B.11. Secondary Power Source

Secondary power sources increase power system resilience and mitigate the impacts of natural hazards while increasing the resilience of critical functions.

The purchase and installation of secondary power sources and related equipment, such as hookups and transfer switches, are generally eligible if they are cost-effective, contribute to a long-term solution to the problem they are intended to address, and meet all other program eligibility criteria. Additional secondary power sources not listed below may be eligible and will be reviewed on a case-by-case basis.

Generators, including combined heat power systems, are emergency equipment that provide a secondary source of power. The type of generator, portable or permanent (fixed), is irrelevant to the eligibility if the project that the generator is used for, or the generator (and related equipment), meet the requirements of the program and the HMA Guide.

A permanent generator, also referred to as a fixed or standby generator, is a permanently installed generator that provides power by being hard-wired into the facility’s main distribution panel and can be started manually or automatically in the event of a power outage. During a power failure, an automatic transfer switch isolates the electrical wiring from the utility grid and signals the generator to start functioning. The generator begins to feed power to the lines. When power is restored, a reverse action takes place, the incoming feed is once again procured from utility lines, and the generator ceases to function and goes into a standby mode.

Portable generators work with stand-alone applications and are meant to temporarily energize a few critical applications via external cords. These are usually functional for a short period of time. Different models of portable units can be fueled using one or more energy sources, such as gasoline, diesel, biodiesel, solar, propane or natural gas.

Hookups provide a pre-installed connection for generators to be connected to the facility’s electrical system quickly when needed. Transfer switches are devices that safely connect standby or emergency generators to the electrical system.

There are two types of transfer switches:

• Manual transfer switches: Used to transfer power between the utility and portable or optional standby generators. Manual transfer switches must be operated manually when utility power is lost and when it is restored. The switches can be wired to a separate subpanel to run essential circuits in the building, such as lights, or they can be wired to run the entire building if the attached generator is sufficiently sized. Manual transfer switches are most used when a portable generator system is involved but may be used with fixed generators.
• Automatic transfer switches: Automatically starts the generator and provides power from the generator to the facility when a utility power loss is detected. Automatic transfer switches also retransfers the facility back to the utility when the utility power is restored and shuts down the generator. Automatic transfer switches can be beneficial because of their simplicity and automatic action but are generally more expensive. Automatic transfer switches are typically only used with fixed generators. Applicants should discuss their needs with a licensed electrician or a licensed electrical engineer to determine which type of transfer switch would be better suited for each project.

Fuel is needed for most generators to function. Natural gas is piped from a utility, while propane and diesel use fuel tanks. The diesel fuel tanks need some form of spill prevention, usually in the form of a double walled tank. Propane and diesel tanks are mounted on concrete pads. Diesel tanks can be mounted below the generator as a subbase fuel tank. 

Though historically, alternative sources of power have been generators fueled by non-renewable resources, other forms of power, such as solar photovoltaic technology, may be viable as an effective alternative source of power. Solar photovoltaic technology, as an alternative source of power, may reduce risk and loss of function. Certain solar photovoltaic system configurations can provide an alternative source of power if the electric utility experiences an outage. While it is generally impractical to provide sufficient energy generation for a facility to operate indefinitely or during prolonged power outages, it may be practical for solar photovoltaic and battery storage systems to have sufficient capacity to allow facilities to function fully or partially for short-duration power outages. For solar photovoltaic systems to be effective in reducing loss of function, energy storage sized to provide power to critical loads is essential while accounting for the solar energy generation in a day. For some critical facilities, a solar photovoltaic system may not meet performance requirements for the primary secondary power source.

A microgrid is a group of interconnected energy-consuming devices and equipment (e.g., homes, businesses or industrial facilities) and distributed energy resources within clearly defined electrical boundaries that act as a single controllable entity with respect to the utility grid. These microgrids generally operate while connected to the utility grid but control capabilities such as smart controls, enable these microgrid systems to disconnect from the conventional utility grid, and operate autonomously to meet anticipated or potential utility outages.

A microgrid typically consists of a smart distribution network limited to a well-defined boundary, a load management system, distributed energy resources and storage solutions. Distributed energy resources generate power in the form of solar panels, wind turbines, engine generators or another power generation source.

With the ability to disconnect and operate independently, microgrid systems can provide for grid resilience, mitigate disturbances caused by natural disasters, and allow for faster system response and recovery. The presence of a storage system (e.g., battery), with sufficient capacity for the specific application, such as waiting out the transition of power during a utility outage (which could range from a few seconds or minutes to hours or even days), can also reduce the loss of function of critical infrastructure.

A backup battery system is an energy storage resource capable of receiving electrical power from a conventional utility grid or other electrical power source and storing it for later use. Battery systems can be located at the transmission-system level or at the customer level. On the utility scale these systems are typically used for managing power demand, but on the customer level a battery system can be used to provide backup power during utility outage events. The battery system achieves this by being connected to the utility grid during normal utility operation so it can maintain a full charge, and when the system senses the utility source is inadequate, the system disconnects from the conventional utility grid to provide the customer with power.

Battery systems are measured by a kilowatt rating and a kilowatt-hour rating. The kilowatt rating is a measure of instantaneous power output. The kilowatt-hour rating is a measure of battery capacity. For example, a 50 kilowatt, 100 kilowatt-hour battery system could continuously supply power to a 25 kilowatt load for four hours but would not be able to sufficiently power a 75 kilowatt load, as the battery system kilowatt rating is too low.

With the ability to disconnect and operate independently, backup battery systems can provide for grid resilience, mitigate disturbances caused by natural disasters, and allow for faster system response and recovery. The battery system can be selected to meet the needs of the specific intended applications during a utility outage to reduce the loss of function of critical infrastructure. Subapplicants must clearly document how a proposed battery system’s capacity, including limitations without a power source, can meet the performance requirements to support the resilience of critical functions.

Secondary power sources for critical facilities must be protected as a Risk Category IV and a Flood Design Class 4 facility. For additional information about design classes, refer to ASCE 7. For additional information about flood design classes, refer to Table 7-1 in ASCE 24.

Generators are emergency equipment that provide a secondary source of power to a facility. Generators and related equipment (e.g., hookups) are eligible under HMGP, HMGP Post Fire and BRIC if they contribute to a long-term solution to the problem they are intended to address. Generator projects must be cost-effective. If there is insufficient data to evaluate the generator project using standard BCA methods, the project may be eligible under the 5 Percent Initiative.

Generators and/or related equipment are eligible:

• As a stand-alone project if the generator protects a critical facility.
• As a functional portion of an otherwise eligible mitigation solution (whether the facility is critical or not).

Related equipment is eligible if it is necessary to distribute power efficiently and effectively from a generator (e.g., generator hookups and pads).

For generators that are components of larger projects, the costs and benefits from the generator, along with any related equipment, may be aggregated with the costs and benefits from the other part of the project.

For purposes of eligibility, the size of the generator may be relevant. In general, to be eligible the generator size must be appropriate for the facility; the appropriate size may vary by facility and generator usage. It is not always necessary for the generator to support a facility’s operation to its full capacity, but it must be sized appropriately to ensure the facility can provide uninterrupted critical functions in the event of future power outages. Determining what facility functions the generator needs to support is crucial in selecting the correct generator for the facility. The rated output of the selected generator must be matched to the maximum anticipated capacity needed.

Eligible solar photovoltaic mitigation projects incorporate the use of solar photovoltaic systems as an alternative source of power or as a distributed energy resource.

Solar photovoltaic systems are eligible:

• As a stand-alone project if the solar photovoltaic system(s) protects a critical facility. Individual communities may determine what is considered a critical facility within their area, and the facility must be noted in the hazard mitigation plan for that community.
• As a functional portion of an otherwise eligible mitigation solution (whether the facility is critical or not).
• If required by code and the project meets all other programmatic requirements (whether the facility is critical or not).

Related equipment, such as battery storage, is eligible if it is necessary to store power efficiently and effectively from the solar photovoltaic system.

FEMA will ensure the eligibility of solar photovoltaic systems in the context of specific facility needs. For the facilities that require standby power supply, a local alternative source of power (such as a generator) may be necessary in addition to a solar photovoltaic system to provide sufficient local generation to power critical loads during a grid outage. In addition, batteries for solar photovoltaic systems may require significant storage space; this consideration should be addressed for the specific facility. Solar photovoltaic systems without an additional means of local generation are unlikely to be cost-effective and technically feasible, which are requirements for funding.

Documentation to demonstrate the feasibility and practicality of the proposed solar photovoltaic system must be provided to support project eligibility in the context of specific facility needs.

To be eligible for funding under HMA programs, the solar photovoltaic system configuration must be one of the following and be equipped with the features outlined below:

• The stand-alone solar photovoltaic system must be provided with an automatic disconnecting means that allows it to isolate from the grid if the system is grid connected.
• The capacity of the solar photovoltaic system and constituent equipment (including inverter and energy storage) proposed must reduce loss of function when the grid experiences an outage.

If the solar photovoltaic is a hybrid system, then the system must be provided with an automatic disconnecting means that allows it to isolate from the grid if the system is grid connected.

• The capacity of the generator, inverter and amount of energy storage proposed (if applicable) must reduce loss of function when the grid experiences an outage.
• If the hybrid system does not include a battery energy storage system, the following conditions must be fulfilled:
  • The capacity of the generator must be sized to serve all critical functions of the facility.
  • Reliable fuel sources must be available to support the generator.

Microgrids are eligible under HMGP, HMGP Post Fire and BRIC. Unlike generators or solar photovoltaic secondary power sources, microgrids are not limited to critical facilities. Microgrid projects will be evaluated by FEMA on a case-by-case basis, given that they meet other program requirements.

Backup battery systems are eligible under HMGP, HMGP Post Fire and BRIC. In general, to be eligible the battery system size must be appropriate for the facility. It is not often necessary for the battery system to support a facility’s operation to its full capacity, but it must be sized appropriately to ensure the facility can provide uninterrupted critical functions in the event of future power outages. Determining what facility functions the backup battery system needs to support is crucial in selecting the correct battery system for the facility. The rated power output, in kilowatts, of the selected battery system must be matched to the maximum anticipated capacity needed. The rated energy storage capacity, in kilowatt-hours, must be selected to provide emergency power for sufficient time to mitigate a loss of function due to a natural hazard or for a secondary power source to provide power to the facility and charge the battery system. While there is no minimum duration established, subapplicants must clearly document how long a proposed battery system can support the resilience of critical functions and ensure that duration is consistent throughout the subapplication, including the level of effectiveness assumed in the BCA.

Backup battery systems are eligible under the following scenarios:

• As a stand-alone project if the battery system protects a critical facility.
• As a functional portion of an otherwise eligible mitigation solution (whether the facility is critical or not).

Related equipment is eligible if it is necessary to distribute power efficiently and effectively from the backup battery system (e.g., convertors and pads).

For backup battery systems that are components of larger projects, the costs and benefits from the battery system, along with any related equipment, may be aggregated with the costs and benefits from the other part of the project.

The purchase of a secondary power source must be for a critical facility or constitute a functional portion of an otherwise eligible mitigation solution. The purchase of a secondary power source for the singular purposes of maintaining power for a single residential structure is therefore not an eligible activity for purposes of HMGP, HMGP Post Fire and BRIC.

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

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

Information needed for performing the BCA for secondary power source projects may vary by facility. The following are typically key inputs in the BCA for purposes of secondary power source projects:

• Project useful life:
  • Generators: According to OMB Circular A-76 - Revised Appendix 3, Useful Life and Disposal Value, the useful life for generators or generator sets is 19 years. This value can be used as the default useful life value when performing the BCA. It may be altered based on manufacturer warranty or other documentation that can demonstrate that the generator may be able to provide service for longer than 19 years.
  • Solar photovoltaic systems: The project must provide an alternative source of power for short-duration power outages over the project useful life. According to the National Renewable Energy Laboratory, the project useful life of a solar photovoltaic system ranges from 25 to 40 years. The subapplicant should demonstrate and document the rationale for the chosen project useful life of a solar photovoltaic system.
  • Microgrids: The project useful life ranges from 20 to 35 years and is most likely dependent on the secondary power source. The project useful life can be estimated longer dependent on the microgrid components and whether maintenance cost is incorporated to account for components being replaced.
  • Battery backup systems: The current project useful life typically lasts up to 10 years.
• Project costs: The cost of a secondary power source varies by size, installation and purpose. The secondary power source’s size and specifications must be reasonable, appropriate and necessary to continuing the critical functions of the facility. The subapplicant should (1) provide the exact costs for the secondary power source, installation and components and (2) include the costs in the BCA.
• Facility and value of service: For potable water, wastewater, police and fire stations and hospital facilities, analyses can be performed via the Historic/Professional Expected Damage methodology in the BCA Toolkit, which provide service values for these facilities. To use these values, the BCA Toolkit requires information regarding the population served by the facility. For example, if a secondary power source is to be installed at a wastewater treatment plant, the BCA Toolkit user must input how many customers are served by the facility and how many days the facility was inoperable because of power failure. These values can typically be obtained from the facility manager and can be provided on official letterhead for documentation purposes.
• Recurrence intervals: Recurrence information used in the analysis may vary by location or by the hazard that is anticipated to be or is the cause of power failure, such as wind or flood.
• Other benefits: Other benefits (or costs avoided) may be included if they are addressed by the secondary power source project if they are a direct result of interrupted power service that a secondary power source would have mitigated.

Information on pre-calculated benefits for generators for certain types of hospital projects can be found in Part 12.B.11.2.6.3 or on the FEMA “Benefit-Cost Analysis” webpage.

The following tools may be useful in determining a recurrence interval for secondary power source projects:

• If the facility lost power because of wind damage to power lines feeding the facility, the analyst can use the Applied Technology Council Wind Speed Tool to determine the frequency of the coastal wind event.
• If power outages are attributed to flooding, recurrence information for the flooding event should be used in the analysis. The National Weather Service’s Precipitation Frequency Data Server can be used to establish a frequency for various precipitation events.
• U.S. Geological Survey stream gauge data can also be used to extrapolate frequency information for flood events; details of this can be found in the Supplement to the Benefit-Cost Analysis Reference Guide FEMA guidance (June 2011).
• The National Snow and Ice Data Center.
• Default values from the generator module of the BCA Toolkit.
• Insurance claims, damage repair records or data from a state/local agency or local government newspaper accounts citing credible sources (other than anecdotal accounts) could be used in conjunction with the Unknown Frequency Calculator within the BCA Toolkit. Using this method may require more time as three events are required to complete the analysis.

All costs associated with power failure that would be mitigated by a secondary power source should be considered. For example, a wastewater treatment plant sometimes requires additional costs to bring the facility back to operating status after an extended power failure. This may include the removal of sludge in equipment or additional labor hours needed to bring the facility back to operational status. Those additional costs can be included above and beyond the value of service costs if a secondary power source would have prevented those additional costs.

To the extent they can be captured and justified, environmental cleanup costs associated with raw sewage discharge can be included in the BCA for wastewater treatment plants. FEMA does not have a default value for these associated costs, and these costs will vary by location. The subapplicant should include all reasonable costs that will be mitigated by having a secondary power source installed at a facility.

Additionally, finding the value (in loss of service terms) of a state emergency operations center to prove the cost-effectiveness of a secondary power source project is difficult. FEMA will allow reasonable and justified loss of service costs for state and local emergency operations centers identified by the subapplicant to be entered into the BCA Toolkit to evaluate the cost-effectiveness of an emergency operations center secondary power source project. An additional option is to investigate the costs of remobilizing an emergency operations center to an alternate/continuity of operations location that could be avoided should the emergency operations center be supplied with an uninterruptible power source.

FEMA established the use of a pre-calculated benefit to demonstrate cost-effectiveness for certain hospital generator projects.

The pre-calculated benefit is available for hospital generator projects if all the following requirements are satisfied:

• The hospital must have an emergency department.
• The project represents a stand-alone solution.^[484] The subapplication must provide enough information to demonstrate technical feasibility and effectiveness of the mitigation solution. This includes information from a licensed design professional for cost, generator capacity related to critical services throughout the hospital, and scope for a transfer switch, fuel storage and other required components.
• If the generator is part of a larger project, the pre-calculated benefits from the generator portion cannot be combined or aggregated with the benefits from another portion of the project.
• The total cost of the project must be less than or equal to the pre-calculated benefits.^[485]
  • The pre-calculated benefits for a hospital generator project are $6.95 per hospital building gross square footage in urban areas and $12.62 per hospital building gross square footage in rural areas.^[486] For purposes of this pre-calculated benefit, “urban” is defined as any location within an urbanized area as defined by the Census Bureau.^[487] “Rural” is defined as any location outside of an urbanized area (including urban clusters).
  • Furthermore, all locations in Alaska, Hawaii, Puerto Rico, the U.S. Virgin Islands and other island territories are considered rural for the purposes of this pre-calculated benefit. The applicant or subapplicant must use the address or latitude/longitude of the hospital to determine urban/rural status; this designation cannot be applied countywide or across Metropolitan Statistical Areas.

Documentation that the project meets the criteria above must be included in the project subapplication to use this pre-calculated benefit to demonstrate cost-effectiveness. Cost estimates must be based on industry standards, vendor estimates or other reliable sources.

All subapplications submitted to FEMA must meet the EHP eligibility criteria in Part 4. All subapplications must have a scoping narrative in accordance with Part 6.

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.

The subapplication must include the following:

• Scope of work: Provide a project scoping narrative identifying the proposed mitigation action and structures requesting backup power, including a description of the proposed activities, information on the critical facility, mitigation alternatives and an explanation of how the project will mitigate risk. The scope of work must include key milestones and correspond with the design information, project schedule and budget.
  • Solar photovoltaic systems must be designed in accordance with relevant industry standards and best practices to accomplish the intended risk reduction. Applicable design standards may vary depending on the proposed project and facility type. In addition, the subapplicant must work with the authorities having jurisdiction to ensure that all state and local requirements are being met.
  • Microgrids must be designed in accordance with relevant industry standards to accomplish the intended risk reduction. Examples include the Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces (IEEE 1547) and the Guide for Smart Grid Interoperability of Energy Technology and Information Technology Operation with the Electric Power System (IEEE 2030), End-Use Applications, and Loads.
  • Backup battery systems must be designed in accordance with relevant industry standards to accomplish the intended risk reduction. Examples include the International Electrotechnical Commission and Underwriters Laboratories Inc. standards.
  • The subapplicant must illustrate that the project is either a stand-alone solution (incorporating new control capability, load management systems, distributed energy resources or storage solutions into an already resilient grid) or a component of an overall solution (new solutions being implemented along with retrofit measures to make the distribution of power more resilient).
• Technical data to support the scope of work: Technical data is necessary to demonstrate that a project is feasible and effective at reducing risk. This data may consist of information such as engineering or design plans showing the existing electrical system including the utility transformer(s) and the proposed secondary power source size, interconnections and fuel source. This information can be further developed following the award and should be accounted for in the scoping narrative, schedule and budget if not available during application development.
• Critical facility information: The information is necessary to demonstrate that the project is feasible and effective at reducing risk. Information on the facility may include the date the structure was built, building type and the functions provided, construction type, and additional details relating to the existing condition of the structure.
• Project schedule: The application must include a detailed project schedule for all tasks identified in the project budget and the scope of work. The schedule identifies major milestones with start and end dates for each activity. Project schedules must show completion of all activities (including construction period) within the period of performance allowed by the relevant HMA program. Sufficient detail must be provided so FEMA can determine whether the proposed activities can be accomplished within the period of performance.
• Project budget: The project budget must contain a detailed line-item budget for all tasks identified in the project schedule and the scope of work. All costs included in the application should be reviewed to verify they are necessary, reasonable and allocable consistent with the provisions of 2 CFR Part 200. Include sufficient detail so that FEMA can determine whether costs are reasonable based on proposed activities and level of effort. Costs incurred prior to award may be considered pre-award costs (and eligible for reimbursement) if they are incurred after the date of the major disaster declaration (HMGP and HMGP Post Fire). For BRIC and FMA, refer to the relevant Notice of Funding Opportunity for eligibility of pre-award costs.
• Project location map: The application must include a map showing the project location. If the project includes multiple sites, the map should show the project boundaries, including the staging area.
• Property location information: An application must contain the physical address and latitude and longitude coordinates to the nearest sixth decimal place of each critical facility in the project application. If the project has multiple properties, the information for all properties should be provided. In general, a post office box number is not an acceptable address. If the address provided does not clearly match up with the structure(s) to be mitigated, provide photos or a site map with the structure(s) footprint(s) clearly identified.
• Flood Insurance Rate Map: The applicant should determine whether the project is located in a floodplain and provide a FIRM showing the project location. The applicant should include a description of the flood zone in which the existing structure is located and whether the site is in a regulatory floodway.
• Description of the hazard to be mitigated: The application must include information on the risk to be mitigated. Mitigation projects assisted under HMGP, HMGP Post Fire and BRIC must demonstrate the proposed mitigation activity will address a problem that has been repetitive or that poses a significant risk to public health and safety if left unresolved. Secondary power source projects must document the risk to the critical facility from natural hazards. Because multiple natural hazards can disrupt power supply, specify which hazard(s) is causing the loss of power that the secondary power source will mitigate and provide documentation of the hazard’s risk. The risk to be mitigated can be based on either documented historical damage (such as loss of function during a previous disaster event) or professionally expected damage (estimated damage that has not yet occurred or that occurred but not to the extent possible).

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 costs request can be found in Part 13.

The following are basic steps in implementing an approved HMA secondary power source project:

1. Pre-construction (carry out design process, seek technical consultant, prepare cost estimate, obtain building permits, hire project manager, hire construction manager/contractor).
2. Prepare site.
3. Install foundations and supports as needed.
4. Install secondary power source and supporting equipment.
5. Connect to utilities, battery system and/or to fuel system, as appropriate and required.
6. Conduct inspections.
7. Complete load testing.
8. Prepare operations and maintenance plans/agreements, which should include regular startup testing and load testing. Secondary power sources serving buildings should be tested in accordance with the latest published edition of NFPA 110, Standard for Emergency and Standby Power Systems.

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 secondary power sources 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.
• Any other milestones that have been identified in the subapplication or 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.^[488] 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.

In addition to the typical HMA program closeout procedures, closeout of secondary power source projects generally includes:

• Inspection report that verifies all work noted in the scope of work was completed and is consistent with the size, specifications and instillation method identified in the scope of work. The report must indicate the date the inspection was completed and who completed the inspection.
• Latitude/longitude to the nearest sixth decimal place of the project site and secondary power source location.
• Clearly labeled photographs, which must include a picture of the transfer switch. Photographs should also include a general overview of the installation and close-up views of the secondary power source.
• For portable generators, Standard Form 428, Tangible Personal Property Report, must be submitted if applicable to comply with disposition of equipment requirements. For more information, refer to Part 9.