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FEMA Public Assistance (PA) 406 Hazard Mitigation (HM)

BEFORE MITIGATION: CULVERTS WASHED OUT DURING EVENT

AFTER MITIGATION: NEW CULVERT WITH PROTECTIVE HEADWALL

Hazard mitigation (HM) is defined in Federal law [44 Code of Federal Regulations (CFR) 201.2] as any sustained action taken to reduce or eliminate the long-term risk to human life and property from hazards.

Value of Hazard Mitigation (HM) Measures

HM measures break the cycle of damage reconstruction and repeat damage, resulting in safer and stronger communities. HM measures can reduce loss of life and/or property due to an emergency or disaster.

Stronger communities lessen physical and financial impacts of disaster at the State + Federal level and to local + Tribal communities.
Hazard mitigation measures result in more resilient communities, enabling them to recover more rapidly from future disasters.

Funding Sources

There are multiple funding sources within the Stafford Act and the National Flood Insurance Act of 1968 (NFIA) available to eligible Subrecipient (Applicant) for BOTH post-disaster as well as non-disaster HM activities. Many people are familiar with the post-disaster Hazard Mitigation Grant Program (HMGP) and anual non-disaster grants within the Hazard Mitigation Assistance (HMA) Program.

Less well known are Mitigation opportunities within the FEMA Public Assistance Program authorized under Section 406 of the Stafford Act. This section contains provisions within the PA Program to fund additional measures that enhance a facility’s ability to resist similar damage in future events. This program is commonly known as 406 Hazard Mitigation (HM).

Summary of Non-disaster + Post-disaster Mitigation Funding

Applicability

406 HM funding can ONLY be spent on eligible permanent repair work.

406 HM measures MUST be cost effective.
406 HM can be used ONLY to fund protective measures that reduce or eliminate the threat of future similar damages to a disaster-damaged element or facility.

Common Mitigation Measures

Common mitigation measures include:

Elevation of buildings or equipment.
Increased size in culverts or other drainage systems.
Shuttering to protect windows from wind-blown debris.
Different materials that provide stronger protection from the hazard.
Dry and wet flood proofing.

For a more detailed list of HM measures, visit the GRANTS section, the Hazard Mitigation Grant Program (HMGP) page of this website.

Cost Effectiveness

FEMA requires all HM projects to be cost effective. Cost effective simply means that benefits (avoidance of future damages) of a mitigation measure are appropriate to the expenditure. Benefits must equal or exceed the cost of the hazard mitigation measure.

Cost-effective mitigation measures include:
Applicable mitigation measures that cost up to 15 percent of the total eligible repair cost (e.g. equipment elevation, window shutters, hurricane clips, headwalls, floodwalls, erosion control, etc.).
Certain mitigation measures (see Appendix A of FEMA RP 9526.1) are predetermined as cost effective if the cost of the mitigation measure:
Does not exceed 100 percent of the total eligible cost of the eligible repair work on the project;
Is appropriate to the disaster damage (e.g. wind, flood, rain, etc.);
Prevents future similar damage;
Is directly related to the eligible damaged elements;
Does not increase risks or cause adverse effects to surrounding areas or damage from another hazard;
Is technically feasible for the hazard + location; and
Meets requirements stipulated in policy + law + regulation.

Those measures include:

Drainage and crossings and bridges
Sanitary/storm sewer systems
Wastewater treatment plants
Potable water systems
Electrical power distribution systems
Above ground storage tanks
Underground pipelines

For those mitigation measures that do not fall within the above two (2) categories, an acceptable Benefit-Cost Analysis (BCA) methodology must be used to demonstrate cost effectiveness.

Example
SCENARIO 1: A project cost $2M to restore a flooded building to its pre- disaster condition. FEMA can approve up to an additional $2M in 406 HM funding for cost-effective, mitigation measures.

SCENARIO 2: A project cost $2M to restore. The proposed mitigation measures cost more than $2M – an analysis is required to determine if the additional expenditure is cost effective.

GETTING STARTED IS AS EASY AS 1, 2, 3, 4 . . .

Step 1: When evaluating disaster damages, Subrecipients (Applicants) are encouraged and responsible to identify potential hazard mitigation opportunities.

Step 2: Hazard mitigation opportunities are then evaluated for cost effectiveness and applicability.

Step 3: Subrecipients (Applicants) prepare a Hazard Mitigation Proposal (HMP). The HMP must:

Identify cause + damages to be mitigated.
Include proposed mitigation measures.
Demonstrate methodology (including scope of work [SOW], determination of cost effectiveness, etc.) used to determine applicability of proposed mitigation measures.

Step 4: HMP is submitted through GOHSEP to FEMA.

Proposed 406 HM measure(s) must be approved by FEMA prior to start of work to ensure eligibility and compliance with Federal requirements.