Mitigation and Multiple Loss Properties: Factors Influencing the High Cost of Flooding

Mitigation and Multiple Loss Properties: Factors Influencing the High Cost of Flooding

Hearing on "Mitigation and Multiple Loss Properties: Factors Influencing the High Cost of Flooding"

Statement of:

Diane P. Horn, Specialist in Flood Insurance and Emergency Management

Before:

Financial Services Committee, Housing and Insurance Subcommittee, U.S. House of Representatives

March 26, 2026 (TE10122)

Chairman Flood, Ranking Member Cleaver, and Members of the subcommittee, thank you for the opportunity to testify before you today. My name is Diane Horn. I am a Specialist in Flood Insurance and Emergency Management at the Congressional Research Service (CRS) where I focus on federal policy surrounding flood insurance and mitigation of natural hazards. I have been in this role at CRS since 2016. The role of CRS is to provide objective, nonpartisan research and analysis to Congress. CRS takes no position on the desirability of any specific policy. Any arguments presented in my written and oral testimony are intended to inform Congress, not to advocate for a particular policy outcome.

In support of the Committee's investigation into flood mitigation and multiple loss properties, my testimony today will give an overview of federal mitigation efforts to reduce the cost and damage of flooding. The first section will describe key aspects of the National Flood Insurance Program (NFIP) and the approaches it leverages to reduce the cost and damage of flooding. Following this is a discussion of the major federal programs that provide funding to reduce flood risk: the Federal Emergency Management Agency (FEMA) Hazard Mitigation Assistance programs. It concludes with a summary of what is known about the current status of these programs.

Introduction

Flooding is the most frequent and expensive natural hazard in the United States. Approximately 90% of all natural disasters in the U.S. involve a flood.¹ The impacts of natural hazards, including floods, are expected to increase during the useful lifetime of much existing and new U.S. property and infrastructure,² placing an increasing burden on federal, state, and local governments, as well as individuals and businesses. In the United States, as in many countries, increasing losses from natural disasters have been largely attributed to a combination of factors: population growth in disaster-prone areas, rising property values in these areas, inflation and increasing building costs, inadequate building codes, and climatological changes in weather patterns and storm intensities.³ In 2023, the Congressional Budget Office (CBO) looked at potential flooding-related losses to homes with federally backed mortgages in the 30-year period ending in 2050. They estimated that the current expected annual damage of $9.4 billion would rise to about $12.8 billion, with total expected damage projected to increase from $190 billion to $258 billion.⁴

Floods can cause substantial property damage. In turn, this damage can destabilize household finances, particularly when there are significant uninsured losses.⁵ In the U.S., flood damage is not covered under standard homeowners insurance policies; instead, households must pay for direct damages through some combination of self-insurance and optional, though sometimes required, flood insurance. The majority of flood insurance policies in the United States are written by the NFIP.⁶

The National Flood Insurance Program

The NFIP was created by the National Flood Insurance Act of 1968.⁷ Since the end of FY2017, 35 short-term NFIP reauthorizations have been enacted and the NFIP is currently authorized until September 30, 2026.⁸ The general purposes of the NFIP include offering primary flood insurance to properties with significant flood risk and reducing flood risk through the adoption of floodplain management standards. Communities volunteer to participate in the NFIP to have access to federal flood insurance, and in return are required to adopt minimum standards.

As of December 31, 2025, the NFIP had over 4.57 million flood insurance policies providing over $1.3 trillion in coverage to home and business owners, as well as renters. The program collects about $4.6 billion in revenue from policyholders' premiums, fees, and surcharges.⁹ Nationally, 22,745 communities in 56 states and jurisdictions participated in the NFIP as of March 21, 2026.¹⁰

A number of studies have shown that NFIP-insured structures with multiple losses represent a significant portion of annual NFIP claims.¹¹ OpenFEMA data gives some details of multiple loss structures, which FEMA refers to as "repetitive loss" (RL)¹² and "severe repetitive loss" (SRL)¹³ structures, depending on the number and dollar amount of claims. While the OpenFEMA dataset includes the number of claims for each structure,¹⁴ it does not include data on the dollar amount of claims for RL and SRL structures. No information is available online with which to calculate total claims from multiple loss structures.

NFIP Funding

The funding for the NFIP is primarily maintained in an authorized account called the National Flood Insurance Fund (NFIF).¹⁵ NFIP funding comes from several sources, including:

receipts from the premiums of flood insurance policies, including fees and surcharges;

direct annual appropriations for specific costs of the NFIP;

borrowing from the U.S. Treasury when the balance of the NFIF becomes insufficient to pay the NFIP's obligations (e.g., insurance claims); and

claims on reinsurance (if certain "trigger" conditions are met).¹⁶

All premiums from the sale of NFIP insurance policies are transferred to FEMA and deposited in the NFIF.¹⁷ Congress then authorizes FEMA to withdraw funds from the NFIF and use those funds for the specified purposes needed to operate the NFIP. In addition to premiums, Congress has also provided annual appropriations to supplement the NFIP's funding for floodplain mapping activities. Discretionary and mandatory funding levels are set by Congress.¹⁸

NFIP Premium Rates

A key design feature of the NFIP is that policyholders' premiums, fees, and surcharges are intended to pay for all flood-related damages and program expenses. The option to borrow from the U.S. Treasury exists to pay claims for extreme events, as was done after Hurricane Katrina. From the inception of the NFIP, the program has been expected to set premiums that are simultaneously "risk-based" and "reasonable."¹⁹

In 2021, the U.S. Government Accountability Office (GAO) noted that FEMA has been tasked with two competing goals: keeping flood insurance affordable and keeping the NFIP program solvent.²⁰ In many cases, premiums charged by the NFIP do not completely reflect the full risk of loss, so the NFIP has not had sufficient funds to pay claims.²¹ GAO has been reporting since 1983 that this can be attributed to various legislative requirements and that exacerbate the program's fiscal exposure.²² The NFIP has been on the GAO high-risk list since 2006 due to concerns about its long-term fiscal solvency and related operational issues as well as, more recently, concerns about the NFIP's fiscal exposure to climate change.²³ GAO has also noted that while Congress has directed FEMA to provide subsidized premium rates for certain policyholders meeting certain criteria, Congress has not provided FEMA with funds to offset these subsidies and discounts. This has contributed to FEMA's need to borrow from the Treasury to pay NFIP claims.²⁴

In a 2017 report, the Congressional Budget Office estimated that the NFIP had an expected one-year actuarial shortfall²⁵ of $0.7 billion.²⁶ CBO also estimated that the cost of providing discounted rates to some NFIP policies was about $0.3 billion more than the receipts from surcharges created to help cover the costs of those discounts.²⁷ This shortfall was attributed to the fact that NFIP premiums do not fully reflect the risk of its insured policies. This applies both to the risk of individual properties as well as the risk of catastrophic losses to the program as a whole, which FEMA has traditionally managed by relying on its authority to borrow from the Treasury.²⁸

Competing objectives of the NFIP, particularly the desire to keep flood insurance affordable while also ensuring its fiscal solvency, have made it challenging to reform the program.²⁹ Different Administrations and Congresses have placed varied emphases and priorities on affordability or solvency with regard to premium setting.

In 2021, FEMA began introducing a change to the way it calculates NFIP premiums through a system known as Risk Rating 2.0, with the program fully implemented as of April 1, 2023. This change represents the most significant change to the way the NFIP calculates flood insurance premiums since the program's inception. Under Risk Rating 2.0, premiums for individual properties are tied to their actual flood risk and the premium is calculated based on the specific features of an individual property—rather than using a few broad characteristics such as flood zone to classify flood risk, as was done previously.³⁰ GAO analyzed the methodology of Risk Rating 2.0 and concluded that although Risk Rating 2.0 substantially improves ratemaking by aligning premiums with the flood risk of individual properties, other aspects of the NFIP still limit the program's actuarial soundness.

NFIP Borrowing and Debt

A particular challenge for the NFIP is that the premiums collected have been insufficient to cover claims payments from catastrophic flooding events. The NFIP was not designed to retain funding to cover claims from extreme events; there was a recognition by Congress from the beginning of the program that there might be truly exceptional events for which the NFIP would have to borrow from the Treasury and pay it back with interest. Currently, Congress has authorized FEMA to borrow no more than $30.425 billion from the Treasury to operate the NFIP.³¹

Prior to Hurricane Katrina in 2005, the NFIP had generally been able to cover its costs and borrowed relatively small amounts from the Treasury. However, between 2005 and 2024, the NFIP has been forced to borrow heavily to pay claims in the aftermath of a number of catastrophic flood seasons.³² The NFIP most recently borrowed $2 billion from the Treasury in February 2025.³³ Currently the NFIP owes $22.525 billion to the Treasury, with $7.9 billion of remaining borrowing authority.³⁴

Although NFIP borrowing from the Treasury since 2005 has followed major flood events, the NFIP's debt to the Treasury cannot be tied directly to any single incident, as any insurance claim paid by the NFIP is in some way responsible for the existing debt of the NFIP (i.e., a dollar paid in claims, and therefore expended by the NFIP, following a minor flooding incident is no different than a dollar paid following a major hurricane).

The NFIP's debt is conceptually owed by current and future participants in the NFIP, as the insurance program itself owes the debt to the Treasury and pays for accruing interest on that debt through the premium revenues of policyholders. As of October 2023, the NFIP was paying approximately $1.7 million in interest per day on the debt accrued from past events, with an average annual interest rate of 3.02%.³⁵ The burden of the NFIP's debt is expected to grow with increases in benchmark interest rates, as the interest expenses depend exclusively on U.S. Treasury rates.³⁶

As required by law, FEMA submits semiannual debt repayment reports to Congress on how the borrowed amount from the U.S. Treasury could be repaid within a 10-year period.³⁷ The February 2024 report concluded that it is not possible for the NFIP, as currently structured, to fully repay the NFIP debt over the coming 10 years, though the program's financial position is expected to improve.³⁸

Flood Risk Reduction Under the NFIP

FEMA supports a number of flood mitigation initiatives that are designed to reduce flood risk and thus the NFIP's financial exposure. The NFIP accomplishes this primarily by requiring participating communities to collaborate with FEMA to develop and adopt flood maps called Flood Insurance Rate Maps (FIRMs) and enact minimum floodplain standards based on those maps. Communities are required to adopt these minimum floodplain management standards to participate in the NFIP.³⁹ Though these standards appear in federal regulations,⁴⁰ they only have the force of law because they are also adopted and enforced by a state or local government. According to FEMA, the NFIP's flood management standards have saved the nation almost $2.4 billion annually in flood losses avoided.⁴¹ Other risk-reduction activities that are implemented at the state and local level include hazard mitigation planning and the adoption and enforcement of building codes.⁴²

In addition to these standards, the NFIP employs at least three other initiatives to reduce flood risk, including:

Increased Cost of Compliance Coverage;

the Flood Mitigation Assistance Grant Program; and

the Community Rating System.

Increased Cost of Compliance (ICC) Coverage

The NFIP requires most policyholders⁴³ to purchase what is, in effect, a separate insurance policy to offset the expense of complying with more rigorous building code standards when local ordinances require them to do so. This "increased cost of compliance" coverage is authorized in law, and rates for the coverage, as well as how much can be paid out for claims, are set by FEMA.⁴⁴ The premium that can be charged for Increased Cost of Compliance coverage is capped at $75.⁴⁵

The ICC policy provides an amount up to $30,000 in payments for certain eligible expenses. For example, when a building is determined to be substantially damaged⁴⁶ following a flood, floodplain management standards adopted by local communities require that building to be rebuilt to current floodplain management requirements, even if the property previously did not need to do so. For instance, an ICC claim may then be submitted by the policyholder to offset the cost of complying with an elevation standard that may have increased since the property was originally constructed. ICC claims payments may be used toward the costs of elevating, demolishing, relocating, or flood-proofing non-residential buildings, or any combination of these actions. According to FEMA, elevation is the most common form of mitigation funded by ICC.⁴⁷ Although the cost of elevating a structure depends on the type of building and elevation requirement, the average cost of elevating an existing property generally exceeds $30,000. Suggestions from stakeholders and researchers have been made for years that the amount of ICC coverage should be increased.⁴⁸

FEMA also makes ICC coverage available if a building has been declared a "repetitive loss" by a community's floodplain management regulations.⁴⁹ However, not all participating NFIP communities have or enforce a "repetitive loss provision" that records, declares, and mandates improvements to properties that have experienced repetitive loss. Thus, certain structures that have experienced repetitive loss may not be eligible for ICC payments.⁵⁰

Flood Mitigation Assistance Grant Program

The NFIP operates a Flood Mitigation Assistance (FMA) Grant Program that is only available to NFIP-participating communities to assist in efforts to reduce or eliminate flood damage to buildings and structures insurable under the NFIP, particularly repetitive loss (RL) and severe repetitive loss (SRL) properties.⁵¹ The FMA program awards grants for a number of purposes, including state and local mitigation planning; the elevation, relocation, demolition, or flood proofing of covered structures; the acquisition of properties; and other activities.⁵² FMA grants are mainly funded through revenue collected by the NFIP.⁵³ The Infrastructure Investment and Jobs Act (IIJA)⁵⁴ appropriated $3.5 billion for the FMA program, with $700 million for each of FY2022 to FY2026. This represented a significant increase in the amount of funding available for flood mitigation.⁵⁵

Community Rating System

Through a program called the Community Rating System (CRS), FEMA encourages communities to improve upon the minimum floodplain management standards required to participate in the NFIP. The CRS program, as authorized by law, is intended to incentivize the reduction of flood and erosion risk, as well as the adoption of more effective measures to protect natural and beneficial floodplain functions.⁵⁶ To participate in the CRS program, a community must apply to FEMA and document its creditable improvements through site visits and assessments. FEMA awards points that increase a community's "class" rating in the CRS on a scale of 1 to 10, with 1 being the highest ranking. Points are awarded for an array of improvements for how the community informs its public on flood risk; maps and regulates its floodplain; reduces possible flood damage; and provides immediate warnings and responds to flooding incidents.⁵⁷ Starting at Class 9, policyholders in a CRS community receive a 5% discount on their NFIP premiums, with increasing discounts of 5% per class. At the Class 1 level, policyholders can receive a 45% discount on their flood insurance premiums. As of October 2025, two communities have reached CRS Class 1, with 26 communities in Classes 2-4 (discounts of 30% to 40%).⁵⁸ As of October 2025, 1,504 communities participated in the CRS, which represents 6.6% of all NFIP communities;⁵⁹ however, more than 72% of NFIP policies are written in CRS communities.⁶⁰

News reporting and press releases from local governments indicated that, in early March 2026, the contract to administer the NFIP Community Rating System has been cancelled,⁶¹ with at least one community reporting the program to be "inactive."⁶² No information on the status of the CRS program is currently available from FEMA.

Hazard Mitigation Assistance

With the increasing severity and frequency of natural disasters, policymakers often view mitigation⁶³ as a way to control disaster-related spending. The value of federal mitigation funding is illustrated by a 2019 study which looked at the impacts of 23 years of federal mitigation grants provided by FEMA, the Department of Housing and Urban Development (HUD), and the Economic Development Administration (EDA) while also examining the costs and benefits of designing all new construction to exceed select provisions in the 2015 building codes. The study found that for every $1 invested by federal grant programs, society as a whole was expected to save $6, largely due to reduced future losses.⁶⁴ Adopting stronger building codes was estimated to save $11 for every dollar spent.⁶⁵ A separate 2024 study by the U.S. Chamber of Commerce indicated that each dollar invested in resilience and disaster preparedness reduced a community's economic costs after a disaster by approximately $7, saving a total of $13 in reduced future economic costs, damages, and cleanup.⁶⁶

FEMA Hazard Mitigation Assistance

The majority of funding for hazard mitigation comes from FEMA, and this testimony will focus on FEMA's Hazard Mitigation Assistance (HMA) programs. However, other agencies⁶⁷ have also funded mitigation; for example, HUD, through Community Development Block Grant (CDBG) funding, particularly for disaster recovery (CDBG-DR) and its post-disaster mitigation (CDBG-MIT) variant,⁶⁸ as well as the Small Business Administration's Disaster Loan Program.⁶⁹

FEMA-funded mitigation measures aim to provide a long-term solution to a risk or resilience problem. To receive FEMA mitigation funding, a project must demonstrably increase the degree of protection a structure receives against a natural hazard such as flooding. Projects that only return a structure to its previous or pre-disaster condition without increasing its level of protection are not eligible for FEMA mitigation funding.

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 to reduce future damage from an anticipated event, such as flooding. Flood mitigation measures are eligible for FEMA funding through a number of programs:

Any of the HMA grant programs: (1) Building Resilient Infrastructure and Communities (BRIC); (2) the Hazard Mitigation Grant Program (HMGP); (3) the Flood Mitigation Assistance Grant Program; (4) the Pre-Disaster Mitigation Grant Program (PDM); and (5) the Safeguarding Tomorrow Revolving Loan Fund Program (STRLF).

Certain mitigation activities can be funded by FEMA Public Assistance (PA)⁷⁰ and FEMA Individual Assistance (IA).⁷¹

PA, IA, and HMGP are post-disaster funding, and require a form of disaster declaration: an emergency declaration (certain forms of PA and IA), a major disaster declaration from the President (all forms of PA and IA, and HMGP)⁷², or a Fire Management Assistance Grant (FMAG) declaration (certain forms of PA, and HMGP).⁷³ These three programs are funded from the Disaster Relief Fund (DRF). The other programs (BRIC, PDM, and STRLF, as well as FMA) represent pre-disaster mitigation funding, and applicants can request funding from these programs to reduce future risks without waiting for a disaster to occur.⁷⁴ The source of funding for each program is given in Table 1.

The Current Status of HMA Programs

FEMA has made a number of announcements about the status of the BRIC program in 2025 and 2026, which are outlined below. The status of the other HMA programs is unclear, as FEMA has not made announcements about these programs. The analysis below is based on the most recent and publicly available information.

Flood Mitigation Assistance Grant Program

The structure and objectives of the FMA program are discussed in the NFIP section of this testimony.

FEMA issued a Notice of Funding Opportunity (NOFO) for FMA FY2024 on January 6, 2025, with $600 million available.⁷⁵ FEMA retracted the NOFO in mid-February 2025 and it has not been reissued. FEMA has not made any announcements about the status of FMA, but the FMA obligations dashboard⁷⁶ and Congressional Research Service analysis of OpenFEMA data⁷⁷ indicate that, although FEMA obligated funding in 2025 for projects awarded in previous years, no new FMA funding was awarded or obligated in grant years FY2024, FY2025, or FY2026.

Hazard Mitigation Grant Program

The key purpose of HMGP is to ensure that state, local, tribal, and territorial governments have the financial opportunity to plan for and implement hazard mitigation measures that reduce the risk of loss of life and property from future disasters during the reconstruction process following a disaster.⁷⁸ The President may award HMGP funding on request from a state/territory governor or tribal chief executive following a major disaster declaration or FMAG declaration. HMGP funding is awarded on a sliding scale as a percentage of the estimated amount of total federal assistance for the disaster and is normally available statewide (i.e., it is not limited to the hazard or area for which HMGP was awarded). States can use HMGP funds for any eligible activity for any type of hazard (i.e., it does not have to relate to the declared incident type), to include flooding. For example, a receiving state could use HMGP funding allocated pursuant to a declaration for wildfires in one county to conduct flood mitigation in a different county, as long as the activity was eligible.

OpenFEMA data indicates that HMGP has not been approved for any new major disaster declaration since March 18, 2025.

Safeguarding Tomorrow Revolving Loan Fund Program

In 2021, the STORM Act⁷⁹ amended the Stafford Act⁸⁰ to authorize FEMA to enter into agreements with eligible entities to establish hazard mitigation revolving loan funds,⁸¹ but did not appropriate funding. The IIJA appropriated $500 million for STRLF, with $100 million for each of FY2022 through FY2026.

The STRLF program began in FY2023, and NOFOs were issued for FY2023, FY2024, and FY2025. FEMA selected 8 state applications for FY2023 funding⁸² and 12 state applications for FY2024.⁸³ The outcome of the FY2025 NOFO⁸⁴ has not been announced and the FY2026 NOFO has not been issued, and it is unclear to what extent STRLF funds have been obligated.⁸⁵

Pre-Disaster Mitigation Grant Program

Funding for pre-disaster mitigation was first appropriated in 1997 and FEMA used this funding to establish a pilot program called Project Impact.⁸⁶ The Disaster Mitigation Act of 2000⁸⁷ placed pre-disaster mitigation in the Stafford Act and created the Pre-Disaster Mitigation Grant Program.⁸⁸ From FY1997 to FY2018, the funding available for pre-disaster mitigation was appropriated on an annual basis.

Funding for pre-disaster mitigation changed significantly with the passage of Disaster Recovery Reform Act of 2018 (DRRA).⁸⁹ Section 1234 of DRRA authorized a new source of funding for pre-disaster mitigation, for which the President may set aside from the Disaster Relief Fund an amount equal to 6% of the estimated aggregate amount of funding awarded under seven sections of the Stafford Act.⁹⁰ Based on historical disaster expenditures, FEMA's expectation was that this set-aside would receive $300-$500 million per year on average.⁹¹ The disaster assistance associated with the COVID-19 major disaster declarations,⁹² however, resulted in significant additions to this fund. FEMA introduced the BRIC program (discussed below) in FY2020 to distribute the set-aside.

Since FY2022, FEMA has used the PDM program to fund pre-disaster mitigation projects through Community Project Funding (House) and Congressionally Directed Spending (Senate), commonly known as earmarks. PDM funding was made available FY2022-FY2024. Earmarks were not funded for FY2025, and funding for FY2026 has not yet been appropriated.⁹³

Building Resilient Infrastructure and Communities

FEMA introduced a new program, BRIC, in FY2020 to award the funding set aside under DRRA. In addition, the IIJA appropriated an additional $1 billion for BRIC, adding $200 million for each of FY2022 through FY2026. The most recent DRF monthly report shows $5.082 billion set aside for BRIC.⁹⁴

BRIC funding was only awarded in FY2020 through FY2023; during that period, BRIC represented the largest FEMA competitively awarded pre-disaster mitigation program, making over $4.6 billion available. The timeline of recent actions related to BRIC are outlined below.⁹⁵

FEMA issued a NOFO for BRIC FY2024 on January 6, 2025, with $750 million available.⁹⁶

The NOFO was retracted in mid-February.⁹⁷

On April 4, 2025, FEMA issued a press release indicating that it was ending the BRIC program⁹⁸ and issued an advisory update on April 16, 2025 that set out the procedure by which BRIC projects would be cancelled.⁹⁹

In mid-July 2025, 20 states filed a lawsuit against FEMA about the cancellation of BRIC.¹⁰⁰

The judge granted a preliminary injunction on August 5, 2025, "enjoin[ing] [the government] from spending the funds allocated to BRIC for non-BRIC purposes until the court is able to render a final judgment on the merits."¹⁰¹

On August 29, 2025, the states filed an amended complaint.¹⁰²

On December 11, 2025, the judge issued an order permanently enjoining the termination of the BRIC program. The ruling does not compel FEMA to award any specific grants, nor does it enjoin FEMA from replacing the BRIC program in future with a different mitigation program with the authorization and approval of Congress.¹⁰³

FEMA indicated that they would comply with the order, but provided no timetable to restore BRIC.¹⁰⁴

On February 17, 2026, the same states filed a motion asking the court to enforce its order prohibiting FEMA from terminating BRIC.¹⁰⁵

On March 6, 2026, the judge issued an order to enforce the court's December 11, 2025 order, setting deadlines for specific actions within 14 and 21 days of the order.¹⁰⁶

The first deadline set by the judge was on March 20, 2026. By this date, FEMA was required to (1) communicate to each plaintiff state the status of all BRIC projects in that state; (2) identify for the court (i) all BRIC projects that had been awarded; (ii) all BRIC projects moved to phase 2; (iii) all period of performance extensions; and (iv) all BRIC projects for which the defendants had sent requests for information since the December 11, 2025, order; and (3) file a status report on steps remaining and timeline to reverse the termination of BRIC, including when FEMA expected to issue BRIC NOFOs for FY2025 and FY2026.

The second deadline set by the judge is March 27, 2026, when FEMA is required to issue the FY2024 BRIC NOFO.

On March 20, 2026, FEMA filed a status report with the court describing actions it has taken to comply with the December 11, 2025 order.¹⁰⁷

On March 18, 2026, FEMA sent letters to each plaintiff state's emergency management agency providing each agency with the status of BRIC projects in its respective states. In addition, FEMA communicated to all other BRIC recipients (consisting of 144 states, tribal nations, and territories) the status of their BRIC projects.

FEMA has directed its Regional Offices to begin communicating with existing applicants and recipients, and has issued advisories to congressional offices, states, tribal nations, and territories, as well as private stakeholders, about programmatic support for BRIC awards and subapplications.

FEMA is to publish a combined FY2024 and FY2025 NOFO on or before March 27, 2026. The combined FY2024 and FY2025 NOFOs would make available up to $1 billion in funding. FEMA plans to use this funding opportunity to make available the entire remaining appropriation for BRIC under the IIJA. This includes funds appropriated for FY2025 and FY2025. In addition to IIJA funding, the $1 billion funding opportunity includes funds from the BRIC set-aside within the DRF.

FEMA plans to publish the FY2026 NOFO in early FY2027.

Table 1. FEMA Programs Providing Funding for Hazard Mitigation

Source of Funding and Status in 2025 and 2026

Program

Statutory Authorization

Source of Funding

Status in March 2026

IA

Stafford Act Section §408

Post-disaster, funded from DRF

Mitigation funding continues to be awarded

PA

Stafford Act Section §406

Post-disaster, funded from DRF

Mitigation funding continues to be awarded

HMGP

Stafford Act Section §404

Post-disaster, funded from DRF

No new awards approved since March 18, 2025

FMA

National Flood Insurance Act §4104c

Pre-disaster, funded by NFIP policyholders and additional appropriations from IIJA for FY2022-FY2026

No new awards in grant years FY2024, FY2025, FY2026

STRLF

Stafford Act Section §205

Pre-disaster, funded by appropriations from IIJA for FY2022-FY2026

Not clear

PDM

Stafford Act Section §203

Pre-disaster, funded by annual appropriations

Community Project Funding and Congressionally Directed Spending not funded in FY2025; funding for FY2026 not yet appropriated

BRIC

Stafford Act Section §203

Pre-disaster; funded from 6% set-aside in DRF and additional appropriation from IIJA for FY2022-FY2026

FY2024 BRIC NOFO to be issued on or before March 27, 2026

Source: CRS's analysis of OpenFEMA data and FEMA policies; Robert T. Stafford Disaster Relief and Emergency Assistance Act (P.L. 93-288, as amended); Disaster Recovery Reform Act of 2018 (DRRA, P.L. 115-24); Infrastructure Investment and Jobs Act (IIJA, P.L. 117-58); Safeguarding Tomorrow through Ongoing Risk Mitigation (STORM) Act of 2020 (P.L. 116-284).

Notes: This table reports new funding in calendar years 2025 and 2026. FEMA obligated funding in 2025 and 2026 for projects awarded in previous years.

Footnotes

1.

FEMA, Flooding Happens Everywhere, https://www.floodsmart.gov/ and FEMA, Know Your Risk of Flooding, https://www.floodsmart.gov/know-your-risk/cost-of-flooding.

2.

Multihazard Mitigation Council, National Institute of Building Sciences, Natural Hazard Mitigation Saves, 2017 Interim Report, Washington, DC, December 2017, p. 17, https://www.preventionweb.net/files/56608_nibsmitigationsavesinterim.pdf.

3.

See, for example, J.P. Morgan, Insurance: Weathering the Storm of Inflation, Climate Change, and Market-Distorting State Regulation, March 31, 2025, https://www.jpmorgan.com/content/dam/jpm/cib/documents/Weathering_the_storm.pdf (hereinafter J.P. Morgan: Insurance); Swiss Re, "2025 marks sixth year insured natural catastrophe losses exceed USD 100 billion, finds Swiss Re Institute," press release, December 16, 2025, wissre.com/press-release/2025-marks-sixth-year-insured-natural-catastrophe-losses-exceed-USD-100-billion-finds-Swiss-Re-Institute/f710c271-58c8-4c48-9004-05203634d1e0; and Munich Re, "Climate Change Presses On: Devastating Wildfires and Intense Thunderstorms Exacerbate Losses for Insurers," press release, January 13, 2026, https://www.munichre.com/en/company/media-relations/media-information-and-corporate-news/media-information/2026/natural-disaster-figures-2025.html.

4.

Congressional Budget Office, Flood Damage and Federally Backed Mortgages in a Changing Climate, Publication 59379, Washington, DC, November 13, 2023, https://www.cbo.gov/publication/59379. CBO estimates account only for changes in flood risk. The underlying housing stock, housing values, flood protection infrastructure, insurance prices, population, and economic variables are fixed at their 2020 levels.

5.

See, for example, Benjamin Collier and Carolyn Kousky, Household Financial Resilience after Severe Climate Events: The Role of Insurance, Temple University Fox School of Business Research Paper, June 1, 2024, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4857411; and.Eva Nagypal and Judith Ricks, Flood Risk and the U.S. Mortgage Market, Consumer Financial Protection Bureau, Report by Office of Research Publication, January 13, 2025, p. 2, https://files.consumerfinance.gov/f/documents/cfpb_Flood-Risk-and-Mortgages_Report_2025-01.pdf.

6.

Firas Saleh, "Why Does the U.S. Flood Insurance Gap Persist, and How Can Private Insurance Transform the Market? ," Moody's, December 3, 2025, https://www.moodys.com/web/en/us/insights/insurance/us-flood-insurance-gap-how-private-insurers-can-transform-the-market.html.

7.

Title XIII of P.L. 90-448, as amended, 42 U.S.C. §§4001 et seq.

8.

P.L. 119-75.

9.

Statistics on the NFIP policy and claims are available from FEMA's website: https://agents.floodsmart.gov/flood-maps-and-data/flood-insurance-data.

10.

Detailed information about which communities participate and where they are located is available from the Community Status Book, found on FEMA's website at https://www.fema.gov/flood-insurance/work-with-nfip/community-status-book.

11.

See, for example, U.S. Government Accountability Office (GAO), National Flood Insurance Program: Fiscal Exposure Persists Despite Property Acquisitions, GAO-20-508, June 25, 2020, https://www.gao.gov/products/gao-20-508; Office of the Inspector General, Department of Homeland Security, FEMA Is Not Effectively Administering a Program to Reduce or Eliminate Damage to Severe Repetitive Loss Properties, OIG-20-68, September 8, 2020, https://www.oig.dhs.gov/sites/default/files/assets/2020-09/OIG-20-68-Sep20.pdf; Noreen Clancy, Lloyd Dixon, and Erin N. Leidy, et al., One- to- Four-Family Properties with Multiple Losses Insured by the National Flood Insurance Program: Property Characteristics, Community Demographics, and Mitigation Strategies, RAND, July 19, 2023, https://www.rand.org/pubs/research_reports/RRA2462-1.html; Anna Weber, Losing (More) Ground: Updated Severe Repetitive Loss Data, Natural Resources Defense Council, January 9, 2024, https://www.nrdc.org/bio/anna-weber/losing-more-ground-updated-severe-repetitive-loss-data; and Anna Weber, Susan Lee, and Joel Scata, Flooded Again: Flood Data Visualization Tool, Natural Resources Defense Council, September 17, 2024, https://www.nrdc.org/resources/flooded-again-flood-data-visualization-tool.

12.

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.

13.

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).

14.

FEMA, OpenFEMA Dataset: NFIP Multiple Loss Properties – v1, https://www.fema.gov/openfema-data-page/nfip-multiple-loss-properties-v1.

15.

The NFIF is authorized by 42 U.S.C. §4017.

16.

Reinsurance is essentially insurance for insurers. The NFIP purchased reinsurance between 2016 and 2025. The NFIP has not made a traditional reinsurance purchase in 2026. The NFIP also transferred risk to the private risk market through the issuance of catastrophe bonds between 2018 and 2024. The NFIP did not issue a catastrophe bond in 2025, and no information is available on NFIP reinsurance or catastrophe bonds in 2026. The NFIP has claimed on reinsurance once, after Hurricane Harvey in 2017, receiving the full $1.042 billion of coverage. For further information, see FEMA, National Flood Insurance Program's Reinsurance Program, https://www.fema.gov/flood-insurance/work-with-nfip/reinsurance, and CRS Report R44593, Introduction to the National Flood Insurance Program (NFIP), by Diane P. Horn and Baird Webel, pp. 28-31.

17.

42 U.S.C. §4017(b).

18.

For details of the budget authority for the NFIP in FY2015 to FY2023, see Table 5 in CRS Report R44593, Introduction to the National Flood Insurance Program (NFIP), by Diane P. Horn and Baird Webel.

19.

See 82 Stat. 573 for text in original statute (§1302(c) of P.L. 90-448). This language remains in statute (see 42 U.S.C. §4001(c)).

20.

GAO, High-Risk Series: Dedicated Leadership Needed to Address Limited Progress in Most High-Risk Areas, GAO-21-119SP, March 2, 2021, pp. 281-283, https://www.gao.gov/products/gao-21-119sp.

21.

See, for example, GAO, Flood Insurance: Comprehensive Reform Could Improve Solvency and Enhance Resilience (hereinafter GAO Solvency), GAO-17-425, April 2017, https://www.gao.gov/products/GAO-17-425.

22.

GAO, National Flood Insurance Program: Fiscal Exposure Persists Despite Property Acquisitions, GAO-20-509, June 25, 2020, p. 29, https://www.gao.gov/assets/710/707821.pdf.

23.

GAO, Climate Change: Opportunities to Reduce Federal Fiscal Exposure, Testimony Before the Committee on the Budget, House of Representatives, GAO-19-625T, June 11, 2019, p. 7, https://www.gao.gov/products/gao-19-625t.

24.

GAO Solvency, p. 17.

25.

An actuarial shortfall is when income from premiums, fees, and surcharges is too low to cover the costs associated with paying claims on existing policies and writing and servicing those policies. Congressional Budget Office (CBO), The National Flood Insurance Program: Financial Soundness and Affordability (hereinafter CBO Affordability), Washington, DC, September 1, 2017, p. 7, https://www.cbo.gov/system/files/115th-congress-2017-2018/reports/53028-nfipreport2.pdf. Note that this report was published before the introduction of Risk Rating 2.0.

26.

CBO Affordability, pp. 4-5. The actuarial shortfall estimated by CBO in this report excludes $0.7 billion for mapping floodplains, mitigating flood risk, and interest payment on the NFIP's debt to the Treasury.

27.

CBO Affordability, p. 8.

28.

GAO, National Flood Insurance Program: Fiscal Exposure Persists Despite Property Acquisitions, GAO-20-509, June 25, 2020, p. 32, https://www.gao.gov/assets/710/707821.pdf.

29.

GAO Solvency, p. 1.

30.

For additional information on Risk Rating 2.0, see CRS Report R45999, National Flood Insurance Program: The Current Rating Structure and Risk Rating 2.0, by Diane P. Horn, and CRS Insight IN11777, National Flood Insurance Program Risk Rating 2.0: Frequently Asked Questions, by Diane P. Horn.

31.

P.L. 113-1.

32.

Hurricane Katrina in 2005; Hurricane Sandy in 2012; Hurricanes Harvey, Irma, and Maria in 2017; and Hurricanes Helene and Milton in 2024.

33.

FEMA, "FEMA Exercises Borrowing Authority for National Flood Insurance Program," press release, February 10, 2025, https://www.fema.gov/press-release/20250210/fema-exercises-borrowing-authority-national-flood-insurance-program.

34.

For details of NFIP borrowing from the Treasury, see CRS Insight IN10784, National Flood Insurance Program Borrowing Authority, by Diane P. Horn.

35.

FEMA, "National Flood Insurance Program Continues to Pay Interest on its Treasury Debt," press release, October 24, 2023, https://www.fema.gov/press-release/20231024/national-flood-insurance-program-continues-pay-interest-its-treasury-debt.

36.

FEMA, National Flood Insurance Program Debt Repayment Report, as of September 30, 2023, Report to Congress and the Secretary of the Treasury, February 14, 2024, p. 6. The February 2024 report is the most recent debt repayment report provided by FEMA to CRS.

37.

See 42 U.S.C. §4016(d), as enacted by §100213(a) of P.L. 112-141 (BW-12).

38.

FEMA, National Flood Insurance Program Debt Repayment Report, as of September 30, 2023, Report to Congress and the Secretary of the Treasury, February 14, 2024, p. 6.

39.

42 U.S.C. §4022(a)(1).

40.

See 44 C.F.R. Part 60, particularly 44 C.F.R. §60.3.

41.

U.S. Congress, Senate Committee on Banking, Housing, and Urban Affairs, Reauthorization of the National Flood Insurance Program, Part II, Statement of David Maurstad, Deputy Associate Administrator for Insurance and Mitigation, Federal Insurance and Mitigation Administration, FEMA, 117th Cong., 1st sess., June 17, 2021, p.2, https://www.banking.senate.gov/imo/media/doc/Maurstad Testimony 6-17-21.pdf.

42.

GAO Solvency, p. 5.

43.

For example, ICC coverage is not required on condominium units and content-only policies.

44.

42 U.S.C. §4011(b).

45.

Ibid.

46.

44 C.F.R. §59.1 defines "substantial damage" as damage of any origin sustained by a structure whereby the cost of restoring the structure to its before damaged condition would equal or exceed 50% of the market value of the structure before the damage occurred.

47.

FEMA, NFIP: Use of Increased Cost of Compliance Coverage, FY2009 Report to Congress, October 2009, p. 6. Report provided by FEMA Congressional Affairs Staff.

48.

See, for example, Association of State Floodplain Managers, Suggestions for Improving Increased Cost of Compliance Coverage Under the National Flood Insurance Program, 2007, http://www.floods.org/PDF/ASFPM_ICC_Positions_Recommendations_0807.pdf; FEMA, NFIP: Use of Increased Cost of Compliance Coverage, FY2009 Report to Congress, October 2009, p. 32; and Lingle, B. and Kousky, C., Mitigation Post-Flood: FEMA's Increased Cost of Compliance (ICC) Coverage, http://www.rff.org/blog/2017/mitigation-post-flood-fema-s-increased-cost-compliance-icc-coverage.

49.

42 U.S.C. §4011(b)(1).

50.

For additional information on repetitive loss and repetitive loss provisions, see FEMA, Increased Cost of Compliance (ICC) Coverage, https://www.fema.gov/floodplain-management/financial-help/increased-cost-compliance.

51.

In 2012, Congress mandated that the grant assistance previously delivered by two grant programs specifically directed at properties with multiple losses, the Repetitive Flood Claims (RFC) and the Severe Repetitive Loss (SLR) grant programs, should be unified into a single program, Flood Mitigation Assistance (FMA), by rescinding the authorization for the SLR program and the RFC program. See Sections 100225(b)-(c) of P.L. 112-141, respectively.

52.

For additional information on the FMA Program, see 44 C.F.R. Part 78, and FEMA's website, https://www.fema.gov/grants/mitigation/floods.

53.

42 U.S.C. §4104c.

54.

P.L. 117-58.

55.

For the amounts of funding available for the FMA program FY2015 to FY2023, see Table 5 in CRS Report R44593, Introduction to the National Flood Insurance Program (NFIP), by Diane P. Horn and Baird Webel.

56.

42 U.S.C. §4022(b)(1).

57.

For a full listing of possible creditable activities in the Community Rating System (CRS), see FEMA, NFIP Community Rating Coordinator's Manual 2017, https://www.fema.gov/sites/default/files/documents/fema_community-rating-system_coordinators-manual_2017.pdf.

58.

FEMA, Community Rating System: CRS Data Visualizations, https://www.fema.gov/floodplain-management/community-rating-system.

59.

FEMA, Community Rating System: CRS Participating Communities, https://www.fema.gov/floodplain-management/community-rating-system#participating.

60.

FEMA, Frequently Asked Questions: Community Rating System Discount, September 2024, https://agents.floodsmart.gov/sites/default/files/media/document/2025-07/fema-nfip-community-rating-system-discount-faq-09-2024.pdf.

61.

Chad Berginnis, NFIP Code Blue, News and Views from the Director's Desk, Association of State Floodplain Managers, March 13, 2026, https://www.floods.org/news-views/from-the-directors-desk/nfip-code-blue/.

62.

City of Port Richey, Florida, "The CRS Program is Inactive - Not Cancelled," press release, March 20, 2026, https://www.cityofportrichey.gov/development-services/page/crs-program-inactive-not-cancelled.

63.

FEMA defines mitigation as any sustained action to reduce or eliminate long-term risk to people and property from natural hazards and their effects.

64.

This is an average for four natural hazards: riverine flooding (7:1), hurricane winds (5:1), earthquakes (3:1), and wildfires (3:1).

65.

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.

66.

U.S. Chamber of Commerce, The Preparedness Payoff: The Economic Benefits of Investing in Climate Resilience, June 25, 2024, p. 8, https://www.uschamber.com/assets/documents/USChamber_AllState-2024-Climate-Resiliency-Report.pdf.

67.

See, for additional information, CRS Report WMR10001, CRS Guide to Federal Emergency Management, by Lauren R. Stienstra et al. and CRS Infographic IG10047, Federal Business Disaster Assistance, coordinated by Bruce R. Lindsay and Julie M. Lawhorn.

68.

For additional information, see HUD, CDBG Disaster Recovery Funds, https://www.hudexchange.info/programs/cdbg-dr/, and CRS Report R46475, The Community Development Block Grant's Disaster Recovery (CDBG-DR) Component: Background and Issues, by Joseph V. Jaroscak.

69.

For additional information, see SBA, Disaster Assistance, https://www.sba.gov/funding-programs/disaster-assistance, and CRS Report R45238, FEMA and SBA Disaster Assistance for Individuals and Households: Application Processes, Determinations, and Appeals, by Bruce R. Lindsay and Elizabeth M. Webster.

70.

For more information, see FEMA, Public Assistance Hazard Mitigation, https://www.fema.gov/assistance/public/hazard-mitigation, and CRS Report R46749, FEMA's Public Assistance Program: A Primer and Considerations for Congress, by Erica A. Lee.

71.

For more information, see FEMA, Individual Assistance, https://www.fema.gov/assistance/individual, and CRS Report R46014, FEMA Individual Assistance Programs: An Overview, by Elizabeth M. Webster.

72.

For more information, see FEMA, How a Disaster Gets Declared, https://www.fema.gov/disaster/how-declared; and CRS Report R43784, FEMA's Disaster Declaration Process: A Primer, by Bruce R. Lindsay.

73.

For more information, see FEMA, Fire Mitigation Assistance Grants, https://www.fema.gov/assistance/public/fire-management-assistance.

74.

For additional information on FEMA Hazard Mitigation Assistance, see CRS Report R46989, FEMA Hazard Mitigation: A First Step Toward Climate Adaptation, by Diane P. Horn; CRS In Focus IF12833, Post-Disaster and Pre-Disaster Hazard Mitigation Assistance, by Diane P. Horn; and CRS Insight IN12642, Funding for FEMA Hazard Mitigation Assistance in 2025, by Diane P. Horn.

75.

FEMA, Notice of Funding Opportunity for Fiscal Year 2024 Flood Mitigation Assistance Program, https://www.fema.gov/sites/default/files/documents/fema_hma_fma-nofo-fact-sheet_fy2024.pdf.

76.

FEMA, Building Resilient Infrastructure and Communities and Flood Mitigation Assistance Obligations Dashboard, https://www.arcgis.com/apps/dashboards/8812b5926abd408cbb340b2159b98732. Data last refreshed January 29, 2026. Accessed March 22, 2026.

77.

FEMA: OpenFEMA Dataset: HMA Subapplications – v2, https://www.fema.gov/openfema-data-page/hma-subapplications-v2.

78.

FEMA, Hazard Mitigation Assistance Program and Policy Guide, Version 2.1, FP-206-21-0001, January 1, 2025, p. 5, https://www.fema.gov/sites/default/files/documents/fema_hma-guide-v2.1_2025.pdf.

79.

P.L. 116-284, Safeguarding Tomorrow through Ongoing Risk Mitigation Act (STORM Act).

80.

42 U.S.C. §5135.

81.

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.

82.

FEMA, Safeguarding Tomorrow Revolving Loan Fund Program Fiscal Year 2023 Selections, https://www.fema.gov/grants/mitigation/learn/storm-rlf/after-you-apply/fiscal-year-2023-selections.

83.

FEMA, Safeguarding Tomorrow Revolving Loan Fund Program Fiscal Year 2024 Selections, https://www.fema.gov/grants/mitigation/learn/storm-rlf/after-you-apply/fy-24-selections.

84.

Grants.gov, NOFO for Fiscal Year 2025 Safeguarding Tomorrow Revolving Loan Fund Program, https://www.grants.gov/search-results-detail/358188.

85.

FEMA does not report STRLF funding in the OpenFEMA datasets.

86.

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.

87.

P.L. 106-390.

88.

42 U.S.C. §5133.

89.

P.L. 115-24.

FEMA, FEMA Fact Sheet: Notice of Funding Opportunity for Fiscal Year 2024 Flood Mitigation Assistance Program, https://www.fema.gov/sites/default/files/documents/fema_hma_fma-nofo-fact-sheet_fy2024.pdf.

90.

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.

91.

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.

92.

FEMA, COVID-19 Declarations, https://www.fema.gov/covid-19.

93.

For additional details of PDM and earmarks, see CRS Insight IN12642, Funding for FEMA Hazard Mitigation Assistance in 2025, by Diane P. Horn, CRS Report RS22866, Earmark Disclosure Rules in the House: Member and Committee Requirements, by Megan S. Lynch, and CRS Report RS22867, Earmark Disclosure Rules in the Senate: Member and Committee Requirements, by Megan S. Lynch.

94.

FEMA, Disaster Relief Fund: Monthly Report as of January 31, 2026, Fiscal Year 2026 Report to Congress, February 20, 2026, p. 17, https://www.fema.gov/sites/default/files/documents/fema_ocfo_disaster-relief-fund-report_012026.pdf.

95.

For additional information and a detailed timeline of the status of BRIC and hyperlinks to all of the actions on this list, see CRS Insight IN12609, FEMA's Building Resilient Infrastructure and Communities (BRIC): Recent Developments, by Diane P. Horn. Note that several of the FEMA documents have been removed from the agency website.

96.

Grants.gov, NOFO for Fiscal Year 2024 Building Resilient Infrastructure and Communities (BRIC), https://www.grants.gov/search-results-detail/358006.

97.

Thomas Frank, "FEMA Docs for Addressing Climate Change Disappear from Websites," E&E News by Politico, February 18, 2025, https://www.eenews.net/articles/fema-docs-for-addressing-climate-change-disappear-from-websites/.

98.

FEMA Cancels BRIC Program, Returns Millions in Unused Funds to U.S. Treasury," Government Technology & Service Coalition's Homeland Security Today, April 7, 2025, https://wordpress-1394530-5169507.cloudwaysapps.com/subject-matter-areas/emergency-preparedness/fema-cancels-bric-program-returns-millions-in-unused-funds-to-u-s-treasury/. Note that the press release was removed from the FEMA website.

99.

"Update on FEMA Ending the Building Resilient Infrastructure and Communities Program," Government Technology & Service Coalition's Homeland Security Today, April 21, 2025, https://www.hstoday.us/subject-matter-areas/emergency-preparedness/update-on-fema-ending-the-building-resilient-infrastructure-and-communities-program/. Note that the advisory update was removed from the FEMA website.

100.

Complaint, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. July 16, 2025), ECF No. 1, available at https://storage.courtlistener.com/recap/gov.uscourts.mad.286918/gov.uscourts.mad.286918.1.0.pdf.

101.

Memorandum and Order on Plaintiffs' Motion for a Preliminary Injunction, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. Aug. 5, 2025), ECF No. 79, available at https://storage.courtlistener.com/recap/gov.uscourts. mad.286918/gov.uscourts.mad.286918.79.0.pdf.

102.

First Amended Complaint, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. Aug. 29, 2025), ECF No. 85, available at https://storage.courtlistener.com/recap/gov.uscourts.mad.286918/gov.uscourts.mad.286918.85.0.pdf.

103.

The Summary Judgment Order, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. Dec. 11, 2025), ECF No. 130, available at gov.uscourts.mad.286918.130.0.pdf.

104.

Thomas Frank, "Emails Show DHS Agreed to Restore Canceled Disaster Grant Program," E&E News by Politico, February 18, 2026, https://www.eenews.net/articles/emails-show-dhs-agreed-to-restore-canceled-disaster-grant-program/.

105.

Motion to Enforce the Court's Summary Judgment Order, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. Feb. 17, 2026), ECF No. 132, available at https://storage.courtlistener.com/recap/gov.uscourts.mad.286918/gov.uscourts.mad.286918.132.0.pdf.

106.

Order to Enforce the Court's Summary Judgment Order, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. March 6, 2026), ECF No. 137, available at https://storage.courtlistener.com/recap/gov.uscourts.mad.286918/gov.uscourts.mad.286918.137.0.pdf.

107.

Status Report, Washington v. Federal Emergency Management Agency, No. 1:25-cv-12006 (D. Mass. March 20, 2026), ECF No. 138.