FMA Colorado Guidance

Background

FEMA has formally announced the FY 2020 FMA grant. These nationally competitive grants provide mitigation funding on a cost-share basis to local communities for the completion of eligible, cost-effective mitigation projects and hazard mitigation plans. FEMA’s announcement stated that $160 million has been allocated to the FMA program for FY 2020. The Flood Mitigation Assistance (FMA) program makes federal funds available to states, U.S. territories, Indian tribal governments, and local communities to reduce or eliminate the risk of repetitive flood damage to buildings and structures insured under the National Flood Insurance Program (NFIP). Generally, eligible project types include flood control infrastructure, stream restoration, property acquisition and demolition. For a complete list of eligible project types please see the FEMA’s Eligible Activities by Progr
 
FEMA FMA grants require a 25 percent local cost share; 75 percent of project funding for approved projects will come from FEMA. The Period of Performance (POP) for the grants is 48 months for community flood mitigation projects and 36 months for all other sub-applications. The POP begins on the date of the Recipient’s federal Award.  To be eligible for project funding under the FMA 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 all Hazard Mitigation Plan projects, it is not a requirement that the community has a FEMA approved HMP at the time of application or award.
 
The Colorado Division of Homeland Security & Emergency Management (DHSEM) encourages local communities throughout the State interested in learning more about this opportunity to contact one of the State Hazard Mitigation Specialists listed below for additional information.

Flood Mitigation Assistance Funding Caps

The $160 million available under the FY20 FMA Grant Program may be used to fund the traditional FMA grant program priorities as well as the community flood mitigation priorities (both projects and project scoping). The funding caps (federal share) for the FMA program are as follows:

  • $600,000 per applicant for all for project scoping sub-applications
  • $30,000,000 cap per community flood mitigation project sub-application
  • $50,000 per applicant for all technical assistance sub-applications, for recipients to which FEMA obligated an FY2019 FMA Award of at least $1 million federal share
  • $100,000 per applicant for flood hazard mitigation planning with maximums of $50,000 for state flood hazard mitigation planning and $25,000 for local flood hazard mitigation planning

Up to five percent of the total mitigation project, project scoping, and planning sub-application budget is available for Sub-applicant management costs to manage sub-award activities.  Eligible activities must benefit the National Flood Insurance Program (NFIP) insured properties and include, but are not limited to:

  • Infrastructure protective measures
  • Localized flood control
  • Floodwater storage and diversion
  • Floodplain and stream restoration
  • Water and sanitary sewer system protective measures
  • Utility protective measures
  • Stormwater management
  • Aquifer storage and recovery
  • Wetland restoration/creation

Performance Metrics

Benefit-Cost Analysis (BCA) is the method by which the future benefits of a hazard mitigation project are determined and compared to its costs. The result is a Benefit-Cost Ratio (BCR), which is calculated by a project’s total benefits divided by its total costs. The BCR is a numerical expression of the "cost-effectiveness" of a project. A project is considered cost-effective when the BCR is 1.0 or greater, indicating FEMA expects the benefits of a prospective hazard mitigation project are sufficient to justify the costs. DHSEM will use the BCR as a key factor in project ranking.

Key Changes for FY2020

Important changes introduced in the FY20 FMA program are provided below:

Project Scoping

  • Changed from “Advance Assistance” to align with the purpose of this project type
  • Available for project development activities associated with individual property mitigation (acquisition, elevation, relocation, & reconstruction)
  • Increase in funding caps for Community Flood Mitigation Project Scoping sub-applications: For FY2020, $600,000 per applicant ($400,000 increase over FY19)

Community Flood Mitigation Projects

  • Increase in funding caps for Community Flood Mitigation Project sub-applications: For FY2020 $30 million cap per project sub-application ($20 million increase over FY19)

Grants Management System

  • All FY2020 FMA grants must be applied for using the new FEMA Grants Outcome (FEMA GO), which is now the FMA grants management system.
  • The development of FEMA GO was a multi-year effort to modernize and transform the way FEMA conducts grants management. FEMA GO will streamline the process to apply for, track, and manage FEMA grants.

Competitive Funding Prioritization for All Individual Flood Mitigation Projects (in Priority Order)

  • Projects with lower federal funding needed;
  • Structures that have been determined Substantially Damaged; and
  • Primary residences over non-primary residences

Additional Resources

Please take a thorough look at the FY2015 Hazard Mitigation Assistance Guidance and FY2015 Hazard Mitigation Assistance Guidance Addendum for guidance on project eligibility. The FY2015 Hazard Mitigation Assistance Guidance Addendum provides project-specific guidance (e.g., wildfire, property acquisition) and is recommended for its project focus. Please note, although these guidance documents are dated 2015, they represent the most current FEMA PDM and FMA guidance available.

  • Flood Mitigation Assistance Program
  • FEMA Benefit Cost Toolkit: please note, for FY 2020 PDM applications FEMA will only accept BCA outputs from version 6.0. A non-FEMA BCA methodology may only be used if pre-approved by FEMA in writing.
  • FEMA Benefit Cost Helpline: 855-540-6744 or via email.
  • FEMA Hazard Mitigation Assistance Helpline or 1-866-222-3580.
  • FEMA GO Log-in and Helpdesk

DHSEM will provide application development and technical assistance support for projects meeting FMA program priorities for the national funding competition. An overview of the FEMA and DHSEM attachments is provided in the FHA Resource Library. The FMA NOFO provides details regarding the program and application process. The application schedule is provided in the resource library.  Program resources providing additional details on key aspects of FMA are provided as Attachments C through J of the FHA 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.  Please e-mail your completed project NOI by October 4, 2020, to Matt Arsenault with a copy to Patricia Gavelda and Steven Boand.

Mitigation projects eligible for FMA funding are specified in FEMA’s Hazard Mitigation Assistance Guidance and Addendum available on the FEMA website. 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.

DHSEM FMA Application Schedule

FEMA requires that all state FMA 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 3 p.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 FMAC sub-applications is provided below and in the FHA 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 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 FMA application period closes at 3 p.m. EST

Project Eligibility and DHSEM Project Ranking Criteria

Please carefully review the FEMA NOFO sections discussion Other Eligibility Criteria (page 5), Cost Share or Match (page 5), and Application Review Information (page 17) to make sure the sub-application reflects these FMA elements. 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. 

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

  1. Priority Scoring Criteria for Community Flood Mitigation Project and Project Scoping: Sub- Applicants are required to submit a narrative self-evaluation of the FMA Scoring Criteria (see page 20 in the FMA NOFO) for flood mitigation and scoping projects. Information from the sub-application and the narrative will be used to access the potential for Scoring Criteria success.
  2. 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.
  3. 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.
  4. 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 and 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.  Attachments E and F of the FHA Resource Library 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.