State Mitigation Plan Review Guide - FEMA.gov

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State Mitigation PlanReview GuideReleased March 2015Effective March 2016FP 302-094-2

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State Mitigation Plan Review Guide 2015Table of ContentsList of Acronyms and Abbreviations . iiiSECTION 1: INTRODUCTION . 11.1 Purpose . 11.2 Guiding Principles . 21.3 Organization . 3SECTION 2: MITIGATION PLANNING RESPONSIBILITIES. 52.1 FEMA Responsibilities . 52.1.1 Communicating Mitigation Plan Status . 52.1.2 Mitigation Program Consultation . 62.2 State Responsibilities . 8SECTION 3: STANDARD STATE PLAN REQUIREMENTS . 113.1 Planning Process . 113.2 Hazard Identification and Risk Assessment. 133.3 Mitigation Strategy. 173.4 State Mitigation Capabilities . 193.5 Local Coordination and Mitigation Capabilities . 203.6 Plan Review, Evaluation, and Implementation . 223.7 Adoption and Assurances. 233.8 Repetitive Loss Strategy. 25SECTION 4: ENHANCED STATE PLAN REQUIREMENTS . 274.1 Meet Required Standard Plan Elements. 284.2 Integrated Planning . 284.3 State Mitigation Capabilities . 294.4 HMA Grants Management Performance. 32APPENDIX A: SUBMISSION AND REVIEW PROCEDURES. 35A.1 Communication . 35A.2 Plan Submittal . 35A.3 Plan Adoption. 35A.4 Plan Review Status. 36A.4.1 Requires Revisions . 36A.4.2 Approvable Pending Adoption . 36A.4.3 Approved . 36A.5 Enhanced State Mitigation Plan Review . 36A.5.1 Status Categories . 37A.5.2 Hazard Mitigation Assistance Grants Management Performance Review . 38A.5.3 FEMA Regional Review . 38A.5.4 National Review Panel . 38A.5.5 Enhanced Plan Review Procedure Summary . 39A.6 Review of Mitigation Commitments. 40APPENDIX B: STATE MITIGATION PLAN REVIEW TOOL . 43B.1 Plan Review Tool Summary . 44Page i

State Mitigation Plan Review Guide 2015B.2B.3B.4Standard State Mitigation Plan Regulation Checklist . 45Enhanced State Mitigation Plan Regulation Checklist . 47Strengths and Opportunities for Improvement . 48APPENDIX C: APPROVAL LETTER TEMPLATE . 49APPENDIX D: CONSULTATION SUMMARY TEMPLATE . 51TablesTable A-1. Summary of Enhanced Plan Status, Review Panel Types, and Review PanelComposition. . 37Table A-2. Summary of Enhanced Plan Review Procedures. . 39Page ii

State Mitigation Plan Review Guide 2015List of Acronyms and AbbreviationsAPAApprovable Pending AdoptionBW-12Biggert-Waters Flood Insurance Reform Act of 2012CFRCode of Federal RegulationsCRSCommunity Rating SystemFEMAFederal Emergency Management AgencyFFRFederal Financial ReportFMAFlood Mitigation AssistanceFMAGFire Management Assistance GrantsHMAHazard Mitigation AssistanceHMGPHazard Mitigation Grant ProgramNFIPNational Flood Insurance ProgramPA C-GPublic Assistance Categories C-GPDMPre-Disaster Mitigation ProgramPPDPresidential Policy DirectiveRisk MAPRisk Mapping, Assessment, and Planning ProgramRLRepetitive LossSFStandard FormSRLSevere Repetitive LossU.S.C.United States CodePage 3

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State Mitigation Plan Review Guide 2015SECTION 1: INTRODUCTION1.1PurposeHazard mitigation is sustained action to reduce or eliminate the long‐term risk to humanlife and property from hazards. Natural hazard mitigation planning is a process used bystate, tribal, and local governments to engage stakeholders, identify hazards andvulnerabilities, develop a long-term strategy to reduce risk and future losses, andimplement the plan, taking advantage of a wide range of resources. A state mitigationplan demonstrates commitment to reduce risks from natural hazards and serves as a guidefor decision makers for reducing the effects of natural hazards as resources arecommitted.FEMA supports hazard mitigation planning as a means to: Foster partnerships for natural hazard mitigation;Promote more resilient and sustainable states and communities; andReduce the costs associated with disaster response and recovery.This State1Mitigation Plan Review Guide (Guide) is FEMA’s official policy on andinterpretation of the natural hazard mitigation planning requirements.2 The intended useof the Guide is to facilitate consistent evaluation and approval of state mitigation plans,as well as to facilitate state compliance with the mitigation planning requirements whenupdating plans. Separate local and tribal mitigation planning guidance is available fromthe FEMA Mitigation Planning website.This Guide incorporates principles from the following documents: Presidential Policy Directive (PPD)o PPD 8 National Preparedness (March 2011)o PPD 21 Critical Infrastructure Security and Resilience (February 2013) National Preparedness Goal3 (September 2011)1For mitigation planning, the term “state” is inclusive of the District of Columbia, American Samoa, Commonwealthof Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands [44 Code of Federal Regulations (CFR)§201.2 Definitions]. Indian tribal governments follow the Tribal Multi-Hazard Mitigation Planning Guidance. Ifinterested in being eligible for the 20 percent Hazard Mitigation Grant Program funding, the tribal mitigation plan mustmeet the enhanced state mitigation plan criteria presented in this Guide [44 CFR §201.3(e)(3)].2The mitigation planning requirements are authorized under the Robert T. Stafford Disaster Relief and EmergencyAssistance Act (Stafford Act) (Public Law 93-288; 42 United States Code [U.S.C.] 5121 et seq.), as amended by theDisaster Mitigation Act of 2000; National Flood Insurance Act of 1968, as amended [42 U.S.C. 4001 et seq.]; 44 CFRPart 201 Mitigation Planning; and 44 CFR Part 206, Subpart N Hazard Mitigation Grant Program, §206.434 Eligibility.3“A secure and resilient nation with the capabilities required across the whole community to prevent, protect against,mitigate, respond to, and recover from the threats and hazards that pose the greatest risk.”Page 1

State Mitigation Plan Review Guide 2015 National Mitigation Framework (May 2013)FEMA’s Climate Change Adaptation Policy (January 2012)Executive Order 13653: Preparing the United States for the Impacts of ClimateChange (November 2013)This Guide supersedes the following policies: “Multi-Hazard Mitigation Planning Guidance under the Disaster Mitigation Actof 2000” (January 2008) “Guidance to FEMA Regions and States for Updating Standard State MultiHazard Mitigation Plans” (Mitigation Planning Memorandum #5, November 6,2006) “Blue Book Guidance to FEMA Regions and States for New and UpdatedEnhanced State Multi-Hazard Mitigation Plans” (Mitigation PlanningMemorandum #7, July 10, 2007) “Implementation of State Mitigation PlanRequirement for Severe Repetitive LossStrategy” (Mitigation PlanningMemorandum #9, January 11, 2008)FEMA supports hazard “Enhanced Mitigation Plan Reviewmitigation planning as aProcedure” (Mitigation Planningmeans to:Memorandum #14, December 6, 2010) Foster partnerships for “Restrictions on Grant Obligations tonatural hazard mitigation;State, Tribal and Local Governments Promote more resilientwithout a FEMA-Approved Mitigationand sustainable statesPlan” (FP 306-112-1, August 19, 2013)and communities; and Reduce the costs1.2Guiding Principlesassociated with disaster1. Foster Cooperative Relationships.response and recovery.FEMA will focus on maintaining a closeand constructive working relationshipwith the state. FEMA, as a partner withthe state, will conduct plan review and approval, and will work with the stateswhere possible, to help the states achieve mitigation goals through theimplementation of activities and programs proposed in the plans. Plan review andapproval should not be the sole focal point of communication concerningmitigation planning and programs. FEMA will facilitate technical assistance bothduring the approval period and during the plan update process to strengthen thisrelationship.2. Emphasis on the Planning Processes. FEMA encourages states to focus on acomprehensive and inclusive planning process to support mitigation throughoutstate government and at the community level. While the plan providesdocumentation of state mitigation planning processes, continuous coordinationamong state agencies and communities is the key to achieving mitigation goalsand long-term resilience.Page 2

State Mitigation Plan Review Guide 20153. Focus on Reducing Risks. Resilience4, in terms of mitigation planning, meansthe ability to adapt to changing conditions and prepare for, withstand, andrapidly recover from disruptions caused by a hazard. State risk assessments mustbe current, relevant, and include new hazard data, such as recent events, currentprobability data, loss estimation models, or new flood studies as well asinformation from local and tribal mitigation plans, as applicable, andconsideration of changing environmental or climate conditions that may affectand influence the long-term vulnerability from hazards in the state. FEMArecognizes there exists inherent uncertainty about future conditions and will workwith states to identify tools and approaches that enable decision-making to reducerisks and increase resilience from a changing climate. An understanding ofvulnerabilities will assist with prioritizing mitigation actions and policies thatreduce risk from future events.4. Improve Mitigation Capabilities. FEMA seeks opportunities for engagement tosupport and advance hazard mitigation. The National Mitigation Frameworkfocuses on core capabilities, including community resilience and the connectionsbetween economy, housing, health and social services, infrastructure, as well asnatural and cultural resources. State governments contribute to hazard mitigationthrough the integration of planning processes, policies, and programs. FEMA willwork with the states to provide technical assistance beyond plan review andapproval so that coordination and mitigation capabilities are strengthened.1.3OrganizationThis Guide is organized as follows:1.2.3.4.IntroductionMitigation Planning ResponsibilitiesStandard State Plan RequirementsEnhanced State Plan RequirementsAppendicesA:B:C:D:Submission and Review ProceduresState Mitigation Plan Review ToolApproval Letter TemplateConsultation Summary TemplateGuiding Principles:1. Foster CooperativeRelationships.2. Emphasis on the PlanningProcesses.3. Focus on Reducing Risks.4. Improve MitigationCapabilities.Section 2 clarifies the state and FEMA responsibilities set forth in the mitigation planningregulations at 44 CFR Part 201, and explains the mitigation program consultation processfor supporting state mitigation activities and programs. The sections on standard stateplan requirements and enhanced state plan requirements (Sections 3 and 4) describe the4According to PPD 8 National Preparedness, the term "resilience" “refers to the ability to adapt to changing conditionsand withstand and rapidly recover from disruption due to emergencies.”Page 3

State Mitigation Plan Review Guide 2015requirements for each element reviewed by FEMA in order to approve the plan. Excerptsfrom the mitigation planning regulations are included for reference.Appendix A, Submission and Review Procedures, sets forth the standard operatingprocedures for the submission and review of both Standard and Enhanced state mitigationplans and includes information on:1.2.3.4.5.6.CommunicationPlan SubmittalPlan AdoptionPlan Review StatusEnhanced State Mitigation Plan ReviewReview of Mitigation CommitmentsAppendix B, State Mitigation Plan Review Tool, is for use by FEMA plan reviewers todetermine if the plan meets the standard or enhanced state mitigation plan requirements,to provide more comprehensive feedback to the state to acknowledge where the planexceeds minimum standard or enhanced state mitigation plan requirements, and toprovide suggestions for improvements. State staff may use the Tool as a checklist toensure all requirements have been addressed.Appendix C, Approval Letter Template, is for use by FEMA Mitigation Planning staff incommunicating the plan approval status to the state.Appendix D, Consultation Summary Template, is for use by FEMA Mitigation staff toprovide a written summary of the mitigation program consultation to the state.Page 4

State Mitigation Plan Review Guide 2015SECTION 2: MITIGATION PLANNINGRESPONSIBILITIESThis section outlines the responsibilities for both FEMA and the state regarding theupdate, review, and approval of the state mitigation plan, including implementation, planmaintenance, and support of local and tribal, as applicable, mitigation planning, andreview of the state’s mitigation planning program and commitments.This section is organized as follows:2.1 FEMA Responsibilities under 44 CFR Part 2012.1.1 Communicating Mitigation Plan Status2.1.2 Mitigation Program Consultation2.2 State Responsibilities under 44 CFR Part 2012.1FEMA Responsibilities44 CFR§201.3(b)§201.4(d) and§201.6(d)(2)§201.7(d)(2)REGULATORY TEXTThe key responsibilities of the Regional Administrator are to:(1) Oversee all FEMA related pre- and post-disaster hazard mitigationprograms and activities;(2) Provide technical assistance and training to State, local, and Indian tribalgovernments regarding the mitigation planning process;(3) Review and approve all Standard and Enhanced State Mitigation plans;(4) Review and approve all local mitigation plans, unless that authority hasbeen delegated to the State in accordance with §201.6(d);(5) Conduct reviews, at least once every five years, of State mitigationactivities, plans, and programs to ensure that mitigation commitments arefulfilled, and when necessary, take action, including recovery of funds ordenial of future funds, if mitigation commitments are not fulfilled.The Regional review will be completed within 45 days after receipt from theState, whenever possible.The Regional review will be completed within 45 days after receipt from theIndian tribal government, whenever possible.2.1.1 Communicating Mitigation Plan StatusAt a minimum of 12 months prior to each state mitigation plan expiration date, FEMAwill provide the state with written information, including but not limited to: State mitigation plan expiration date; Consequences of not having a FEMA-approved mitigation plan with respect toeligibility for the following FEMA programs:oooooPublic Assistance Categories C-G (PA C-G)Fire Management Assistance Grants (FMAG)Hazard Mitigation Grant Program (HMGP)Pre-Disaster Mitigation (PDM)Flood Mitigation Assistance (FMA)Page 5

State Mitigation Plan Review Guide 2015 Availability of mitigation planning technical assistance.At a minimum of every 6 months, FEMA will provide the state with written information,including but not limited to: Local and tribal, as applicable, mitigation plan expiration dates;Consequences of not having a FEMA-approved mitigation plan with respect toeligibility for FEMA mitigation grants, such as HMGP, PDM, and FMA; andAvailability of mitigation planning training and technical assistance.For more information on the mitigation plan requirement relative to eligibility for FEMAmitigation grants, refer to the Hazard Mitigation Assistance (HMA) Guidance.2.1.2 Mitigation Program ConsultationFEMA is responsible for providing technical assistance and reviewing state activities,plans, and programs to ensure mitigation commitments are fulfilled. Many states and thecorresponding FEMA Regional Mitigation staff already coordinate regularly on the statusof the state’s mitigation program, in particular, the status of HMA grants or other FEMAassistance.FEMA will provide the opportunity for technical assistance through review andconsultation on the state’s mitigation program, to be completed at least annually. Thebenefits of an annual mitigation program consultation to the state include but are notlimited to: Promoting dialogue between FEMA and the state on the means to achieve,support, and maintain effective state mitigation programs;Identifying the status of the state’s mitigation program, including strengths andchallenges, as well as specific needs and opportunities;Ensuring feedback to the state on maintaining continuous HMA grantsmanagement performance, particularly for states interested in developing anenhanced plan; andFor states that currently have an approved enhanced plan, demonstratingcontinued mitigation capabilities, including HMA grants managementperformance, in advance of a plan update and not at the review of a five-yearmitigation plan update.During the consultation, topics of discussion will include, but are not limited to, status ofand specific needs for: Advancing implementation of the state mitigation strategy;Ensuring the state mitigation plan remains relevant over the approval period;Facilitating the plan update and approval process;Building mitigat

risks and increase resilience from a changing climate. An understanding of . vulnerabilities will awith prioritssist izing mitigation actions and policies that . review of the state’s mitigation planning program and commitments. This section is organized as follows:

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