B.5. Flood Risk Reduction

Flood risk reduction projects are designed to lessen the frequency or depth of flood water. Flood risk reduction project types fall into two categories:

• Localized flood risk reduction measures.
• Non-localized flood risk reduction measures.

This section defines localized and non-localized flood risk and discusses several common project types to address each type of flood risk. The project types are not exhaustive but rather reflect those that are most common to the HMA programs.

Localized flood risk reduction measures are those actions or projects taken to lessen the frequency or severity of flooding and decrease predicted flood damage within an isolated or confined drainage or catchment area that is not hydraulically linked or connected to a larger basin that is regional in scale.

Eligible localized flood risk reduction efforts include measures that reduce flood losses for single structures or facilities, groups of structures, or whole neighborhoods within an isolated or confined drainage area that is not hydraulically linked to another area. Eligible localized flood risk reduction projects also include urban flooding measures. These projects include but are not limited to:

• Stormwater management projects, including the construction, installation or modification of culverts, drainage pipes, pumping stations, floodgates, bioswales, detention and retention basins, and other stormwater management facilities.
• Flood diversion and storage measures.
• Slope stabilization or grading to direct flood waters away from homes, schools, businesses, utilities or governmental facilities.
• Flood protection measures for water and sanitary sewer systems or other utility systems.
• Vegetation management for shoreline stabilization (coastal, riverine, riparian and other littoral zones).
• Flood protection and stabilization measures for roads and bridges.

FEMA encourages innovative technologies and project types that mitigate and reduce the impact of flood losses. Localized flood risk reduction projects are eligible for assistance under HMGP, HMGP Post Fire, BRIC and FMA.

While there may be many different types of localized flood risk reduction projects, stormwater management projects are some of the most common to the HMA programs. Stormwater management is defined as efforts to reduce the impact of increased runoff that results from new development in a watershed. Stormwater management also encompasses many aspects of water quality and includes efforts to reduce erosion and the entry of sediment and pollutants into receiving streams.

The objective of this activity is to prevent future development from increasing flood hazards to existing development, to protect existing hydrologic functions within the watershed, and to maintain and improve water quality. Unmanaged stormwater runoff from new development and redevelopment throughout a watershed increases flood hazards by causing more frequent flooding, greater flood depths and longer-lasting floods. As forests, fields and farms are covered by impermeable surfaces such as streets, rooftops and parking lots, more of the rain runs off, and at a faster rate. When an area is urbanized, the rate and volume of runoff can increase fivefold or more. Communities are affected by development that takes place upstream in their watershed, and the community’s own development can have an impact on downstream communities. Communities are encouraged to cooperate with adjacent communities to manage stormwater. Stormwater management regulations regulate development on a case-by-case basis to ensure the peak flow and volume of stormwater runoff from each site will be no greater than the runoff from the site before it was developed or redeveloped.

Stormwater management practices can be grouped loosely into the following categories:

• Infiltration: These approaches manage stormwater by infiltrating it into the ground. These methods are considered pollutant-reducing. Some examples include porous pavement, subsurface infiltration and bioinfiltration.
• Slow release: These approaches detain and slowly release stormwater over time. An example is a detention/retention pond.
• Pollutant-reducing: These approaches incorporate pollutant-reducing practices. They may include infiltration practices and some slow-release practices.
• Vegetated: These approaches use vegetation as a significant component within the storage area. Examples include bioretention basins, ponds and wet basins, green roofs, and vegetated media filters.
• Non-vegetated: These approaches do not have a significant vegetation component. They include but are not limited to porous pavements, blue roofs, media filters, cisterns, and subsurface storage and conveyance methods.

Flood diversion and storage projects are climate resilient mitigation actions. These projects involve diverting floodwaters from a stream, river or other body of water into a wetland, floodplain, canal, pipe or other conduit (e.g., tunnels, wells) and storing them in aboveground reservoirs, floodplains, wetlands, green infrastructure elements or other storage facilities. Flood diversion and storage projects can be used to retain water to allow infiltration to groundwater supplies. This allows for a controlled way to mitigate flooding and enhance usable water supply to mitigate the effects of drought. Flood diversion and storage projects can also help maintain healthy ecosystems.

Depending on the scope, scale and location of potential sites, flood diversion and storage projects can vary in size and complexity. Proper planning, siting, sizing and construction are required to implement successful flood diversion and storage systems. In general, there are five different categories of flood storage areas:

• Online: Both dry and wet weather flows pass through the flood storage area.
• Offline: Dry and first-flush wet weather flows pass through the flood storage area. Larger flows bypass the facility.
• Dry: The flood storage system is kept essentially dry because of infiltration and evapotranspiration.
• Wet: The flood storage area contains water under all flow conditions.
• Wet/dry: Part of the flood storage area contains water and part is dry during various flow conditions.

Many flood diversion and storage projects are currently eligible for HMA as flood risk reduction activities. The HMA Guide focuses on flood diversion and storage projects implemented using green infrastructure methods as much as possible to address drought mitigation and climate change resilience in addition to reducing flood risk. Green infrastructure methods involve diverting the water into appropriately sized bioretention or biodetention basins. Smaller projects can provide localized flood reduction by channeling the diverted water into a bioswale, rain garden, stormwater tree trench or smaller bioretention or biodetention basin.

Non-localized flood risk reduction measures are those actions or projects that lessen the frequency or severity of flooding and decrease predicted flood damage within an area that is hydraulically linked or connected to a drainage basin that is regional in scale. These projects reduce flood hazards in areas larger than those of localized flood risk reduction projects and may include but are not limited to:

• The construction, demolition or rehabilitation of dams and weirs.
• Construction or modification of dikes, levees, floodwalls, seawalls, groins, jetties, breakwaters and stabilized sand dunes.
• Large-scale channelization of a waterway.

Non-localized flood risk reduction measures are eligible under HMGP, HMGP Post Fire and BRIC. For FMA, non-localized flood risk reduction projects such as dikes, levees, floodwalls, seawalls, groins, jetties, dams and large-scale waterway channelization projects are not eligible unless 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.^[441]

For complex flood risk reduction projects, subapplicants are strongly encouraged to use project scoping/advance assistance or a phased project approach. Refer to Part 10 for more information. Examples of common project types are highlighted below. This is not an exhaustive list, and additional project types may be eligible.

Definitions of a dam vary among federal and state agencies based on regulatory criteria. The National Dam Safety Program Act of 1996^[442] authorizes the national dam safety program and defines the term “dam” as:

Dams are classified to identify their potential hazard. Hazard potential classification systems are numerous and vary within and between state and federal agencies. The hazard classifications are used by state dam safety regulators for several purposes, including for planning at the state and local levels, assigning design requirements, and determining the frequency of operations and maintenance activities and inspections.

Section III of FEMA 333, Federal Guidelines for Dam Safety: Hazard Potential Classification System for Dams defines a system of low-, significant- and high-hazard potential classifications depending on the potential for loss of life, economic loss and environmental damage resulting from a hypothetical dam failure.

Eligible activities related to dam safety may include:

• Dam breach/break analysis to determine the effect on the downstream floodplain in the event of a dam break.
• Engineering studies to determine potential dam enhancements to increase reservoir capacity/reduce downstream flooding or reduce upstream backwater flood conditions.
• Enhancements to dam control structures, the emergency spillway or other critical dam infrastructure to mitigate existing natural hazard conditions.

A levee system is a human-made barrier along a watercourse, designed and constructed in accordance with sound engineering practices. Levee systems have the principal function of excluding flood waters from a limited range of flood events from a portion of the floodplain. Levee systems can consist of earthen embankments, floodwalls or a combination of both. Levee systems often include other features such as gates, pipes and pump stations.

A levee system cannot be constructed in open space that has been created because of an acquisition project and subapplicants will be required to reject consideration of such use if they accept FEMA assistance to convert a property to permanent open space. For more information about required consultations, refer to Part 12.B.1.3.8.

Floodplain and stream restoration projects are used primarily to reduce flood risk and erosion by providing stable reaches. Through the use of nature-based solutions, they may also mitigate drought impacts and extreme heat, while restoring and enhancing the floodplain, stream channel and riparian ecosystem’s natural function. They provide baseflow recharge, water supply augmentation, floodwater storage, terrestrial and aquatic wildlife habitat, and recreation opportunities by restoring the site’s soil, hydrology and vegetation conditions that mimic predevelopment channel flow and floodplain connectivity.

Floodplain and stream restoration projects can be scaled as needed to fit the site conditions and goals of the project. Typical goals and objectives include:

• Reduce peak velocities and stream bank erosion.
• Reduce peak flood stages.
• Protect bridge abutments, bridges, road crossings and other infrastructure.
• Protect valuable land and property.
• Increase or improve water supply and capacity.
• Restore ecological habitats for plants and aquatic species such as fish and other wildlife.
• Restore or improve water quality.

Floodplain and stream restoration projects readily lend themselves to nature-based solutions to achieve the desired impact. Potential projects that can emphasize the role of nature-based solutions to maximize the ecosystem service benefits in addition to risk reduction include:

• Floodplain setbacks: Removing structures from the floodplain and restoring the channel to its historical configuration. The stream is left to freely meander and flood its overbanks. This may include acquiring at-risk structures for removal and establishing levee setbacks.
• Multistage channels: Involves an upper channel section(s) to provide flood conveyance with a natural low‐flow channel(s) within it to provide habitat enhancement and improved sediment transport capacity.
• Relief channels: This technique typically involves restoring the channel to its original configuration and constructing a high‐flow channel or relief culvert to provide for additional flood conveyance. The restored channel provides habitat benefits while the high‐flow channel can be designed to divert excess flows, providing wetland or lowland habitat or recreational benefits.
• Addition of in‐stream structures: Flow-changing devices are a broad category of structures that can be used to divert flows away from eroding banks. They are often used to shield banks from eroding flows, build up the toe of the bank, and direct flows to create a stable alignment.
• Bank vegetation and seeding: Trees and shrubs can provide lowland habitat, channel shading, soil and bank stabilization, and aesthetic benefits. The use of native vegetation is strongly encouraged to support creation or restoration of habitat and to maintain natural ecosystem conditions.

FEMA encourages communities to incorporate methods to mitigate the impacts of climate change into eligible HMA-assisted risk-reduction activities by providing guidance on mitigating flood and drought conditions.

The following sections highlight eligible activities and costs for both localized and non-localized flood risk reduction measures.

The costs necessary to design and construct HMA flood risk reduction projects in accordance with the latest edition of ASCE 24 are eligible costs.

These costs may include:

• Professional services necessary to design, manage and implement the project.
• Data analyses/investigations directly related to the mitigation project (including geotechnical investigations, engineering reports and hydraulic analyses).
• Project planning and design activities, including construction verification.
• Site preparation, building materials and construction.
• Structural and conveyance systems capable of supporting flood loads.
• Other flood-resistant components that meet feasibility and regulatory requirements.
• Measures to avoid or treat adverse effects to historical properties and cultural resources.
• Costs related to complying with local utility requirements.
• Conditional Letters of Map Revisions/Letters of Map Revisions associated with the project.

Localized flood risk reduction projects are considered minor projects and are eligible for assistance under HMGP, HMGP Post Fire, BRIC and FMA.

Eligible minor physical mitigation efforts include measures that reduce flood losses for single structures or facilities, groups of structures or whole neighborhoods.

Any non-localized flood risk reduction activities—including long-term flood hazard mitigation measures such as major flood risk reduction projects—that are cost-effective, feasible and designed to substantially reduce the risk of future damage and loss of life from flooding are eligible for consideration under HMGP, HMGP Post Fire and BRIC.

For FMA, non-localized flood risk reduction projects such as dikes, levees, floodwalls, seawalls, groins, jetties, dams and large-scale waterway channelization projects are not eligible unless 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.^[443]

Section 1210(b) of the Disaster Recovery Reform Act creates an exception for HMGP to the prohibition under HMA that FEMA will not provide financial assistance for activities FEMA has determined another federal agency has more specific authority to conduct.^[444] Specifically, Section 1210(b) of the Disaster Recovery Reform Act provides that FEMA may use HMGP assistance to fund activities authorized for the construction of federally authorized water resources development projects that would normally fall under the authority of USACE, as long as those activities are also eligible under HMGP. For more information, refer to Part 12.B.5.2.3.1.

Flood risk reduction projects that address, without an increase in the level of protection, the operation, deferred or future maintenance, rehabilitation, restoration, repair or replacement of existing structures, facilities or infrastructure (e.g., dredging, debris removal, replacement of obsolete stormwater systems or bridges, and maintenance/rehabilitation of facilities, including dams and other flood risk reduction structures) are not eligible.

A general list of ineligible activities is included in Part 4.

In addition, ineligible costs associated with flood risk reduction projects include but are not limited to:

• General geotechnical or hydraulic studies not specifically related to the project site of the proposed mitigation activity, although engineering costs associated with the design (hydrologic and hydraulic calculations) and benefit cost are acceptable.
• Flood risk reduction projects related to the repair or replacement of dams and other flood risk reduction structures and repair of dams for the purpose of regular prescheduled or damage-induced maintenance.
• Project components not consistent with FEMA-approved performance criteria.

For FMA, non-localized flood risk reduction projects are generally not eligible, unless 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.^[445]

Federal law and FEMA's regulations prohibit duplication of programs, although, for HMGP, there may be exceptions under limited circumstances if there is an extraordinary threat to lives, public health or safety, or improved property.^[446]

Generally, no duplication of programs is presented by FEMA performing property acquisition for open space, elevation or localized flood risk reduction measures within a USACE or Natural Resource Conservation Service flood risk reduction project or study area. However, FEMA regulations require subrecipients to coordinate with USACE to ensure that no levee projects are planned in areas proposed for HMA property acquisition for open space activities.^[447]

FEMA may not use HMA to mitigate a portion of a structure/facility owned or operated by another federal agency. However, if the structure/facility is only regulated by another federal agency for a purpose other than flood risk reduction, mitigation of the structure is still eligible for consideration under HMA programs. For example, dams regulated by the Environmental Protection Agency for water quality may be eligible for HMGP and BRIC flood protection improvements.

FEMA may not assist a project in an area if a statute states that another federal agency has exclusive jurisdiction to construct flood risk reduction structures in that specific area of the U.S.

FEMA cannot provide assistance for activities for which it determines the more specific authority lies with another federal agency or program.

For certain non-localized flood risk reduction projects, FEMA’s authority to assist the project may overlap with USACE’s or the Natural Resource Conservation Service’s authority to fund a similar project. To avoid a duplication of programs concerning a non-localized flood risk reduction project, recipients and subrecipients should consult their local USACE or Natural Resource Conservation Service office prior to developing an HMA application for the project (for additional information regarding USACE coordination for HMGP projects, refer to Part 12.B.5.2.3.1). In general, duplication of programs should be evaluated at the project and site levels.

The following represent the most common duplication of programs situations with respect to non-localized flood risk reduction projects:

• If the USACE or Natural Resource Conservation Service is authorized to complete a specific structural flood risk reduction project, FEMA may not assist a structural flood risk reduction project of a similar nature in the area identified in the USACE or Natural Resource Conservation Service project plan. A duplication of programs exists regardless of whether assistance has been appropriated for the project.
• If the USACE or Natural Resource Conservation Service is authorized to perform a flood risk reduction study with the goal of exploring options for structural flood protection systems in a specified area, FEMA generally may not provide HMA for projects of a similar nature in the same area. When the other federal agency has completed the study and selected a project alternative—as indicated by a public record of decision—the study no longer presents a duplication of programs. At that point, generally only the selected project elements indicated in the public record of decision represent a duplication of programs.

Section 1210(b) of the Disaster Recovery Reform Act^[448] creates an exception for HMGP to the prohibition under HMA that FEMA will not provide financial assistance for activities the agency has determined another federal agency has more specific authority to conduct. Specifically, Section 1210(b) of the Disaster Recovery Reform Act provides that FEMA may use HMGP assistance to fund the construction of federally authorized water resources development projects that would normally fall under the primary authority of USACE, if those activities are also eligible under HMGP. These include smaller projects that Congress has granted USACE continuing authority to construct, such as under Section 205 of the Flood Control Act of 1948, Section 103 of the River and Harbor Act of 1962, and other similar flood control acts, as well as larger projects that Congress has specifically authorized for construction (such as in the Water Resources Development Acts, which are periodically reauthorized).^[449] These projects can address a variety of needs, including structural and non-structural flood risk reduction, coastal storm risk reduction and other water resources development purposes.

HMGP recipients may choose to prioritize and submit risk reduction applications for federally authorized water resources development projects normally under the primary purview of USACE. FEMA will contact the respective USACE District Office to identify the HMGP project potentially qualifying under USACE’s various statutory and program authorities. Once identified for HMGP assistance, these projects require coordination with USACE (through FEMA) and they may be subject to certain conditions such as Section 408 permits and USACE standards, if applicable.

HMGP provides up to 75% federal cost share with a 25% non-federal cost share requirement. FEMA’s federal cost share must be applied toward the federal share of the construction project and the non-federal cost share applied to the non-federal share of the construction project. HMGP funding may not exceed the total federal share for such project.

This provision does not affect:

1. The cost-share requirement of a mitigation measure under HMGP.
2. The eligibility criteria of the mitigation measure under HMGP.
3. The cost share requirement for a federally authorized water resources development project.
4. The responsibilities of a non-federal interest with respect to the federally authorized water resources development project, including those related to the provision of lands, easements, rights-of-way, relocation and disposal areas.

Once HMGP assistance is applied to the construction of the federally authorized water resources development project, no further federal assistance shall be provided for the project’s construction. This prohibition is an important consideration when choosing to apply for HMGP assistance. However, the prohibition does not apply to subsequent modifications and repairs, which may be funded and implemented by USACE.

Applicants and subapplicants must demonstrate that mitigation projects are cost-effective. Projects must be consistent with Part 5.

While the Office of Management and Budget (OMB) Circular A-94, Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs, describes an exemption for water resources projects (refer to the White House Council on Environmental Quality’sUpdated Principles, Requirements and Guidelines for Water and Land Related Resources Implementation Studies [PR&G] [Dec. 2014]) the cost-effectiveness requirement in the HMA program authorizing statutes must be met. The cost-effectiveness determination should be supplemented by consideration of the PR&G criteria if applicable. Water resources projects may include flood diversion and storage and floodplain and stream restoration.

Floodplain and stream restoration and floodwater storage and diversion projects can provide flood risk reduction benefits that can be calculated using the BCA Toolkit. In addition, there are drought mitigation and ecosystem services benefits that may also be considered.

For more information, refer to Part 5.C.1.1.10 Ecosystem Service Benefits.

If the subapplicant wants to include benefits from drought mitigation, the project application must identify the increased water supply capacity the floodplain and stream restoration or floodwater storage and diversion project would provide in relation to the population that will be supported in a drought and during the project’s useful life.

FEMA encourages communities to use the best available data to document a recurrence interval.

Floodplain and stream restoration or floodwater storage and diversion projects that result in new or restored wetlands; estuaries; or riparian, green or open space may leverage the ecosystem service benefits included in the BCA Toolkit. . For these benefits, it would be necessary to quantify the total restored ecosystem area (in acres or square feet), define the land use type.

Projects must be consistent with Part 3. Mitigation projects assisted by HMA must be both feasible and effective at mitigating the risks of the hazard(s) for which the project was designed. A project’s feasibility is demonstrated through conformance with accepted engineering practices, established codes, standards, modeling techniques and best practices.

FEMA requires that certain HMA flood mitigation projects be designed and constructed in conformance with the design criteria of the latest published edition of ASCE 24 as a minimum standard for structures that are subject to building code requirements and that are located, in whole or in part, in flood hazard areas. Other infrastructure types must be designed in accordance with the codes and standards that govern the design and construction of the type of infrastructure.

FEMA will consider a project application that uses ASCE 24 (or other codes and standards applicable to the type of infrastructure) as consistent with HMA program engineering feasibility and effectiveness requirements. Project applications that do not use ASCE 24 or the infrastructure equivalent must submit documentation to demonstrate the project meets the engineering feasibility and effectiveness requirement. At closeout, the subrecipient will have to provide certification from the design professional that the design standards have been addressed.

Some water use projects are subject to water rights laws, which vary by jurisdiction. In the western U.S., the process of obtaining water rights may take several years. These issues should be addressed and, where possible, water rights should be obtained prior to application submission to prevent delays.

All subapplications submitted to FEMA must meet the EHP criteria in Part 4. All subapplications must provide the information described in Part 6 so that FEMA may perform the EHP review.

FEMA, in consultation with appropriate federal and state agencies, will use the information provided in the application to ensure compliance with EHP requirements. This may include demonstrating methods to incorporate public participation in the review process and/or mitigate any EHP impacts resulting from the mitigation action.

The scope of the floodplain and stream restoration project and the presence of potentially sensitive environmental and cultural resources may impact the level of complexity of the EHP review. A floodplain restoration project with a smaller scope involving the removal of at-risk structures and planting native vegetation for bank stabilization may not require an EHP review as complex as a project with a larger scope.

The size and scale of the floodwater storage and diversion project and the presence of potentially sensitive environmental or cultural resources may impact the level of complexity of the EHP review. Neighborhood-scale projects in urban areas may not require as complex an EHP review as a larger-scale project impacting a floodplain. Projects larger than a neighborhood scale are more likely to affect wetlands, coastal zones, cultural resources or habitat for plants and wildlife. These issues need to be carefully evaluated during the design and planning of the project; a hydrologic and hydraulic analysis must be included as a part of the application package. In particular, the impacts on downstream flow patterns need to be considered to evaluate the effects on land use, the SFHAs, stream functions, stream habitat, and erosion or sedimentation rates.

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. Project-specific criteria 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 HMA Guide must be received before an assistance decision and award or final approval can be made.

For flood risk reduction structures, the subapplication must include the following:

• Site map and location information.
• Site photographs of proposed project area and the impacted properties.
• Narrative of the flood risk being mitigated, including flood event history in the project area, if available.
• Description of the existing conditions of the project area, including existing drainage systems, if any, and structures and infrastructure impacted by flooding.
• Description of how the project will reduce flooding depths and damage and specify the level of protection provided.
• Description of the structures and infrastructure that will benefit from the project.
• Documentation of two alternatives that were considered as part of the planning process. One alternative may be a “no action alternative” that would reflect the impacts if no action were taken. Describe why the selected project was the most practical, effective and environmentally sound alternative.
• Description of proposed activity, including deliverables and tasks required to complete the proposed activity.
• Documentation that the project can independently solve the problem and is a functional portion of a solution. Projects that are dependent on a contingent action to be effective or feasible are not eligible.
• Description of the project components (e.g., alignment, materials, structural design, maintenance and how the project will fit in with surrounding systems).
• Description of construction activities (e.g., site access, storage and security; site preparation; temporary construction; earthwork, including importation of fill or disposal of fill; installation of conveyance features; and repairs to infrastructure that might be damaged during construction so that subsurface components can be installed).
• Description of installation of grade structures and scour protection.
• Description of all permitting requirements.

It is necessary for subapplicants to demonstrate that there are no adverse impacts. Flood risk reduction projects are unique in that there is the potential to reduce risk of flooding in one area while increasing flood risk in another location. In addition to the items identified in Part 6, the following technical data are required:

• Design plans, specifications and engineering analysis (such as design calculations and minimum level of protection provided by the project).
• A statement by a licensed professional engineer that the project will not have negative impacts upstream or downstream of the project.
• Hydrologic and hydraulic report that provides data to support engineering analysis.
• Pre- and post-project inundation maps.

Because of the technical and complex nature of some flood risk reduction measures, FEMA may request additional information to determine/demonstrate technical feasibility and cost-effectiveness and to complete required EHP reviews.

All subapplications must include a line-item breakdown of all anticipated costs.

Subapplicants may apply for subrecipient management costs to cover administrative costs. Management costs must be included in the subapplication budget as a separate line item. More information about the requirements for management cost requests can be found in Part 13.

A detailed schedule must be provided for all tasks identified in the project cost estimate and scope of work. The schedule should identify major milestones, with start and end dates for each activity. Project schedules must show completion of all activities including the construction period within the period of performance. Sufficient detail must be provided to document that the project can be completed within the period of performance.

Typical costs for a flood risk reduction project may include but are not limited to:

• Engineering and design services and cost estimate preparation.
• Data analysis/investigations directly related to the mitigation project, including geotechnical investigations, engineering reports, and hydrologic and hydraulic analyses.
• Construction management.
• Surveying.
• Permitting and/or legal fees.
• Project planning and design activities, including construction verification.
• All construction activities required for project completion.
• Cost related to complying with local utility requirements.
• Other costs mentioned above for specific flood risk reduction projects.

The following are the basic steps in implementing an approved HMA flood risk reduction project:

1. Pre-construction (acquire land, if applicable; carry out design process; seek technical consultant; prepare cost estimate; obtain construction permits; hire construction manager/contractor).
2. Clear/prepare site and install erosion control measures to prepare for construction activities.
3. Complete excavation, foundation work and grading.
4. Construct project.
5. Relocate/restore utility lines.
6. Install plantings.
7. Complete inspections.

Post-award monitoring helps ensure subrecipients are achieving the objectives of the federal award consistent with the performance goals and milestones described in the subaward. To assist the recipient in monitoring flood risk reduction projects, the following milestone information or events should be included in Quarterly Progress Reports:

• If the subrecipient is acquiring contract support, the subrecipient should report when the request for proposal is completed, when the contract is out for bid, when the bid period closes, when proposals are reviewed, when the contractor is selected and the date of the kickoff meeting.
• Describe the current status including a summary of:
  • Recent progress and planned work.
  • Risks identified or changes from the milestones/deliverables submitted with the scope of work (e.g., financial concerns, coordination issues with state or local governments and utilities, project management or contracting issues, legal disputes, and significant changes impacting construction activities or timelines such as delays due to weather, materials, procurement or labor issues).
  • When construction has started, is substantially complete or completed.
• If property is purchased, the report should provide property address, purchase price and date.
• Any other milestones that have been identified in the subapplication, agreed to or are required by the recipient.

Recipients are required to report deviations from budget, project scope or objectives in accordance with Part 8. Recipients must request prior approvals from FEMA for budget and program plan revisions.^[450] If the final design is not complete prior to award, once the project is awarded, the design must be finalized by a licensed design professional. Any changes to the scope of work or budget because of completing the final design or to address permitting requirements must be consistent with Part 8. Construction design activities are defined as construction activities; therefore, budget changes involving them must be consistent with Part 8.F.2.

Recipients and subrecipients must closeout projects in a timely manner consistent with Part 9.

Upon completing an HMA flood risk reduction project, the authority having jurisdiction over the project must submit to the recipient a final verification assurance that the HMA flood risk reduction project was constructed as designed and in accordance with the approved scope of work. This documentation is included as project closeout documentation and must confirm that the HMA flood risk reduction project provides the intended level of protection. If the HMA flood risk reduction project is in an SFHA, the recipient must provide FEMA documentation of flood insurance for the structure and a copy of the recorded deed amendment. All other HMA program closeout requirements must also be addressed.

The recipient shall provide the following information:

• A Letter of Map Revision if a map revision was required.
• Photographs of the property site before and after project completion.
• Latitude/longitude of the project location to the nearest sixth decimal place. Starting and ending points may be required for large or linear projects such as a drainage improvement.
• Vicinity map and map of the SFHA, if applicable.
• Copy of the as-built drawings.
• Certification from a design professional that documents the project was completed in accordance with the scope of work and that all regulatory compliance grant conditions were implemented and documented.
• Final inspection report including the date of inspection and the name and job position of the inspector.
• Final signed operations and maintenance plan.

Closeout of flood risk reduction projects includes the submittal of an operations and maintenance plan to FEMA for review prior to subaward closeout. In the plan, the recipient must confirm the plan is consistent with the HMA Guide, meets or exceeds local codes, and is in conformance with appropriate permits. At a minimum, the operations and maintenance plan must include the following information:

• Information demonstrating the completed project will be maintained to achieve the proposed hazard mitigation.
• A description of the post-closeout maintenance activities that will be undertaken to maintain the project area.
• The period of time the community is committing to maintaining the area and/or project site, which must be consistent with the project useful life in the BCA.
• The department and job position that will be responsible for the project after construction has ended.
• Estimated costs for annual maintenance of the project.
• The schedule for completion of the maintenance activities.

As with any constructed project, project plans for flood risk reduction projects that include bioengineering must include maintenance and monitoring. These activities may occur more frequently while plans are establishing but will likely be minimal after they are established. Maintenance costs are a local responsibility and not a FEMA-eligible cost. The overall need for these activities depends on site conditions, including climate, ongoing coastal erosion, storm impacts and probability of animal disturbance.