A.4. Application and Submission Information

All subapplications submitted to FEMA must meet the eligibility criteria in Part 4. All subapplications must have a scoping narrative in accordance with Part 6. Specific criteria for mitigation planning subapplications are highlighted below.

FEMA may request additional information after the subapplication has been submitted to ensure all necessary information is received. However, all information required by the regulations and the guidance must be received before an assistance decision and award or final approval can be made.

The subapplication must:

• Include a statement that the deliverable will be an approved hazard mitigation plan that complies with the regulatory requirements at 44 CFR Part 201 and 44 CFR Part 206.
• Use applicable state, local or tribal mitigation planning guidance to determine the specific requirements for new plans and plan updates regarding the planning process; hazard identification and risk assessment; mitigation strategy; plan review, evaluation and implementation; and plan adoption.
• Include the scope of work and schedule that explains how a subapplicant will organize and execute the planning process, including how to engage with stakeholders and the public, if applicable. Generally, the scope of work also explains the planning team’s role, identifies stakeholders, explains public outreach (as applicable for local and tribal governments) and specifies whether the subapplicant expects to use contract support.

The following elements must be included in the scope of work for planning grants for subapplications seeking to create or update a new or existing plan:

• Description of previous planning efforts: Describes past mitigation plans and mitigation efforts to identify priorities for plan updates. The FEMA plan review tool from the previous plan should be included as an attachment.
• Description of planning area: Describes the planning area, including any non-contiguous land holdings or assets and demographics. The description must include the number and names of participating governments, private nonprofits, or other partners. Planning areas may include governments, such as states, territories, tribal lands, cities, townships, counties or other districts. Planning areas may also be defined by watersheds or other natural features. Planning areas can crossover or encompass other jurisdictions, such as a fire protection district or a utility district.
• List of jurisdictions participating in plan: Lists each community that will participate in the plan and seek plan approval. A written commitment from each jurisdiction seeking plan approval will be required before assistance is obligated.
• Public and stakeholder engagement plan: Provides an outreach and engagement plan that describes the opportunity for the public and stakeholders to be involved in the planning process. The plan must include required meetings and public comment periods. The outreach and engagement plan must account for the time needed to incorporate public and stakeholder feedback into the plan. If the subapplicant plans to conduct a public survey, the scope of work should describe the intent and value of the survey, how the results will be used and who the target audience is.
• Planning process: Provides a stakeholder and public engagement strategy that describes the planning process to engage stakeholders and the public. The description must explain the planning team’s proposed role, provide the anticipated number of planning team meetings, identify stakeholders and explain public outreach.
• Available data and risk assessment process: Describes the planning team’s process to research, collect, analyze and summarize hazard and risk data. The plan must include a description of the natural hazards that can affect the planning area. Man-made hazards may be included in the plan but are not required and will not be reviewed to meet plan requirements.
  • FEMA encourages states, tribes and territories to consider how they can create efficiencies, such as sharing relevant and scalable data and analysis with local governments to reduce costs, avoid the duplication of effort, and allow for the planning efforts to focus on mitigation strategy development. Subapplicants should generally coordinate with the state and FEMA to make use of existing data and risk assessments when developing or updating a mitigation plan.
  • Applicants and subapplicants should:
    • Describe the number of natural hazards that will be profiled.
    • If the subapplicant is completing a plan update, include a description of the data gaps and deficiencies the subapplicant is looking to fill in the updated risk assessment. If the subapplicant plans to generate new data, the subapplicant should explain the use of the new data and the value the new data will add to the plan. Explain how the new data will build a better risk assessment and mitigation strategy and describe where the source data will come from (including federal and non-federal sources) and how it will be processed.
    • Ensure the scope of work narrative includes a description of any known data sources, such as FEMA Risk MAP flood maps, to be used in the risk assessment. If the subapplicant relies on state plan data, the subapplicant should explain why the subapplicant does so. Similarly, if the subapplicant intends to develop new risk data, the subapplicant must describe the proposed process and sources.
    • Include an explanation of any geographic information system mapping and analysis needs for the plan.
    • If the subrecipient intends to use the FEMA Hazus model or other geographic information system software to support assessing vulnerability, explain the proposed level of analysis and describe how this enhanced analysis will add value to the plan in the planning narrative.
  • For local and tribal governments, if a community is participating or has participated in the Risk MAP process recently, the subapplicant must describe how the community plans to incorporate or upgrade the results of Risk MAP into the mitigation planning process. This might not apply to state plan updates.
• Development of capabilities assessment: Describes the process to develop strategies to address issues, challenges and obstacles jurisdictions face within given capabilities to deliver an effective mitigation program, including existing plans, programs, ordinances and policies that support long-term risk reduction efforts.
• Development of mitigation strategy: Describes the process to develop a mitigation strategy for each participating jurisdiction based on the risk assessment completed for the plan. For state mitigation plans, this narrative can include Coordination of Local Mitigation Planning, Severe Repetitive Loss Strategy and the Comprehensive State Hazard Mitigation Planning program. The process must include^[350]:
  • An explanation of how the subapplicant intends to gather information on the status of previous mitigation actions.
  • A status report on all the previously prioritized mitigation actions if the plan is being updated. Further, the plan must include an evaluation and prioritization of new mitigation actions identified since the previous plan was approved.
• Plan implementation, maintenance and evaluation: Describes how the plan will be used to carry out actionable projects identified in the plan and the process to develop an implementation/maintenance and evaluation plan/strategy.
• Plan adoption: Describes the plan drafting process, including state and FEMA reviews, adoption by participating jurisdictions, and final approval by FEMA or the state, tribe or territory, as applicable, under the PAS delegation of local plan approval authority.
• Schedule: Outlines the time frame, which must match all tasks noted in the scope of work. If a proposed activity is a new or updated mitigation plan, the schedule must include tasks for draft review. It must also allow sufficient time for the state, tribe or territory and FEMA reviews; preparation of required revisions, if needed; formal adoption by the jurisdiction(s); and FEMA approval within the period of performance.
• Deliverables, tasks and schedule: Describes the deliverables for a new or updated approved mitigation plan consistent with mitigation planning regulations for state,^[351] local^[352] or tribal^[353] governments as well as the applicable mitigation planning guidance. Refer to the FEMA “Hazard Mitigation Planning” webpage for additional information on state, local and tribal mitigation planning.

If communities participate in the NFIP and/or CRS, the scope of work should account for the level of effort needed to capture information related to NFIP and CRS compliance. CRS communities may receive additional points for having an adopted hazard mitigation plan; points can be maximized by undertaking the additional tasks prescribed for each mitigation planning phase. More details can be found in theNational Flood Insurance Program Community Rating System Coordinator’s Manual (2017), the Addendum to the 2017 CRS Coordinator’s Manual (2021) and in the Local Mitigation Planning Handbook (March 2013) (specifically, refer to Appendix A, Worksheet 1.1).

Planning-related activities are not required to result in an approved mitigation plan. Instead, planning-related activities are intended to advance mitigation and resilience outcomes.

In general, a subapplication must describe the deliverable for the proposed activities in the planning narrative. The planning narrative explains how a subapplicant will organize and execute the planning-related activity. Generally, the narrative also explains the planning team’s role, identifies stakeholders, explains public outreach, and specifies whether the subapplicant expects to use contract support.

A planning-related activity scope of work should include the following items:

• Tasks: The subapplicant must describe the tasks needed to accomplish the proposed activity as well as any procurement that would be required.
• Alignment with current mitigation plans: The scope of work must describe how the proposed activity aligns with the current mitigation plan or how mitigation plan information will be incorporated into other planning-related activities.
• Public and stakeholder engagement: The scope of work must identify the outreach and engagement plan (if applicable to the activity). The narrative should account for the time and effort it may take to incorporate public and stakeholder feedback.
• Goals: The scope of work must include the goals of the planning-related activity and identify specific deliverables that will be completed by the activity.
• Implementation strategy: The scope of work must outline the steps the subapplicant will follow to implement planning-related activities and to complete the proposed deliverables. This information must include a project schedule.
• Deliverables, tasks and schedule: The narrative must describe the deliverables for any mitigation planning-related activities eligible under HMGP, HMGP Post Fire and BRIC that enhance an existing mitigation plan consistent with mitigation planning regulations for state (44 CFR § 201.4 or 44 CFR § 201.5), tribal (44 CFR § 201.7 or 44 CFR § 201.5) or local governments (44 CFR § 201.6) as well as the applicable mitigation planning guidance. Refer to the FEMA “Hazard Mitigation Planning” webpage for additional information on state, tribal and local mitigation planning.

Allowable costs for hazard mitigation planning and planning-related activities include:

• Pre-award costs to prepare a subapplication: Pre-award costs to prepare a subapplication must be included as separate line items and supported with a budget narrative.
• Training: Applicable training costs for the planning team to travel to and attend applicable training.
• In-kind staff time: Subapplications should identify all in-kind staff time, including costs incurred to support plan coordination and outreach. In-kind costs can be applied to meet the non-federal match, which is up to 25% of the total cost of the plan. Timesheets will be required at closeout to document expenses.

Assistance may be subject to statutory limits (assistance restrictions) on planning and management costs as described in previous sections. Under planning and planning-related subawards, the following costs are not eligible:

• Data that is publicly available for free.
• Engineering or design costs.
• Other costs for implementing plans.
• Costs that may be part of another technical assistance, project scoping, advance assistance, or codes and standards subaward.

Budgets must be supported with documentation. Budgets must include detailed estimates of various cost item categories such as labor, materials, equipment and subcontractor costs. Lump-sum estimates are not acceptable. Subapplicants should provide a record of all documents used to develop the budget and a budget narrative that describes how each cost item in the budget was derived.

FEMA requires an itemized budget that is reasonable and cost beneficial and corresponds to the schedule. The itemized budget should be added as an attachment to the subapplication.

Budgets should include:

• An accounting for the entire period of performance to produce the plan or planning-related activity and include enough time for state and FEMA review, potential revisions and plan adoption, including grants management activities required for closing out the subaward.
• An accounting for any special studies or additional assistance needed to support an enhanced analysis and data that will be included as part of the plan or planning-related activity.
• Data research and collection, including eligible mapping activities or risk assessment.
  • If Hazus is used for flood, earthquake or hurricane risk assessments, the subapplicant should include costs for user defined/provided hazard and inventory data.
• A mitigation strategy development and prioritization.
• Professional development training, tuition and travel costs, if applicable.
• Costs related to plan drafting, state and FEMA review, revisions, and final production and distribution.
• Public outreach and stakeholder coordination efforts.
• Management costs, which are indirect costs and administrative expenses anticipated during plan development.
  • The amounts, allowable uses and procedures to request management cost assistance vary by HMA program. Refer to Part 10 for more information.
• Supportive documentation, such as contractor estimates, that should demonstrate a clear understanding of the scope of work, limitations and final outcomes of the plan.
  • If the estimate is based on carefully thought-out assumptions, it will have factored in many of the changes that come after the grant is awarded.