; or at least two claims with a cumulative total exceeding the
value of the property. See 42 U.S.C. §4014(h) and 44 C.F.R. §79.2(h).
89 This figure represents the total amount of federal assistance, without subtracting the cost share, for the three flood
mitigation programs that existed during this time: the Severe Repetitive Loss (SRL) grant program, the Repetitive
Flood Claim (RFC) grant program, and the FMA grant program. See FEMA, OpenFEMA Data Sets,
https://www.fema.gov/openfema-data-page/hazard-mitigation-assistance-projects-v2, accessed November 1, 2021.
90 FEMA, Hazard Mitigation Assistance (HMA) Annual Grant Cycle Submissions Summary, March 17, 2021,
https://www.fema.gov/fact-sheet/hazard-mitigation-assistance-hma-annual-grant-cycle-submissions-summary.
91 FEMA, FEMA Receives Record-Breaking Amount in Requested Funding for Mitigation Grant Programs, February
4, 2022, https://content.govdelivery.com/accounts/USDHSFEMA/bulletins/309b032.
92 FEMA, Flood Mitigation Assistance FY 2020 Subapplication Status, https://www.fema.gov/grants/mitigation/floods/
previous-fiscal-year-subapplication-statuses/fy2020-subapplication-status.
93 Ibid.
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Figure 4. FMA FY2020 Applications

Source: FEMA, Hazard Mitigation Assistance (HMA) Annual Grant Cycle Submissions Summary, March 17, 2021,
https://www.fema.gov/fact-sheet/hazard-mitigation-assistance-hma-annual-grant-cycle-submissions-summary.

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The FMA program has $160 million available for FY2021. FEMA plans to select applications up
to the available funding amount of $160 million in the following order: (1) project scoping; (2)
community mitigation projects; (3) technical assistance; (4) flood hazard mitigation planning; and
(5) individual flood mitigation projects.94
Infrastructure Funding for FMA
The IIJA appropriated $3.5 billion for the FMA program, with $700 million for each of FY2022
to FY2026. This represents a significant increase in the amount of funding available for flood
mitigation, and the first time that funding has been appropriated for the FMA program. On March
14, 2022, FEMA announced the first FEMA initiative to be funded with the IIJA funding, the
Swift Current Initiative Funding Opportunity. Swift Current is a FEMA initiative that seeks to
expedite FMA awards after a flooding event and reduce the complexity of the application process,
with the goal of obligating FMA dollars for NFIP-insured and substantially damaged properties as
quickly and equitably as possible after a flood. Swift Current allocates $60 million to Louisiana,
Mississippi, New Jersey, and Pennsylvania. These states were selected because they were affected
by Hurricane Ida and have the highest repetitive loss and severe repetitive loss of NFIP-insured
unmitigated properties, and the highest total insurance claims within their respective FEMA
regions.95
STORM Act State Hazard Mitigation Revolving Loan Program
A new source of hazard mitigation funding will be available through the Safeguarding Tomorrow
through Ongoing Risk Mitigation Act of 2020, or the STORM Act (P.L. 116-284). This law
amends the Stafford Act by authorizing FEMA to enter into agreements with eligible entities to
establish hazard mitigation revolving loan funds.96 Funds made available through the STORM
Act may be used to assist homeowners, businesses, certain nonprofit organizations, and
communities to reduce risk in order to decrease the loss of life and property, the cost of flood
insurance, and federal disaster payments. The legislation is intended to provide states with
funding that will help them carry out their own hazard mitigation projects.97
A revolving loan fund (RLF) is a self-replenishing financial mechanism that starts with a base
level of capital, often consisting of grants from the federal government or a state, or private
investment. RLFs can make loans targeted to specific types of borrowers or for specific types of
activities, and are designed to use loan repayments to recapitalize the fund and therefore make
additional loans.98 This may create an ongoing source of funding and potentially reduce the need
for annual appropriations. Revolving loan funds for states have been operating for many years
through the Clean Water State Revolving Fund, established in 1987, and the Drinking Water State

94 See FEMA, Notice of Funding Opportunity (NOFO) Fiscal Year 2021 Flood Mitigation Assistance,
https://www.fema.gov/sites/default/files/documents/fema_nofo-fiscal-year-2021-flood-mitigation-assistance-grants.pdf.
95 FEMA, Swift Current Initiative, https://www.fema.gov/grants/mitigation/floods/swift-current.
96 42 U.S.C. §5135.
97 Senate Committee on Homeland Security and Governmental Affairs, S.Rept. 116-249, August 10, 2020, p. 3,
https://www.congress.gov/congressional-report/116th-congress/senate-report/249.
98 For additional information on revolving loan funds, see CRS Report R46471, Federally Supported Projects and
Programs for Wastewater, Drinking Water, and Water Supply Infrastructure, coordinated by Jonathan L. Ramseur;
CRS Report R45304, Drinking Water State Revolving Fund (DWSRF): Overview, Issues, and Legislation, by Mary
Tiemann; and CRS In Focus IF11449, Economic Development Revolving Loan Funds (ED-RLFs), by Julie M.
Lawhorn.
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Revolving Fund, established in 1996.99 However, the STORM Act represents the first time that
such a fund has been set up to fund hazard mitigation.
Eligible entities include states, tribal governments that have received a major disaster declaration
during a five-year period ending on the date of enactment of the STORM Act (January 1, 2021),
and insular areas.100 All participating entities are required to provide matching funds from
nonfederal sources in an amount equal to 10% of the amount that they receive for the revolving
fund.101
In awarding capitalization grants, the STORM Act directs FEMA to give priority to:
 projects that increase resilience and reduce the risk of harm to natural and built
infrastructure;
 projects that involve a partnership between two or more eligible entities to carry
out a project or similar projects;
 projects that take into account regional impacts of hazards; and
 projects that increase resilience of major economic sectors or critical national
infrastructure, including ports, global commodity supply chain assets, power and
water production and distribution centers, and bridges and waterways essential to
interstate commerce.102
Interest rates on the loans cannot exceed 1%. Annual principal and interest payments must start
no later than one year after the completion of projects for which the loan was made and must be
fully paid within 20 years, except for loans provided to projects in low-income geographic
areas,103 which must be paid off not later than 30 years after the date on which the project is
completed and not longer than the expected design life of the project. A participating entity may
not provide an amount equal to or more than $5 million to a single hazard mitigation project.
Infrastructure Funding for the STORM Act
The STORM Act authorized the appropriation of $100 million annually for FY2022 and FY2023
to make grants to capitalize new revolving funds to be administered by states or insular areas. The
IIJA appropriated $500 million for the revolving loan program, with $100 million for each of
FY2022 to FY2026.

99 For additional information on the Clean Water State Revolving Fund and the Drinking Water State Revolving Fund,
see CRS Report R46464, EPA Water Infrastructure Funding in the American Recovery and Reinvestment Act of 2009,
by Jonathan L. Ramseur and Elena H. Humphreys.
100 The STORM Act defines the term “insular area” to mean Guam, American Samoa, the Commonwealth of the
Northern Mariana Islands, and the United States Virgin Islands. See 42 U.S.C. §5135(m)(5).
101 If the deposit from the entity is less than 10% of the amount of the capitalization grant, FEMA is required to reduce
the amount of the capitalization grant proportionately.
102 42 U.S.C. §5135 (d)(3).
103 The STORM Act defines the term “low-income geographic area” to mean an area described in paragraph (1) or (2)
of Section 301(a) of the Public Works and Economic Development Act of 1965 (42 U.S.C. §3161(a)). Paragraph (1)
defines a low per capita income as when the area has a per capita income of 80% or less of the national average.
Paragraph (2) defines an unemployment rate above national average as when an area has an unemployment rate that is,
for the most recent 24-month period for which data are available, at least 1% greater than the national average
unemployment rate. See https://www.govinfo.gov/content/pkg/COMPS-331/pdf/COMPS-331.pdf.
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Implementation of STORM Act State Hazard Mitigation Revolving Loan
Program
Following the appropriation of funding in the IJJA, FEMA is working on implementation of the
STORM Act State Hazard Mitigation Revolving Loan Program, beginning with program design
and options for stakeholder engagement. FEMA expects that it will take 18-24 months to stand up
and implement the program, with the first Notice of Funding Opportunity (NOFO) in FY2023.104
Considerations for Congress
Pre-Disaster vs. Post-Disaster Mitigation Funding
Historically post-disaster mitigation has received significantly more funding than pre-disaster
mitigation. For example, GAO found that most of the hazard mitigation funding obligated by
FEMA from FY2010 though FY2018 was for post-disaster mitigation. Of the approximately
$11.3 billion obligated during that period, 88% was for post-disaster grants through HMGP and
PA ($10 billion). FEMA’s competitive pre-disaster grant programs, FMA and BRIC’s
predecessor, the Pre-Disaster Mitigation Grant Program (PDM), accounted for about 12% of the
total ($1.3 billion).105 GAO argued that this emphasis on the post-disaster environment can create
a reactionary approach where disasters determine where and for what purpose the federal
government invests in disaster resilience, which may limit states’ ability to plan and prioritize for
maximum risk reduction. Post-disaster funding, such as IA, PA, and HMGP, arrive after the
disaster incident and are only available to states that have suffered the impact of a disaster, and
cannot be targeted at areas that might have a greater risk of a more damaging disaster that has not
yet occurred.
Despite the substantial increase in overall funding for pre-disaster mitigation that the 6% BRIC
set-aside and the additional funding appropriated in the IIJA represent, the post-disaster
mitigation approach embodied in HMGP still receives more resources. FEMA’s open data sets
show that between 1996 and 2019, approximately $1.86 billion was awarded for FMA grants,
$1.92 billion was awarded for PDM grants, and $22.4 billion was awarded in HMGP funding.106
In addition, according to FEMA, approximately $8.5 billion was obligated for PA mitigation
projects from 1999 to August 2020.107 The total amount of pre-disaster mitigation funding in this
period (a total of $3.78 billion, with an annual average of $80.9 million for FMA and an annual
average of $88.5 million for PDM) is so much less than post-disaster funding (PA annual average
$386.4 million, HMGP annual average $973.9 million) that even the large amounts of funding
from DRRA and the IIJA will not end the disparity.
Arguably, increased funding for pre-disaster mitigation is even more impactful in the context of
climate change, as many projected climate impacts may not have happened yet, or may occur
with a higher magnitude or frequency under a changing climate. Congress could change the
balance between pre- and post-disaster funding. For example, Congress could change the amount

104 FEMA briefing for House and Senate Committee staff and CRS, November 22, 2021.
105 GAO, Disaster Resilience: FEMA Should Take Additional Steps to Streamline Hazard Mitigation Grants and Assess
Program Effects, GAO-21-140, February 2, 2021, pp. 12-13, https://www.gao.gov/products/gao-21-140.
106 This figure represents the total amount of federal assistance, without subtracting the cost share. See FEMA,
OpenFEMA Data Sets, https://www.fema.gov/openfema-data-page/hazard-mitigation-assistance-projects-v2, accessed
November 1, 2021.
107 See p. 23, CRS Report R46749, FEMA’s Public Assistance Program: A Primer and Considerations for Congress,
by Erica A. Lee.
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of funding available for pre-disaster mitigation, or include pre-disaster mitigation in the formula
funding available after a disaster declaration, or change the 6% BRIC set-aside.
BRIC
Congress may wish to consider how FEMA should address the uncertainty in BRIC funding from
year to year, and the potential variability in funding available following ‘large’ and ‘small’
disaster years. FEMA could be directed to consider whether there should be a required minimum
level of distribution. FEMA could also be directed to consider whether, if there is a year with a
high set-aside for pre-disaster mitigation, all of the funds should be distributed in that year, or
whether some funding should be held in reserve for low set-aside years.
In addition, Congress may wish to require FEMA to report on the types of projects funded under
BRIC. The ASPFM has identified this as a major area of concern, commenting that
Although ASFPM was cautiously optimistic that BRIC would routinely fund flood
mitigation efforts for buildings, like elevation, buyouts, and small floodproofing projects,
after the FY2020 grant winners108 were announced, it was clear that this would not be the
case.109
The ASFPM expressed concern that the heavy weighting of infrastructure and lifeline projects
greatly reduced the ability of traditional “incremental” flood mitigation projects to compete,
despite evidence that such projects are effective in reducing flood risk.110
Congress could consider requiring FEMA to develop procedures to ensure that small projects are
not at a disadvantage for funding selection, or requiring FEMA to report on the balance of large
and small projects selected for funding. Congress could appropriate additional funding for BRIC,
or for the older PDM program. BRIC could be used to provide seed funding to attract additional
funding for public-private partnerships (an approach used by Project Impact),111 which could
potentially be carried out as part of a time-limited pilot project. FEMA could introduce a new
means-tested mitigation program; for example, the Build Back Better Act,112 as passed by the
House on November 19, 2021, would appropriate funding for a means-tested affordability
program for the National Flood Insurance Program.
Individual Assistance
Congress may wish to consider whether the mitigation measures now provided for IHP Home
Repair Assistance are sufficient, or if FEMA should increase the pace of program implementation
and expedite its consideration of other types of mitigation assistance potentially supported under
IHP for Home Repair Assistance. In addition, Congress could consider allowing mitigation

108 The FY2020 grant winners have not been announced; it appears that the ASFPM was referring here to the projects
selected for further review, as in other places the resolution refers to projects selected.
109 ASFPM, ASFPM Board Unanimously Approves BRIC Resolution, News & Views, Vol. 34, No. 6, December 1,
2021, p. 1, https://asfpm-library.s3.us-west-2.amazonaws.com/NewsViews/NewsViews_December2021_FINAL.pdf.
110 ASFPM, ASFPM BRIC Resolution, pp. 1-3.
111 See, for example, Eric Holdeman and Ann Patton, “Project Impact Initiative To Create Disaster-Resistant
Communities Demonstrates Worth In Kansas Years Later,” Government Technology, July 9, 2009,
https://www.govtech.com/em/safety/project-impact-initiative-to.html; Adam Rose et al., “Benefit-Cost Analysis of
FEMA Hazard Mitigation Grants,” Natural Hazards Review, vol. 8, no. 4 (November 1, 2007), p. 99; and U.S.
Congress, House Committee on Oversight and Reform, Subcommittee on Environment, Testimony of James Lee Witt,
116th Cong., 1st sess., June 25, 2019, https://docs.house.gov/meetings/GO/GO28/20190625/109630/HHRG-116-GO28-
Wstate-WittJ-20190625.pdf.
112 H.R. 5376.
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measures for real property components that did not exist or were not functional prior to the
declared disaster.
Currently, there is not a way for individuals to receive pre-disaster mitigation funding through the
IHP. Congress may wish to consider whether there is a need to expand eligibility for, or programs
that support, pre-disaster mitigation measures in IHP. If so, FEMA will need to determine how to
provide grants of pre-disaster mitigation assistance to individuals. One consideration relates to
whether an individual could apply directly for funding, as is currently the case with HMA, or if
they must have an eligible entity, such as a state, local, tribal, or territorial government, or a
private nonprofit organization, apply on their behalf.
Public Assistance
As noted earlier, a fraction of historical PA obligations has supported mitigation projects. If
Congress wishes to increase mitigation support through PA, Congress could consider a number of
measures.
First, Congress may wish to consider relaxing the restrictions around the use of PA for mitigation;
for example, enhancing FEMA’s authority under the PA program to provide additional assistance
for mitigation and/or building code compliance for entire facilities and/or on non-disaster
damaged components. Congress may wish to enhance FEMA’s authorities to provide PA to cover
the costs of rebuilding in compliance with the highest consensus-based codes for an entire
facility—even if only part of a facility is damaged—to ensure that federal funds promote resilient
rebuilding whenever possible. Congress may also wish to consider directing FEMA to relax
restrictions on cost-effectiveness that PA mitigation projects must meet in order to be approved so
as to promote more resilient PA projects,113 and to re-evaluate how cost effectiveness is measured,
in order to make PA mitigation funding criteria more comparable to HMA mitigation funding
criteria.
FEMA has recently addressed concerns that communities with fewer resources, including low-
income communities, tribal communities, and communities of color, may face barriers to
accessing FEMA grant resources.114 If Congress wishes to improve access to PA for mitigation for
applicants with fewer financial and human resources, Congress could consider increasing the
federal cost-share for communities with fewer resources for certain PA activities (for example, for
mitigation expenses) to acknowledge their reduced financial resources and to ensure that these
communities may access mitigation funds.115 Congress could also increase support for technical
assistance or embedded FEMA mitigation teams to ensure that communities facing capacity
constraints are able to identify and complete mitigation projects through PA.

113 For further information on FEMA cost share requirements for PA, see p. 23 of CRS Report R46749, FEMA’s Public
Assistance Program: A Primer and Considerations for Congress, by Erica A. Lee.
114 See, for example, FEMA, Equity, September 21, 2021, https://www.fema.gov/emergency-managers/national-
preparedness/equity, and National Low Income Housing Coalition, FEMA Holds Civil Rights Summit on Equity:
NLIHC Speaks on Panel of Leaders for Equitable Disaster Recovery, November 22, 2021, https://nlihc.org/resource/
fema-holds-civil-rights-summit-equity-nlihc-speaks-panel-leaders-equitable-disaster.
115 For discussion of these barriers, see Gavin Smith and Olivia Villa, “A National Evaluation of State and Territory
Roles in Hazard Mitigation: Building Local Capacity to Implement FEMA Hazard Mitigation Assistance Grants,”
Sustainability 2020, 12 (23), https://www.mdpi.com/2071-1050/12/23/10013/htm.
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STORM Act
The $500 million appropriated by the IIJA to fund the revolving loan funds under the STORM
Act is less than the amounts that established other revolving loan funds. For example, when the
Drinking Water State Revolving Fund (DWSRF) was established, Congress authorized
appropriations at a level of $599 million for FY1994 and $1 billion annually for each of FY1995
through FY2003.116 Congress may wish to consider whether it should fund the new state
revolving loan funds for a longer period of time, and provide more funding, to give the program
additional time to become established.
Hazard Mitigation Assistance and Equity
Prioritizing Disadvantaged Communities
The Justice40 Initiative is a whole-of-government initiative to ensure that federal agencies work
with states and communities to deliver at least 40% of the overall benefits from federal
investments in climate and clean energy to disadvantaged communities.117 BRIC and FMA have
been selected as pilot programs for the Justice40 Initiative.118 For FY2021, FEMA intends to
promote equity in the delivery of funds as referenced in E.O. 14008119 by prioritizing 40% of the
benefits to disadvantaged communities in both BRIC and FMA.120
However, FEMA has set different criteria related to disadvantaged communities in the two
programs. When scoring applications for FMA funding, FEMA will use the Centers for Disease
Control and Prevention (CDC) Social Vulnerability Index (SVI)121 at the census tract level at a
threshold of 0.7501 or greater as a priority scoring criterion.122 Although the SVI Index was not
mentioned in the FMA FY2020 Notice of Funding Opportunity,123 FEMA used this criterion for
FY2020 submissions to measure the social vulnerability of communities. Of the projects selected,

116 See CRS Report R45304, Drinking Water State Revolving Fund (DWSRF): Overview, Issues, and Legislation, by
Mary Tiemann.
117 The White House, “The Path to Achieving Justice40,” press release, July 20, 2021, https://www.whitehouse.gov/
omb/briefing-room/2021/07/20/the-path-to-achieving-justice40/.
118 Executive Office of the President Office of Management and Budget, Memorandum for the Heads of Departments
and Agencies, M-21-28, Washington, DC, July 20, 2021, p. 12, https://www.whitehouse.gov/wp-content/uploads/2021/
07/M-21-28.pdf.
119 Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” 86 Federal Register 7619-7633,
February 1, 2021, https://www.govinfo.gov/content/pkg/FR-2021-02-01/pdf/2021-02177.pdf.
120 DHS, Notice of Funding Opportunity (NOFO), Fiscal Year 2021 Building Resilient Infrastructure and
Communities, p. 15, https://www.fema.gov/sites/default/files/documents/fema_nofo-fiscal-year-2021-building-resilient-
infrastructure.pdf.
121 The Centers for Disease Control/Agency for Toxic Substances and Disease Registry (CDC/ATSDR) Social
Vulnerability Index (SVI) uses United States Census Data to determine the social vulnerability of every census tract,
ranked on 15 social factors. SVI scores range from 0 to 1, with 1 representing the highest level of social vulnerability.
For example, a SVI ranking of 0.75 means that 75% of census tracts in the nation are less vulnerable than the tract of
interest. See CDC/ATSDR SVI Fact Sheet, https://www.atsdr.cdc.gov/placeandhealth/svi/fact_sheet/fact_sheet.html,
and CDC SVI 2018 Documentation, https://www.atsdr.cdc.gov/placeandhealth/svi/documentation/pdf/
SVI2018Documentation-H.pdf.
122 DHS, Notice of Funding Opportunity (NOFO), Fiscal Year 2021 Flood Mitigation Assistance, p. 4,
https://www.fema.gov/sites/default/files/documents/fema_nofo-fiscal-year-2021-flood-mitigation-assistance-grants.pdf.
123 DHS, Notice of Funding Opportunity (NOFO), Fiscal Year 2020 Flood Mitigation Assistance,
https://www.fema.gov/sites/default/files/2020-08/fema_fy-2020_fma-notice-of-funding-opportunity_0.pdf.
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the average CDC SVI score was 0.47,124 which correlates to a low to moderate level of
vulnerability. The funding appropriated to FMA under the IIJA will provide a 90% federal cost
share125 for a property that is (1) located in a census tract with a CDC SVI score of not less than
0.5001; or (2) that serves as a primary residence for individuals with a household income of not
more than 100% of the applicable area median income.
BRIC does not identify comparable criteria for prioritizing in FY2021, although four of the six
BRIC qualitative evaluation criteria for FY2021 subapplications do require explanation of how
the project will benefit disadvantaged communities.126 In addition, FEMA will reduce the
nonfederal cost share of BRIC from 25%127 to 10% for economically disadvantaged rural
communities.128 This suggests that BRIC may prioritize a narrower range of communities than
FMA.
The ASFPM expressed their concern that FEMA’s definition of small and impoverished
communities “does not include the disadvantaged communities that need FEMA mitigation grant
assistance,” concluding that “a review of the grant projects that have been identified for further
review demonstrates that FEMA did not prioritize vulnerable communities even though FEMA
expressed a desire to do so.”129
Congress may wish to consider requiring BRIC and FMA to use the same priority criteria for
identifying disadvantaged communities, and requiring FEMA to report on the outcomes of the
FY2021 funding round in order to compare funding awarded to disadvantaged communities in
BRIC and FMA.
Capacity Constraints
In addition, some stakeholders have expressed concern that smaller projects or funding for
planning may be less likely to obtain support in BRIC,130 and that small, impoverished, rural, or
historically disadvantaged communities may not have the capacity to apply for and administer the
larger amounts which could be funded by BRIC.131 The increase in funding for pre-disaster

124 FEMA, Flood Mitigation Assistance FY2020 Subapplication Status, https://www.fema.gov/grants/mitigation/floods/
fy2020-subapplication-status.
125 The cost share for FMA funding is generally 75% federal and 25% nonfederal, but FEMA may contribute up to 90%
for repetitive loss properties and 100% for severe repetitive loss properties.
126 FEMA, BRIC Qualitative Criteria, https://www.fema.gov/sites/default/files/documents/fema_fy21-bric-qualitative-
criteria-psm.pdf.
127 Generally, BRIC’s cost share is 75% federal and 25% nonfederal, but small, impoverished communities are eligible
for an increase in cost share up to 90% federal and 10% nonfederal. The Stafford Act defines the term “small
impoverished community” to mean a community of 3,000 or fewer individuals that is economically disadvantaged, as
determined by the state in which the community is located and based on criteria established by the President” (42
U.S.C. §5133(a)).
128 FEMA defined economically disadvantaged rural communities as communities of 3,000 or fewer individuals with
residents having an average per capita annual income not exceeding 80% of national per capita income. See DHS
Notice of Funding Opportunity (NOFO), Fiscal Year 2021 Building Resilient Infrastructure and Communities, p. 12,
https://www.fema.gov/sites/default/files/documents/fema_nofo-fiscal-year-2021-building-resilient-infrastructure.pdf.
129 ASFPM, ASFPM BRIC Resolution, p. 2.
130 FEMA, Summary of Stakeholder Feedback, Building Resilient Infrastructure and Communities (BRIC),
Washington, DC, March 2020, https://www.fema.gov/sites/default/files/2020-06/fema_bric-summary-of-stakeholder-
feedback-report.pdf.
131 See, for example, Thomas Frank, “FEMA Climate Grants Pose Challenge for Poor Communities,” E&E News, June
1, 2021, https://www.eenews.net/climatewire/stories/1063733777/.
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mitigation may also lead to challenges for some communities in meeting the nonfederal cost
share.
The ASFPM noted that mitigation planning projects and capacity building projects were limited
to state set-aside funding only and were excluded from funding under the national competition.
They argued that limiting mitigation planning to highly competitive state set-aside funding has
negatively impacted mitigation planning efforts, especially in large states with many jurisdictions.
They expressed their opposition to FEMA using priorities to limit or give preference to certain
types of mitigation projects, arguing that this is contrary to the stated priority of capacity
building.132
The ASFPM also criticized the BRIC application process, noting that “although FEMA’s stated
intent is to reduce the complexity of their programs and delivery, their actions in nearly every
area are the opposite.” They argued that the BRIC program specifically focuses on large, complex
infrastructure projects that many underserved and disadvantaged communities do not have the
capacity to develop, apply for, manage, and maintain into the future. They also commented on the
complexity of the grant management system and the administration of grant management.133 The
ASFPM recommended that as part of streamlining the application and administrative processes,
FEMA should clearly define what they mean by disadvantaged communities so that all
communities, particularly those with limited resources who are disproportionately affected by
flooding and other disasters, can effectively participate.134
The application scores and ranking process FEMA used to decide which projects will receive
funding were not made public by FEMA. The ASFPM argued that if communities do not know
where they missed points in the scoring process or receive feedback on how applications could be
improved for future funding rounds, not only do they get discouraged, but they cannot take
actions to correct those deficiencies and ensure that future applications are more competitive.
Congress may wish to consider requiring FEMA to provide feedback to communities that were
unsuccessful in order to help them better prepare for future applications. The number of non-
financial Direct Technical Assistance awards could be increased, or some form of technical
assistance could be made available automatically for all communities without the capacity to
apply for, or administer, BRIC funding.
U.S. Territories and Tribal Governments
Another area of equity concern is that states, territories, and communities that are, perhaps, most
in need of pre-disaster mitigation funding did not apply for BRIC or FMA funding. Mississippi,
Puerto Rico, and the United States Virgin Islands did not apply for BRIC funding in FY2020 and
26 states did not submit FMA applications; no territories applied for FMA funding in FY2020.135
U.S. territories may also be at a disadvantage in applications for FMA funding. For example, the
CDC does not provide SVI data for any territories other than Puerto Rico because

132 ASFPM, ASFPM BRIC Resolution, pp. 1-3.
133 For example, the ASFPM stated that the administration of grant management costs to state partners, which used to
be a relatively simple calculation, now requires a seven-page memo describing multiple subapplications and reporting
requirements. See ASFPM, ASFPM BRIC Resolution, pp. 3-4.
134 ASFPM, ASFPM BRIC Resolution, p. 4.
135 FEMA, Flood Mitigation Assistance FY2020 Subapplication Status, https://www.fema.gov/fact-sheet/hazard-
mitigation-assistance-hma-annual-grant-cycle-submissions-summary#fma.
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sociodemographic census variables for the other territories136 are unavailable or are not collected
at similar geographic resolutions as those required for the SVI.137 Congress may wish to direct
FEMA to consider how to prioritize disadvantaged communities in the four territories not
included in the SVI.
The STORM Act also makes less funding available to these four U.S. territories, as it designates
them as insular areas rather than states.138 FEMA is required to reserve no more than 2.5% of the
amount appropriated for FEMA’s administrative costs, technical assistance, and grants to insular
areas. FEMA may make grants to insular areas from any amount remaining from the reserved
2.5%.139 As the IIJA appropriates $100 million annually for FY2022 to FY2026, this means that
no more than $2.5 million is available each year for FEMA’s costs and all grants to five insular
areas. In contrast, in FY2021 BRIC makes up to $1 million available for the five U.S. territories.
Congress may wish to consider whether additional funds should be made available to the four
territories designated as insular areas in the STORM Act.
Also in contrast to BRIC, the STORM Act does not set aside any funding for tribal governments,
and Congress may wish to direct FEMA to ensure that funding is prioritized or set aside for tribal
governments. FEMA could also be required to develop policies that would encourage and support
states, territories, and tribes that have not applied for mitigation funding to do so in future funding
rounds.
Funding Allocations
The ASPFM expressed their concern about a proportionately significant reduction in the state set-
aside amount when considering the total funding available, and suggested that at least 49% of
available funds should allocated to the state and tribal set-aside. They also suggested that FEMA
should allow states, communities, tribes, and territories to decide which projects are awarded.
Another option would be to turn BRIC entirely into a block grant program.140
The original pre-disaster mitigation program, Project Impact, provided funding directly to
communities in every state, regardless of whether the state had experienced a disaster recently.141
BRIC funding could be awarded to every state, either automatically or with a minimal application
process. The Stafford Act sets a minimum amount of funding guaranteed to states: the lessor of
$575,000 or the amount that is equal to 1% of the total funds appropriated to carry out this section
for the fiscal year.142 This minimum amount could be increased to allow disadvantaged
communities to receive funding without the challenges associated with submitting a full
application.

136 American Samoa, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands.
137 Agency for Toxic Substances and Disease Registry, CDC/ATSDR SVI Frequently Asked Questions,
https://www.atsdr.cdc.gov/placeandhealth/svi/faq_svi.html.
138 The Stafford Act generally includes insular areas in the definition of a state (42 U.S.C. §5122(4)), while the
STORM Act only includes the 50 states, the District of Columbia, and Puerto Rico (42 U.S.C. §5135(m)(10)).
139 42 U.S.C. §5135(d)(2)(C).
140 ASFPM, ASFPM BRIC Resolution, p. 2.
141 GAO, Hazard Mitigation: Proposed Changes to FEMA’s Multihazard Mitigation Programs Present Challenges,
GAO-02-1035, September 2002, p. 3, https://www.gao.gov/assets/gao-02-1035.pdf.
142 42 U.S.C. §5133(f)(2)(A).
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Hazard Mitigation and Climate Adaptation
Congress may wish to consider targeting funding to specified communities or types of projects to
encourage climate adaptation actions. For example, climate resilience projects or applications
from communities which are particularly vulnerable to the impacts of climate change could be
awarded a higher federal cost share. Additional funding, or a proportion of the available funding
could be targeted at, or directed to, climate-vulnerable communities.
Both BRIC and the STORM Act require applicants to have had a recent major disaster declaration
within a set period of time. For BRIC, this is seven years for all applicants; in the STORM Act,
this is five years for tribes only. There is no comparable requirement for states. All states,
territories, the District of Columbia, and three tribes are currently eligible for BRIC due to the
COVID-19 major disaster declarations. However, this will not necessarily continue to be the case
in the future, and the majority of tribes will not be able to apply for STORM Act loans.
Restricting pre-disaster mitigation funding to communities which have experienced a disaster
recently could preclude communities with a clear risk under a changing climate from receiving
funding when that risk has not yet eventuated, and may make it more difficult for locations facing
major impacts of climate change to plan ahead. For this reason, Congress may wish to consider
whether these requirements should be relaxed. Congress could choose to appropriate mitigation
funding specifically for communities which are subject to damages from climate impacts, but
which do not receive a major disaster declaration.143
Congress may also wish to direct FEMA to address climate change by requiring communities
receiving mitigation funding to implement higher standards to prepare for climate-change related
impacts, or by requiring communities to restrict development in high-risk areas.
Concluding Comments
As disasters become more frequent and more expensive, there is an increasing interest in reducing
their impacts. The benefits of hazard mitigation—saving lives, protecting property, and reducing
damage from future disasters—are widely accepted. However, GAO has found that federal
investments in resilience could be more effective if post-disaster hazard mitigation were balanced
with resources for pre-disaster hazard mitigation, as part of a comprehensive resilience
investment strategy.144 The recent increases in funding for pre-disaster mitigation represent a
significant step towards changing the balance between and pre- and post-disaster funding.

Author Information

Diane P. Horn

Analyst in Flood Insurance and Emergency
Management

143 See CRS Insight IN11696, Climate Change, Slow-Onset Disasters, and the Federal Emergency Management
Agency, by Diane P. Horn, Erica A. Lee, and Elizabeth M. Webster.
144 GAO, High-Risk Series, GAO-21-119SP, March 2, 2021, p. 28, https://www.gao.gov/products/gao-21-119sp.
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Congressional Research Service
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