B.8. Safe Room

HMGP, HMGP Post Fire and BRIC may provide assistance for residential and community safe rooms for tornadoes and hurricanes. Safe rooms provide immediate life-safety protection for a limited population that cannot evacuate out of harm’s way before an event. Safe room projects include retrofits of existing facilities and new safe room construction. Assistance can be used for both single- and multi-use facilities.

BRIC, HMGP, and HMGP Post Fire assistance may only be used for safe room projects designed to achieve “near-absolute protection” as described in the latest published edition of FEMA P-361, Safe Rooms for Tornadoes and Hurricanes: Guidance for Community and Residential Safe Rooms, Fourth Edition (April 2021). Any lower threshold of protection exposes safe room occupants to a greater degree of risk than is acceptable. FEMA P-320, Taking Shelter from the Storm: Building or Installing a Safe Room for Your Home, Fifth Edition (March 2021), provides guidance and prescriptive plans for residential safe rooms, but refers to FEMA P-361 for the criteria. Therefore, the HMA Guide uses FEMA P-361 as the basis for safe room design requirements.

Safe rooms may also be designated to serve as recovery shelters, but only features required for the safe room functionality will be eligible for BRIC, HMGP or HMGP Post Fire assistance. BRIC, HMGP and HMGP Post Fire safe room assistance is not available for facilities that will solely be used as general population shelters, including evacuation and recovery shelters. Safe rooms and general population shelters are different in two ways. First, general population shelters are generally not intended to withstand extreme wind events and therefore do not provide near-absolute protection consistent with residential and community safe room criteria in FEMA P-361. Also, general population shelters are intended to provide longer-term services and housing for people who have left the anticipated impact area after a disaster event; safe rooms are intended to provide protection for a minimum of two hours in tornado events and 24 hours in hurricane events.

The planning and operation of BRIC, HMGP and HMGP Post Fire safe rooms must not conflict with state and/or local evacuation plans. BRIC, HMGP and HMGP Post Fire safe room projects must not be used as a substitute for, or as an option for individuals to ignore, local community and/or state evacuation plans or any other law or ordinance.

When there is sufficient warning time in extreme wind events, such as hurricanes, the general population can be expected to leave the area of anticipated immediate impact and seek shelter outside of the impacted area. Therefore, for hurricane threats, FEMA considers providing assistance only for safe room projects designed for populations the state, local community and/or other authorities having jurisdiction indicates cannot remove themselves from harm’s way before a hurricane that is anticipated to make landfall. This should normally be limited to first responders and continuity of operations essential staff; in rare geographic circumstances (such as island states or territories where vehicle access to the continental U.S. by roadway is not available) it may include populations that cannot evacuate. The applicant and subapplicant must provide a basis for the intended population.

In extreme wind events, such as tornadoes, there may be little or no warning to allow the general population to leave the area of immediate impact, and they must, therefore, seek immediate life-safety protection. Little or no warning limits the potential occupancy of tornado residential and community safe rooms to the people who are on-site or nearby.

FEMA requires applicants and subapplicants to design and site all hurricane or tornado saferoom projects in accordance with FEMA Funding Criteria in the latest publication of FEMA P-361 and latest edition of ICC 500, ICC/National Storm Shelter Association Standard for the Design and Construction of Storm Shelters,as minimum design criteria. The scope of work narrative must clearly state the hurricane or tornado saferoom will be designed to meet or exceed FEMA Funding Criteria, which are more conservative than code and standard minimum requirements provided in FEMA P-361.

FEMA will consider an extreme wind event mitigation activity, consisting of the retrofit or construction of a residential or community safe room (single- or multi-use), to be an eligible project type for HMGP, HMGP Post Fire and BRIC if:

• The safe room project provides immediate life-safety protection in the projected impact area of a hurricane and/or tornado.
• The safe room project is designed and constructed to meet or exceed the requirements in the latest published edition of the ICC 500 and the FEMA Funding Criteria in the latest published edition of FEMA P-361 (based on award agreement date) and is verified by a licensed design professional.
• The safe room project is not sited in FEMA-designated SFHAs, or if the saferoom project is located in a FEMA-designated SFHA area or the 500-year flood hazard area, but the 8-Step Decision Process was successfully completed for Executive Order (EO) 11988 on Floodplain Management (May 24, 1977), as amended by EO 13690 on Establishing a Federal Flood Risk Management Standard and a Process for Further Soliciting and Considering Stakeholder Input (Jan. 30, 2015), as provided by 44 CFR § 9.6 (i.e., the consultation with the local and state emergency management officials led to the conclusion that there is no other feasible option than having the safe room project sited in an SFHA or the 500-year flood hazard area, as outlined in FEMA P-361).^[465]
• The lowest floor of residential tornado safe rooms must be elevated to at least 1 foot above the Base Flood Elevation, the height required by the Federal Flood Risk Management Standard, or the minimum elevation required by the local floodplain ordinance or flood design requirements, whichever is highest.
• The safe room is designed and sized only to the extent necessary for the limited population that must remain in the impact strike area during an extreme wind event.
• The safe room is designed to accommodate occupants for a minimum duration time frame as required in FEMA P-361. Safe rooms must be sized according to the defined population that will use the facility during a storm event.
• Project costs are directly related to and necessary for the hazard mitigation purpose of providing immediate life-safety protection through the structure and the building envelope for the limited population required to remain in the impact area during an extreme wind event.
• For community saferooms, the subapplicant develops an operations and maintenance plan. At a minimum, the process to include operations and maintenance plans includes the following:
  • Descriptive statement of the operations and maintenance plan at the time of the application along with a statement of assurances that the operations and maintenance plan will be developed during project implementation.
  • Final operations and maintenance plan prior to project closeout.
• The safe room project demonstrates cost-effectiveness.
• The safe room project complies with all relevant EHP regulations.
• The safe room project adheres to other program conditions as described in the HMA Guide.

Table 28 highlights eligible safe room activities.

Table 28: Eligible Safe Room Activities

Eligible Activities	HMGP	HMGP Post Fire	BRIC	FMA
Hurricane residential safe room	Yes	Yes	Yes	No
Hurricane community safe room	Yes	Yes	Yes	No
Tornado residential safe room	Yes	Yes	Yes	No
Tornado community safe room	Yes	Yes	Yes	No

FEMA will only consider subapplications for safe room projects that identify the safe room population that must remain behind or will not have time to leave and faces an imminent threat of a tornado, hurricane or both. The applicant or subapplicant will identify and quantify this population so the safe room’s size can be verified during the subapplication review process. The size of the safe room is demonstrated by risk assessment information, such as information that is developed as part of a mitigation plan or evacuation plan.

The following information provides details to help applicants and subapplicants identify, quantify and document eligible populations needing hazard mitigation life-safety protection during extreme wind events. This section further describes categories of populations that are affected by tornadoes, hurricanes or both.

At a minimum, the applicant will demonstrate consideration of the following components in determining the eligible safe room population:

• Population to be protected within the area of impact by tornado and/or hurricane hazards.
• Warning capabilities, logistics and operation components that support basic safe room functions.
• Travel times and routes for the population to be protected to reach the safe room so that people are not exposed to additional risk when moving to the protected area.
• Hazard mitigation time of protection: minimum of two hours for tornadoes and 24 hours for hurricanes.
• Relationship of the population to be protected by the safe room to state or local emergency evacuation requirements.
• Effective and accessible warnings (alerts) that address the needs of individuals with disabilities and other access and functional needs and/or individuals who have limited English proficiency.

Community safe rooms are intended for a limited population, but the criteria for tornadoes and hurricanes differ in certain applications. When the limited population for tornadoes and hurricanes is identified, the respective mitigation activities must be considered separately and then combined (if both exist) using the most conservative requirements between the two. A combined safe room will have to comply with the larger square footage area per person and longer protection and with the more stringent debris impact protection. Characteristics such as the size of the targeted area, the warning time before the impact, and the duration of the storm affect the population requiring protection differently; therefore, the impacted population must be determined for each type of event.

Applicants and subapplicants must provide documentation to support the identified population for the safe room and must also submit adequate documentation in support of their risk assessments to allow grant program reviewers to determine whether the proposed safe room size is appropriate for the identified population. The documentation should be sufficiently detailed to be verified during the subapplication review process. Applicant and subapplicant coordination with the applicable federal, state or local (if applicable) agency responsible for developing emergency action plans is critical. In general, emergency response plans, evacuation plans, area maps, building construction drawings and meeting notes that can be used to quantify the population are acceptable. In addition, local or federally recognized tribal mitigation plans are required to describe the susceptibility of the community (especially high-risk populations) and structures, and they may also be sources for this information. The following sections identify issues to consider when applying for assistance for a hurricane, tornado or combined hazard community safe room. Applicants and subapplicants should select the most appropriate population for their safe room project using the steps described in the sections that follow.

Determining the hurricane safe room population depends on the assumptions used in the evacuation or emergency response plans and policies being administered by federal, state and local emergency management organizations. Therefore, applicants and subapplicants are encouraged to coordinate with the relevant agency in the jurisdiction that developed the plans. In addition, local or federally recognized tribal mitigation plans are required to include a risk assessment that defines the hazard characteristics within an area and the specific needs for the affected population. Evacuation plans are likely to be more specific in terms of population, but the risk assessment in a community’s existing mitigation plan may also be a source for this information. Documentation to support the determination of the impacted population may be directly related to the planning tools mentioned above and should be included in the subapplication.

Generally, two broad categories of potential hurricane safe room occupants may be identified as part of the limited population in need of life-safety protection: (1) first responders and continuity of operations essential staff and, in rare circumstances, (2) populations on island states or territories where vehicle access to the continental United States by a roadway is not available.

The impacted population must be accommodated within the safe room for a minimum of 24 hours (the FEMA P-361 minimum design occupancy time for hurricane safe rooms). Applicants and subapplicants are encouraged to use verifiable information, such as emergency evacuation plans and local emergency management plans (or other applicable sources), to identify potential safe room occupants from the categories listed below.

Category 1: First Responders, Critical and Essential Services Personnel, and Facility Occupants

The civilian personnel of emergency response services, also known as first responders, may be required to remain in harm’s way. First responders include but are not limited to fire and police department personnel, rescue squads, emergency operations center personnel, emergency medical and ambulance service providers, search and rescue teams, and similar personnel whom a local community may depend upon for a successful response to an extreme wind event.

In many cases, other critical services personnel may be required to remain in harm’s way to facilitate the continued operation of certain critical facilities, including material storage facilities, communications and data centers, and others that a local community may depend on for a successful response to an extreme wind event.

Category 2: Individuals Who Cannot Evacuate

This category may include occupants of facilities, such as patients in hospitals, residents of long-term care facilities and other occupants for which evacuation would be detrimental to their well-being. This category could also include prison populations that are unable to be evacuated safely, populations on island states or territories where vehicle access to the continental U.S. by a roadway is not available and who do not have the option to evacuate, or other vulnerable populations that cannot be easily moved.

B.8.2.2.1.1.2. Hurricane Travel Time Considerations

The issues to consider in estimating travel time to the safe room facility include local emergency management and law enforcement requirements, mandatory evacuations, evacuation times from the anticipated area of impact, and any other plans that affect the movement of at-risk populations. Further information is provided in FEMA P-361.

Occupants of one- and two-family dwellings with a residential safe room that meets the siting and elevation requirements in FEMA P-361 are assumed to use that room and require no evacuation and minimal travel time unless evacuation has been deemed mandatory by the authority having jurisdiction.

B.8.2.2.1.1.3. Hurricane Period of Protection

As identified in FEMA P-361, the hazard mitigation time of protection for safe rooms is a minimum of 24 hours for hurricane events. Therefore, any ancillary equipment required to operate during an event for the safe room must also be properly sized and protected to the same level as the safe room.

B.8.2.2.1.1.4. Coordination with State/Local/Tribal/Territorial Evacuation Plans

In all cases, planning and operation safe rooms, including the identification of the population to be protected, must not conflict with state, local, tribal and/or territorial evacuation plans.

Safe room activities must not be used as a substitute or as an option for individuals to ignore state, local, tribal and/or territorial evacuation plans or any other law or ordinance.

B.8.2.2.1.1.5. Hurricane Warning Capabilities

In addition to design and construction criteria, an accessible and effective warning system must be in place to notify prospective community safe room occupants when they should evacuate to the safe room facility. Applicants and subapplicants for community safe room projects must demonstrate that the population can be properly notified to allow sufficient travel time to the community safe room.

B.8.2.2.1.1.6. Population Impacted by Tornadoes

Populations impacted by tornadoes are generally limited to the family or group of families who live in the dwelling or dwellings served by the safe room, workers or students who have access to a safe room at their place of business or school and individuals who have access to an on-site community safe room. Because of the short period between tornado identification and impact, these at-risk populations must be close to the safe room to benefit from it.

Tornado safe room populations are determined based on limited warning times (i.e., minutes) and the maximum reasonable travel time for potential safe room occupants to reach the safety of the facility. The populations that cannot reach the safe room within a reasonable time are not considered as potential occupants of the safe room.

The following two aspects of higher risk should be considered when identifying and quantifying the population impacted by a tornado:

• The physical characteristics of the built environment (buildings or other structures) in which the population resides. Because buildings differ in their susceptibility to damage from a tornado, building occupants are exposed to varying risks of injury or death. Individuals living in non-engineered, older and/or manufactured housing are more susceptible to catastrophic damage from a tornado.
• The ability of the population to mobilize to the safe room during a tornado, regardless of where they are located. Children and adults with disabilities and others with access and functional needs may require a greater level of assistance, time to mobilize and attention during an emergency. These considerations should be factored into planning.

B.8.2.2.1.1.7. Tornado Travel Time Considerations

The most effective tornado safe rooms minimize occupant travel time. Consequently, on-site community safe rooms, built either as integral parts of a building or as separate structures, offer the greatest level of protection to occupants. Community safe rooms in hospitals, schools, long-term care centers and other facilities that house highly susceptible populations are the most successful in minimizing the risks. These safe rooms may be designed to serve the community-at-large in addition to on-site residents. In such cases, the population of the safe room is limited by the proximity of potential occupants to the safe room, which is defined by the maximum allowed travel time and/or the maximum distance to the safe room.

The distance from the safe room for the at-risk population is based on a maximum walking travel time of five minutes, or 0.25 miles, or a maximum driving travel distance of approximately 0.5 miles. When considering a single- or multi-use community safe room, the five-minute walk time or the equivalent 0.5-mile driving distance must be calculated by the actual travel route or pathway that a pedestrian or a driver will be required to follow. Where intended occupants are coming from nearby buildings (e.g., school or hospital campuses with multiple buildings), a maximum distance of 1,000 feet between occupant-source buildings and the safe room entrance is recommended to allow time for egressing the occupant-source buildings. A 1,000-foot maximum distance from not fewer than one exterior door of each building to a door of the shelter serving that building may be required by building code for newly constructed safe rooms in some areas.

The pathway must not be restricted, bottlenecked or obstructed by barriers such as multilane highways, railroad tracks, bridges or similar facilities or by topographic features. Traffic congestion (including parking constraints) during the movement of the potentially affected population to the safe room once a storm watch/warning notification is issued should be considered when defining the limited population for the community safe room. In either case, whether walking or driving, prospective safe room occupants must be able to safely reach the facility within five minutes of receiving a tornado warning or notice to seek shelter.

B.8.2.2.1.1.8. Tornado Period of Protection

As identified in FEMA P-361, the occupancy duration in a tornado safe room is a minimum of two hours for a tornado event. Therefore, any ancillary equipment required to operate during an event for the safe room must also be properly sized and protected to the same level as the safe room.

The identified population directly affects the proposed safe room design size and is verified during the subapplicant review process. HMGP, HMGP Post Fire and BRIC assistance is provided only for the minimum size required to accommodate the identified population; costs for space that exceed the allowable size must be fully funded by non-FEMA sources and cannot be counted toward the federal cost-share of the award. HMA program safe room project subapplications are subject to usable floor area per occupant space requirements and size limitations identified in the design criteria noted in this section. Table 29 identifies the minimum required usable floor area per safe room occupant consistent with FEMA-recognized design criteria.

Table 29: HMA Safe Room Minimum Usable Floor Area per Safe Room Occupant^[466]

Type of Safe Room	Occupant	Minimum Usable Floor Area per Occupant* (square feet)
Tornado community safe room	Standing or seated	5
	Wheelchair user	10
	Relocated to a bed or stretcher	30
Hurricane community safe room	Standing or seated	20
	Wheelchair user	20
	Relocated to a bed or stretcher	40
Tornado residential safe room	One- and two-family dwelling	3
	Other residential	5
Hurricane residential safe room	One- and two-family dwelling	7
	Other residential	10

^* For community safe rooms, at least one wheelchair user-sized space is required for every 200 occupants or portion thereof.

In addition to the square footage requirement per person, applicants and subapplicants must consider the normal functional use of the area. The type of durable medical equipment and furniture in the dual-purpose safe room will determine how to calculate the net usable area, which is the available area to be used by the occupants after reducing the non-usable area from the gross area.

For example, a community may decide to build a multi-use facility that includes a tornado safe room function in a community center. The new facility may include an assembly or multipurpose room that has 1,185 square feet. To use the space as a community tornado safe room, the gross square footage must be reduced to account for egress circulation, partitions, interior columns, furnishings, finishes, equipment and other features. The calculation may be exact or estimated using the methodology in FEMA P-361. For this example, the area is considered an open floor plan, and only 85% of the gross area can be considered net usable area for the occupants seeking shelter. Using 85% of the gross square footage as usable square footage, the 1,185 square feet is reduced to 1,007 usable square feet:

According to FEMA P-361 design criteria, a minimum of 5 square feet per safe room occupant must be provided in a tornado community safe room (refer to Table 29). In this example, safe room designers must also account for the use of durable medical equipment (e.g., wheelchairs, walkers or hospital beds).

A tornado community safe room must be sized to accommodate a minimum of one wheelchair space (at 10 square feet) for every 200 occupants or portion thereof. Therefore, the 1,007-square-foot usable floor area would provide enough space to protect 200 occupants (refer to Table 30) and would be eligible for HMGP, HMGP Post Fire and BRIC assistance. It would not be reasonable for an application in this example to include a request for usable square footage of 2,000 square feet because that amount of space has not been demonstrated as being necessary for an identified at-risk population of 200 occupants.

Table 30: Example Community Safe Room Size

Occupants	Required Square Feet per Person	Total Square Footage of Usable Floor Area
199 occupants	5	995
One occupant in wheelchair	10	10
Total 200 occupants	-	1,005

Applicants and subapplicants should refer to FEMA P-361 for further information on sizing criteria.

To be considered for assistance, HMGP, HMGP Post Fire and BRIC safe room projects must include maps or other documentation that identify the project location relative to the floodplain and meet FEMA Funding Criteria, flood hazard siting limitations and elevation requirements in FEMA P-361.

Except in special circumstances, safe rooms should not be sited in FEMA-designated SFHAs unless consultation with state and local emergency management officials concludes there is no other feasible option. If it is not possible to locate a safe room outside of the SFHA, precautions must be taken to ensure the safety and well-being of anyone using the safe room. If a saferoom is sited in a SFHA, there are additional design and siting requirements, such as elevation, that must be addressed. Refer to the latest published edition of FEMA P-361 for design and siting criteria.

The needs of the whole community requiring safe room space must be considered. Safe room construction should integrate considerations for:

• Proximity of location to affected populations.
• The size of the safe room.
• Egress/ingress of the safe room to accommodate the affected populations.
• Ensuring facilities within the safe room comply with ADA regulations, such as toilets or hand-washing stations.
• Accessible alerts and warnings.
• Appropriate access for persons with disabilities, which must be provided in accordance with all federal, state and local ADA requirements and ordinances.

Safe room subrecipients should be aware that accessibility provisions of the applicable code may exceed the minimum requirements of the ADA. For example, provisions for accessible routes connecting multistory buildings in Section 1104.4 of the 2021 IBC are more extensive than similar criteria in the ADA.

HMGP, HMGP Post Fire and BRIC assistance is not available for general population shelters, including evacuation and recovery shelters. The emergency management measures necessary to afford protection to thousands of occupants of large, public venues, such as stadiums or amphitheaters, are beyond the scope of BRIC, HMGP and HMGP Post Fire community safe rooms; therefore, general population shelters are not eligible for assistance under BRIC, HMGP or HMGP Post Fire.

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

To be considered for assistance, HMGP, HMGP Post Fire and BRIC community safe room project subapplications must include a written statement acknowledging the requested community safe room will be operated and maintained in a manner that achieves the proposed hazard mitigation. FEMA will only consider operations and maintenance plans that have considered the guidance in FEMA P-361. Operations and maintenance plans are not required for residential safe rooms.

Community safe rooms are built and operated to provide immediate life-safety protection during extreme wind hazards. To achieve this purpose, community safe rooms must be built to the design criteria and be operated and maintained so that they are able to provide intended occupants with the timely protection and services that they need. Subapplicants must provide an operations and maintenance plan statement of assurances with the safe room project subapplication acknowledging the requested community safe rooms will be operated and maintained in a manner that achieves the proposed hazard mitigation.

The steps in meeting the operations and maintenance plan requirements are as follows:

1. The subapplicant develops a description of the operations and maintenance plan that includes an assurance that the plan will be developed during project implementation and includes the description in the subapplication. The operations and maintenance plan description must include:
   1. A description of the maintenance procedures.
   2. A brief statement about the operation of the safe room when it is in use.
   3. Basic information about how the safe room will be used, including how use is initiated, the warning system, and basic procedures for opening the doors to the public.
   4. Key components of the safe room maintenance procedures.
   5. The office that will be responsible for the operations and maintenance of the safe room.
   6. Assurance the operations and maintenance plan will be developed and completed before project closeout.
2. The subrecipient develops the operations and maintenance plan.
3. Prior to closeout, the recipient and FEMA review the subapplicant’s final signed operations and maintenance plan. The community safe room inventory in the operations and maintenance plan must include essential equipment and supplies, such as communications equipment, emergency equipment, first-aid supplies, water and sanitary supplies.

The development of an operations and maintenance plan should be coordinated with the appropriate entities using and operating the community safe room and should be signed by authorized officials in these organizations.

The operations and maintenance plan may be based on preliminary engineering drawings and must include, at a minimum, the components listed below. FEMA P-361 provides guidance and best practices on operations and maintenance plan components. The required components of a plan are summarized below.

The operations components of an operations and maintenance plan must include the following, at a minimum:

• Community organization(s) responsible for operating and maintaining the community safe room, such as the local emergency management office, and contact information for the relevant office(s).
• Command and management roles and responsibilities for key individuals, such as the safe room manager and site coordinator, and their essential duties and/or the agency responsible for fulfilling these roles.
• Major tasks that the safe room management team will perform during a tornado/hurricane watch issued by the National Weather Service.
• General operation tasks in the community safe room from the time the emergency is announced to the time occupants may safely leave.

The maintenance components of an operations and maintenance plan should include assurance from the organization responsible for operating and maintaining the community safe room of the following during the useful life of the community safe room:

• Non-mitigation uses will not prohibit the use of the community safe room to perform its hazard mitigation purpose of life-safety protection (i.e., the safe room will not be used for storage or other activities that would reduce the available occupancy/space).
• A designated party will schedule and perform regular maintenance during the useful life of the community safe room.
• Basic exterior and interior signage will be posted as necessary and appropriate for adequate safe room operations.
• A redundant power source, such as batteries or generators, will be available to provide standby (emergency) power for lighting and ventilation for the community safe room in the event of primary power failure, as required.

FEMA requires that the recipient affirm that the final operations and maintenance plan meets the FEMA P-361 requirements by following the steps below:

1. Review the final operations and maintenance plan to ensure it addresses the operations and maintenance components.
2. Coordinate with the subrecipient to address any missing components.
3. Transmit the final operations and maintenance plan to FEMA with a written statement affirming that it is consistent with FEMA P-361 guidance.

FEMA will review the plan and inform the recipient in writing once it has determined that the final plan has all the required components. FEMA’s comments on the final operations and maintenance plan must be addressed before FEMA makes a final determination of consistency. Recipients not completing a final operations and maintenance plan at closeout will be subject to the recoupment of award assistance as determined by FEMA.

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

HMGP, HMGP Post Fire and BRIC safe room project subapplications must demonstrate project cost-effectiveness using one of the methodologies described in Part 5. Pre-calculated benefits may only be used for tornado residential safe rooms.

This section discusses the total project costs required to demonstrate compliance with cost-effectiveness requirements. The total project cost for BCA purposes is the sum of all eligible costs necessary to achieve life-safety protection. Eligible project costs generally include:

• Design activities.
• Site preparation and building foundation materials and construction.
• Structural systems capable of resisting the design wind loads (including roof and wall framing).
• Protective envelope components such as walls, ceiling/roof systems and impact protective systems (doors, shutters).
• Other retrofit hardening activities that meet FEMA-approved performance criteria.
• Functional components such as permanent electrical lighting, heating, ventilation, air conditioning, and toilets and hand-washing facilities consistent with FEMA P-361 criteria; fire suppression sprinkler systems; and signage, emergency communications equipment and backup power generation for the safe room area.
• Operations and maintenance plan development.
• Costs associated with the acquisition of land.

In some cases, the total project cost of a safe room for a large community may exceed HMGP, HMGP Post Fire or BRIC limits. In these cases, the actual total project cost must be used in the BCA. The program funding limit (which would be less than the actual project cost) may not be used as the total project cost entered into the BCA. Similarly, some applications may not request HMGP, HMGP Post Fire and BRIC assistance up to the available federal cost share. In these cases, the BCA must still use the sum of all required (not just requested) costs necessary to achieve the hazard mitigation purpose of immediate life-safety protection.

Tornado residential safe rooms have different requirements than community tornado safe rooms. Unlike community safe rooms, tornado residential safe room construction projects may use pre-calculated benefits to demonstrate cost-effectiveness methodology.

Applicants must use the Expedited HMGP Application for Residential Safe Rooms to apply for pre-calculated benefits under HMGP and HMGP Post Fire. The pre-calculated benefit provides standardized BCA benefit values associated with residential safe rooms so that individual BCAs are not required as long as the project costs do not exceed the benefits (shown in Table 31). A safe room that costs less than the value indicated for the state where it is located is automatically considered cost-effective. For subapplications that contain multiple structures, the average cost of all structures in the project must be less than the value provided below. For additional information, refer to the Safe Room Project Application Using Pre-Calculated Benefits FEMA job aid.

For up-to-date information on the dollar value of the pre-calculated benefit, refer to the FEMA “Benefit-Cost Analysis” webpage.

Table 31: Tornado Residential Safe Room Aggregate Benefits by State

State	Aggregate Benefit	State	Aggregate Benefit
Alabama	$13,336.96	Nebraska	$9,921.78
Arkansas	$16,717.85	North Carolina	$5,723.26
Georgia	$5,290.98	Ohio	$11,469.38
Illinois	$13,685.72	Oklahoma	$18,366.36
Iowa	$14,962.87	Pennsylvania	$4,065.90
Indiana	$18,126.34	South Carolina	$6,139.38
Kansas	$14,005.75	South Dakota	$5,230.17
Kentucky	$13,554.96	Tennessee	$13,579.58
Louisiana	$9,921.94	Texas	$5,421.32
Michigan	$6,522.49	Virginia	$3,936.05
Missouri	$15,654.96	West Virginia	$4,973.50
Mississippi	$20,067.64	Wisconsin	$9,025.48
Minnesota	$7,092.39

Projects must be consistent with Part 4. 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 or established codes, standards, modeling techniques or best practices.

To qualify for HMGP, HMGP Post Fire or BRIC assistance, a safe room must be designed and constructed to meet the requirements and FEMA Funding Criteria in FEMA P-361 (refer to Appendix D). Applicants must submit documents that include a statement that safe room design conforms to the provisions of the latest editions of ICC 500 and FEMA P-361.

In addition, all HMA-assisted safe room projects in flood hazard areas must also comply with the requirements established by the Federal Flood Risk Management Standard. Refer to Part 4.I for more information about these requirements.

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.

To assist with the EHP review, FEMA has prepared a Programmatic Environmental Assessment to help project application developers and reviewers streamline the evaluation of potential impacts to the human environment resulting from the construction of residential and community safe rooms that are proposed for HMGP, HMGP Post Fire or BRIC assistance. The Programmatic Environmental Assessment provides the public and decision-makers with helpful information necessary to understand and evaluate the potential environmental consequences of these hazard mitigation actions and helps streamline the National Environmental Policy Act review process.

The Safe Rooms–Required Information for EHP Review FEMA job aid lists the documentation needed for FEMA to complete the EHP compliance review process for projects.

Mitigation projects sited within the SFHA are eligible only if the jurisdiction is participating in the NFIP. For more information, refer to Part 4.J.

For structures in the SFHA at the completion of the project, flood insurance must be maintained for the life of the property.^[467] For more information, refer to Part 4.J.

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 identification of the impacted population:

• Documentation on the composition, size and rationale for including each group designated as a disproportionately impacted population.
• Description of warning capabilities, logistics and operation components that support basic safe room functions.
• Documentation that demonstrates how the designated population would reach the safe room within the prescribed time limit after notification as required by FEMA P-361 (for tornado residential and community safe rooms).
• If land acquisition is proposed, the current value of property and documentation demonstrating how the market value was determined.
• For community safe rooms, description of the approach the subapplicant will use in preparing the operations and maintenance plan.

As part of the scope of work, all subapplications must include an activities description referencing industry standards or project plans and specifications and a schedule for the project. Additionally, a scope of work must include work activities, deliverables and timelines associated with a project.

If property acquisition is proposed, the subrecipient must conduct a title search for the property it plans to acquire. The purpose of the title search is to ensure the owner is the sole and actual titleholder to the property, to identify other persons with a property interest if the owner is not the sole and actual titleholder and to ensure the title is clear (i.e., no mortgages or liens are outstanding on the sale of the property).

The subapplicant should document the process they will use to gain the necessary state and local approvals to construct a community saferoom, prior to the purchase of the property.

Other title-related requirements are as follows:

• A title insurance policy demonstrating the clear title must be obtained for each approved property that will be acquired.
• A physical site inspection for each property must be conducted to verify there are no physical encumbrances to the property (a site survey may be necessary to clearly establish property boundaries).
• The property title must be transferred by a warranty deed in all jurisdictions that recognize warranty deeds.
• The subrecipient must take possession at settlement.
• The subrecipient must record the deed at the same time as settlement along with any program deed restrictions.
• The deed transferring title to the property and the program deed restrictions will be recorded according to state law and within 14 calendar days after the settlement.

Eligible costs for BRIC, HMGP and HMGP Post Fire assisted safe room projects are costs for project components (e.g., design, construction, project management) that are related directly to and necessary for the hazard mitigation purpose of providing immediate life-safety protection by means of the structure and the building envelope to the limited population that must remain in the impact area during an extreme wind event.

For each structure type, eligible project costs are limited to:

• Protection by design components, including the safe room envelope and impact protective systems (walls, ceilings, doors, windows, as specified in FEMA P-361, ICC 500 and applicable local building codes).
• Ancillary components required by FEMA P-361, including standby (backup) power, communications and emergency electrical lighting limited to within the safe room, as well as protection of ancillary components to the same degree as the safe room.
• Design and construction components for safe room portion only, including engineering fees, permit fees, special inspection fees and excavation.
• Required features necessary for safe room function and habitation, including ventilation, permanent electrical lighting, and ADA requirements such as accessible toilets and hand-washing stations.

Costs associated with providing facilities for any function that is not essential for life-safety protection of occupants are not eligible. If a safe room facility can fulfill its basic function of life-safety protection for occupants during a storm without a building feature or component that provides conveniences or additional comfort, costs associated with that feature or component are not eligible. Examples are flooring, seating and food preparation facilities. This is a significant issue in multi-use community safe rooms, which are designed to provide other functions that are not eligible for funding.

Table 32 shows examples of eligible and ineligible components of residential and community safe rooms. This table can be referred to when determining whether a component is an eligible cost of a safe room application. Note there are differences in what is considered an eligible cost for a residential safe room versus a community safe room because of the different scope of the projects. Some items for multi-use safe rooms may be prorated based on safe room-specific occupancy.

Table 32: Eligible and Ineligible Components of Residential and Community Safe Rooms

Building Systems and Components	Residential	Community
Structural systems that directly support or protect the safe room to provide near-absolute life-safety protection	Yes	Yes
Impact protective systems (doors, windows and other opening protection)	Yes	Yes
Protection of backup mechanical, electrical, ventilation and communication equipment necessary to provide life safety for the safe room	Yes	Yes
Safe room signage	Yes	Yes
Communications, including Local Area Network drops and wiring if used for emergency communication during an event	Yes	Yes
Construction permit fees	Yes	Yes
Alternate source of power for the safe room	Yes	Yes
First aid supplies and equipment to meet safe room occupancy requirements	Yes	Yes
Fire suppression systems (sprinklers systems and fire extinguishers)	No*	Yes
Electrical lighting and outlets	Yes	Yes
ADA requirements	Yes	Yes
Ventilation	Yes	Yes
Heating, ventilation and air conditioning used for required ventilation	Yes	Yes
Heating, ventilation and air conditioning not used for required ventilation	No	No
Accessible toilets and hand-washing stations in safe room	No	Yes
Planning/engineering/architecture design fees	Yes	Yes
Engineering study to calculate undefined flood elevations	Yes	Yes
Engineering peer review	Yes	Yes
Site preparation	Yes	Yes
Inspections, including special inspections	Yes	Yes
Soil test	No	Yes
Storage room for food, water and safety equipment	No	Yes
Purchase of land (market value of the real property [land and structures] at the time of sale)	No	Yes
Fees for necessary appraisals, title searches, title insurance, property inspections, permit fees, and surveys	No	Yes
Fees associated with the title transfer and contract review, and other costs associated with conducting the real estate settlement, including recordation of the deed and deed restrictions	No	Yes
Property tax liens or tax obligations that can be extinguished with proceeds from property sale while performing the transfer of title	No	Yes
Safe room maintenance	No	No
Restroom fixtures not required by code or FEMA P-361	No	No
Paint on walls and ceilings of safe room	No	No
Floor coverings – subfloors not required for life safety	No	No
Removal of structures from developed land	No	No
Kitchen cabinets, countertops and other equipment not required for life safety	No	No
Security cameras and emergency operations center-type equipment	No	No
Landscaping	No	No
Parking and all non-building elements unless required for ADA compliance	No	No

^* Eligible if required by local codes

All subapplications must include a line-item breakdown of all anticipated costs. Refer to Part 6 for more information.

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.

Applications for safe room projects must include detailed line-item costs in the project budgets. Well-documented project budgets contain quantities, unit costs, and a source for each unit cost. In contrast, lump-sum estimates do not provide quantities and unit costs required to evaluate the accuracy of the project budget. Lump-sum estimates are not acceptable.

HMGP, HMGP Post Fire and BRIC project budgets include unit costs related to the proposed square footage of the protected area or areas of the safe room. Unit costs may also be related to the protected population (occupants) of the safe room.

For property identified for acquisition, the subrecipient shall establish and document a property value based on market value, which is defined as:

The current market value reflects the property value at the time of purchase. The following appraisal methodology must be used to determine property value:

• The appraisal must be conducted by an appraiser in accordance with the Uniform Standards of Professional Appraisal Practice.
• The appraiser must comply with relevant state laws and requirements and have the appropriate certification, qualifications and competencies based on the type of property being appraised.

The basic steps in implementing an approved HMA safe room project are:

1. Pre-construction (acquire land, if applicable, or rights to modify a portion of an existing structure; carry out design process; seek technical consultant; prepare cost estimate; obtain building permits; hire construction manager/contractor).
2. Before construction begins, obtain copies of submittal documents (e.g., plans and specifications) and peer-reviewed report and quality assurance plan as required to be provided to the authority having jurisdiction (e.g., building official) in accordance with the latest editions of ICC 500 and FEMA P-361. Note that FEMA Funding Criteria requires a statement be included with the submittal documents that states the design conforms to (1) the provisions of ICC 500 with the edition year specified and (2) the FEMA Funding Criteria of FEMA P-361 with the edition year specified.
3. Clear/prepare site and install erosion control measures to prepare for construction activities.
4. Construct or install saferoom in accordance with all guidance and codes.
5. Conduct inspections and obtain certificate of occupancy.
6. Prepare the operations and maintenance plan.

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 safe room projects, the following information 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.
• Describe planned and completed peer reviewed and inspection activities.
• If property is purchased, the report should provide property address, purchase price and date.
• 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.^[469] 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 and verified by a peer review as required by FEMA P-361. 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.

Safe rooms must have all required inspection and peer reviews as required in FEMA-361 and ICC 500. Safe rooms have significantly more administrative checks than other HMA projects. Recipients/subrecipients are encouraged to review code requirements to determine the inspection schedule/requirements throughout the construction process.

The peer review’s purpose is for independent design professionals to review design and construction documents of the safe room to ensure it meets FEMA design standards. If issues are found in the design of the safe room, they can be addressed and resolved. The peer review typically involves multiple design professionals to adequately address all architectural and engineering disciplines.

The peer review must be completed by an independent registered design professional; they must not be the design professional providing design oversight of the safe room. The peer reviewer in charge must be hired by the safe room owner or owner’s representative. The peer reviewer(s) must disclose any conflicts of interest (financial or otherwise) that could compromise the independence of the review to the authority having jurisdiction and must meet the requirements to be a peer reviewer outlined in FEMA P-361.

The peer reviewer will review the structural design, occupancy, means of egress, access and accessibility, fire safety and essential features of the safe room. Peer review is required to cover ICC 500 Chapters 3, 4, 5 ,6 and 7 and Sections 106, 107, 110 and 111. Applicants and subapplicant should review FEMA P-361 and ICC 500 to determine which aspects of the project require peer review. This may require inspections and peer review before, during and after construction.

Following the review, the signed, sealed report must be submitted by the owner or owner’s representative to the authority having jurisdiction of the recipient. The report should include detailed descriptions of the items reviewed and a recommendation of acceptance or rejection for each with an explanation provided for rejected items. The recipient will submit the peer review report as part of closeout.

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

The review of the completed saferoom must verify the safe room meets or exceeds FEMA P-361 and ICC 500 standards that were in force on the award date.

In addition to the typical HMA program closeout procedures, closeout of safe room projects generally includes:

• Documentation that completed projects provide the level of protection approved in the scope of work. This may be included as a part of the required statements and peer review reports to verify compliant design, structural observations and special inspections.
• Photographs of the project site before, during and after construction. Photographs should confirm the scope of work is completed and be taken from the inside of the structure(s) and saferoom(s). For community saferooms, photographs of bathrooms should be included. Photographs may be included in the inspection report.
• Latitude/longitude of each project site and safe room entrance(s) to the nearest sixth decimal place.
• For community safe rooms:
  • When required by FEMA P-361, any structural and non-structural design peer review reports from an independent registered design professional certifying the community safe room is designed to meet or exceed FEMA P-361requirements.
  • A final, signed operations and maintenance plan.
  • Photos of the project site before and after construction. Photos should confirm the scope of work is completed.
  • Latitude/longitude of each project site and safe room entrance(s) to the nearest sixth decimal place.
  • A vicinity map and map of the SFHA if applicable.
  • A record of completed structural observations in accordance with ICC 500 and FEMA P-361 that includes:
    • A written statement from the registered design professional who performed the structural observations that the required site visits have been made. The statement must also identify any reported deficiencies that, to the best of their knowledge, have not been resolved.
    •  Where special inspections are required, the statement of special inspections.
    • Where safe room construction included changes to specifications in the submittal documents, approved change orders and a final as-built set of construction drawings.
  • A final operations and maintenance plan signed and dated by authorized officials for that community saferoom.
• For residential safe rooms:
  • For prefabricated safe rooms: The building official’s approval of installation or signed statement from the installer that the safe room foundation capacity (including thickness, steel reinforcement and concrete cover) and post-installed foundation anchors (locations and capacities) meet or exceed the corresponding design information submitted in accordance with ICC 500 and FEMA P-361.
  • For site-built safe rooms: Where FEMA P-320 design plans are constructed, the professional engineer who reviews the selected plan and site conditions is required to sign and seal the design plan page SR0.0 of the prescriptive design plans in FEMA P-320, complete any missing information on page SR0.1 of the prescriptive design plans in FEMA P-320, and provide all approved field change orders.
  • Property site inventory listing properties that were mitigated including property address, parcel information and latitude/longitude coordinates to the nearest sixth decimal place for the main egress into the safe room for each property.
  • For properties located within the SFHA:
    • If applicable, a copy of the Elevation Certificate (FEMA Form 086-0-33).
    • Recorded deed for each mitigated property, indicating compliance with the FEMA Acknowledgement of Conditions for Properties Using FEMA Hazard Mitigation Assistance.
    • Proof of appropriate level of flood insurance (such as a copy of the flood insurance policy).

All subrecipients must comply with Part 9.

The subrecipient should retain construction documents that are in support of FEMA-assisted work for the lifespan of the safe room.