BRIC Colorado Guidance

Background

FEMA released the Notice of Funding Opportunity (NOFO) for the FY 2020 Building Resilient Infrastructure and Communities (BRIC) grant program on August 4, 2020. The NOFO makes available $500 million in federal funding for mitigation projects across the nation. Within that total amount, $33.6 million is available as set-aside (up to $600,000 per state/territory), $20 million for federally recognized tribal governments and an estimated $446.4 million in remaining allocated funds are available in the national competition for funding of mitigation projects.  The Colorado Division of Homeland Security and Emergency Management (DHSEM) has developed this guidance to help explain the state’s interpretation of the BRIC program and provide an overview of the criteria and guidance contained in the NOFO. DHSEM is the Applicant and Recipient for this program. Local communities, special districts, and other state agencies are the Sub-Applicants and Sub-Recipients.

Colorado’s strategy for set-aside funding is to utilize up to $300,000 to support hazard mitigation planning at the state and local level. The remaining funds will be applied to key capacity building and mitigation projects that further the state’s resilience efforts and activities addressing significant hazards. DHSEM will provide application development and technical assistance support for projects meeting BRIC program priorities for the national funding competition. An overview of the FEMA and DHSEM attachments is provided as Exhibit 1 to this guidance.  The  BRIC NOFO  provides details regarding the program and application process. The application schedule is provided in the section below. Program resources providing additional details on key aspects of BRIC are provided in a BRIC Resource Library.

DHSEM requires that all project sponsors (denoted as Sub-Applicants in the federal process) submit a Notice of Intent (NOI) to DHSEM by October 5, 2020. The NOI will be used by DHSEM staff to help you develop your agency’s project application. As you will note, completion of the NOI will require that you become familiar with the quantitative technical and qualitative ratings FEMA will use to evaluate all projects submitted for the BRIC funding review. FEMA’s Technical and Qualitative Criteria for BRIC are reviewed in the BRIC Resource Library.  Please e-mail your completed project NOI by October 4, 2020 to Matt Arsenault with a copy to Patricia Gavelda and Steven Boand.  

An important BRIC program element is compliance with the building code requirement established by FEMA and Colorado for the program. All BRIC construction projects must be constructed in accordance with the 2015 or 2018 versions of the International Building Code (IBC) and/or the International Residential Code (IRC) as may apply. Upon completion of the project, a certification of compliance by a registered professional engineer will be required during project closeout. Mitigation projects eligible for BRIC funding are specified in FEMA’s Hazard Mitigation Assistance Guidance and Addendum available at https://www.fema.gov/grants/mitigation. The FEMA-GO Sub-application form provides information regarding eligible projects.

Another key area of project development in compliance with environmental and historic preservation requirements. If environmental and historic preservation review analysis has not yet been completed for your proposed project, please make sure that those costs are considered as the project budget is developed. The projects Benefit-Cost Ratio (BCR) must be supported by a solid Benefit-Cost Analysis (BCA). All assumptions, cost, and benefit factors mush be well supported and repeatable by FEMA in the BCA.  To be eligible for project funding under the BRIC grant, it is a requirement that Sub-applicants have adopted a current (non-expired) FEMA-approved local Hazard Mitigation Plan (HMP) both at the time of sub-application submission to FEMA and at the time of project award obligation. For hazard mitigation planning projects, it is not a requirement that the community has a FEMA approved HMP at the time of application or award. 

DHSEM BRIC Application Schedule

FEMA requires that all state BRIC applications be submitted by states no later than 3 p.m. EST on January 29, 2021. FEMA is also curtailing application submission assistance as of 3p.m. EST on January 27, 2021. DHSEM will therefore begin the state application submission on January 23, 2021, continuing through January 26, 2021.

DHSEM’s schedule for receipt and review of BRIC sub-applications is provided below and in the BRIC Resource Library. That schedule reflects:

  • September 4 -October 5, 2020: Notices of Intent accepted by DHSEM
  • September 30, 2020: Application period opens in the FEMA Grant Outcomes (FEMA-GO) system
  • November 30, 2020: Draft applications and BCA submitted for DHSEM review in FEMA-GO
  • December 1-11, 2020: DHSEM draft application review
  • December 11, 2020 - January 15, 2021: Sub-Applicant updates to final project sub-applications and BCA
  • January 15, 2021: Final sub-application and BCA submission by sub-applicants
  • January 18-22, 2021: State review and rankings
  • January 23-26, 2021: Final state application submission
  • January 27, 2021: FEMA requests for application assistance ends at 3 p.m. EST
  • January 29, 2021: FEMA BRIC application period closes at 3 p.m. EST

FEMA Project Eligibility and Ranking Criteria

The NOFO defines the guiding principles of the BRIC program as (1) support state and local governments, tribes, and territories through capability- and capacity-building to enable them to identify mitigation actions and implement projects that reduce risks posed by natural hazards; (2) encourage and enable innovation while allowing flexibility, consistency, and effectiveness; (3) promote partnerships and enable high-impact investments to reduce risk from natural hazards with a focus on critical services and facilities, public infrastructure, public safety, public health, and communities; (4) provide a significant opportunity to reduce future losses and minimize impacts on the Disaster Relief Fund; and (5) support the adoption and enforcement of building codes, standards, and policies that will protect the health, safety, and general welfare of the public, take into account future conditions, and have long-lasting impacts on community risk reduction, including critical services and facilities and future disaster costs.

For FY2020, the priorities for the program are to prioritize and incentivize projects that:

  • build and support public infrastructure resilience;
  • mitigate risk to one or more lifelines;
  • incorporate nature-based solutions, and;
  • provide funding to applicants to facilitate the adoption and enforcement of the latest published editions of building codes.

Projects will first be scored by FEMA on technical evaluation criteria presented in the NOFO. The technical criteria receive a binary score of zero or full allocation of points as follows:

  • Infrastructure projects (up to 20 points)
  • Mitigating risk to one or more lifelines (up to 15 points)
  • Incorporation of nature-based solutions (up to 10 points)
  • The applicant has mandatory building code adoption requirement (2015 or 2018 versions of the International Building Code and International Residential Code) (up to 20 points)
  • Sub-Applicant has Building Code Effectiveness Grading Schedule (BCEGS) rating of 1 to 5 (up to 15 points)
  • The application generated from a previous FEMA HMA Advance Assistance award (up to 10 points)
  • Increased non-federal cost-share (up to 5 points)
  • Designation as a small impoverished community (as defined in the BRIC Policy and referenced in 42 U.S.C. § 5133(a)) (up to 5 points)

FEMA will also convene a National Review Panel to score sub-applications based upon six qualitative evaluation criteria. FEMA will ensure that at least one eligible sub-application from each Applicant will be sent to the qualitative evaluation panel for review but does not guarantee any sub-awards from the competitive category to Applicants.

The qualitative criteria will be evaluated based on narrative information submissions to allow sub-applicants the flexibility to fully explain the strengths of their proposed project(s). Qualitative evaluation criteria have graded scales of point-scoring. The qualitative evaluation criteria include:

  • Risk Reduction/Resiliency Effectiveness (up to 35 points)
  • Future Conditions (up to 15 points)
  • Implementation Measures (up to 15 points)
  • Population Impacted (up to 15 points)
  • Outreach Activities (up to 5 points)
  • Leveraging Partners (up to 15 points)

The BRIC Resource Library includes attachments C and D provide supplemental information on the NOFO regarding the quantitative and qualitative project rating criteria that FEMA will apply in its review process. Please note that these rating factors will also be used by DHSEM in the development of project rankings for the state application submission.

Focus and Use of BRIC Funding

The NOFO states this funding is intended for:

  • Mitigation Projects: cost-effective projects designed to increase resilience and public safety, reduce injuries and loss of life, and reduce damage and destruction to property, critical services, facilities, and infrastructure. Projects must demonstrate in the application that they save lives and/or reduce property damage.
  • Capability and Capacity-Building (C&CB): activities that enhance the knowledge, skills, expertise, etc., of the current workforce to expand or improve the administration of mitigation assistance.
  • This includes activities in the following sub-categories: building codes activities, partnerships, project scoping, mitigation planning and planning-related activities, and other activities.
  • Management Costs: financial assistance to reimburse the Recipient and Sub-Recipients for eligible and reasonable indirect costs, direct administrative costs, and other administrative expenses associated with a specific mitigation measure or project in an amount up to 15 percent of the total amount of the grant award, of which not more than 10 percent of the total award amount may be used by the recipient and five percent by the sub-recipient for such costs.

Direct Technical Assistance Projects

Each FEMA Region will designate a single project within the region to provide non-financial Direct Technical Assistance for communities to encourage community capacity and capability to improve its resilience to natural hazards and to ensure stakeholders are capable of building and sustaining successful mitigation programs, submitting high-quality applications, and implementing new and innovative projects that reduce risk from a wide range of natural hazards. To be considered for non-financial Direct Technical Assistance, all states, territories, or federally recognized Indian tribal governments may submit one letter of interest provided to them by a local government/community to BuildBRIC@fema.dhs.gov. Communities are eligible to request this assistance even if they are not applying for financial assistance under this NOFO.

FEMA may prioritize Direct Technical Assistance for communities that:

  • Have not received a project award under the Pre-Disaster Mitigation (PDM) program, FMA, or the Hazard Mitigation Grant Program (HMGP) within the past five years
  • Have not received an Advanced Assistance award under PDM, FMA, or HMGP within the past 5 years
  • Are Tribal entities
  • Are small impoverished communities
  • Have demonstrated a compelling need (e.g., have a significant social vulnerability, multiple major disaster declarations within the past 5 years, etc.)

Key NOFO Information

  • Sub-Applicants are required to have a FEMA-approved Local or Tribal Hazard Mitigation Plan (HMP) in accordance with 44 CFR Part 201 by the application deadline and at the time of obligation of grant funds for mitigation projects and Capability and Capacity Building (C&CB) activities (with the exception of mitigation planning).
  • Phased projects are where FEMA provides funding for complex mitigation projects to Sub-Applicants to allow them to develop all the technical and environmental information, including design, engineering studies, and permitting, before issuing a full construction approval.
  • All BRIC project submissions must include a Benefit-Cost Analysis (BCA) and must have a FEMA verified Benefit-Cost Ratio (BCR) of 1.0 or greater to be considered.
  • Projects can be approved for up to $50 million in Federal cost-share per project. Please note that all projects require a 25 percent local match or a 10 percent match when a sub-recipient qualifies.
  • The Period of Performance (PoP) for all mitigation projects will be 36 months from the date of the award while local HMPs will have a 24-month State PoP.
  • FEMA Application deadline is January 29, 2021, at 3 p.m. EST (1 p.m. MST).

DHSEM Project Ranking Criteria

DHSEM will prioritize all sub-applications and submit them within a single state application to FEMA. DHSEM is required to prioritize projects submitted within the state application. Sub-application prioritization recommendations will be developed by a working group of the State Hazard Mitigation Team. Those recommendations will be reviewed and approved by the director of the Colorado Office of Emergency Management. The prioritization process is generally defined in the Enhanced State Hazard Mitigation Plan (E-SHMP) Chapter 8. The E-SHMP is available at https://www.colorado.gov/pacific/mars/enhanced-state-hazard-mitigation-plan-e- shmp.

DHSEM will use FEMA’s criteria as a key part of its prioritization process but will also consider other factors.

  • T&Q Rating Support: Sub-Applicants are required to submit a self-evaluation of FEMA’s quantitative technical and qualitative (T&Q) rating criteria as primary project evaluation elements. Documentation that supports the T&Q ratings will be carefully evaluated during the state review.
  • BCR: The Benefit-Cost Ratio and supporting analysis (the BCA) is a key project evaluation element. While FEMA requires a minimal 1.0 BCR for project funding, preference will be given to projects that have a well-documented BCA and a BCR rating of 2.0 or higher. All assumptions and factors utilized in the BCA must be supported and documented in the sub-application analysis package. 
  • HMP Mitigation Action Element: An important element of the state evaluation is the hazard being mitigated and that hazard’s significance in the associated local Hazard Mitigation Plan. Please provide detail regarding how the proposed project aligns with risk reduction efforts in the local Hazard Mitigation Plan. 
  • Colorado Resiliency Framework Criteria: The Colorado Resiliency Framework identified a series of criteria of value in building community resilience. Resilience factors are described in the 2015 Colorado Resiliency Framework. These criteria will be evaluated in each sub-application by the State review panel to help inform the project ranking submitted as a part of the State application. The criteria include:
  • Co-Benefits
  • High Risk & Vulnerability
  • Economic Benefit-Cost (as determined by FEMA’s Benefit-Cost Analysis tool)
  • Social Equity
  • Technical Soundness
  • Innovation
  • Adaptive Capacity
  • Harmonize with Existing Activity
  • Long-Term and Lasting Impact

Submitting BRIC Sub-applications: FEMA-GO

With the release of the BRIC 2020, FEMA is also rolling out their new grant management platform called FEMA Grants Outcomes (FEMA-GO). As an initial step, all sub-applicants must register in the System for Award Management before beginning their application in the FEMA-GO platform. FEMA-GO may be accessed on the FEMA website. In the BRIC Resource Library, Attachments E and F provide detailed information regarding FEMA- GO. The FEMA-GO system will be available for application development beginning September 30, 2020. The FEMA Grants Outcomes (FEMA-GO) system automatically imports certain information from an organization’s active SAM record, including the organization’s legal name, mailing and physical address, EIN, DUNS and DUNS +4 numbers, and the Electronic Business Point of Contact (eBIZPOC).

FEMA’s expected outcomes for launching this new grant management platform are:

  • Improved technology to meet business needs
  • Simplified grants life cycle processes
  • Improved timeliness of grant awards to survivors and communities
  • Access to complete and accurate grants data in one system

DHSEM will be seeking additional guidance on how the new FEMA-GO platform will work for us as the applicant and you as sub-applicants. Supplemental information will be provided as it is issued by FEMA.

Program Contacts at DHSEM

Effective communication will be key as the BRIC program develops leading to the submission of the Colorado application no later than January 29, 2021. Your contacts for project and planning applications at DHSEM are:

 BRIC Mitigation Project Sub-applications: 

For BRIC Hazard Mitigation Planning Sub-applications: