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F.2. Project and Activity Changes

Substantial project and activity related changes included in the HMA Guide are outlined in this section.

  • Eligibility of HMA Applications with Pre-Award Demolitions: FEMA has generally found acquisitions, mitigation reconstruction and other mitigation projects that included properties with structures that had been demolished prior to application to FEMA as ineligible for HMA funding because of its interpretation of these costs as “pre-award costs.”
    • FEMA issued a policy clarification: Eligibility of Hazard Mitigation Assistance Applications with Pre-Award Demolitions (Aug. 26, 2019), specifying that when a property owner uses private funds to demolish an event-damaged structure—and the property had not been in an application submitted to FEMA at the time of the demolition—the demolition is not a “connected action” under the National Environmental Policy Act (i.e., is not connected to the FEMA federal project).[24]
    • Therefore, the demolition is not subject to FEMA review and approval for Environmental and Historic Preservation compliance, the costs of the demolition are not considered pre-award costs, and the demolition does not preclude a finding of project eligibility. The demolition must be in accordance with state and local legal requirements as well as any applicable federal law.
    • The HMA Guide supersedes the policy clarification and any FEMA materials or content relating to it, unless stated otherwise, and information regarding pre-award demolitions is in Part 4 and Part 12.
  • Eligibility of Non-Localized Flood Risk Reduction Projects under FMA: In Part 12, FEMA updated content to reflect that non-localized flood risk reduction projects may be eligible for FMA if the Administrator specifically determines in approving a mitigation plan that such activities are the most cost-effective mitigation activities for the National Flood Mitigation Fund. This change reflects revisions to the FMA regulations that became effective Oct. 1, 2021.
  • Codes and Standards Activities: In Part 11, FEMA provided more information on codes and standards as eligible HMA activities.
  • Nature-Based Solutions: In Part 12, FEMA provided more information on the eligibility of nature-based solutions for many different project types and included an overarching philosophy to encourage these approaches. FEMA also included more detailed information on nature-based solutions.
  • Acquisition Projects: The HMA Guide incorporates FEMA Policy #302-094-0333, Hazard Mitigation Assistance Acquisition Projects: Hydraulic Fracturing and Horizontal Directional Drilling (July 6, 2017), and information regarding acquisition projects is in Part 12. The HMA Guide supersedes the policy and any FEMA materials or content relating to it, unless stated otherwise. FEMA also clarified recipient responsibilities and requirements for post-closeout monitoring and reporting, including requirements to review post-acquisition land uses based on 44 CFR § 80.19 in Part 12.
  • Mitigation Reconstruction Projects: In Part 12, FEMA updated the cap on the federal cost share for mitigation reconstruction from $150,000 to $220,000 per structure. FEMA also clarified that it will no longer provide square-foot cost estimates for mitigation reconstruction projects.
  • Sinkhole Projects: The HMA Guide supersedes the FEMA policy clarification: Acquisition and Relocation or Demolition of Structures on or near Sinkholes (April 24, 2015), which clarified the eligibility of acquisition and relocation of demolition projects when the structure is subject to sinkhole hazards. Information regarding the policy clarification is in Part 12.
  • Safe Room Projects: In Part 12, FEMA updated requirements to align with FEMA P-361, Safe Rooms for Tornadoes and Hurricanes: Guidance for Community and Residential Safe Rooms, Fourth Edition (April 2021), and the 2020 edition of International Code Council (ICC) 500, ICC/National Storm Shelter Association Standard for the Design and Construction of Storm Shelters.
  • Secondary Power Source Projects: he HMA Guide supersedes the FEMA fact sheet: Hazard Mitigation Assistance Grant Funding for Microgrid Projects and the FEMA job aid: Eligibility of Generators as a Fundable Project by the Hazard Mitigation Grant Program and Pre-Disaster Mitigation Program. Information regarding these topics is in Part 12. In addition, FEMA expanded the eligibility of secondary power source projects, including generators, microgrids, solar photovoltaic systems, and battery back-up systems.
  • Tsunami Vertical Evacuation Refuge Projects: In Part 4 and Part 12, FEMA provided updated guidance for tsunami vertical evacuation refuge projects.
  • Wind Retrofit for Non-Residential Buildings Projects: In Part 12, FEMA expanded the eligibility of wind retrofits to non-residential structures under HMGP and BRIC.
  • Wildfire Mitigation Activities: FEMA provided updated guidance for post-wildfire flood prevention activities and fire suppression systems, and removed the requirement that hazardous fuels reduction projects must be located within a 2-mile distance of an at-risk building or structure to be eligible to receive assistance under HMA grant programs. The update is reflected in Part 12.
  • Beach Nourishment Projects: In the 2015 Guidance, beach nourishment was listed as an ineligible mitigation activity. Beach nourishment is now eligible based on the FEMA Policy #204-078-112-1, Eligibility of Flood Risk Reduction Measures under the Hazard Mitigation Assistance (HMA) Programs (June 27, 2014). The HMA Guide supersedes this policy. FEMA also added information to clarify the eligibility of these activities under shoreline stabilization in Part 12.
  • New Information on Mitigation Planning as an Eligible HMA Activity: Planning is one of the cornerstones of effective hazard mitigation activities. Therefore, FEMA included additional guidance and resources in Part 2 and Part 11 regarding mitigation plan creation and updates and planning-related activities. Also, FEMA strengthened language in Part 2 to reinforce the connection across planning and project identification, selection and scoping.
  • Planning Related Activities: In Part 11, FEMA included more detailed information on the eligibility of planning-related activities from the Hazard Mitigation Grant Program Planning-Related Activities FEMA fact sheet.
  • Aquifer Recharge, Storage and Recovery Projects: The HMA Guide supersedes the FEMA fact sheet: Aquifer Storage and Recovery, and any materials and related content. Information regarding aquifer recharge, storage and recovery is in Part 12.
  • Flood Diversion and Storage Projects: The HMA Guide supersedes the FEMA fact sheet: Flood Diversion and Storage, and any materials and related content. Information regarding flood diversion and storage projects is in Part 12.
  • Floodplain and Stream Restoration Projects: The HMA Guide supersedes the FEMA fact sheet: Floodplain and Stream Restoration, and any materials and related content. Information regarding floodplain and stream restoration projects is in Part 12.
  • Extreme Temperature Projects: In Part 12, FEMA included information on the eligibility of activities that mitigate extreme temperature from the Mitigating the Risk of Extreme Temperatures with Hazard Mitigation Assistance Funds FEMA fact sheet.
  • Partnership Activities: In Part 11, FEMA added information indicating that partnership activities are eligible for BRIC and FMA.
  • Floodproofing: In Part 12, FEMA clarified the differences between wet and dry floodproofing and their eligible uses.

Footnotes

24. Public Law 91-190 (Jan. 1, 1970), 42 U.S.C. § 4321