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Plan Review Guide
October 1, 2011
Local Mitigation Plan Review Guid
Local Mitigation Plan Review Guide
TABLE OF CONTENTS
MITIGATION PLAN REVIEW GUIDE
SECTION 1: INTRODUCTION .......................................................................................... 1
1.1 Purpose of Local Mitigation Plan Review Guide ..................................................... 1
1.2 Organization of Guide ............................................................................................. 2
1.3 Roles & Responsibilities .......................................................................................... 2
1.4 Mitigation Plan Updates ......................................................................................... 3
1.5 Flood and Multi‐hazard Mitigation Plans ............................................................... 3
SECTION 2: PLAN REVIEW GUIDING PRINCIPLES ............................................................ 5
SECTION 3: COMPLETING THE PLAN REVIEW TOOL ...................................................... 7
3.1 Regulation Checklist ................................................................................................ 7
3.2 Plan Assessment ..................................................................................................... 8
3.3 Multi‐Jurisdiction Summary Spreadsheet ............................................................. 11
SECTION 4: REGULATION CHECKLIST .......................................................................... 13
4.1 ELEMENT A: Planning Process ............................................................................... 14
4.2 ELEMENT B: Hazard Identification and Risk Assessment ..................................... 18
4.3 ELEMENT C: Mitigation Strategy .......................................................................... 22
4.4 ELEMENT D: Plan Review, Evaluation, and Implementation .............................. 26
4.5 ELEMENT E: Plan Adoption ................................................................................... 28
SECTION 5: PLAN REVIEW PROCEDURE ....................................................................... 31
5.1 Communicating the Review .................................................................................. 31
5.2 Mitigation Plan Submittal ..................................................................................... 32
5.3 Mitigation Plan Review ........................................................................................ 32
5.4 Mitigation Plan Approval and Adoption .............................................................. 34
APPENDIX A: LOCAL MITIGATION PLAN REVIEW TOOL .................................................. A‐1
SECTION 1: REGULATION CHECKLIST ....................................................................... A‐2
SECTION 2: PLAN ASSESSMENT ............................................................................... A‐5
SECTION 3: MULTI‐JURISDICTION SUMMARY SPREADSHEET ................................... A‐9
Local Mitigation Plan Review Guide
Local Mitigation Plan Review Guide
SECTION 1:
INTRODUCTION
1.1 PURPOSE OF LOCAL MITIGATION PLAN REVIEW GUIDE
The purpose of this Local Mitigation Plan Review Guide is to help Federal and State officials
assess Local Mitigation Plans in a fair and consistent manner, and to ensure approved Local
Mitigation Plans meet the requirements of the Stafford Act and Title 44 Code of Federal
Regulations (CFR) §201.6.1
The target audience for this Guide is Federal and State officials that complete Local
Mitigation Plan reviews. Plan developers are directed to the Local Mitigation Planning
Handbook2. The Local Mitigation Plan Review Guide (or Plan Review Guide) and the Local
Mitigation Planning Handbook (or Planning Handbook) may be used in tandem by plan
reviewers and developers so that communities understand the technical requirements, as
well as understand the various ways that plans can be developed to meet these
requirements. FEMA supports, coordinates and reviews local plans as a means to:
•
Foster federal, state, and local partnerships for hazard mitigation;
•
Promote more resilient and sustainable communities; and
•
Reduce the costs associated with disaster response and recovery by promoting
hazard mitigation activities.
This Local Mitigation Plan Review Guide, as interpretation and explanation for the
Mitigation Planning regulation in 44 CFR Part 201, is the Federal Emergency Management
Agency’s (FEMA) official source for defining the requirements of original and updated Local
Mitigation Plans. The Guide represents FEMA’s interpretation of a statutory or regulatory
requirement. By itself, the Guide does not impose legally enforceable rights and
obligations, but sets forth a standard operating procedure or agency practice that FEMA
employees follow to be consistent, fair, and equitable in the implementation of the
agency’s authorities. The Guide includes references to specific language in 44 CFR §201.6
and descriptions of the relevant requirement to meet the Mitigation Planning regulation.
1
Section 322 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), as
amended, 42 U.S.C. 5165, and the National Flood Insurance Act of 1968, as amended, 42 U.S.C. 4001 et seq.,
44 Code of Federal Regulations (CFR) Part 201.
2
The Local Mitigation Planning Handbook is under development; once issued, the Plan Review Guide and
Planning Handbook will supersede the Local Multi‐Hazard Mitigation Planning Guidance (also known as the
“Blue Book”).
Local Mitigation Plan Review Guide
1
1.2 ORGANIZATION OF GUIDE
This Plan Review Guide has six sections:
Section 1: Introduction
Section 2: Plan Review Guiding Principles
Section 3: Completing the Plan Review Tool
Section 4: Regulation Checklist
Section 5: Plan Review Procedure
Appendix A: Plan Review Tool
Section 1 describes the purpose and organization of the Plan Review Guide. Section 2
describes the overall guiding principles for Local Mitigation Plan reviews. Section 3
provides instructions on how FEMA will complete the Local Mitigation Plan Review Tool,
including the Regulatory Checklist and Plan Assessment. Section 4 provides the detailed
guidance on how FEMA interprets the regulation through the Regulatory Checklist for all
Local Mitigation Plan reviews. Section 5 describes the Plan Review Procedure from
submittal through approval, including methods of communication between FEMA, States
and local governments that develop Local Mitigation Plans. Finally, Appendix A includes the
Plan Review Tool to document the evaluation of any Local Mitigation Plan.
1.3 ROLES & RESPONSIBILITIES
The primary audience for this Plan Review Guide is Federal and State officials or staff that
complete reviews of Local Mitigation Plans developed to meet FEMA’s Mitigation Planning
requirement under 44 CFR Part 201. The requirement for plan reviews (44 CFR 201.6(d)(1)),
reads:
Plans must be submitted to the State Hazard Mitigation Officer (SHMO) for initial
review and coordination. The State will then send the plan to the appropriate FEMA
Regional Office for formal review and approval. Where the State point of contact for
the FMA program is different from the SHMO, the SHMO will be responsible for
coordinating the local plan reviews between the FMA point of contact and FEMA.
The State is responsible for the initial review and coordination of the plan between the local
government and FEMA. Additional information on the roles of the State official completing
the plan review is described in Section 5, Plan Review Procedure.
FEMA is responsible for the final review and approval of all Local Mitigation Plans. Once a
Local Mitigation Plan is submitted by the State, FEMA is responsible for the overall
coordination of plan review, revisions, tracking and approval.
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Local Mitigation Plan Review Guide
1.4 MITIGATION PLAN UPDATES
Local Mitigation Plans must be updated at least once every five years in order to continue to
be eligible for FEMA hazard mitigation project grant funding. Specifically, the regulation at
44 CFR §201.6(d)(3) reads:
A local jurisdiction must review and revise its plan to reflect changes in development,
progress in local mitigation efforts, and changes in priorities, and resubmit it for
approval within five (5) years in order to continue to be eligible for mitigation project
grant funding.
The Local Mitigation Plan Review Guide addresses plan updates within each required
Element, and more specifically in Element D, Plan Updates. First, each required Element
for Local Mitigation Plans must be met with current information. For example, the planning
process and public participation that were completed in the previous planning cycle will not
meet the requirements for the planning process in the five‐year update. Likewise, if the
plan update does not include major disaster declarations that occurred since the previous
plan was written, FEMA will not approve the plan update. Although several sub‐elements
(A1, B2 and C6) have explicit guidance for plan updates, all sub‐elements must be met with
current information for FEMA approval of a plan update. Second, Element D identifies the
plan update requirements to “reflect changes in development, progress in local mitigation
efforts, and changes in priorities” (44 CFR §201.6(d)(3)). Specific guidance on how to meet
each of these requirements is included in Element D, Plan Updates.
1.5 FLOOD AND MULTI‐HAZARDS MITIGATION PLANS
Some communities choose to develop Local Mitigation Plans that only address flood
hazards. In order to receive FEMA approval, flood mitigation plans must meet all Elements
identified in the regulation at 44 CFR §201.6 and in the Regulation Checklist for flood
hazards. FEMA and State officials that review and approve a flood‐only mitigation plan will
clearly inform the community that the community’s eligibility is limited to the flood
mitigation programs authorized by the National Flood Insurance Act of 1968, as amended,
and that the community will not be eligible for other FEMA assistance programs, such as
Pre‐Disaster Mitigation (PDM) and Hazard Mitigation Grant Program (HMGP), that require a
multi‐hazard mitigation plan.
Local Mitigation Plan Review Guide
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Local Mitigation Plan Review Guide
SECTION 2:
PLAN REVIEW GUIDING PRINCIPLES
The purpose of hazard mitigation is to reduce potential losses from future disasters. The
intent of mitigation planning, therefore, is to maintain a process that leads to hazard
mitigation actions. Mitigation plans identify the natural hazards that impact communities,
identify actions to reduce losses from those hazards, and establish a coordinated process to
implement the plan. (44 CFR §201.1(b))
Hazard mitigation is any sustained action taken to reduce or eliminate the long‐term risk to
human life and property from hazards (44 CFR 201.2). Hazard mitigation activities may be
implemented prior to, during, or after an event. However, it has been demonstrated that
hazard mitigation is most effective when based on an inclusive, comprehensive, long‐term
plan that is developed before a disaster occurs.
In 2004, FEMA published mitigation planning guidance with a ‘performance’ based
approach, rather than a ‘prescriptive’ approach. This means that the requirements identify,
generally, what should be done in the process and documented in the plan, rather than
specify exactly how it should be done. This performance approach continues along with a
set of Guiding Principles to assist with the review of all Local Mitigation Plans. This Local
Mitigation Plan Review Guide also includes a description of the intent specific to each
requirement.
The following Guiding Principles will be applied to all plan reviews:
1. Focus on Mitigation Strategy. Plan reviews will emphasize actions and
implementation of the hazard mitigation strategy. All other sections of the plan
contribute to and result in the hazard mitigation strategy and specific hazard
mitigation actions. For example, a sound hazard identification and risk assessment is
an important part of the plan, but is the basis, in part, for the strategy which is the
focus of the Local Mitigation Plan. Submission of a Local Mitigation Plan for FEMA
review and approval is not the end state, but is the beginning of implementing
hazard mitigation action.
2. Review for Intent, as well as Compliance. Plan reviews will focus on whether the
mitigation plan meets the intent of the law and regulation. FEMA considers the
overall plan and each Element (for example, planning process, risk assessment,
mitigation strategy), as well as the individual requirements. A comprehensive
review of the plan assists FEMA to validate that the plan meets the overall intent of
mitigation planning, whereas only a strict interpretation of individual requirements
may cause unnecessary revisions.
Local Mitigation Plan Review Guide
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3. Process is as important as the Plan itself. FEMA will accept the planning process as
defined by the community. In hazard mitigation planning, as with most other
planning efforts, the actual process of planning is as important as the plan itself.
Said another way, the plan is only as good as the planning process that people chose
to develop it. Bringing together local officials, stakeholders and the public in a
community‐driven planning process to develop the plan also helps build the
community’s overall hazard mitigation program. Therefore, FEMA considers the
plan as the written record, or documentation, of the planning process. This is why
some of the plan requirements ask for a “discussion” or “description” of generally,
what must be documented in the plan, rather than specify exactly how it must be
done.
4. This is the Community’s Plan. Plan reviews will recognize the effort and interest of
each community that develops a mitigation plan. To emphasize the importance of
the community’s ownership of the plan, FEMA will recognize the inherent
differences that exist among local governments with respect to size, resources,
capability, and vulnerability. FEMA will not penalize communities that have less
capability or demonstrate little progress in hazard mitigation efforts over time. In
addition, FEMA will not require specific formats (for example, stand‐alone plan,
chapter in emergency operations plan, or integrated into comprehensive plan), and
FEMA will not require information above or beyond the requirements to be
removed (for example, non‐natural, climate change). In fact, FEMA acknowledges
that some plans will simply “pass” the minimum plan requirements to receive FEMA
approval. However, communities of any size, resources or capability that
demonstrate a genuine interest in and commitment to hazard mitigation through
their planning process will be better positioned to receive FEMA technical and
financial assistance to implement their actions or projects.
5. Foster Relationships. FEMA’s relationship with the State and community is as
important as the words in the plan. Although the plan review is a necessary step for
FEMA approval, FEMA’s role is to provide technical assistance, not to be gatekeepers
of plan approval. FEMA will work with States to ensure the plan review is
communicated clearly and in a timely manner. FEMA will communicate the
requirement through constructive and positive feedback, particularly if clarification
or additional documentation is needed. FEMA understands that there is a whole
planning process that has already happened, and FEMA’s review of the plan is
intended to benefit the community’s hazard mitigation program.
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Local Mitigation Plan Review Guide
SECTION 3:
COMPLETING THE PLAN REVIEW TOOL
The Local Mitigation Plan Review Tool (See Appendix A) demonstrates how the Local
Mitigation Plan meets the regulation in 44 CFR §201.6 and offers States and FEMA
Mitigation Planners an opportunity to provide feedback to the community.
• The Regulation Checklist provides a summary of FEMA’s evaluation of whether the
Plan has addressed all requirements.
• The Plan Assessment identifies the plan’s strengths as well as documents areas for
future improvement.
• The Multi‐jurisdiction Summary Sheet is an optional worksheet that can be used to
document how each jurisdiction met the requirements of the each Element of the
Plan (Planning Process; Hazard Identification and Risk Assessment; Mitigation
Strategy; Plan Review, Evaluation, and Implementation; and Plan Adoption).
The FEMA Mitigation Planner must reference this Local Mitigation Plan Review Guide when
completing the Local Mitigation Plan Review Tool.
3.1 REGULATION CHECKLIST (Completion by FEMA required)
The purpose of the Checklist is to identify the location of relevant or applicable content in
the Plan by Element/sub‐element and to determine if each requirement has been ‘Met’ or
‘Not Met.’ The ‘Required Revisions’ summary at the bottom of each Element must be
completed by FEMA to provide a clear explanation of the revisions that are required for
plan approval. Required revisions must be explained for each plan sub‐element that is ‘Not
Met.’ Sub‐elements should be referenced in each summary by using the appropriate
numbers (A1, B3, etc.), where applicable. Requirements for each Element and sub‐element
are described in detail in this Plan Review Guide in Section 4, Regulation Checklist.
3.2 PLAN ASSESSMENT (Completion by FEMA Required)
The purpose of the Plan Assessment is to offer the local community more comprehensive
feedback on the quality and utility of the plan in a narrative format. The audience for the
Plan Assessment is not only the plan developer/local community planner, but also elected
officials, local departments and agencies, and others involved in implementing the Local
Mitigation Plan. The Plan Assessment must be completed by FEMA and is not required
from the State. The Plan Assessment is an opportunity for FEMA to provide feedback and
information to the community on: 1) suggested improvements to the Plan; 2) specific
sections in the Plan where the community has gone above and beyond minimum
requirements; 3) recommendations for plan implementation; and 4) ongoing partnership(s)
and information on other FEMA programs, specifically RiskMAP and Hazard Mitigation
Assistance programs.
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The Plan Assessment is divided into two sections:
A. Plan Strengths and Opportunities for Improvement
B. Resources for Implementing Your Approved Plan
Plan Strengths and Opportunities for Improvement is organized according to the plan
Elements listed in the Regulation Checklist. Each Element includes a series of italicized
bulleted items that are suggested topics for consideration while evaluating plans, but it is
not intended to be a comprehensive list. FEMA Mitigation Planners are not required to
answer each bullet item, and should use them as a guide to paraphrase their own written
assessment (2‐3 sentences) of each Element.
The Plan Assessment must not reiterate the required revisions from the Regulation
Checklist or be regulatory in nature, and should be open‐ended to provide the community
with suggestions for improvements or recommended revisions. The recommended
revisions are suggestions for improvement and are not required to be made for the Plan to
meet Federal regulatory requirements. The italicized text should be deleted once FEMA has
added comments regarding strengths of the plan and potential improvements for future
plan revisions. It is recommended that the Plan Assessment be a short synopsis of the
overall strengths and weaknesses of the Plan (no longer than two pages), rather than a
complete recap section by section.
Resources for Implementing Your Approved Plan provides a place for FEMA to offer
information, data sources and general suggestions on the overall plan implementation and
maintenance process. Information on other possible sources of assistance including, but
not limited to, existing publications, grant funding or training opportunities, can be
provided. States may add state and local resources, if available.
Sample Completed Plan Assessment
I. Plan Strengths and Opportunities for Improvement
Element A: Planning Process
Plan strengths
• Public involvement process, as described in the planning process section, comprised of meetings
with homeowners associations and public representation on various county boards and councils.
A letter included in the Plan also indicates that the Plan was placed in public libraries along with
preparedness and other hazard notices; and that comments were received and incorporated.
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Local Mitigation Plan Review Guide
Sample Completed Plan Assessment (continued)
Opportunities for improvement:
• Consider providing more detail on the planning process. For example, list every meeting
conducted and agencies represented at these meetings.
• Provide a list of comments received from all stakeholders, including the public. This information
will provide specific direction for the next plan update.
• Consider providing additional information on outreach methods, etc., for additional Community
Rating System (CRS) credit. Contact the State CRS coordinator at 234‐234‐2345 for more
information.
• For the next plan update, consider gaining participation from the local media to help increase
public awareness and participation. Posting documents on the web will also allow for more
citizens to participate.
Element B: Hazard Identification and Risk Assessment
Plan strengths:
• Table 4.1 is an excellent presentation of the actions for each participating jurisdiction and
identifies the responsible party, timeframe, hazard, possible funding source, priority,
implementation schedule, and impediments to implementation.
• The Plan adequately identifies geographic information system (GIS) data gaps to improve the
impact analysis and contains an associated action to acquire additional data for seismic landslide
maps.
• The Plan does a good job of describing general development trends. Countywide trends are well
described, and some attempt is made to describe trends within each incorporated jurisdiction.
The reliance on 1990 and 2000 Census data to highlight these changes is effective in
communicating long term trends, but more current data from the 2010 Census, local
information, or other sources may bring further clarity to the Plan. Additionally, it may be useful
to expand the discussion of development trends to include other agencies that may be
represented in the Plan (for example, school districts and special districts) since changes in
development may greatly impact the vulnerability for these jurisdictions.
Opportunities for improvement:
• Potential dollar losses are not addressed in this version and would be a good addition to the next
update. The methodology on how loss estimates are prepared should also be included.
• The maps presented within the Plan provide an excellent perspective on vulnerability for various
jurisdictions, but more detail concerning these efforts to analyze hazards through advanced GIS
methods would be useful. For instance, it is evident that spatial analysis was conducted to
determine if there were dams located in close proximity to structures owned by jurisdictions, but
no information concerning the buffer distance (or definition of “close”) is included for this
analysis.
Element C: Mitigation Strategy
Plan strengths:
• The Plan contains excellent information on funding sources and resources for implementing
mitigation actions. It may also be useful to include contact information for the State Hazard
Mitigation Officer and the State Mitigation Management website location among these
resources since the State is responsible for coordinating the implementation of many of these
programs within the State.
Local Mitigation Plan Review Guide
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Sample Completed Plan Assessment (continued)
Opportunities for improvement:
• Some linkages between the mitigation strategy and Hazard Identification and Risk Assessment
are evident, but could be better explained in future Plan Updates. As more refined information is
created for certain hazards (such as dam failure) it may be possible to target mitigation actions
more specifically at certain hazard areas likely to be vulnerable to these hazards.
• The Plan does a good job of identifying other resources such as U.S. Department of Agriculture
(USDA) and Community Development Block Grant (CDBG) programs that may be useful for
mitigation. Linking these programs to mitigation actions could increase the effectiveness of the
Plan and make it a more valuable resource for community officials and citizens.
Element D: Plan Update, Evaluation, and Implementation (applicable to plan updates only)
Plan strengths:
• The XXX County Hazard Mitigation Planning Committee was formed to update and revise the
plan as a multi‐jurisdictional plan. Items covered in this update addressed the annual review
process. Section 1.2 states that the Plan will be reviewed and updated annually to monitor the
progress of its mitigation strategies and to integrate new technologies.
Opportunities for improvement:
• The Plan documents changes that have occurred in the planning area as well as updates to the
HIRA section. A clearer linkage between these updates and changes that have occurred should
be included. It may also be useful to provide description of any items that prevented progress on
mitigation actions (for example, funding, regulations, political issues, authorities, etc.) so that
these items may be addressed more fully during the next update.
2. Resources for Implementing Your Approved Plan
•
•
•
•
•
•
10
The 2010 State of AAA Hazard Mitigation Plan identifies a number of potential funding resources
for various mitigation actions. The grants identified in Chapter 7 of the State Plan are from both
Federal and State sources. More information about applying for grants can be obtained from Joe
Johns, AAA’s State Hazard Mitigation Officer.
FEMA is currently conducting a Risk MAP project in City of YYY. This project is in its infancy stage
(LiDAR will be conducted in Fall 2011). In an effort to capitalize on current data and flood risk
information, it is important that, during the Discovery Process, the municipality include
representatives from departments that deal with flood risk (for example, hazard mitigation
planning, emergency planning, and land use and zoning).
The AAA State Division of Emergency Management mitigation team is available to help identify
possible forms of assistance (technical and financial) to improve GIS capabilities, conduct studies
and implement projects identified in the Plan.
The AAA State DNR is currently working to create inundation maps for each high hazard dam in
the State. This information will be made available and will assist in creating a more accurate
hazard profile for dam failure events within the planning area.
Benefit cost analysis (BCA) courses are offered through the State Hazard Mitigation Officer at
123‐234‐3456. As a key component of Hazard Mitigation Assistance (HMA) sub‐application
development, this course assists communities seeking funding for implementing effective
mitigation projects. This course will also provide supplemental material on changes to the
Tornado Safe Room program and will be led by State Division of Emergency Management.
The FEMA Region has expressed interest in direct technical assistance on integrating non‐
regulatory flood risk products into hazard mitigation plans. The availability of this assistance is
limited, but additional information can be found at:
http://www.fema.gov/library/viewRecord.do?id=4763.
Local Mitigation Plan Review Guide
3.3 MULTI‐JURISDICTION SUMMARY SPREADSHEET (Optional)
For multi‐jurisdictional plans, a Multi‐jurisdiction Summary Spreadsheet may be completed
by listing each participating jurisdiction, which required Elements for each jurisdiction were
‘Met’ or ‘Not Met,’ and when the adoption resolutions were received. This Summary Sheet
does not imply that a mini‐plan be developed for each jurisdiction; it should be used as an
optional worksheet to ensure that each jurisdiction participating in the Plan has been
documented and has met the requirements for those Elements (A through E).
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Local Mitigation Plan Review Guide
SECTION 4:
REGULATION CHECKLIST
This section provides detailed guidance on how FEMA interprets the various requirements
of the regulation for all Local Mitigation Plan reviews through a Regulatory Checklist. The
guidance is limited only to the minimum requirements of what must be in a Local Mitigation
Plan, and does not provide guidance on how the community should develop a plan. The
Regulation Checklist includes the following Elements:
4.1 ELEMENT A: Planning Process
4.2 ELEMENT B: Hazard Identification and Risk Assessment
4.3 ELEMENT C: Mitigation Strategy
4.4 ELEMENT D: Plan Review, Evaluation, and Implementation
4.5 ELEMENT E: Plan Adoption
4.6 ELEMENT F: Additional State Requirements
Many requirements in the Checklist call for the plan to “document” or “describe”
information. FEMA does not require specific formats for the plan or its content. Required
information to “document” can be provided in the plan through a variety of formats, such
as narrative, tables, lists, maps, etc. Examples provided in this Guide are samples of one or
more approaches to meeting that particular requirement. Examples are not inclusive of all
possible solutions to meet a requirement, and they are not necessarily considered “best
practices” or exemplary. FEMA will recognize that there are many formats and types of
documentation that may meet a particular requirement.
Terms from the regulation are defined in this Guide, where necessary. For example, many
of the plan requirements ask for a “discussion” or “description.” FEMA considers the plan
as the written record, or documentation, of the planning process. Therefore, many of these
terms have the same meaning to document what was done. In addition, this Guide uses the
terms “jurisdiction” and “community” interchangeably. For purposes of this Guide, these
terms are equal to any local government developing a Local Mitigation Plan. This is defined
at 44 CFR §201.2 as:
“any county, municipality, city, town, township, public authority, school district, special district,
intrastate district, council of governments (regardless of whether the council of governments is
incorporated as a nonprofit corporation under State law), regional or interstate government entity, or
agency or instrumentality of a local government; any Indian tribe or authorized tribal organization, or
Alaska Native village or organization; and any rural community, unincorporated town or village, or
other public entity.”
Finally, an important distinction must be made between the words “shall” and “should” in
the Mitigation Planning regulation at 44 CFR Part 201. The Regulation Checklist only
includes the requirements where the regulation uses the words “shall” and “must,” and
does not include the “should.” When the word “should” is used, the item is strongly
recommended to be included in the plan, but its absence will not cause FEMA to disapprove
the plan.
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4.1 ELEMENT A: PLANNING PROCESS
Requirement
An open public involvement process is essential to the development
§201.6(b)
of an effective plan. In order to develop a more comprehensive
approach to reducing the effects of natural disasters, the planning
process shall include:
§201.6(b)(1)
(1) An opportunity for the public to comment on the plan during the
drafting stage and prior to plan approval;
§201.6(b)(2)
(2) An opportunity for neighboring communities, local and regional
agencies involved in hazard mitigation activities, and agencies that
have the authority to regulate development, as well as businesses,
academia and other private and non‐profit interests to be involved
in the planning process; and
§201.6(b)(3)
(3) Review and incorporation, if appropriate, of existing plans, studies,
reports, and technical information.
§201.6(c)(1)
[The plan shall document] the planning process used to develop the
plan, including how it was prepared, who was involved in the process,
and how the public was involved.
§201.6(c)(4)(i)
[The plan maintenance process shall include a] section describing the
method and schedule of monitoring, evaluating, and updating the
mitigation plan within a five‐year cycle.
§201.6(c)(4)(iii)
[The plan maintenance process shall include a] discussion on how the
community will continue public participation in the plan maintenance
process.
Overall Intent. The planning process is as important as the plan itself. Any successful
planning activity, such as developing a comprehensive plan or local land use plan, involves a
cross‐section of stakeholders and the public to reach consensus on desired outcomes or to
resolve a community problem. The result is a common set of community values and
widespread support for directing financial, technical, and human resources to an agreed
upon course of action, usually identified in a plan. The same is true for mitigation planning.
An effective and open planning process helps ensure that citizens understand risks and
vulnerability, and they can work with the jurisdiction to support policies, actions, and tools
that over the long‐term will lead to a reduction in future losses.
Leadership, staffing, and in‐house knowledge in local government may fluctuate over time.
Therefore, the description of the planning process serves as a permanent record that
explains how decisions were reached and who involved. FEMA will accept the planning
process as defined by the community, as long as the mitigation plan includes a narrative
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Local Mitigation Plan Review Guide
description of the process used to develop the mitigation plan—a systematic account about
how the mitigation plan evolved from the formation of a planning team, to how the public
participated, to how each section of the plan was developed, to what plans or studies were
incorporated into the plan, to how it will be implemented. Documentation of a current
planning process is required for both new and updated plans.
ELEMENT
A1. Does the Plan document the
planning process, including how it
was prepared and who was
involved in the process for each
jurisdiction?
44 CFR 201.6(c)(1)
Intent: To inform the public and
other readers about the overall
approach to the plan’s development
and serve as a permanent record of
how decisions were made and who
was involved. This record also is
useful for the next plan update.
REQUIREMENTS
a.
b.
c.
d.
e.
A2. Does the Plan document an
opportunity for neighboring
communities, local and regional
agencies involved in hazard
mitigation activities, agencies that
have the authority to regulate
development as well as other
interests to be involved in the
planning process? 44 CFR
201.6(b)(2)
a.
Documentation of how the plan was prepared must include the
schedule or timeframe and activities that made up the plan’s
development as well as who was involved. Documentation
typically is met with a narrative description, but may also include,
for example, other documentation such as copies of meeting
minutes, sign‐in sheets, or newspaper articles.
Document means provide the factual evidence for how the
jurisdictions developed the plan.
The plan must list the jurisdiction(s) participating in the plan that
seek approval.
The plan must identify who represented each jurisdiction. The
Plan must provide, at a minimum, the jurisdiction represented and
the person’s position or title and agency within the jurisdiction.
For each jurisdiction seeking plan approval, the plan must
document how they were involved in the planning process. For
example, the plan may document meetings attended, data
provided, or stakeholder and public involvement activities offered.
Jurisdictions that adopt the plan without documenting how they
participated in the planning process will not be approved.
Involved in the process means engaged as participants and given
the chance to provide input to affect the plan’s content. This is
more than simply being invited (See “opportunity to be involved
in the planning process” in A2 below) or only adopting the plan.
Plan updates must include documentation of the current planning
process undertaken to update the plan.
The plan must identify all stakeholders involved or given an
opportunity to be involved in the planning process. At a
minimum, stakeholders must include:
1) Local and regional agencies involved in hazard mitigation
activities;
2) Agencies that have the authority to regulate development; and
3) Neighboring communities.
An opportunity to be involved in the planning process means that
the stakeholders are engaged or invited as participants and given
the chance to provide input to affect the plan’s content.
Local Mitigation Plan Review Guide
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ELEMENT
Intent: To demonstrate a
deliberative planning process that
involves stakeholders with the data
and expertise needed to develop the
plan, with responsibility or authority
to implement hazard mitigation
activities, and who will be most
affected by the plan’s outcomes.
A3. Does the Plan document how
the public was involved in the
planning process during the
drafting stage?
44 CFR 201.6(b)(1) and 201.6(c)(1)
Intent: To ensure citizens
understand what the community is
doing on their behalf, and to provide
a chance for input on community
vulnerabilities and mitigation
activities that will inform the plan’s
content. Public involvement is also
an opportunity to educate the public
about hazards and risks in the
community, types of activities to
mitigate those risks, and how these
impact them.
16
REQUIREMENTS
b.
c.
The Plan must provide the agency or organization represented
and the person’s position or title within the agency.
The plan must identify how the stakeholders were invited to
participate in the process.
Examples of stakeholders include, but are not limited to:
Local and regional agencies involved in hazard mitigation
include public works, zoning, emergency management, local
floodplain administrators, special districts, and GIS
departments.
Agencies that have the authority to regulate development
include planning and community development departments,
building officials, planning commissions, or other elected
officials.
Neighboring communities include adjacent counties and
municipalities, such as those that are affected by similar
hazard events or may be partners in hazard mitigation and
response activities.
Other interests may be defined by each jurisdiction and will
vary with each one. These include, but are not limited to,
business, academia, and other private and non‐profit
interests depending on the unique characteristics of the
community.
a.
b.
The plan must document how the public was given the
opportunity to be involved in the planning process and how their
feedback was incorporated into the plan. Examples include, but
are not limited to, sign‐in sheets from open meetings, interactive
websites with drafts for public review and comment,
questionnaires or surveys, or booths at popular community
events.
The opportunity for participation must occur during the plan
development, which is prior to the comment period on the final
plan and prior to the plan approval / adoption.
Local Mitigation Plan Review Guide
ELEMENT
REQUIREMENTS
A4. Does the Plan document the
review and incorporation of
existing plans, studies, reports, and
technical information? 44 CFR
201.6(b)(3)
Intent: To identify existing data and
information, shared objectives, and
past and ongoing activities that can
help inform the mitigation plan. It
also helps identify the existing
capabilities and planning
mechanisms to implement the
mitigation strategy.
A5. Is there discussion on how the
community(ies) will continue public
participation in the plan
maintenance process? 44 CFR
201.6(c)(4)(iii)
Intent: To identify how the public
will continue to have an opportunity
to participate in the plan’s
maintenance and implementation
over time.
A6. Is there a description of the
method and schedule for keeping
the plan current (monitoring,
evaluating and updating the
mitigation plan within a 5‐year
cycle)? 44 CFR 201.6(c)(4)(i)
Intent: To establish a process for
jurisdictions to track the progress of
the plan’s implementation. This also
serves as the basis of the next plan
update.
a.
b.
a.
The plan must document what existing plans, studies, reports, and
technical information were reviewed. Examples of the types of
existing sources reviewed include, but are not limited to, the state
hazard mitigation plan, local comprehensive plans, hazard specific
reports, and flood insurance studies.
The plan must document how relevant information was
incorporated into the mitigation plan.
Incorporate means to reference or include information from other
existing sources to form the content of the mitigation plan.
The plan must describe how the jurisdiction(s) will continue to
seek public participation after the plan has been approved and
during the plan’s implementation, monitoring and evaluation.
Participation means engaged and given the chance to provide
feedback. Examples include, but are not limited to, periodic
presentations on the plan’s progress to elected officials, schools or
other community groups, annual questionnaires or surveys, public
meetings, postings on social media and interactive websites.
a.
b.
c.
d.
The plan must identify how, when, and by whom the plan will be
monitored. Monitoring means tracking the implementation of the
plan over time. For example, monitoring may include a system for
tracking the status of the identified hazard mitigation actions.
The plan must identify how, when, and by whom the plan will be
evaluated. Evaluating means assessing the effectiveness of the
plan at achieving its stated purpose and goals.
The plan must identify how, when, and by whom the plan will be
updated. Updating means reviewing and revising the plan at least
once every five years.
The plan must include the title of the individual or name of the
department/ agency responsible for leading each of these efforts.
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4.2 ELEMENT B. HAZARD IDENTIFICATION AND RISK ASSESSMENT
Requirement
[The risk assessment shall include a] description of the type, location
§201.6(c)(2)(i)
and extent of all natural hazards that can affect the jurisdiction. The
plan shall include information on previous occurrences of hazard
events and on the probability of future hazard events.
§201.6(c)(2)(ii)
[The risk assessment shall include a] description of the jurisdiction’s
vulnerability to the hazards described in paragraph (c)(2)(i) of this
section. This description shall include an overall summary of each
hazard and its impact on the community. All plans approved after
October 1, 2008 must also address NFIP insured structures that have
been repetitively damaged by floods. The plan should describe
vulnerability in terms of:
§201.6(c)(2)(ii)(A)
(A) The types and numbers of existing and future buildings,
infrastructure, and critical facilities located in the identified hazard
areas;
§201.6(c)(2)(ii)(B)
(B) An estimate of the potential dollar losses to vulnerable
structures identified in … this section and a description of the
methodology used to prepare the estimate.
§201.6(c)(2)(ii)(C)
(C) Providing a general description of land uses and development
trends within the community so that mitigation options can be
considered in future land use decisions.
§201.6(c)(2)(iii)
For multi‐jurisdictional plans, the risk assessment section must assess
each jurisdiction’s risks where they vary from the risks facing the
entire planning area.
Overall Intent. The risk assessment provides the factual basis for activities proposed in the
strategy that will reduce losses from identified hazards. A quality risk assessments makes a
clear connection between the community’s vulnerability and the hazard mitigation actions.
In other words, it provides sufficient information to enable the jurisdiction(s) to identify and
prioritize appropriate hazard mitigation actions.
Local risk assessments do not need to be based on the most sophisticated technology, but
do need to be accurate, current, and relevant. During a plan update, local jurisdictions
assess current and expected future vulnerability to all hazards and integrate new hazard
data such as recent hazard events and new flood studies. In the mitigation plan review,
FEMA looks at the quality of the information in the risk assessment, not the quantity of
information in the risk assessment.
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Local Mitigation Plan Review Guide
The Mitigation Planning regulation includes several “optional” requirements for the
vulnerability assessment. These are easily recognizable with the use of the term “should” in
the requirement (See §201.6(c)(2)(ii)(A‐C)). Although not required, these are strongly
recommended to be included in the plan. However, their absence will not cause FEMA to
disapprove the plan. These “optional” requirements were originally intended to meet the
overall vulnerability assessment, and this analysis can assist with identifying mitigation
actions.
ELEMENT
B1. Does the Plan include a
description of the type, location,
and extent of all natural hazards
that can affect each jurisdiction?
44 CFR 201.6(c)(2)(i) and 44 CFR
201.6(c)(2)(iii)
Intent: To understand the potential
and chronic hazards affecting the
planning area in order to identify
which hazard risks are most
significant and which jurisdictions or
locations are most adversely
affected.
REQUIREMENTS
a.
The plan must include a description of the natural hazards that
can affect the jurisdiction(s) in the planning area.
A natural hazard is a source of harm or difficulty created by a
meteorological, environmental, or geological event3. The plan
must address natural hazards. Manmade or human‐caused
hazards may be included in the document, but these are not
required and will not be reviewed to meet the requirements for
natural hazards. In addition, FEMA will not require the removal of
this extra information prior to plan approval.
b.
The plan must provide the rationale for the omission of any
natural hazards that are commonly recognized to affect the
jurisdiction(s) in the planning area.
c.
The description, or profile, must include information on location,
extent, previous occurrences, and future probability for each
hazard. Previous occurrences and future probability are addressed
in sub‐element B2.
The information does not necessarily need to be described or
presented separately for location, extent, previous occurrences,
and future probability. For example, for some hazards, one map
with explanatory text could provide information on location,
extent, and future probability.
Location means the geographic areas in the planning area that are
affected by the hazard. For many hazards, maps are the best way
to illustrate location. However, location may be described in other
formats. For example, if a geographically‐specific location cannot
be identified for a hazard, such as tornados, the plan may state
that the entire planning area is equally at risk to that hazard.
Extent means the strength or magnitude of the hazard. For
example, extent could be described in terms of the specific
measurement of an occurrence on a scientific scale (for example,
Enhanced Fujita Scale, Saffir‐Simpson Hurricane Scale, Richter
Scale, flood depth grids) and/or other hazard factors, such as
duration and speed of onset. Extent is not the same as impacts,
which are described in sub‐element B3.
3
DHS Risk Lexicon, 2010 Edition. http://www.dhs.gov/xlibrary/assets/dhs‐risk‐lexicon‐2010.pdf
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ELEMENT
REQUIREMENTS
d.
B2. Does the Plan include
a.
information on previous
occurrences of hazard events and
on the probability of future hazard b.
events for each jurisdiction? 44 CFR
201.6(c)(2)(i)
Intent: To understand potential
impacts to the community based on
information on the hazard events
that have occurred in the past and
the likelihood they will occur in the
future.
c.
B3. Is there a description of each
identified hazard’s impact on the
community as well as an overall
summary of the community’s
vulnerability for each jurisdiction?
44 CFR 201.6(c)(2)(ii)
Intent: For each jurisdiction to
consider their community as a whole
and analyze the potential impacts of
future hazard events and the
vulnerabilities that could be reduced
through hazard mitigation actions.
a.
For participating jurisdictions in a multi‐jurisdictional plan, the
plan must describe any hazards that are unique and/or varied
from those affecting the overall planning area.
The plan must include the history of previous hazard events for
each of the identified hazards.
The plan must include the probability of future events for each
identified hazard.
Probability means the likelihood of the hazard occurring and may
be defined in terms of general descriptors (for example, unlikely,
likely, highly likely), historical frequencies, statistical probabilities
(for example: 1% chance of occurrence in any given year), and/or
hazard probability maps. If general descriptors are used, then they
must be defined in the plan. For example, “highly likely” could be
defined as equals near 100% chance of occurrence next year or
happens every year.
Plan updates must include hazard events that have occurred since
the last plan was developed.
For each participating jurisdiction, the plan must describe the
potential impacts of each of the identified hazards on the
community.
Impact means the consequence or effect of the hazard on the
community and its assets. Assets are determined by the
community and include, for example, people, structures, facilities,
systems, capabilities, and/or activities that have value to the
community. For example, impacts could be described by
referencing historical disaster impacts and/or an estimate of
potential future losses (such as percent damage of total
exposure).
b.
The plan must provide an overall summary of each jurisdiction’s
vulnerability to the identified hazards. The overall summary of
vulnerability identifies structures, systems, populations or other
community assets as defined by the community that are
susceptible to damage and loss from hazard events. A plan will
meet this sub‐element by addressing the requirements described
in §201.6(c)(2)(ii)(A‐C).
Vulnerable assets and potential losses is more than a list of the
total exposure of population, structures, and critical facilities in
the planning area. An example of an overall summary is a list of
key issues or problem statements that clearly describes the
community’s greatest vulnerabilities and that will be addressed in
the mitigation strategy.
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Local Mitigation Plan Review Guide
ELEMENT
REQUIREMENTS
B4. Does the Plan address NFIP
insured structures within each
jurisdiction that have been
repetitively damaged by floods? 44
CFR 201.6(c)(2)(ii)
Intent: To inform hazard mitigation
actions for properties that have
suffered repetitive damage due to
flooding, particularly problem areas
that may not be apparent on
floodplain maps. Information on
repetitive loss properties helps
inform FEMA hazard mitigation
assistance programs under the
National Flood Insurance Act.
a.
The plan must describe the types (residential, commercial,
institutional, etc.) and estimate the numbers of repetitive loss
properties located in identified flood hazard areas.
Repetitive loss properties are those for which two or more losses
of at least $1,000 each have been paid under the National Flood
Insurance Program (NFIP) within any 10‐year period since 1978.
Severe repetitive loss properties are residential properties that
have at least four NFIP payments over $5,000 each and the
cumulative amount of such claims exceeds $20,000, or at least two
separate claims payments with the cumulative amount exceeding
the market value of the building.
Use of flood insurance claim and disaster assistance information is
subject to The Privacy Act of 1974, as amended, which prohibits
public release of the names of policy holders or recipients of
financial assistance and the amount of the claim payment or
assistance. However, maps showing general areas where claims
have been paid can be made public. If a plan includes the names
of policy holders or recipients of financial assistance and the
amount of the claim payment or assistance, the plan cannot be
approved until this Privacy Act covered information is removed
from the plan.
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4.3 ELEMENT C. MITIGATION STRATEGY
Requirement
[The plan shall include the following:] A mitigation strategy that
§201.6(c)(3)
provides the jurisdiction’s blueprint for reducing the potential losses
identified in the risk assessment, based on existing authorities,
policies, programs, and resources, and its ability to expand on and
improve these existing tools.
§201.6(c)(3)(i)
[The hazard mitigation strategy shall include a] description of
mitigation goals to reduce or avoid long‐term vulnerabilities to the
identified hazards.
§201.6(c)(3)(ii)
[The hazard mitigation strategy shall include a] section that identifies
and analyzes a comprehensive range of specific mitigation actions and
projects being considered to reduce the effects of each hazard, with
particular emphasis on new and existing buildings and infrastructure.
All plans approved by FEMA after October 1, 2008, must also address
the jurisdiction’s participation in the NFIP, and continued compliance
with NFIP requirements, as appropriate.
§201.6(c)(3)(iii)
[The hazard mitigation strategy shall include an] action plan,
describing how the action identified in paragraph (c)(3)(ii) of this
section will be prioritized, implemented, and administered by the
local jurisdiction. Prioritization shall include a special emphasis on the
extent to which benefits are maximized according to a cost benefit
review of the proposed projects and their associated costs.
§201.6(c)(3)(iv)
For multi‐jurisdictional plans, there must be identifiable action items
specific to the jurisdiction requesting FEMA approval or credit of the
§201.6(c)(4)(ii)
plan.
[The plan shall include a] process by which local governments
incorporate the requirements of the mitigation plan into other
planning mechanisms such as comprehensive or capital
improvements, when appropriate.
Overall Intent. The mitigation strategy serves as the long‐term blueprint for reducing the
potential losses identified in the risk assessment. The Stafford Act directs Local Mitigation
Plans to describe hazard mitigation actions and establish a strategy to implement those
actions.4 Therefore, all other requirements for a Local Mitigation Plan lead to and support
the mitigation strategy.
4
Section 322(b), Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), as amended,
42 U.S.C. 5165.
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Local Mitigation Plan Review Guide
The mitigation strategy includes the development of goals and prioritized hazard mitigation
actions. Goals are long‐term policy statements and global visions that support the
mitigation strategy. A critical step in the development of specific hazard mitigation actions
and projects is assessing the community’s existing authorities, policies, programs, and
resources and its capability to use or modify local tools to reduce losses and vulnerability
from profiled hazards.
In the plan update, goals and actions are either reaffirmed or updated based on current
conditions, including the completion of hazard mitigation initiatives, an updated or new risk
assessment, or changes in State or local priorities.
ELEMENT
C1. Does the plan document each
a.
jurisdiction’s existing authorities,
policies, programs and resources,
and its ability to expand on and
improve these existing policies and
programs? 44 CFR 201.6(c)(3)
Intent: To ensure that each
jurisdiction evaluates its capabilities
to accomplish hazard mitigation
actions, through existing
mechanisms. This is especially
useful for multi‐jurisdictional plans
where local capability varies widely.
C2. Does the Plan address each
a.
jurisdiction’s participation in the
NFIP and continued compliance
with NFIP requirements, as
appropriate? 44 CFR 201.6(c)(3)(ii)
Intent: To demonstrate flood hazard
mitigation efforts by the community
through NFIP activities. Where FEMA
is the official administering Federal
agency of the NFIP, participation in
the program is a basic community
capability and resource for flood
hazard mitigation activities.
REQUIREMENTS
The plan must describe each jurisdiction’s existing authorities,
policies, programs and resources available to accomplish hazard
mitigation.
Examples include, but are not limited to: staff involved in local
planning activities, public works, and emergency management;
funding through taxing authority, and annual budgets; or
regulatory authorities for comprehensive planning, building codes,
and ordinances.
The plan must describe each jurisdiction’s participation in the NFIP
and describe their floodplain management program for continued
compliance. Simply stating “The community will continue to
comply with NFIP,” will not meet this requirement. The
description could include, but is not limited to:
Adoption and enforcement of floodplain management
requirements, including regulating new construction in
Special Flood Hazard Areas (SFHAs);
Floodplain identification and mapping, including any local
requests for map updates; or
Description of community assistance and monitoring
activities.
Jurisdictions that are currently not participating in the NFIP and
where an FHBM or FIRM has been issued may meet this
requirement by describing the reasons why the community does
not participate.
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23
ELEMENT
REQUIREMENTS
C3. Does the Plan include goals to
a.
reduce/avoid long‐term
vulnerabilities to the identified
hazards? 44 CFR 201.6(c)(3)(i)
Intent: To guide the development
and implementation of hazard
mitigation actions for the
b.
community(ies). Goals are
statements of the community’s
visions for the future.
C4. Does the Plan identify and
a.
analyze a comprehensive range of
specific mitigation actions and
projects for each jurisdiction being
considered to reduce the effects of
hazards, with emphasis on new and
existing buildings and
infrastructure? 44 CFR
201.6(c)(3)(ii) and 44 CFR
201.6(c)(3)(iv)
Intent: To ensure the hazard
mitigation actions are based on the
identified hazard vulnerabilities, are
within the capability of each
jurisdiction, and reduce or avoid
future losses. This is the heart of the
mitigation plan, and is essential to
leading communities to reduce their
risk. Communities, not FEMA, “own”
the hazard mitigation actions in the
strategy.
b.
c.
The plan must include general hazard mitigation goals that
represent what the jurisdiction(s) seeks to accomplish through
mitigation plan implementation.
Goals are broad policy statements that explain what is to be
achieved.
The goals must be consistent with the hazards identified in the
plan.
The plan must include a mitigation strategy that 1) analyzes
actions and/or projects that the jurisdiction considered to reduce
the impacts of hazards identified in the risk assessment, and 2)
identifies the actions and/or projects that the jurisdiction intends
to implement.
Mitigation actions and projects means a hazard mitigation action,
activity or process (for example, adopting a building code) or it
can be a physical project (for example, elevating structures or
retrofitting critical infrastructure) designed to reduce or eliminate
the long term risks from hazards. This sub‐element can be met
with either actions or projects, or a combination of actions and
projects.
The mitigation plan may include non‐mitigation actions, such as
actions that are emergency response or operational preparedness
in nature. These will not be accepted as hazard mitigation actions,
but neither will FEMA require these to be removed from the plan
prior to approval.
A comprehensive range consists of different hazard mitigation
alternatives that address the vulnerabilities to the hazards that the
jurisdiction(s) determine are most important.
Each jurisdiction participating in the plan must have mitigation
actions specific to that jurisdiction that are based on the
community’s risk and vulnerabilities, as well as community
priorities.
The action plan must reduce risk to existing buildings and
infrastructure as well as limit any risk to new development and
redevelopment. With emphasis on new and existing building and
infrastructure means that the action plan includes a consideration
of actions that address the built environment.
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ELEMENT
REQUIREMENTS
C5. Does the Plan contain an action
plan that describes how the actions
identified will be prioritized
(including cost benefit review),
implemented, and administered by
each jurisdiction? 44 CFR
201.6(c)(3)(iii) and 44 CFR (c)(3)(iv)
Intent: To identify how the plan will
directly lead to implementation of
the hazard mitigation actions. As
opportunities arise for actions or
projects to be implemented, the
responsible entity will be able to
take action towards completion of
the activities.
C6. Does the Plan describe a
process by which local governments
will integrate the requirements of
the mitigation plan into other
planning mechanisms, such as
comprehensive or capital
improvement plans, when
appropriate? 44 CFR 201.6(c)(4)(ii)
Intent: To assist communities in
capitalizing on all available
mechanisms that they have at their
disposal to accomplish hazard
mitigation and reduce risk.
a.
b.
c.
a.
b.
The plan must describe the criteria used for prioritizing
implementation of the actions.
The plan must demonstrate when prioritizing hazard mitigation
actions that the local jurisdictions considered the benefits that
would result from the hazard mitigation actions versus the cost of
those actions. The requirement is met as long as the economic
considerations are summarized in the plan as part of the
community’s analysis. A complete benefic‐cost analysis is not
required. Qualitative benefits (for example, quality of life, natural
and beneficial values, or other “benefits”) can also be included in
how actions will be prioritized.
The plan must identify the position, office, department, or agency
responsible for implementing and administering the action (for
each jurisdiction), and identify potential funding sources and
expected timeframes for completion.
The plan must describe the community’s process to integrate the
data, information, and hazard mitigation goals and actions into
other planning mechanisms.
The plan must identify the local planning mechanisms where
hazard mitigation information and/or actions may be
incorporated.
Planning mechanisms means governance structures that are used
to manage local land use development and community decision‐
making, such as comprehensive plans, capital improvement plans,
or other long‐range plans.
c.
d.
e.
A multi‐jurisdictional plan must describe each participating
jurisdiction’s individual process for integrating hazard mitigation
actions applicable to their community into other planning
mechanisms.
The updated plan must explain how the jurisdiction(s)
incorporated the mitigation plan, when appropriate, into other
planning mechanisms as a demonstration of progress in local
hazard mitigation efforts.
The updated plan must continue to describe how the mitigation
strategy, including the goals and hazard mitigation actions will be
incorporated into other planning mechanisms.
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25
4.4 ELEMENT D. PLAN REVIEW, EVALUATION, AND IMPLEMENTATION (Plan Updates Only)
Requirement
A local jurisdiction must review and revise its plan to reflect changes
§201.6(d)(3)
in development, progress in local mitigation efforts, and changes in
priorities, and resubmit if for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
Overall Intent. In order to continue to be an effective representation of the jurisdiction’s
overall strategy for reducing its risks from natural hazards, the mitigation plan must reflect
current conditions. This will require an assessment of the current development patterns
and development pressures as well as an evaluation of any new hazard or risk information.
The plan update is an opportunity for the jurisdiction to assess its previous goals and action
plan, evaluate progress in implementing hazard mitigation actions, and adjust its actions to
address the current realities.
Where conditions of growth and revisions in priorities may have changed very little in a
community, much of the text in the updated plan may be unchanged. This is acceptable as
long as it still fits the priorities of their community, and it reflects current conditions. The
key for plan readers to recognize a good plan update is documentation of the community’s
progress or changes in their hazard mitigation program, along with the community’s
continued engagement in the mitigation planning process.
ELEMENT
D1. Was the plan revised to reflect
changes in development? 44 CFR
201.6(d)(3)
Intent: To ensure that the
mitigation strategy continues to
address the risk and vulnerabilities
to existing and potential
development, and takes into
consideration possible future
conditions that can impact the
vulnerability of the community.
26
REQUIREMENTS
a.
The plan must describe changes in development that have
occurred in hazard prone areas and increased or decreased the
vulnerability of each jurisdiction since the last plan was approved.
If no changes in development impacted the jurisdiction’s overall
vulnerability, plan updates may validate the information in the
previously approved plan.
Changes in development means recent development (for
example, construction completed since the last plan was
approved), potential development (for example, development
planned or under consideration by the jurisdiction), or conditions
that may affect the risks and vulnerabilities of the jurisdictions (for
example, climate variability, declining populations or projected
increases in population, or foreclosures). Not all development will
affect a jurisdiction’s vulnerability.
Local Mitigation Plan Review Guide
ELEMENT
D2. Was the plan revised to reflect
progress in local mitigation efforts?
44 CFR 201.6(d)(3)
Intent: To evaluate and
demonstrate progress made in the
past five years in achieving goals
and implementing actions outlined
in their mitigation strategy.
D3. Was the plan revised to reflect
changes in priorities? 44 CFR
201.6(d)(3)
Intent: To ensure the plan reflects
current conditions, including
financial, legal, and political realities
as well as post‐disaster conditions.
REQUIREMENTS
a.
The plan must describe the status of hazard mitigation actions in
the previous plan by identifying those that have been completed
or not completed. For actions that have not been completed, the
plan must either describe whether the action is no longer relevant
or be included as part of the updated action plan.
a.
The plan must describe if and how any priorities changed since the
plan was previously approved.
If no changes in priorities are necessary, plan updates may
validate the information in the previously approved plan.
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4.5 ELEMENT E. PLAN ADOPTION
Requirement
[The plan shall include…] Documentation that the plan has been
§201.6(c)(5)
formally adopted by the governing body of the jurisdiction requesting
approval of the plan (e.g., City Council, County commissioner, Tribal
Council). For multi‐jurisdictional plans, each jurisdiction requesting
approval of the plan must document that it has been formally
adopted.
Overall Intent. Adoption by the local governing body demonstrates the jurisdiction’s
commitment to fulfilling the hazard mitigation goals and actions outlined in the plan.
Adoption legitimizes the plan and authorizes responsible agencies to execute their
responsibilities. Updated plans also are adopted anew to demonstrate community
recognition of the current planning process, changes that have occurred within the previous
five years, and validate community priorities for hazard mitigation actions.
ELEMENT
E1. Does the Plan include
documentation that the plan has
been formally adopted by the
governing body of the jurisdiction
requesting approval? 44 CFR
201.6(c)(5)
Intent: To demonstrate the
jurisdiction’s commitment to
fulfilling the hazard mitigation goals
outlined in the plan, and to
authorize responsible agencies to
execute their responsibilities.
REQUIREMENTS
a.
The plan must include documentation of plan adoption, usually a
resolution by the governing body or other authority.
If the local jurisdiction has not passed a formal resolution, or used
some other documentation of adoption, the clerk or city attorney
must provide written confirmation that the action meets their
community’s legal requirements for official adoption and/or the
highest elected official or their designee must submit written
proof of the adoption. The signature of one of these officials is
required with the explanation or other proof of adoption.
Minutes of a council or other meeting during which the plan is
adopted will be sufficient if local law allows meeting records to be
submitted as documentation of adoption. The clerk of the
governing body, or city attorney, must provide a copy of the law
and a brief, written explanation such as, “in accordance with
section ___ of the city code/ordinance, this constitutes formal
adoption of the measure,” with an official signature.
If adopted after FEMA review, adoption must take place within
one calendar year of receipt of FEMA’s “Approval Pending
Adoption.” See Section 5, Plan Review Procedure for more
information on “Approvable Pending Adoption.”
28
Local Mitigation Plan Review Guide
ELEMENT
REQUIREMENTS
E2. For multi‐jurisdictional plans,
has each jurisdiction requesting
approval of the plan documented
formal plan adoption? 44 CFR
201.6(c)(5)
Intent: To demonstrate the
jurisdiction’s commitment to
fulfilling the hazard mitigation goals
outlined in the plan, and to
authorize responsible agencies to
execute their responsibilities.
a.
Each jurisdiction that is included in the plan must have its
governing body adopt the plan prior to FEMA approval, even
when a regional agency has the authority to prepare such plans.
As with single jurisdictional plans, in order for FEMA to give
approval to a multi‐jurisdictional plan, at least one participating
jurisdiction must formally adopt the plan within one calendar year
of FEMA’s designation of the plan as “Approvable Pending
Adoption.” See Section 5, Plan Review Procedure for more
information on “Approvable Pending Adoption.”
Local Mitigation Plan Review Guide
29
30
Local Mitigation Plan Review Guide
SECTION 5:
PLAN REVIEW PROCEDURE
5.1 COMMUNICATING THE REVIEW
FEMA will work with State counterparts to establish mutually agreeable methods of
communication for Local Mitigation Plan reviews. State officials completing reviews may
have their own procedures or preferences for communication with the local government or
with FEMA. However, a clear understanding of how information on Local Mitigation Plan
reviews will be relayed, and where necessary issues resolved, will foster more positive
relationships between all parties and provide for greater understanding of unique local
situations.
FEMA: At a minimum, the following communication techniques will be employed by FEMA
in coordination with State offices responsible for the review of Local Mitigation Plans:
FEMA will provide a completed Plan Review Tool with the review determination,
including a description of the required revisions in the Regulation Checklist, and
recommendations in the Plan Assessment.
FEMA will send copies of all signed correspondence electronically, not just by mail,
to reduce the overall review time.
FEMA, States and Local Governments: The following communication techniques may also
be employed by FEMA in coordination with State offices responsible for the review of Local
Mitigation Plans:
Joint Reviews: FEMA and the State may conduct a joint review by phone or in
person to discuss the plan section‐by‐section, highlighting strengths of the
community’s mitigation plan, as well as areas where improvements make the plan
more effective at reducing risks to known hazards.
Involve the Locals: States may choose to include the local officials in joint reviews, or
allow direct contact between FEMA and the local official to reduce review time.
Positive First Contact: When revisions are required, FEMA may contact the State
directly by phone to discuss revisions and offer an opportunity for changes prior to
issuing a “Required Revisions” letter.
Phone First: When revisions are required, State and/or local officials are
encouraged to call FEMA for any clarifications or questions rather than conduct
communication in writing.
Share Drafts: Local officials may share drafts of their entire plan, or at least the
results of the risk assessment, with the State and/or FEMA well in advance of
finalizing the plan. Early feedback from the State and/or FEMA will let the
jurisdiction know that it is on the right track, that additional material needs to be
Local Mitigation Plan Review Guide
31
added, or that major revisions need to be made in time to develop and submit an
approvable plan by established deadlines.
Stay on Schedule: States and local officials should coordinate with each other on
procedures and schedules for State support of local mitigation planning efforts,
initial State review of Local Mitigation Plans, and FEMA review and approval in time
to meet deadlines.
Request Technical Assistance: States and local officials may request technical
assistance from FEMA during the development of the Local Mitigation Plan, not
simply contact FEMA at the point of review to ensure the planning process is
understood and executed successfully.
5.2 MITIGATION PLAN SUBMITTAL
State: The State is responsible for the initial review and coordination of all Local Mitigation
Plans within that State. Once initial review by the State is complete, the State submits the
plan to the respective FEMA Regional office requesting a FEMA review (See FEMA Regional
office contact information at: http://www.fema.gov/about/contact/regions.shtm). This
submittal consists of the following:
a) Transmittal letter or email from the State Hazard Mitigation Officer, Governor’s
Authorized Representative, or other delegated State officer;
b) Local Mitigation Plan document to be reviewed;
c) Plan Review Tool completed by the State; and
d) If the Plan is already adopted by one or more of the participating local jurisdictions,
copies of any adopting resolution(s) or letter(s).
Plans may be submitted electronically or in paper copy, or both. Hard copies may be
required for review purposes, and electronic copies may be requested for recordkeeping. If
sending a paper copy, the State should include an “ATTENTION:” line on the mailing label
with the name of the FEMA Mitigation Planner in the respective FEMA Regional office.
FEMA: Upon receipt, FEMA will provide confirmation to the State either by phone, email or
mail.
5.3 MITIGATION PLAN REVIEW
Review Timeframes
FEMA: All Local Mitigation Plans submitted to FEMA will be reviewed by FEMA using this
Local Mitigation Plan Review Guide and the corresponding Local Mitigation Plan Review
Tool.
32
Local Mitigation Plan Review Guide
FEMA will work with State officials to ensure plans are reviewed in a timely manner and to
prioritize the order of the review of all plans submitted. All Local Mitigation Plans will be
reviewed within 45 calendar dates, whenever possible. If FEMA is unable to complete a
Local Mitigation Plan review within 45 days of receipt from the State, the FEMA Regional
Administrator, or his/her designee will either:
a) Send a signed letter to be received by the State within 10 calendar days after the
end of the 45‐day review period. The letter will include an explanation of the
cause of any delays in the review of the Local Mitigation Plan and a reasonable
projection of the date by which the plan review will be completed. If a
completed review is sent to the State within 10 calendar days after the end of
the 45‐day review period, a signed cover letter will indicate the reason for the
delay.
or
b) Send a monthly status update to each State listing the status of all plans
submitted to FEMA for review. This will include, at a minimum, the status of all
plans received and currently under review, a reasonable projection of the date
by which the plan review will be completed, and the cause for delays for any
plans projected to be reviewed more than 45 days after receipt. This monthly
update may also include plans approved, plans nearing expiration, or other
status categories as deemed appropriate by FEMA.
Upon completion of a Plan review, FEMA will prepare and forward a notification in the form
of a "Requires Revisions", "Approvable Pending Adoption (APA)" or "Approval" letter to the
State. The notification to the State will include a copy of the Local Mitigation Plan Review
Tool.
Plan Revisions
FEMA: Local Mitigation Plans that do not meet all of the requirements in 44 CFR 201.6 are
returned with a “Requires Revisions.” The required revisions are indicated on the
Regulation Checklist (in the Local Mitigation Plan Review Tool) and sent to the State.
When a plan is not approved upon the first review, and requires revisions to meet 44 CFR
Part 201, FEMA will complete subsequent plan reviews within 45 days of receipt from the
State, whenever possible. Items a and b above, Review Timeframes, apply to these
subsequent plan reviews as well.
The review of a revised Local Mitigation Plan and FEMA’s responses included in the
Mitigation Plan Review Tool will take into consideration:
a.
only those Elements of the Tool where revisions were required in the previous
review(s) to meet 44 CFR Part 201;
Local Mitigation Plan Review Guide
33
b.
information in the plan was deleted or changed from its previous version to
make the plan no longer meet that Element of the Local Mitigation Plan Review
Tool; or
c.
the entire plan if received by the Region more than one year after the Region’s
previous plan review was sent to the State.
State: Unless otherwise agreed upon between the State and FEMA, the State is responsible
for forwarding the Local Mitigation Plan Review Tool to the local community. The local
community may work with the State, jointly with the State and FEMA, or directly with FEMA
to make the revisions. The local community resubmits the plan to the State, who is
responsible again for initial review before forwarding the plan to FEMA.
5.4 MITIGATION PLAN APPROVAL AND ADOPTION
Approvable Pending Adoption.
Approval Pending Adoption (APA) is a recommended and potentially time‐saving process by
which jurisdictions submit the final draft Local Mitigation Plan for a review prior to formal
jurisdictional adoption by the appropriate officials, agencies, or organizations. If FEMA
determines the plan is not approvable, the responsible local agency or office will be able to
address deficiencies before taking the plan through adoption, therefore avoiding
unnecessary delays in plan approval.
FEMA: If all Elements are met except adoption, FEMA determines that the Local Mitigation
Plan is APA. The FEMA Region sends an APA letter to the State who, in turn, forwards the
determination to the local community. The jurisdiction can then proceed with the adoption
process, knowing the adopted plan will be approved. When the APA plan is adopted by the
jurisdiction, and FEMA has received the documentation of adoption, then it will be formally
approved through a signed FEMA approval letter.
State: Unless otherwise agreed upon between the State and FEMA, all APA letters from
FEMA are sent to the State; the State is responsible for communicating the status of the
Plan with the local community.
Local Government: If adopted after FEMA review, adoption must take place within one
calendar year of receipt of FEMA’s APA letter. If the plan is not adopted within one
calendar year of FEMA’s APA letter, the jurisdiction must update the entire plan and
resubmit it for FEMA review. The plan approval date begins the five‐year approval period
and sets the expiration date for the plan. The official approval date is indicated on the
signed FEMA approval letter. In addition to providing the approval date, it also indicates
the expiration date of the plan.
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Local Mitigation Plan Review Guide
As with single jurisdictional plans, in order for FEMA to approve a multi‐jurisdictional plan,
at least one participating jurisdiction must formally adopt the plan within one calendar year
of FEMA’s designation of the plan as APA. Participants of a multi‐jurisdictional plan will
assume the expiration date five years from the first jurisdiction’s approval date regardless
of the other participant’s subsequent adoption date(s). The five‐year approval period does
not get “re‐set” each time another participating jurisdiction adopts the plan.
For example, if jurisdiction #1 is the first jurisdiction to formally adopt the Blue County
Multi‐Jurisdictional Hazard Mitigation Plan and receives FEMA’s “approval” of the plan on
January 15, 2008, the plan will expire on January 15, 2013, exactly five years later. If
jurisdiction #2 does not formally adopt the same plan until July 15, 2009, its eligibility would
expire on January 15, 2013, the same exact date that Blue County’s plan received
“approval” when the plan was first approved. Thus, jurisdiction #2 does not benefit from
the full five‐year approval timeframe, but only 3½ years. FEMA recommends that all
participating jurisdictions coordinate the adoption process as soon as the plan has received
APA status to ensure that all participants are covered by a plan for the full five years.
Approved
FEMA: Once all Elements are ‘Met’ and the adoption resolution is received by the FEMA
Regional office, FEMA will send an “Approved” letter signed by the Regional Administrator
or his/her designee to the State. This designee may be the Regional Mitigation Division
Director, Risk Analysis Branch Chief, or other designated official. Correspondence for
“Approved” plans will identify, at a minimum, the name of the approved plan, jurisdiction(s)
that have adopted the plan, date(s) of plan adoption, date of plan approval, and the
expiration date of FEMA’s approval of the plan. For multi‐jurisdictional plans, this
information may be included in the Local Mitigation Plan Review Tool or other attachment.
Approval letter(s) for multi‐jurisdictional plans will clearly read that the expiration date of
FEMA’s approval of the plan applies for all participating jurisdictions, regardless of different
adoption dates. If the plan is multi‐jurisdictional and all participating jurisdiction’s
adoptions are not received by FEMA at the same time, more than one approval letter will be
sent to the State as additional adoptions are received by FEMA. A completed Local
Mitigation Plan Review Tool will accompany correspondence for all approved Local
Mitigation Plans.
State: Unless otherwise agreed upon between the State and FEMA, all approval letters
from FEMA are sent to the State; the State is responsible for communicating the approval
with the local community.
Local Mitigation Plan Review Guide
35
36
Local Mitigation Plan Review Guide
APPENDIX A:
LOCAL MITIGATION PLAN REVIEW TOOL
The Local Mitigation Plan Review Tool demonstrates how the Local Mitigation Plan meets
the regulation in 44 CFR §201.6 and offers States and FEMA Mitigation Planners an
opportunity to provide feedback to the community.
• The Regulation Checklist provides a summary of FEMA’s evaluation of whether the
Plan has addressed all requirements.
• The Plan Assessment identifies the plan’s strengths as well as documents areas for
future improvement.
• The Multi‐jurisdiction Summary Sheet is an optional worksheet that can be used to
document how each jurisdiction met the requirements of the each Element of the
Plan (Planning Process; Hazard Identification and Risk Assessment; Mitigation
Strategy; Plan Review, Evaluation, and Implementation; and Plan Adoption).
The FEMA Mitigation Planner must reference this Local Mitigation Plan Review Guide when
completing the Local Mitigation Plan Review Tool.
Jurisdiction:
Title of Plan:
Local Point of Contact:
Title:
Agency:
Phone Number:
State Reviewer:
Address:
E‐Mail:
FEMA Reviewer:
Date Received in FEMA Region (insert #)
Plan Not Approved
Plan Approvable Pending Adoption
Plan Approved
Date of Plan:
Title:
Date:
Title:
Date:
Local Mitigation Plan Review Tool
A‐1
SECTION 1:
REGULATION CHECKLIST
INSTRUCTIONS: The Regulation Checklist must be completed by FEMA. The purpose of the
Checklist is to identify the location of relevant or applicable content in the Plan by
Element/sub‐element and to determine if each requirement has been ‘Met’ or ‘Not Met.’
The ‘Required Revisions’ summary at the bottom of each Element must be completed by
FEMA to provide a clear explanation of the revisions that are required for plan approval.
Required revisions must be explained for each plan sub‐element that is ‘Not Met.’ Sub‐
elements should be referenced in each summary by using the appropriate numbers (A1, B3,
etc.), where applicable. Requirements for each Element and sub‐element are described in
detail in this Plan Review Guide in Section 4, Regulation Checklist.
1. REGULATION CHECKLIST
Location in Plan
(section and/or
page number)
Regulation (44 CFR 201.6 Local Mitigation Plans)
Met
Not
Met
ELEMENT A. PLANNING PROCESS
A1. Does the Plan document the planning process, including how it
was prepared and who was involved in the process for each
jurisdiction? (Requirement §201.6(c)(1))
A2. Does the Plan document an opportunity for neighboring
communities, local and regional agencies involved in hazard
mitigation activities, agencies that have the authority to regulate
development as well as other interests to be involved in the planning
process? (Requirement §201.6(b)(2))
A3. Does the Plan document how the public was involved in the
planning process during the drafting stage? (Requirement
§201.6(b)(1))
A4. Does the Plan describe the review and incorporation of existing
plans, studies, reports, and technical information? (Requirement
§201.6(b)(3))
A5. Is there discussion of how the community(ies) will continue public
participation in the plan maintenance process? (Requirement
§201.6(c)(4)(iii))
A6. Is there a description of the method and schedule for keeping the
plan current (monitoring, evaluating and updating the mitigation plan
within a 5‐year cycle)? (Requirement §201.6(c)(4)(i))
ELEMENT A: REQUIRED REVISIONS
A‐2
Local Mitigation Plan Review Tool
1. REGULATION CHECKLIST
Location in Plan
(section and/or
page number)
Regulation (44 CFR 201.6 Local Mitigation Plans)
Not
Met
Met
ELEMENT B. HAZARD IDENTIFICATION AND RISK ASSESSMENT
B1. Does the Plan include a description of the type, location, and
extent of all natural hazards that can affect each jurisdiction(s)?
(Requirement §201.6(c)(2)(i))
B2. Does the Plan include information on previous occurrences of
hazard events and on the probability of future hazard events for each
jurisdiction? (Requirement §201.6(c)(2)(i))
B3. Is there a description of each identified hazard’s impact on the
community as well as an overall summary of the community’s
vulnerability for each jurisdiction? (Requirement §201.6(c)(2)(ii))
B4. Does the Plan address NFIP insured structures within the
jurisdiction that have been repetitively damaged by floods?
(Requirement §201.6(c)(2)(ii))
ELEMENT B: REQUIRED REVISIONS
ELEMENT C. MITIGATION STRATEGY
C1. Does the plan document each jurisdiction’s existing authorities,
policies, programs and resources and its ability to expand on and
improve these existing policies and programs? (Requirement
§201.6(c)(3))
C2. Does the Plan address each jurisdiction’s participation in the NFIP
and continued compliance with NFIP requirements, as appropriate?
(Requirement §201.6(c)(3)(ii))
C3. Does the Plan include goals to reduce/avoid long‐term
vulnerabilities to the identified hazards? (Requirement
§201.6(c)(3)(i))
C4. Does the Plan identify and analyze a comprehensive range of
specific mitigation actions and projects for each jurisdiction being
considered to reduce the effects of hazards, with emphasis on new
and existing buildings and infrastructure? (Requirement
§201.6(c)(3)(ii))
C5. Does the Plan contain an action plan that describes how the
actions identified will be prioritized (including cost benefit review),
implemented, and administered by each jurisdiction? (Requirement
§201.6(c)(3)(iv)); (Requirement §201.6(c)(3)(iii))
C6. Does the Plan describe a process by which local governments will
integrate the requirements of the mitigation plan into other planning
mechanisms, such as comprehensive or capital improvement plans,
when appropriate? (Requirement §201.6(c)(4)(ii))
ELEMENT C: REQUIRED REVISIONS
Local Mitigation Plan Review Tool
A‐3
1. REGULATION CHECKLIST
Location in Plan
(section and/or
page number)
Regulation (44 CFR 201.6 Local Mitigation Plans)
Met
Not
Met
ELEMENT D. PLAN REVIEW, EVALUATION, AND IMPLEMENTATION (applicable to plan updates
only)
D1. Was the plan revised to reflect changes in development?
(Requirement §201.6(d)(3))
D2. Was the plan revised to reflect progress in local mitigation
efforts? (Requirement §201.6(d)(3))
D3. Was the plan revised to reflect changes in priorities?
(Requirement §201.6(d)(3))
ELEMENT D: REQUIRED REVISIONS
ELEMENT E. PLAN ADOPTION
E1. Does the Plan include documentation that the plan has been
formally adopted by the governing body of the jurisdiction requesting
approval? (Requirement §201.6(c)(5))
E2. For multi‐jurisdictional plans, has each jurisdiction requesting
approval of the plan documented formal plan adoption?
(Requirement §201.6(c)(5))
ELEMENT E: REQUIRED REVISIONS
ELEMENT F. ADDITIONAL STATE REQUIREMENTS (OPTIONAL FOR STATE REVIEWERS ONLY;
NOT TO BE COMPLETED BY FEMA)
F1.
F2.
ELEMENT F: REQUIRED REVISIONS
d
A‐4
Local Mitigation Plan Review Tool
SECTION 2:
PLAN ASSESSMENT
INSTRUCTIONS: The purpose of the Plan Assessment is to offer the local community more
comprehensive feedback to the community on the quality and utility of the plan in a
narrative format. The audience for the Plan Assessment is not only the plan developer/local
community planner, but also elected officials, local departments and agencies, and others
involved in implementing the Local Mitigation Plan. The Plan Assessment must be
completed by FEMA. The Assessment is an opportunity for FEMA to provide feedback and
information to the community on: 1) suggested improvements to the Plan; 2) specific
sections in the Plan where the community has gone above and beyond minimum
requirements; 3) recommendations for plan implementation; and 4) ongoing partnership(s)
and information on other FEMA programs, specifically RiskMAP and Hazard Mitigation
Assistance programs. The Plan Assessment is divided into two sections:
1.
Plan Strengths and Opportunities for Improvement
2.
Resources for Implementing Your Approved Plan
Plan Strengths and Opportunities for Improvement is organized according to the plan
Elements listed in the Regulation Checklist. Each Element includes a series of italicized
bulleted items that are suggested topics for consideration while evaluating plans, but it is
not intended to be a comprehensive list. FEMA Mitigation Planners are not required to
answer each bullet item, and should use them as a guide to paraphrase their own written
assessment (2‐3 sentences) of each Element.
The Plan Assessment must not reiterate the required revisions from the Regulation
Checklist or be regulatory in nature, and should be open‐ended and to provide the
community with suggestions for improvements or recommended revisions. The
recommended revisions are suggestions for improvement and are not required to be made
for the Plan to meet Federal regulatory requirements. The italicized text should be deleted
once FEMA has added comments regarding strengths of the plan and potential
improvements for future plan revisions. It is recommended that the Plan Assessment be a
short synopsis of the overall strengths and weaknesses of the Plan (no longer than two
pages), rather than a complete recap section by section.
Resources for Implementing Your Approved Plan provides a place for FEMA to offer
information, data sources and general suggestions on the overall plan implementation and
maintenance process. Information on other possible sources of assistance including, but
not limited to, existing publications, grant funding or training opportunities, can be
provided. States may add state and local resources, if available.
Local Mitigation Plan Review Tool
A‐5
A. Plan Strengths and Opportunities for Improvement
This section provides a discussion of the strengths of the plan document and identifies areas
where these could be improved beyond minimum requirements.
Element A: Planning Process
How does the Plan go above and beyond minimum requirements to document the planning
process with respect to:
Involvement of stakeholders (elected officials/decision makers, plan implementers,
business owners, academic institutions, utility companies, water/sanitation districts,
etc.);
Involvement of Planning, Emergency Management, Public Works Departments or other
planning agencies (i.e., regional planning councils);
Diverse methods of participation (meetings, surveys, online, etc.); and
Reflective of an open and inclusive public involvement process.
Element B: Hazard Identification and Risk Assessment
In addition to the requirements listed in the Regulation Checklist, 44 CFR 201.6 Local
Mitigation Plans identifies additional elements that should be included as part of a plan’s
risk assessment. The plan should describe vulnerability in terms of:
1) A general description of land uses and future development trends within the community
so that mitigation options can be considered in future land use decisions;
2) The types and numbers of existing and future buildings, infrastructure, and critical
facilities located in the identified hazard areas; and
3) A description of potential dollar losses to vulnerable structures, and a description of the
methodology used to prepare the estimate.
How does the Plan go above and beyond minimum requirements to document the Hazard
Identification and Risk Assessment with respect to:
Use of best available data (flood maps, HAZUS, flood studies) to describe significant
hazards;
Communication of risk on people, property, and infrastructure to the public (through
tables, charts, maps, photos, etc.);
Incorporation of techniques and methodologies to estimate dollar losses to vulnerable
structures;
Incorporation of Risk MAP products (i.e., depth grids, Flood Risk Report, Changes Since
Last FIRM, Areas of Mitigation Interest, etc.); and
Identification of any data gaps that can be filled as new data became available.
A‐6
Local Mitigation Plan Review Tool
Element C: Mitigation Strategy
How does the Plan go above and beyond minimum requirements to document the
Mitigation Strategy with respect to:
Key problems identified in, and linkages to, the vulnerability assessment;
Serving as a blueprint for reducing potential losses identified in the Hazard Identification
and Risk Assessment;
Plan content flow from the risk assessment (problem identification) to goal setting to
mitigation action development;
An understanding of mitigation principles (diversity of actions that include structural
projects, preventative measures, outreach activities, property protection measures, post‐
disaster actions, etc);
Specific mitigation actions for each participating jurisdictions that reflects their unique
risks and capabilities;
Integration of mitigation actions with existing local authorities, policies, programs, and
resources; and
Discussion of existing programs (including the NFIP), plans, and policies that could be
used to implement mitigation, as well as document past projects.
Element D: Plan Update, Evaluation, and Implementation (Plan Updates Only)
How does the Plan go above and beyond minimum requirements to document the 5‐year
Evaluation and Implementation measures with respect to:
Status of previously recommended mitigation actions;
Identification of barriers or obstacles to successful implementation or completion of
mitigation actions, along with possible solutions for overcoming risk;
Documentation of annual reviews and committee involvement;
Identification of a lead person to take ownership of, and champion the Plan;
Reducing risks from natural hazards and serving as a guide for decisions makers as they
commit resources to reducing the effects of natural hazards;
An approach to evaluating future conditions (i.e. socio‐economic, environmental,
demographic, change in built environment etc.);
Discussion of how changing conditions and opportunities could impact community
resilience in the long term; and
Discussion of how the mitigation goals and actions support the long‐term community
vision for increased resilience.
Local Mitigation Plan Review Tool
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B. Resources for Implementing Your Approved Plan
Ideas may be offered on moving the mitigation plan forward and continuing the relationship
with key mitigation stakeholders such as the following:
What FEMA assistance (funding) programs are available (for example, Hazard
Mitigation Assistance (HMA)) to the jurisdiction(s) to assist with implementing the
mitigation actions?
What other Federal programs (National Flood Insurance Program (NFIP), Community
Rating System (CRS), Risk MAP, etc.) may provide assistance for mitigation activities?
What publications, technical guidance or other resources are available to the
jurisdiction(s) relevant to the identified mitigation actions?
Are there upcoming trainings/workshops (Benefit‐Cost Analysis (BCA), HMA, etc.) to
assist the jurisdictions(s)?
What mitigation actions can be funded by other Federal agencies (for example, U.S.
Forest Service, National Oceanic and Atmospheric Administration (NOAA),
Environmental Protection Agency (EPA) Smart Growth, Housing and Urban Development
(HUD) Sustainable Communities, etc.) and/or state and local agencies?
A‐8
Local Mitigation Plan Review Tool
SECTION 3:
MULTI‐JURISDICTION SUMMARY SHEET (OPTIONAL)
INSTRUCTIONS: For multi‐jurisdictional plans, a Multi‐jurisdiction Summary Spreadsheet may be completed by listing each
participating jurisdiction, which required Elements for each jurisdiction were ‘Met’ or ‘Not Met,’ and when the adoption resolutions
were received. This Summary Sheet does not imply that a mini‐plan be developed for each jurisdiction; it should be used as an
optional worksheet to ensure that each jurisdiction participating in the Plan has been documented and has met the requirements for
those Elements (A through E).
MULTI‐JURISDICTION SUMMARY SHEET
Jurisdiction
Name
#
1
2
3
4
5
6
7
8
9
Requirements Met (Y/N)
Jurisdiction
Type
Plan
(city/borough/
POC
township/
village, etc.)
Local Mitigation Plan Review Tool
Mailing
Address
Email
Phone
A.
Planning
Process
B.
Hazard
Identification
& Risk
Assessment
C.
Mitigation
Strategy
D.
Plan Review,
Evaluation &
Implementation
E.
Plan
Adoption
F.
State
Require‐
ments
A‐9
MULTI‐JURISDICTION SUMMARY SHEET
Jurisdiction
Name
#
10
11
12
13
14
15
16
17
18
19
20
Requirements Met (Y/N)
Jurisdiction
Type
Plan
(city/borough/
POC
township/
village, etc.)
A‐10
Mailing
Address
Email
Phone
A.
Planning
Process
B.
Hazard
Identification
& Risk
Assessment
C.
Mitigation
Strategy
D.
Plan Review,
Evaluation &
Implementation
E.
Plan
Adoption
F.
State
Require‐
ments
Local Mitigation Plan Review Tool
| File Type | application/pdf |
| File Title | Microsoft Word - PLAN REVIEW GUIDE v5_9-21-11.docx |
| Author | ksmith35 |
| File Modified | 2012-02-07 |
| File Created | 2011-09-21 |