Multi-Hazard Mitigation Planning Guidance blue book

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State/Local/Tribal Hazard Mitigation Plans

Multi-Hazard Mitigation Planning Guidance blue book

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MULTI-HAZARD MITIGATION PLANNING
GUIDANCE UNDER THE DISASTER
MITIGATION ACT OF 2000

Federal Emergency Management Agency
500 C Street, SW
Washington, DC 20472
Original Release March, 2004
With revisions November, 2006, June 2007 & January, 2008

INTRODUCTION
OVERVIEW
The Disaster Mitigation Act of 2000 (DMA 2000) (P.L. 106-390) provides
an opportunity for States, Tribes, and local governments to take a new
and revitalized approach to mitigation planning. DMA 2000 amended the
Robert T. Stafford Disaster Relief and Emergency Assistance Act (the
Act) by repealing the previous Mitigation Planning section (409) and
replacing it with a new Mitigation Planning section (322). This new
section emphasizes the need for State, Tribal, and local entities to
closely coordinate mitigation planning and implementation efforts. It
continues the requirement for a State mitigation plan as a condition of
disaster assistance, and creates incentives for increased coordination
and integration of mitigation activities at the State level through the
establishment of requirements for two different levels of State plans:
“Standard” and “Enhanced.” States that demonstrate an increased
commitment to comprehensive mitigation planning and implementation
through the development of an approved Enhanced State Plan can
increase the amount of funding available through the Hazard Mitigation
Grant Program (HMGP). Section 322 also established a new
requirement for Local Mitigation Plans, and authorized up to 7% of
HMGP funds available to a State to be used for development of State,
Tribal, and Local Mitigation Plans.
To implement the DMA 2000 planning requirements, FEMA published
an Interim Final Rule (the Rule) in the Federal Register on February 26,
2002. This Rule (44 CFR Part 201) established the mitigation planning
requirements for States, Tribes, and local communities. Normally FEMA
publishes a proposed rule for public comment before publishing a final
rule. This process can result in a lengthy comment and response period,
during which the proposed rule is not legally effective or enforceable.
Because certain types of Stafford Act assistance are conditioned on
having an approved mitigation plan, FEMA wanted to publish an
effective rule providing the DMA 2000 planning requirements in order to
position State and local governments to receive these mitigation funds
as soon as possible.
Even though it is an Interim Final Rule, FEMA will still publish a
proposed rule for public comment, to be followed eventually by a final
rule. FEMA is assessing the utility and practicality of these interim final
requirements based on the experience of States, Tribes, and local
governments, and will draw on this experience in preparing the future
Proposed and Final Rules for Mitigation Planning. Until then, the Rule
serves as the governing set of requirements for DMA 2000 planning
implementation.

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Special
Considerations:

In reading the Rule, an important distinction must be made between the
words “shall” and “should.” When the word “shall” is used, the
requirement is mandatory – e.g., “The risk assessment shall include: A
description of the type, location, and extent of all natural hazards that
can affect the jurisdiction.” If the plan does not include this description, it
will not be approvable by FEMA. It should also be noted that the word
“must” carries the same mandatory nature as the word “shall.” For
example, “The plan must be … resubmitted for approval to the
appropriate Regional Director every three years.” This is a mandatory
requirement.
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. For example, where the Rule says, “The plan
should describe vulnerability in terms of … the types and numbers of
existing and future buildings …” this information would make the plan
more useful, but the plan could still be approved if it is not included
(assuming the plan met all the mandatory requirements).
The use of the words “should,” “shall,” and “must” in this Multi-Hazard
Mitigation Planning Guidance is consistent with the use of those words
in the Rule. In the Plan Review Crosswalks found in Section 4, the
“should” requirements are shaded, as a reminder that they are not
required for plan approval.
To help States, Tribes, and local governments better understand the
Rule and meet the DMA 2000 planning requirements, FEMA has
prepared this document, Multi-Hazard Mitigation Planning Guidance
Under the Disaster Mitigation Act of 2000 (Multi-Hazard Mitigation
Planning Guidance). It was designed with three major objectives:
ƒ

To help Federal and State reviewers evaluate mitigation plans from
different jurisdictions in a fair and consistent manner;

ƒ

To help States, Tribes, and local jurisdictions develop new mitigation
plans or modify existing ones in accordance with the requirements of
the Rule, and

ƒ

To help States, Tribes, and local jurisdictions conduct
comprehensive reviews and prepare updates to their plans in
accordance with the review and update requirements of the Rule.

This Multi-Hazard Mitigation Planning Guidance, as interpretation and
explanation for the Rule, is FEMA’s official source for defining the
requirements of original and updated mitigation plans. It includes
references to specific language in the Rule, descriptions of the relevant
requirements, and sample plan text to illustrate distinctions between
plan approaches that would and would not meet DMA 2000
requirements. In addition, this document provides references to a
number of planning tools that FEMA has made available to assist
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States, Tribes, and localities in developing a comprehensive, multihazard approach to mitigation planning, and in preparing plans that will
meet the DMA 2000 requirements. These tools include:
ƒ

State and Local Mitigation Planning How-to Guides – intended to
help States and communities plan and implement practical,
meaningful hazard mitigation actions (FEMA 386-1,2,3,4,5,6,7 and
8); available on the FEMA Web site at
http://www.fema.gov/plan/mitplanning/planning_resources.shtm#1.

ƒ

Planning for a Sustainable Future (FEMA 364) - provides guidance
for integrating hazard mitigation and sustainable practices as part of
pre- and post-disaster mitigation planning efforts; available on the
FEMA Web site at
http://www.fema.gov/plan/mitplanning/planning_resources.shtm#1.

ƒ

Multi-Hazard Identification and Risk Assessment, available on the
FEMA Web site at
http://www.fema.gov/plan/prevent/fhm/ft_mhira.shtm.

ƒ

FEMA Mitigation Resources for Success (FEMA 372) – a compact
disc (CD) with a compendium of FEMA resources related to
mitigation practices and projects; and

ƒ

Mitigation Benefit Cost Analysis (BCA) Toolkit Compact Disc – this
CD includes all the FEMA BCA software, technical manuals, BCA
training course documentation, and other supporting material and
BCA guidance. Copies can be obtained by calling FEMA’s toll-free
BC Hotline at 866-222-3580.

These publications, with the exception of the BCA Toolkit CD, can be
ordered through the FEMA Publications Warehouse at 800-480-2520 or
online at FEMA’s Information Resource Library
http://www.fema.gov/library/index.jsp.
FEMA recently made available HAZUS-MH (Hazards U.S. – MultiHazard), a risk assessment software program. For more information, go
to http://www.fema.gov/plan/prevent/hazus/.
In addition, FEMA has developed the DMA 2000 Mitigation Planning
Workshop for Local Governments (G318), based on the Multi-Hazard
Mitigation Planning Guidance and the reference material described
above. You can obtain information on this course from your FEMA
Regional Office.

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It should be noted that DMA 2000 specifically requires mitigation
planning for natural hazards, but not for manmade hazards. However,
FEMA supports those jurisdictions that choose to consider technological
and manmade hazards in their respective mitigation plans. While it is
true that a State, Tribal, or Local Mitigation Plan can be approved under
the Act without consideration of these hazards, the Multi-Hazard
Mitigation Planning Guidance can be helpful in developing and
evaluating plans that include these hazards as part of a comprehensive
hazard mitigation strategy. For more information on integrating
technological and manmade hazards in mitigation plans, please see:
Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7);
available at http://www.fema.gov/plan/mitplanning/howto7.shtm.

Special
Considerations:

DMA 2000 MITIGATION PLANNING PROVISIONS
As a result of FEMA’s previous mitigation planning requirements, such
as State planning under Section 409 of the Stafford Act, and plan
requirements associated with the Flood Mitigation Assistance (FMA)
Program of the National Flood Insurance Program (NFIP), States and
many communities have developed hazard mitigation plans. The most
successful of these plans—where practical, meaningful mitigation
actions have been the result—have two common elements:
ƒ

Comprehensive risk and capability assessments that form a solid
foundation for decision making; and

ƒ

Input from a wide range of stakeholders who would play a role during
implementation of recommended mitigation actions at the Federal,
State, and local levels.

Accordingly, the Disaster Mitigation Act of 2000 emphasizes greater
interaction between State and local mitigation planning activities, and
highlights the need for improved linkage of hazard and capability
analyses to State and local hazard mitigation strategies. At the same
time, FEMA has a continuing interest in streamlining the mitigation
planning and implementation process. The implementation of planned,
pre-identified, cost-effective mitigation actions based on a sound hazard
identification and assessment of risk will make a major contribution to
such streamlining.
The DMA 2000 mitigation planning provisions, along with other sections
of the Act, provide a significant opportunity to reduce the Nation’s
disaster losses. The language in the Act, taken as a whole, emphasizes
the importance of strong State, Tribal, and local planning processes, and
comprehensive mitigation program management at the State level.
FEMA strongly believes that with hazard mitigation planning, as with
most other planning efforts, the actual process of planning is as
important as the resultant plan. Therefore, we consider 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 a
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process or development of a planning product (such as goals, or hazard
identification).
To emphasize the importance of the process, we have taken, to the
extent possible, a “performance standard,” rather than a “prescriptive”
approach to the planning requirements. This means that the
requirements are designed to identify, generally, what should be done in
the process and documented in the plan, rather than specify exactly how
it should be done. This approach recognizes and appreciates the
inherent differences that exist among State, Tribal, and local
governments with respect to size, resources, capability, and
vulnerability.
Specifically, DMA 2000 enacted the following provisions relative to
mitigation planning:
Standard State Mitigation Plans (§201.4 of the Rule): States with an
approved Standard State Mitigation Plan will qualify for HMGP funding
based on 15% for amounts not more than $2,000,000,000, 10% for
amounts of more than $2,000,000,000 and not more than
$10,000,000,000, and 7.5% on amounts of more than $10,000,000,000,
and not more than $35,333,000,000 of the total estimated eligible
Stafford Act disaster assistance (new formula per Post-Katrina
Emergency Management Reform Act of 2006, October 2, 2006).
Generally, States are required to coordinate mitigation planning with
Tribal and local jurisdictions, and document funding and technical
assistance they will provide to these jurisdictions. More specifically,
§201.4 requires that plans meet the following basic requirements to
receive approval:
9 describe how the State coordinates with local mitigation planning
efforts;
9 develop a mitigation strategy based on local and State
vulnerability analyses and risk assessments;
9 describe how the State provides funding or technical assistance
to local governments;
9 discuss how the State prioritizes jurisdictions that will receive
mitigation planning and project grants and other State
assistance; and
9 establish a plan maintenance process.
ƒ

Enhanced State Mitigation Plans (§201.5 of the Rule): States that
have an approved Enhanced State Mitigation Plan at the time of a
disaster declaration will qualify to receive HMGP funds based on up
to 20% of the total estimated eligible Stafford Act disaster
assistance. Specifically, §201.5 requires that Enhanced Plans meet
all the requirements of the Standard Plan and in addition:
9

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demonstrate a broad, programmatic mitigation approach, and
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9

demonstrate a systematic and effective administration and
implementation of existing mitigation programs.

ƒ

Local Mitigation Plans (§201.6 of the Rule): Local jurisdictions
must also demonstrate that proposed mitigation actions are based
on a sound planning process that accounts for the inherent risk and
capabilities of the individual communities.

ƒ

Tribal Mitigation Plans: Tribal governments will have the
opportunity to fulfill the planning requirements either as a grantee or
as a subgrantee.

ƒ

Funding for Plan Development: DMA 2000 authorizes up to 7% of
available HMGP funds for State, Tribal, or local planning purposes.
Also, funds from the Pre-Disaster Mitigation (PDM) program may be
used to develop mitigation plans, and the FMA program provides
annual grant funds for flood mitigation planning. Other agencies
have funding available that may be used for hazard mitigation
planning. For example, the National Oceanic and Atmospheric
Administration’s Coastal Zone Management (CZM) Program has
funded coastal hazard mitigation activities, including planning.

ƒ

Deadlines and Requirements for Regular Plan Reviews and
Updates: In order to apply for a FEMA PDM project grant, Tribal
and local governments must have a FEMA-approved mitigation plan.
Tribal and local governments must have a FEMA-approved
mitigation plan in order to receive HMGP project funding for
disasters declared on or after November 1, 2004. States and Tribes
must have a FEMA-approved Standard or Enhanced Mitigation Plan
in order to receive non-emergency Stafford Act assistance (i.e.,
Public Assistance categories C-G, HMGP, and Fire Management
Assistance Grants) for disasters declared on or after November 1,
2004. State mitigation plans must be reviewed and reapproved by
FEMA every three years. Local Mitigation Plans must be reviewed
and reapproved by FEMA every five years.

ƒ

Plan updates. In addition to the timelines referenced above, the
Rule includes the following paragraphs that pertain directly to the
update of State and local plans,
9 §201.3(b)(5) [FEMA Responsibilities]…Conduct reviews, at
least once every three years, of State mitigation activities,
plans, and programs to ensure that mitigation commitments
are fulfilled….
9 §201.4(d) Review and updates. [State] Plan must be
reviewed and revised to reflect changes in development,
progress in statewide mitigation efforts, and changes in
priorities and resubmitted for approval…every three years.

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9 §201.6(d) [Local] plans must be reviewed, revised if
appropriate, and resubmitted for approval within five years in
order to continue to be eligible for…project grant funding.
Plan updates must demonstrate that progress has been made in the
past three years (for State plans), or in the past five years (for local
plans), to fulfill commitments outlined in the previously approved
plan. This will involve a comprehensive review and evaluation of
each section of the plan and a discussion of the results of evaluation
and monitoring activities detailed in the Plan Maintenance section of
the previously approved plan. FEMA will leave to State discretion,
consistent with this plan update guidance, the documentation of
progress made. Plan updates may validate the information in the
previously approved plan, or may involve a major plan rewrite. In
any case, a plan update is NOT an annex to the previously approved
plan; it must stand on its own as a complete and current plan.
States may determine, consistent with this guidance, the type and
level of detail of local plan information that they incorporate into the
State plan. A guiding principle is that the documentation provided be
sufficient to maintain the effectiveness of the plan as a primary and
up to date tool for risk reduction.

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NEW REGULATION FOR FLOOD INSURANCE REFORM ACT OF
2004 AND TRIBAL PLANNING PROVISIONS
The Flood Insurance Reform Act of 2004 (P.L. 108-264) created two
new grant programs, Severe Repetitive Loss (SRL) and Repetitive
Flood Claims (RFC), and modified the existing Flood Mitigation
Assistance (FMA) program. The RFC is currently being implemented
through guidance. FEMA has prepared a regulation to implement the
new SRL and changes to the FMA program, and anticipates it to be
published during the summer of 2007. The regulation is expected to
have the following impacts on State and local mitigation planning:
ƒ

The SRL program will require a local mitigation plan as a condition
of project grants (consistent with other grant programs).

ƒ

Provide criteria for provisions of State mitigation plans which, if
included in these plans, will increase the Federal cost share to
90/10 for mitigation of severe repetitive loss properties funded
under the FMA and SRL programs.

ƒ

Clarifies criteria for local plans: one plan will be required for all
mitigation programs (i.e., HMGP, PDM, FMA, and the new SRL).

Included in the updated regulation is a new section for tribal mitigation
plans. Previously, Indian tribal governments could develop plans
under either the State or local criteria, although neither of these
options has sufficiently met the needs of these governments. The
new section will accommodate some of the issues relating to Indian
tribal governments, and streamline their roles and responsibilities with
respect to mitigation planning. Implementation of the tribal mitigation
planning section will be phased in over time, so that plans under
development when the regulation is published will not be impacted by
any changes.
FEMA will provide guidance for States and local and Indian tribal
governments on meeting the requirements of this new regulation
shortly after it is published.

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USING THE MULTI-HAZARD MITIGATION PLANNING GUIDANCE
Organization of
the Multi-Hazard
Mitigation
Planning
Guidance

The Multi-Hazard Mitigation Planning Guidance is divided into four
sections following this Introduction. Parts 1, 2, and 3 address the
requirements for the Standard State, Enhanced State, and Local Plans,
respectively. These sections contain the language of the Rule, an
explanation clarifying the intent of the Rule requirements, excerpts of
plans to illustrate application of the requirements, and references to a
series of resources that address particular planning issues in more
detail. Section 4 contains Plan Review Crosswalks for scoring each of
these three types of plans.
For Part 1 - Standard State Plans, and Part 2 – Enhanced State Plans,
guidance relating to updating the plans has been incorporated for each
regulatory requirement directly underneath the original explanation, and
is labeled Plan Update. It is important to note that the updated plan
must meet the requirements of the original explanations as well as
the update guidance explanation. The update guidance is meant to
highlight issues that apply specifically to those plans being updated, and
is intended to complement – not replace – the original guidance. In
some cases, the original explanation has been revised to provide further
clarification. Where such revisions have been made, a note with the
date of the revision has been placed in the left margin next to the new
language. As stated earlier, the previously approved plan may not
necessarily need comprehensive or significant revision for the update.
The update process requires that each section be reviewed and
evaluated to ensure that it is still valid, or to establish that it needs to be
revised and brought up to date.
NOTE: At this time (June 2007), the examples for the Standard and
Enhanced Plans have not yet been revised. The reader is cautioned not
to confuse the terms “Required Revisions” and “Revised Submittal” that
are used in the examples with the new language for the “Plan Update.”
The Part 4 Plan Review Crosswalk for Standard State Plans and Plan
Review Crosswalk for Enhanced State Plans have been revised to
reflect the new plan update language added to the explanations in Parts
1 and 2. New elements have been added to the crosswalk in those
cases where the existing crosswalk elements were insufficient for plan
updates. In other cases, the update requirement is covered by minor
changes in the wording of the original requirement.
This June 2007 document includes plan update guidance and
requirements for Standard State Plans and Enhanced State Plans only.
Similar guidance for updating Local Mitigation Plans is being prepared.
The next version of this Multi-Hazard Mitigation Planning Guidance will
include guidance for updating Local Plans.
The Rule is as published at 44 CFR 201. Language in brackets does not
appear in the Rule, but has been added to provide the proper context.
For example: [The plan must include] a description of the planning

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process. An ellipsis has been used to indicate that other phrases
precede or follow the requirement language. For example: … using
maps where appropriate.
Plan Evaluation
Methodology

The Multi-Hazard Mitigation Planning Guidance outlines a process for
the review of State and Local Mitigation Plans based on the
requirements described in the Rule. The Plan Review Crosswalks in
Section 4 of this document are important tools in both the review and
development of complete plans, as they mirror the requirements in the
Rule. Standard State Plans must meet the prerequisites and receive a
score of “Satisfactory” for each requirement for the plan to be approved.
To be approved as an Enhanced State Plan, a score of “Satisfactory”
must be attained for all Standard and Enhanced requirements. Local
Plans must be submitted to the State Hazard Mitigation Officer for initial
review and coordination, before submittal to the appropriate FEMA
Regional Office for formal review and approval. Local Plans must also
receive a score of “Satisfactory” for all requirements to be approved.
Except for prerequisites that must be met before the plan can be
approved, the reviewer must score requirements based on the following
scoring system:
N

Needs Improvement: The plan does not meet the minimum for
the requirement. Reviewer’s comments must be provided.

S

Satisfactory: The plan meets the minimum for the requirement.
Reviewer’s comments are encouraged, but not required.

The final, completed Plan Review Crosswalk provides the State, Tribe,
or local jurisdiction with:
ƒ

a score for each requirement;

ƒ

reviewer comments for requirements that need improvement; and

ƒ

a determination of whether the plan is approved by FEMA (and the
State, if a Local Plan).

In those cases where FEMA reviewers provided “recommended
revisions” for those requirements that the previously approved plan met,
the plan update process provides an excellent opportunity to incorporate
these recommendations into the revised plan. When FEMA reviews the
updated plan, it will assess whether and how the plan addresses these
recommendations, although it is not required that the plan does so.
Special
Considerations:

When reviewing plans, the evaluator may find it helpful to first read the
plan and identify the appropriate sections that correspond to the Rule’s
requirements. The Plan Review Crosswalks include a column (second
from left), “Location in the Plan,” that the State, Tribe, or jurisdiction
submitting the plan can complete to assist reviewers in determining
where in the plan the requirements are addressed.

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With the concurrence of FEMA Regions, States can insert additional
State planning requirements, tailoring Part 3 – Local Mitigation Plans
of the Multi-Hazard Mitigation Planning Guidance to account for Statespecific requirements.

Special
Considerations:

PLAN SUBMITTAL AND REVIEW PROCEDURES
Plan Submittal
Procedures

State Plans
FEMA Regional Offices will work with States to identify procedures
and schedules that will facilitate plan review, technical assistance,
and approval. The following recommended approaches may be
helpful:
ƒ

The State may share drafts of the entire plan, or at least the
results of the risk assessment (because of the importance of the
risk assessment to the quality of the overall plan), with FEMA
well in advance of finalizing the plan. Early FEMA feedback will
let the State know either that it is on the right track, that
additional material needs to be added, or that major revisions
need to be made in time to develop and submit an approvable
plan by established deadlines.

ƒ

The State is strongly encouraged to submit a final draft to FEMA
for review before seeking formal adoption of the plan by the
appropriate officials, agencies, or organizations. If FEMA
determines that the plan is “approvable pending adoption,” i.e.,
the plan meets all requirements except for the formal adoption
and final submittal, the State can then proceed with the adoption
process, knowing the adopted plan will be approved. If there are
deficiencies in the plan, the responsible parties will be able to
address them before taking the plan through adoption, and
avoid the potentially awkward situation of having an adopted
plan not be approved.

ƒ

Once the State obtains FEMA approval of the final draft, it can
then proceed with formal adoption, and submit the adopted plan
to FEMA for formal approval.

ƒ

States should consult with their FEMA Regional Office early
enough to ensure that they will be able to obtain FEMA review
and approval of their plans in time to meet established
deadlines.

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Local Plans
The Rule requires that Local Plans be submitted to the State Hazard
Mitigation Officer for initial review and coordination, with the State
then forwarding the plans to FEMA for formal review and approval.
The following recommended approaches may be helpful:
ƒ

States and communities should coordinate with each other to
identify procedures and schedules that will facilitate State
support of local planning efforts and initial review of Local Plans.

ƒ

Local jurisdictions may share drafts of their entire plan, or at
least the results of the risk assessment (because of the
importance of the risk assessment to the quality of the overall
plan), with the State well in advance of finalizing the plan. Early
feedback from the State will let the jurisdiction know that it is on
the right track, that additional material needs to be added, or
that major revisions need to be made in time to develop and
submit an approvable plan by established deadlines.

ƒ

Local jurisdictions are strongly encouraged to submit a final draft
to the State and FEMA for review before seeking formal
adoption of the plan by the appropriate officials, agencies, or
organizations. If FEMA determines that their plan is “approvable
pending adoption,” i.e., the plan meets all requirements except
for the formal adoption and final submittal, they can then
proceed with the adoption process, knowing the adopted plan
will be approved. If there are deficiencies in the plan, the
responsible parties will be able to address them before taking
the plan through adoption, and avoid the potentially awkward
situation of having an adopted plan not be approved.

ƒ

Once FEMA approves the final draft of the plan, the local
jurisdiction can then proceed with formal adoption, and submit
the adopted plan to FEMA for formal approval.

ƒ

Local jurisdictions should consult with their State Hazard
Mitigation Officer early enough to ensure that they will be able to
obtain FEMA review and approval of their plans in time to meet
established deadlines.

Tribal Plans
The modifications to the planning regulation are expected to provide
a new section for tribal mitigation plans. This will allow Tribal
governments to develop a single plan that will satisfy the mitigation
grant program requirement, and will allow them to apply directly to
FEMA as a grantee, or through the State as a subgrantee.
FEMA Regional Offices will work with tribal governments to identify
procedures and schedules that will facilitate plan review, technical

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assistance, and approval. The following recommended approaches
may be helpful:
ƒ

Indian tribal governments may share drafts of the entire plan, or
at least the results of the risk assessment (because of the
importance of the risk assessment to the quality of the overall
plan), with FEMA well in advance of finalizing the plan. Early
FEMA feedback will let the tribal government know either that it
is on the right track, that additional material needs to be added,
or that major revisions need to be made in time to develop and
submit an approvable plan by established deadlines.

ƒ

Tribal governments are strongly encouraged to submit a final
draft to FEMA for review before seeking formal adoption of the
plan by the appropriate officials, agencies, or organizations. If
FEMA determines that the plan is “approvable pending
adoption,” i.e., the plan meets all requirements except for the
formal adoption and final submittal, the tribal government can
then proceed with the adoption process, knowing the adopted
plan will be approved. If there are deficiencies in the plan, the
responsible parties will be able to address them before taking
the plan through adoption, and avoid the potentially awkward
situation of having an adopted plan not be approved.

ƒ

Once the tribal government obtains FEMA approval of the final
draft, it can then proceed with formal adoption, and submit the
adopted plan to FEMA for formal approval.

Tribal governments should consult with their FEMA Regional Office
early enough to ensure that they will be able to obtain FEMA review
and approval of their plans in time to meet established deadlines.
Timeframe for
Review

Once a final plan is submitted, the FEMA Regional Office will
complete the review within 45 days from the day it is received,
whenever possible. In the event that the plan is not approved, the
Regional Office will provide comments on the areas that need
improvement.

Plan Updates

States should develop a schedule that allows for the plan (Standard
and/or Enhanced) update and approval process to occur within
three years from the last approval date. Local jurisdictions should
develop a schedule that allows a plan update and approval to occur
within five years from the last approval date. Tribal plans developed
as State level plans will have a three-year update schedule; Tribal
plans developed as local level plans will follow the five-year update
schedule. [This will be updated to reflect the new regulation.] All
jurisdictions should consider the time needed for State and/or FEMA
reviews as well as time that may be needed for make required
changes identified in the reviews ahead of the deadline. It should
be noted that States could choose to establish a schedule for more
frequent Local Plan updates.

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INTRODUCTION

Special
Considerations:

FEMA no longer requires States to revise their mitigation plan after
every disaster declaration, as it did under former section 409 of the
Stafford Act. We do, however, recommend that States consider updating
their plans whenever a disaster or other circumstances significantly
affect its mitigation priorities. Additionally, because the State
Administrative Plan required under the HMGP (44 CFR 206.437) must
be updated for each new disaster, States may prefer to maintain it
separately from the mitigation plan. The Administrative Plan could
reference the mitigation priorities identified in the mitigation plan, in
order to satisfy the Administrative Plan requirement to establish priorities
for the selection of mitigation projects.

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T A B L E

O F

C O N T E N T S

List of Acronyms........................................................................................................................ iii
Introduction (revised November, 2006) .................................................................................... v
Part 1 – Standard State Mitigation Plans (revised January, 2008) ......................................1-1
Prerequisite .................................................................................................................1-2
Adoption by the State: §201.4(c)(6) and §201.4(c)(7) .............................................1-2
Planning Process ........................................................................................................1-4
Documentation of the Planning Process: §201.4(c)(1) .......................................1-5
Coordination Among Agencies: §201.4(b) .........................................................1-7
Program Integration: §201.4(b) ........................................................................1-11
Risk Assessment.......................................................................................................1-14
Identifying Hazards: §201.4(c)(2)(i) ..................................................................1-15
Profiling Hazards: §201.4(c)(2)(i)......................................................................1-18
Assessing Vulnerability by Jurisdiction: §201.4(c)(2)(ii) ...................................1-23
Assessing Vulnerability of State Facilities: §201.4(c)(2)(ii) ...............................1-27
Estimating Potential Losses by Jurisdiction: §201.4(c)(2)(iii) ...........................1-29
Estimating Potential Losses of State Facilities: §201.4(c)(2)(iii) .......................1-32
Mitigation Strategy ....................................................................................................1-34
Hazard Mitigation Goals: §201.4(c)(3)(i)...........................................................1-35
State Capability Assessment: §201.4(c)(3)(ii) ..................................................1-39
Local Capability Assessment: §201.4(c)(3)(ii) ..................................................1-43
Mitigation Actions: §201.4(c)(3)(iii) ...................................................................1-46
Funding Sources: §201.4(c)(3)(iv) ....................................................................1-50
Coordination of Local Mitigation Planning .................................................................1-53
Local Funding and Technical Assistance: §201.4(c)(4)(i) .................................1-54
Local Plan Integration: §201.4(c)(4)(ii) .............................................................1-57
Prioritizing Local Assistance: §201.4(c)(4)(iii) ..................................................1-58
Plan Maintenance Process........................................................................................1-60
Monitoring, Evaluating, and Updating the Plan: §201.4(c)(5)(i) ........................1-61
Monitoring Progress of Mitigation Activities: §201.4(c)(5)(ii) and (iii) .................1-64
Severe Repetitive Loss Strategy ...............................................................................1-67
Repetitive Loss Mitigation Strategy ...............................................................1-68
Coordination with Repetitive Loss Jurisdictions ............................................1-70
Part 2 – Enhanced State Mitigation Plans (revised June, 2007) ..........................................2-1
Prerequisite .................................................................................................................2-2
Compliance with Standard State Plan Requirements: §201.5(b) .......................2-2
Comprehensive State Hazard Mitigation Planning Program .......................................2-4
Integration with Other Planning Initiatives: §201.5(b)(1).....................................2-5
Project Implementation Capability: §201.5(b)(2)(i) and (ii) ...................................2-8
Program Management Capability: §201.5(b)(2)(iii A-D) ....................................2-12
Assessment of Mitigation Actions: §201.5(b)(2)(iv) ..........................................2-13
Effective Use of Available Mitigation Funding: §201.5(b)(3) .............................2-16
Commitment to a Comprehensive Mitigation Program: §201.5(b)(4)(i-vi) ........2-18
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Part 3 – Local Mitigation Plans ...............................................................................................3-1
Prerequisites ...............................................................................................................3-2
Adoption by the Local Governing Body: §201.6(c)(5) .........................................3-2
Multi-Jurisdictional Plan Adoption: §201.6(c)(5) .................................................3-3
Multi-Jurisdictional Planning Participation: §201.6(a)(3) .....................................3-4
Planning Process ........................................................................................................3-5
Documentation of the Planning Process: §201.6(b) and §201.6(c)(1): ...................3-6
Risk Assessment.........................................................................................................3-9
Identifying Hazards: §201.6(c)(2)(i) ..................................................................3-10
Profiling Hazards: §201.6(c)(2)(i)......................................................................3-13
Assessing Vulnerability: Overview: §201.6(c)(2)(ii) ..........................................3-17
Assessing Vulnerability: Identifying Structures: §201.6(c)(2)(ii)(A) ...................3-19
Assessing Vulnerability: Estimating Potential Losses: §201.6(c)(2)(ii)(B).........3-22
Assessing Vulnerability: Analyzing Development Trends: §201.6(c)(2)(ii)(C) ...3-25
Multi-Jurisdictional Risk Assessment: §201.6(c)(2)(iii): ....................................3-27
Mitigation Strategy ....................................................................................................3-29
Local Hazard Mitigation Goals: §201.6(c)(3)(i) .................................................3-30
Identification and Analysis of Mitigation Actions: §201.6(c)(3)(ii) .....................3-32
Implementation of Mitigation Actions: §201.6(c)(3)(iii) .....................................3-36
Multi-Jurisdictional Mitigation Actions: §201.6(c)(3)(iv).....................................3-41
Plan Maintenance Process........................................................................................3-43
Monitoring, Evaluating, and Updating the Plan: §201.6(c)(4)(i) ........................3-44
Incorporation into Existing Planning Mechanisms: §201.6(c)(4)(ii) ...................3-47
Continued Public Involvement: §201.6(c)(4)(iii) ................................................3-49
Part 4 – Plan Review Crosswalks ...........................................................................................4-1
Standard State Hazard Mitigation Plan Review Crosswalk (revised January, 2008)
Enhanced State Hazard Mitigation Plan Review Crosswalk (revised June, 2007)
Local Mitigation Hazard Mitigation Plan Review Crosswalk

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L I S T
BCA
BMPs
CDBG
CFR
CIP
CRS
CZM
DMA 2000
DOT
FEMA
FIRM
FIS
FMA
GIS
HMC
HMGP
HUD
IBC
IFR
MOU
NEPA
NFIP
OMB
PA
PDM
SBA
SHMO
STAPLE+E
UCC

O F

A C R O N Y M S
Benefit-Cost Analysis
Best Management Practices
Community Development Block Grant
Code of Federal Regulations
Capital Improvement Plan
Community Rating System (part of the National Flood Insurance
Program)
Coastal Zone Management Program
Disaster Mitigation Act of 2000
Department of Transportation
Federal Emergency Management Agency
Flood Insurance Rate Map
Flood Insurance Study
Flood Mitigation Assistance Program
Geographic Information System
Hazard Mitigation Committee
Hazard Mitigation Grant Program
US Housing and Urban Development
International Building Code
Interim Final Rule
Memorandum of Understanding
National Environmental Policy Act
National Flood Insurance Program
Office of Management and Budget
Public Assistance
Pre-Disaster Mitigation Program
Small Business Administration
State Hazard Mitigation Officer
Social, Technical, Administrative, Political, Legal, Economic, and
Environmental
Uniform Construction Code

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(THIS PAGE IS INTENTIONALLY BLANK)

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PART 1 – STANDARD STATE MITIGATION PLANS

PART 1 – STANDARD STATE MITIGATION PLANS
The mitigation plan demonstrates the State’s commitment to reducing the risks from natural
hazards, and should serve as a guide for all levels of State decision makers. The plan should
detail how the State will address planning for natural hazards and the resources they are going
to commit to the process.
The Plan, whether a first-time submittal or an updated plan, must meet certain basic
requirements to receive approval, including:
ƒ

The mitigation strategy should be based on local and State vulnerability analyses and
risk assessments.

ƒ

The State must describe how they will coordinate with local mitigation planning efforts.

ƒ

The State must describe how they will provide funding or technical assistance to local
governments.

ƒ

The State must discuss how they will prioritize jurisdictions that will receive mitigation
planning and project grants and other State assistance.

ƒ

There must be a formal plan maintenance process.

Each requirement must receive a satisfactory score for the plan to be approved. Each State
submitting a hazard mitigation plan must meet the Prerequisite – Adoption by the State, before
the plan can be approved by FEMA.
In those cases where FEMA reviewers provided “recommended revisions” for those
requirements that the previously approved plan met, the plan update process provides an
excellent opportunity to incorporate these recommendations into the revised plan. When FEMA
reviews the updated plan, it will assess whether and how the plan addresses these
recommendations, although it is not required that the plan does so.
The sections covered in Part 1 – Standard State Mitigation Plans include:
ƒ

Prerequisite – Adoption by the State

ƒ

Planning Process

ƒ

Risk Assessment

ƒ

Mitigation Strategy

ƒ

Coordination of Local Mitigation Planning

ƒ

Plan Maintenance Process

ƒ

Severe Repetitive Loss Strategy

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PREREQUISITE
ADOPTION BY THE STATE
Requirement
§201.4(c)(6) and
§201.4(c)(7):

The plan must:
ƒ
ƒ

Explanation:

be formally adopted by the State prior to submittal to [FEMA] for final
review and approval [and]
include assurances that the State will comply with all applicable
Federal statutes and regulations in effect with respect to the periods
for which it receives grant funding, in compliance with 44 CFR
13.11(c). The State will amend its plan whenever necessary to reflect
changes in State or Federal laws and statutes as required in 44 CFR
13.11(d).

An appropriate body in the State must adopt the plan. This could be, for
example, the State Legislature or the Governor, depending on the
State’s established procedures. States with hazard mitigation teams or
councils may choose to use these bodies to adopt the plan. At a
minimum, the plan must be endorsed by the director of the State agency
responsible for preparing and implementing the plan, as well as the
heads of other agencies with primary implementation responsibilities.
Adoption by the State:
ƒ

Demonstrates the State’s commitment to fulfilling the mitigation
objectives outlined in the plan.

ƒ

Legitimizes the plan and authorizes the responsible agencies
identified in the plan to execute their responsibilities.

The section on assurances relates to the State’s understanding and
accountability in complying with Federal statutes and regulations in
effect when it receives grant funding as prescribed in 44 CFR 13.11(c).
Additionally, as required in 44 CFR 13.11(d), the State must amend its
plan to reflect new or revised Federal regulations or statutes, or changes
in State law, organization, policy, or State agency operation. The
amendment can be added as an annex to the plan and later
incorporated into the appropriate section(s) when the plan is formally
updated as required in §201.4(d) of the Rule.
The resolution of adoption can include a statement assuring FEMA that
the State will comply with both of these CFR requirements.
The plan must include a copy of the resolution of adoption.
Plan Update:

An appropriate body in the State must adopt the updated plan
regardless of the degree of modifications to the original plan.

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PART 1 – STANDARD STATE MITIGATION PLANS
Resource:

For more information about adopting a mitigation plan, see:
9 Bringing the Plan to Life (FEMA 386-4), Step 1.

Scoring:

‰
‰

Not Met. The plan has not been formally adopted by the State.

‰

Met. The plan has been formally adopted by the State, and a copy of
the signed resolution is included.

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Not Met. The plan has been formally adopted by the State, but a
copy of the signed resolution is not included.

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PART 1 – STANDARD STATE MITIGATION PLANS
PLANNING PROCESS
§201.4(b) recommends that the State coordinate with other State agencies, appropriate Federal
agencies, and interested groups during the planning process. Early involvement of other parties
provides the opportunity for integration of mitigation actions with other planning efforts. It also
allows for building partnerships with other agencies and interested groups to facilitate data
gathering, analysis, and later implementation of mitigation strategies. §201.4(c)(1) requires that
the State document this planning process.
The planning process is the heart of both the original mitigation plan and updates to that plan.
In a plan update, the description of the planning process is intended to inform the reader what
steps the planning team took to review, evaluate, and update each section of the plan, as well
as provide the rationale for sections that were not changed. It should be based on the update
process described in the plan maintenance section of the previously approved plan. This is the
blueprint for constructing the updated plan, and instills within it a necessary continuity.
States may experience fluctuations in staffing and in-house knowledge of the hazard mitigation
planning process. The description of the planning process will be especially valuable to new
staff and successive leaders as it provides a clear and coherent picture of the steps taken to
update the plan. Also, during intense decision-making situations, such as the period following a
catastrophic event1, an understanding of the planning process and the rationale used to develop
the risk assessment and mitigation strategy will be of assistance as mitigation priorities are
reassessed and revised.
This section includes the following three subsections:
ƒ

Documentation of the Planning Process

ƒ

Coordination Among Agencies

ƒ

Program Integration

1

any large scale event, the result of either man made or natural hazards, that, for a protracted period,
affects governments’ ability to conduct and deliver the day to day civil functions and services, and has
long-term consequences for the local, state or national economy.
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PART 1 – STANDARD STATE MITIGATION PLANS
DOCUMENTATION OF THE PLANNING PROCESS
Requirement
§201.4(c)(1):

[The State plan must include a] description of the planning process used
to develop the plan, including how it was prepared, who was involved in
the process, and how other agencies participated.

Explanation:

A description of the planning process must include how the planning
team or committee was formed, how input was sought from individuals
or other agencies, and how the plan was prepared.

Plan Update:

Resource:

A description of the planning process is required for the update. The
update must describe the process used to review and analyze each
section of the plan. If the planning team or committee finds that some
sections of the plan warrant an update, and others do not, the process
the team undertook to make that determination must be documented in
the plan.
For more information on the planning process, see:
9 Getting Started (FEMA 386-1), Steps 1 – 4.

Examples:
Original Submittal:
The State Hazard Mitigation Plan (the Plan) was prepared by the State
Hazard Mitigation Section. This section, created in 2001 and headed by
the State Hazard Mitigation Officer, is responsible for leading and
coordinating mitigation and long-term redevelopment efforts.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.4(c)(1)

REVIEWER’S COMMENTS

ƒ

ƒ

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The description does not provide
details on how various parties were
involved in the planning process,
what meetings were held to solicit
involvement, how long the process
took, etc.
The plan was prepared by only one
State agency, with no mention of
participation by other agencies or
groups.

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Required Revisions:
For a “Satisfactory” score, the plan must provide more details on how
the plan was prepared and what agencies were involved.
Revised Submittal:
The State Hazard Mitigation Plan (the Plan) was prepared by the State
Hazard Mitigation Section. This section, created in 2001 and headed by
the State Hazard Mitigation Officer, is responsible for leading and
coordinating mitigation and long-term redevelopment efforts. The
Hazard Mitigation Section organized a Hazard Mitigation Committee
(HMC), composed of 14 representatives from Federal and State
agencies, as well as local governments, the private sector, and
non-profit and civic organizations to assist the section in preparing
the Plan (see pages X, Y, and Z for a list of these agencies). Not all
invited civic or non-profit groups or business leaders agreed to join
the HMC. However, two regional public forums were organized: one
at the beginning of the planning process to elicit concerns and
solicit ideas; and a second public forum was held for the general
public to review and comment on the draft plan. These forums were
widely publicized in local newspapers, and flyers were mailed to
agencies that had expressed an interest in participating in some
capacity. Citizens and interested groups could also access the
State public Web site to review the draft plan and provide
comments online. The HMC met every two weeks for the first three
months and later once per month. The plan was completed over a
12-month period.

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PART 1 – STANDARD STATE MITIGATION PLANS
COORDINATION AMONG AGENCIES
Requirement
§201.4(b):

The [state] mitigation planning process should include coordination with
other State agencies, appropriate Federal agencies, interested groups,
and … .

Explanation:

In order to encourage States to develop plans that will be used as
guides for statewide mitigation activities, and for citizens and the private
sector to support such activities, the Rule recommends States
demonstrate coordination with all levels of government, and
representatives from the private and non-profit sectors. The plans
should describe how the State interacted with Federal, State, regional,
and local agencies, as well as other interested parties such as business,
industry, and professional associations, non-profit groups, and
community representatives in the development of the plan.
Of particular importance is the participation by agencies and groups that
can contribute resources to prepare the plan and by agencies that will
likely implement mitigation actions. By including these agencies in the
planning process, the State can build partnerships that will facilitate the
implementation phase of the plan. Merely contacting agencies to solicit
input or sending a draft plan for an agency to review does not constitute
active participation. Participants should play an active role throughout
the planning process and, whenever possible, be involved from the
beginning. The State should identify additional participants as
opportunities arise (e.g., after a disaster).
Examples of how coordination may be demonstrated:
ƒ

Description of outreach efforts to engage interested parties.

ƒ

Description of the types and frequency of meetings of task forces
and committees, inter-disciplinary/inter-agency mitigation planning
teams, or with interested agencies and private sector organizations.

ƒ

Discussion of the nature of the Memoranda of Understanding (MOU)
or other work agreements.

ƒ

Description of how interested parties who could not participate on a
regular basis were kept informed and how they provided comments.

The updated plan should describe how the State interacted with all
levels of government as indicated above. It should also describe how
coordination among agencies changed since approval of the previous
plan.

Plan Update:

Resource:

For information on establishing a mitigation planning team and building
partnerships, see:
9 Getting Started (FEMA 386-1), Step 2.

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PART 1 – STANDARD STATE MITIGATION PLANS

Examples:
Original Submittal:
The State Hazard Mitigation Committee (HMC) distributed the
mitigation plan to other State, Federal, and local agencies. Each
participating agency had an opportunity to comment on preliminary and
draft versions of the plan. The HMC incorporated appropriate
comments and distributed a final copy of the plan to the participants.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(b)

REVIEWER’S COMMENTS

ƒ

ƒ

Coordination only involved
notification of other government
agencies.
No effort was documented regarding
contacting or soliciting involvement
from civic, private, or not-for profit
groups, including those known to
assist in the event of disasters.

Required Revisions:
A “Needs Improvement” score on this requirement will not preclude the
plan from passing. For a “Satisfactory” score, the mitigation plan must
demonstrate that the planning process included active coordination with
and participation by other agencies and/or groups.
Special
Considerations:

This may not be an easy item to “fix” if adequate coordination has not
occurred to date. The State would have to take its plan back for review
by potential participants and revise the content according to their input.
This could be a substantial effort. On the other hand, if the State
actually did the coordination, but did not describe it adequately, then
the State needs to do a better job of documenting its coordination effort.
Revised Submittal:
The State Hazard Mitigation Committee (HMC) distributed coordinated
the development of the mitigation plan to with other State, Federal,
and local agencies. The HMC, on behalf of the Governor, also
solicited participation from industry associations, volunteer
agencies, and other private and non-profit sector representatives.
Fourteen representatives in total committed their time and
available resources to develop a mitigation strategy that would
protect life, property, and the environment as well as contribute to
the economic well being of the State.

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PART 1 – STANDARD STATE MITIGATION PLANS

Each participating agency and group presented its programs,
identified mitigation opportunities, and subsequently had an
opportunity to comment on preliminary and draft versions of the plan.
The HMC jointly reviewed each agency’s function and identified
more opportunities, including some applicable to agencies not
present. The HMC incorporated appropriate comments and distributed
a final copy of the plan to the participants.
Agency
State Office of Natural
Resources
State Building Code
Office
State Office of
Economic Development

State Office of
Emergency
Management
State Public Works and
Utility Office
State Department of
Transportation
State Planning Office

State Historic
Preservation Office

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Designated Responsibilities
To review mitigation project applications and
plans to ensure their environmental
soundness.
To provide information about State building
code requirements and best construction
practices.
To identify opportunities to promote
economic development through mitigation
initiatives. To act as a liaison between local
economic development agencies and the
HMC to identify ways in which economic
development initiatives can encourage
mitigation.
To coordinate mitigation planning and
project implementation. To serve as a liaison
between FEMA’s Federal Insurance and
Mitigation Administration and the HMC.
To help local communities identify mitigation
actions for public infrastructure. To identify
state resources and infrastructure vulnerable
to hazards.
To help local communities identify mitigation
actions for State roads and bridges. To
identify state resources and infrastructure
vulnerable to hazards.
To educate local governments (specifically
local planning departments) on new hazard
mitigation planning requirements and to aid
in the incorporation of mitigation concerns
into local comprehensive planning efforts.
To help communities identify ways to
mitigate hazards that threaten historic
resources in their communities. To assist
communities identified in Section 106 review
processes for mitigation projects in
compliance with Federal and State historic
preservation regulations.

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PART 1 – STANDARD STATE MITIGATION PLANS
Agency
State Parks Association
Association of
Homebuilders
Manufactured Housing
Association
Big River Watershed
Society
State Association of
Disaster Relief
State Association of
County Govt.

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Designated Responsibilities
To identify resources for acquiring funding to
create green- and open-spaces as mitigation
actions.
To represent private development interests
and concerns in relation to mitigation
projects and regulations.
To identify best practices in constructing or
reconstructing low-cost, manufactured
housing threatened by hazards.
To coordinate efforts to improve water
quality, recreation activities, and other
concerns with State mitigation activities.
To provide insight into mitigation actions as
they relate to response and recovery.
To liaison between HMC and local
governments about hazard mitigation
planning requirements. To educate local
officials about the resources available for
mitigation planning assistance and training.

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PART 1 – STANDARD STATE MITIGATION PLANS
PROGRAM INTEGRATION
Requirement
§201.4(b):

[The State mitigation planning process should] be integrated to the
extent possible with other ongoing State planning efforts, as well as
other FEMA mitigation programs and initiatives.

Explanation:

Coordination can result in identifying opportunities to integrate planning
efforts and mitigation actions. FEMA has found that mitigation plan
implementation is most effective when States integrate mitigation
planning efforts with those of other State planning programs and
initiatives.
States might demonstrate that they have made efforts at integration by:
ƒ

Reviewing existing plans and reports to identify opportunities to
integrate mitigation actions.

ƒ

Having mitigation planners/specialists serve on other State
program and planning teams.

ƒ

Consolidating the planning requirements for all State mitigation
programs (e.g., HMGP, FMA, CRS, local comprehensive plans, and
land use plans).

ƒ

Identifying overall goals or priorities common to other State
planning efforts.

ƒ

Requesting that legislation be passed or issuing an Executive
Order mandating integration of mitigation actions into other planning
initiatives.

ƒ

Outlining the State’s approach and providing a timeline for
integrating actions.

ƒ

Describing actual ongoing efforts where mitigation actions have
been integrated into planning mechanisms (e.g., comprehensive
plans, capital improvement plans, and emergency operation plans)
and implementation tools (e.g., building codes, floodplain
ordinances, and land use regulations).

Plan Update:

In addition to discussing what integration efforts have taken place to
date, the update should discuss State planning integration efforts and
opportunities that were identified in the previously approved plan, and
any unforeseen obstacles that emerged since approval of the previous
plan.

Resource:

For information on integrating hazard mitigation actions with other
initiatives, see:
9 Bringing the Plan to Life (FEMA 386-4), Step 2.

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PART 1 – STANDARD STATE MITIGATION PLANS
Examples:
Original Submittal:
The State Hazard Mitigation Committee (HMC) reviewed several State
agencies’ plans to identify programs and policies that promote hazard
mitigation.
Twenty communities currently participate in the Community Rating
System (CRS), part of the National Flood Insurance Program. Each has
prepared a flood mitigation plan and has received funding for flood
mitigation projects.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(b)

REVIEWER’S COMMENTS

ƒ

The plan does not describe all
programs or policies examined, nor
does it identify the mitigation efforts
to be integrated into the State’s CRS
program.

Required Revisions:
A “Needs Improvement” score on this requirement will not preclude the
plan from passing. For a ”Satisfactory” score, the mitigation plan must
document how mitigation actions are integrated into other State
planning efforts as well as Federal mitigation programs.
Revised Submittal:
The State Hazard Mitigation Committee (HMC) reviewed several State
agencies’ plans to identify programs and policies that currently
promote hazard mitigation or could potentially further mitigation
initiatives around the State (see Table XX for a summary of these
findings).
One program the State is implementing is the Growing Smart
Initiative, administered by the Division for Sustainable
Development in the State Department of Planning and
Development. The Growing Smart Initiative has several
components related to hazard mitigation, including funding to
encourage local governments to remove structures from high
hazard areas, creating open space in environmentally sensitive
areas such as the 100-year floodplain, and providing financial
incentives to encourage businesses to upgrade facilities in central
business districts. The HMC will continue its efforts to integrate
hazard mitigation-related concepts into the existing Growing
Smart framework through:
ƒ
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PART 1 – STANDARD STATE MITIGATION PLANS
promote hazard mitigation in the business community.
ƒ

Discouraging development in hazard areas such as steep
slopes with landslide potential.

ƒ

Educating local governments about the benefits of adopting
building standards to mitigate against wind and earthquake
hazards.

Additionally, the Department of Public Works takes into account
hazard-prone areas when siting facilities and infrastructure such
as water and sewer lines. The Public Works Department avoids
such areas, thereby discouraging development while protecting
services in the event of a disaster.
Twenty communities currently participate in the Community Rating
System (CRS), part of the National Flood Insurance Program. Each
community has prepared a flood mitigation plan and has received
funding for flood mitigation projects (see Appendix XX for details).
Additionally, the State is currently developing a strategy to assist
other communities to participate in the CRS, having set a goal to
provide technical support to five communities per year. The
strategy includes providing additional funding to communities
that have adopted FMA Plans, to upgrade these plans into allhazard plans.

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PART 1 – STANDARD STATE MITIGATION PLANS
RISK

ASSESSMENT

§201.4(c)(2) of the Rule requires that States undertake a risk assessment that provides the
factual basis for developing a mitigation strategy. This provision encourages States to produce a
meaningful analysis of the hazards and vulnerabilities that affect them, enabling States to
prioritize jurisdictions or geographic areas to receive funding and technical assistance for
conducting more detailed local risk and vulnerability assessments.
The purpose of the updated risk assessment is to present the current statewide overview of
potential losses to guide implementation of mitigation measures, to prioritize jurisdictions most
at risk from natural disasters, and to integrate data provided in local risk assessments.
The updated risk assessment will also include the integration of new data, where available, such
as National Flood Insurance Program maps or studies, HAZUS analyses, or reports from other
Federal and State agencies. If the previously approved plan identified data deficiencies that
would be addressed at a later time, then FEMA would expect the new information to be
incorporated in the updated risk assessment. However, if the data deficiencies have not been
resolved, they must be addressed in the updated plan, accompanied by an explanation of why
they remain and an updated schedule to resolve the issue.
When the State plans were originally prepared, there were few local plans that met FEMA’s
planning requirements. Therefore, States had limited local information on which to base their
plans. Since then, many local plans have been approved and adopted, providing States with
the opportunity to better coordinate with local jurisdictions and ensure that local risk
assessments complement the State risk assessment.
Additionally, section 201.4(d) requires the State plan be updated regularly to address changes
in development and mitigation priorities. This is reflected in the guidance language under
§201.4(c)(2)(ii) and §201.4(c)(2)(iii).
This section includes the following six subsections:
ƒ

Identifying Hazards

ƒ

Profiling Hazards

ƒ

Assessing Vulnerability by Jurisdiction

ƒ

Assessing Vulnerability of State Facilities

ƒ

Estimating Potential Losses by Jurisdiction

ƒ

Estimating Potential Losses of State Facilities

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PART 1 – STANDARD STATE MITIGATION PLANS
IDENTIFYING HAZARDS
Requirement
§201.4(c)(2)(i):

[The State risk assessment shall include an] overview of the type … of all
natural hazards that can affect the State … .

Explanation:

A State hazard mitigation plan will only be effective if it accounts for all
sources of risk. The intent of this requirement is to insure that all hazards
potentially affecting the State are identified.
During the State’s planning process (as evaluated in the Planning
Process section of this document), it may be determined that some of
these hazard types do not pose a significant enough threat to justify
further study or the identification of corresponding mitigation actions.
However, the mitigation plan should clearly document that a thorough
and comprehensive identification of hazards was performed by the State,
including the fact that certain hazards were deemed not to be significant
enough to warrant further study, to receive a satisfactory score for this
requirement.
This section should include a description of how the State collected the
information to identify these hazards, including the sources of
information. This process should also include incorporating the results of
local level mitigation planning efforts to identify hazards as that
information becomes available.

Plan Update:

The updated plan must address any newly identified hazards or hazards
that have been determined to pose a more significant threat than was
apparent when the previously approved plan was prepared. If improved
descriptions of hazards identified in the previous plan are available, they
must be incorporated into this section.

Special
Considerations:

Although the Rule requires that States only identify natural hazards,
States may include manmade hazards (i.e., technological or accidental
events such as hazardous material accidents and terrorism or intentional
acts such as the release of chemical agents) to provide a more complete
analysis of hazards that may affect the States. However, plans will not be
penalized for not including this information.

Resources:

For more information on identifying hazards, see:
9 Understanding Your Risks (FEMA 386-2), Step 1.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 HAZUS MH http://www.fema.gov/plan/prevent/hazus/

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PART 1 – STANDARD STATE MITIGATION PLANS
Examples:
Original Submittal:
The State Mitigation Plan addresses the risk associated with the
following hazards:
ƒ

Drought

ƒ

Flooding

ƒ

Hurricanes
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(2)(i)

REVIEWER’S COMMENTS

ƒ
ƒ

ƒ

The plan did not include wildfires
that have occurred in the past.
The State did not indicate how
these hazards were identified. As a
result, it cannot be determined if
this is a valid list of all relevant
hazards.
The State did not indicate if
hazards identified as part of
mitigation planning by local
jurisdictions are or will be included
in this listing.

Required Revisions:
For a “Satisfactory” score, the plan must include wildfires. The State is
experiencing a drought and has had wildfires in the past under such
conditions. While not required by the Rule, the plan should also
document the process followed to identify hazards and identify the
extent to which hazards identified through local mitigation planning have
been or will be included in the State plan.

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PART 1 – STANDARD STATE MITIGATION PLANS

Revised Submittal:
The State Hazard Mitigation Committee (HMC) pursued the
following steps to identify hazards that may affect the state:
ƒ

Review of past State and Federal disaster designations.

ƒ

Review of current Flood Insurance Rate Maps (FIRMs).

ƒ

Review of available local mitigation plans (see Appendix XX for
a complete listing of local mitigation plans, including DMA
2000, FMA, and CRS, consulted as part of this planning
process).

ƒ

Review of recent risk assessment related research by State
and Federal agencies, as well as the State University’s (SU)
Emergency Management Program within the Department of
Planning. This research involves long-range weather trends
per the U.S. Meteorological Service as a predictor of potential
periods of drought or increased hurricane activity and the
probability of dam failures within the State per the recent SU
study (see Appendix XX for a complete listing of studies
consulted as part of this planning process).

ƒ

The HMC representative from the State Geological Survey was
consulted regarding the earthquake risk in the State. She
indicated that the risk was minimal (.001%/year of a 4.0+
earthquake); therefore, the HMC decided not to study the
earthquake hazard any further.

As a result, the HMC determined that the State Mitigation Plan
needed to address addresses the risk associated with the following
hazards:
ƒ

Drought

ƒ

Flooding, including related potential for dam failures

ƒ

Hurricanes

ƒ

Wildfires

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PART 1 – STANDARD STATE MITIGATION PLANS
PROFILING HAZARDS
Requirement
§201.4(c)(2)(i):

[The State risk assessment shall include an overview of the] location of
all natural hazards that can affect the State, including information on
previous occurrences of hazard events, as well as the probability of
future hazard events, using maps where appropriate … .

Explanation:

The plan shall provide an overview of the location of all natural hazards
that can affect the State. The plan should describe the geographic
boundaries in the State that would be affected by these hazards.
Where appropriate, the hazard analysis should also broadly identify on a
map the areas of the State affected by each hazard, noting those areas
most severely affected by each hazard. A composite map (i.e., a map
showing combined information from different thematic map layers) can be
provided for hazards that have a recognizable geographic boundary (i.e.,
hazards that are known to occur in particular areas of the State), such as
floods, coastal storms, wildfires, tsunamis, and landslides.
For those hazards that are not geographically determined, plans should
indicate their probable intensity. For example, for areas where tornadoes
occur, plans should indicate the recorded intensities of previous events.
The plan shall also provide a discussion of past hazard events. This
discussion should include:
ƒ

Information on the damages that occurred (e.g., costs of recovery,
property damage, and lives lost) to the extent practicable.

ƒ

Level of severity (i.e., flood depth or extent, wind speeds, earthquake
intensity).

ƒ

Duration of event.

ƒ

Date of occurrence.

ƒ

Sources of information used or consulted for assembling a history of
past occurrences.

The plan shall also include information on the probability of future
hazard events. In addition, it should describe the analysis or sources
used to determine the probability and their magnitudes.
The plan should also describe conditions (i.e., topography, soil
characteristics, meteorological conditions, etc.) in the planning area that
mitigate the hazard effects or make the area more vulnerable to hazards.

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PART 1 – STANDARD STATE MITIGATION PLANS
Plan Update:

The plan update must continue to include occurrences of hazards
profiled in the previous plan, and discuss new occurrences of hazard
events. The updated plan must incorporate any new studies or technical
information related to profiling hazards, such as new National Flood
Insurance Program maps or studies, HAZUS studies, or reports from
other Federal or State agencies that relate to:
•
•
•

Location of natural hazards;
Past hazard events;
Probability of future hazard events.

While maps are not required, any maps included in the updated plan
must be consistent with the updated information.
Resource:

For more information on profiling hazards, see:
9 Understanding Your Risks (FEMA 386-2), Step 2.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 HAZUS MH http://www.fema.gov/plan/prevent/hazus/

Examples:
Original Submittal:
[For illustrative purposes, only the flood hazard is profiled in this
example.]
Through analysis of existing Federal Flood Insurance Rate Maps (FIRMs)
and Flood Insurance Studies (FISs), the Hazard Mitigation Committee
(HMC) determined that every County in the State may be affected by the
flooding hazard. A variety of factors affect the type and severity of
flooding throughout the State, including topography, urban development
and infrastructure, and proximity to the coastline.
The State has been affected by a number of floods over the past several
years. Most notably, Hurricane Young in 1997 caused flooding that
generated a Presidential Disaster Declaration for the Counties of
Allwater, Bedlam, Calm-before-the-Storm, and Turmoil. The flood caused
several million dollars in damages.

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PART 1 – STANDARD STATE MITIGATION PLANS
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(2)(i)

REVIEWER’S COMMENTS

ƒ
ƒ
ƒ
ƒ

ƒ
ƒ

The plan did not include the location
of the type of floods.
The history of floods is only of recent
years.
The plan does not discuss
probability.
The State did not provide details
about conditions, such as
topography, that could make areas
more or less vulnerable to each
hazard.
There is no indication of areas of the
State that are more severely affected
by each hazard.
The State did not provide a map that
identified the areas affected by each
hazard.

Required Revisions:
For a “Satisfactory” score, the plan must describe the hazard areas,
provide a more complete history of past events, and include the
probability of future hazard events. While not required by the Rule, the
plan should also document the process used to determine differences in
vulnerability to the hazard; differentiate the ways in which areas of the
State are affected; and provide a map or other tool to delineate hazard
areas.
Revised Submittal:
Flooding
Through analysis of existing Federal Flood Insurance Rate Maps
(FIRMs) and Flood Insurance Studies (FISs), the Hazard Mitigation
Committee (HMC) determined that every County in the State may be
affected by the riverine flooding hazard (see Flood Hazard Map in
Appendix XX). The State regularly experiences 10-year floods and
has on several instances suffered the devastating effects of 500year floods. See Appendix XX for a history of floods and their
related damages dating back to 1850. This history was assembled
from the information provided in local hazard mitigation plans as
well as the previous State Hazard Mitigation Plan.
The probability of a flood event is expressed as the percent chance
that a flood of a specific magnitude will occur in any given year.
Table 1 summarizes the associated chance of occurrence for the
type of floods the State has experienced.
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PART 1 – STANDARD STATE MITIGATION PLANS

Table 1: Flood Probability of Occurrence
Flood Return
Intervals

Chance of
Occurrence in Any
Given Year

10-Year

10%

50-Year

2%

100-Year

1%

500-Year

0.2%

The State has been affected by a number of floods over the past several
years. Most notably, Hurricane Young in 1997 caused flooding that
generated a Presidential Disaster Declaration for the Counties of
Allwater, Bedlam, Calm-before-the-Storm, and Turmoil. The flood caused
several million dollars in damages.
A variety of factors affect the type and severity of flooding throughout the
State, including topography, urban development and infrastructure, and
proximity to the coastline.
Riverine Flooding
Mountain Region (Allwater, Bedlam, Calm-before-the-Storm, and
Turmoil Counties)
Flooding in the Mountain Region is characterized by high-velocity
waters flowing to the valleys. During heavy rains from storm
systems, including severe thunderstorms and tropical storms,
water flows down from the mountain, collecting in, then
overtopping, valley streams and rivers. The steep slopes of the
region induce high velocities as the water flows downhill and
downstream, in many cases producing flash flooding conditions.
Because some towns in the Mountain Region have the majority of
the corporate limits located in the valley and, therefore, often in the
floodplain, flood waters have the potential to affect or even severely
harm whole towns. Because of the steep topography, developable
areas of the town are within the 100-year floodplain, and some are
affected by 10- and 50-year floods. These conditions, especially in
areas where flash floods are a problem, make response operations
and evacuation very difficult, adversely affecting the safety of the
residents.
These flash flooding response and evacuation problems were
illustrated in Bedlam County during the summer of 1999. The
passage of Tropical Storm Zoe created flash flooding in the towns
of Chaos and Pandemonium. While the floodwaters only reached an
estimated 10-year flood elevation, the sudden onset of the flood
and swift waters did not allow warning to the residents and,
consequently, a driver attempting to drive through waters that had
overtopped a secondary road was swept away by the waters.
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PART 1 – STANDARD STATE MITIGATION PLANS
Furthermore, about 10 homes in Chaos and 15 homes in
Pandemonium were flooded, creating an estimated $100,000 in
damages (see Appendix XX for a detailed history of floods in this
area).

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PART 1 – STANDARD STATE MITIGATION PLANS
ASSESSING VULNERABILITY BY JURISDICTION
Requirement
§201.4(c)(2)(ii):

[The State risk assessment shall include an] overview and analysis of the
State’s vulnerability to the hazards described in this paragraph (c)(2),
based on estimates provided in local risk assessments … . The State
shall describe vulnerability in terms of the jurisdictions most threatened
by the identified hazards, and most vulnerable to damage and loss
associated with hazard events … .

Update:

§201.4(d):

Plan must be reviewed and revised to reflect changes in
development…

Explanation:

The plan shall describe which jurisdictions are most threatened and
vulnerable to hazards and the process used to identify them.
Identification of these jurisdictions shall be based on an analysis of
available local risk assessments conducted throughout the State, and
where not available, on State risk assessments.

Plan Update:

The State shall describe any changes, clarifications, or refinements to
the previous overview of the State’s vulnerability resulting from any new
or updated data, as well as information generated through local mitigation
plans.
The update must explain the process used to analyze information from
the local risk assessments and adjust the statewide risk assessment, as
necessary. Recognizing the differences in local risk assessments,
information from local mitigation plans allows the State to better
understand or describe its vulnerability in terms of the jurisdictions most
threatened by natural hazards. However, the update should not attempt
to include the details provided in every local mitigation plan.
Recognizing that statewide vulnerability may not change much in any
given three-year update cycle, this section provides an opportunity to
anticipate future risk. The State must consider in its assessment, for
jurisdictions in hazard prone areas, changes in development that may
impact vulnerability such as:
•
•
•

Significant population increases and shifts in population to
vulnerable areas;
A concentration or changes in land use or land use activities in
vulnerable areas; and/or
Implementation of mitigation actions that have reduced
vulnerability.

Taking into account that some previously approved local plans included a
general overview of land uses and development trends, it is up to the
State to describe jurisdictions most threatened and vulnerable to damage
and losses associated with hazard event based on such factors as:
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PART 1 – STANDARD STATE MITIGATION PLANS
o
o

The review and incorporation of development trends provided in
local mitigation plans; and,
Statewide population growth estimates, projections, and land use
data.

The State determines the level of detail provided in the updated plan but
it must demonstrate that land uses, development trends, and population
were assessed to obtain a statewide picture of changes to vulnerability.
This information can be presented generally or specifically, using text,
graphics, maps, or a combination of these methods.
In most cases, changes in population and anticipated development
trends are tracked by one or more State agencies as well as Regional or
Metropolitan Planning Organizations. Expected development patterns
may also be described in other State plans, such as Operation Plans and
Land Development Plans, or in functional plans, like transportation and
economic development plans. These agencies, organizations, and plan
documents can provide valuable information to indicate where growth is
likely to occur in the future.

Resource:

For an explanation on ways to determine what areas are the most
vulnerable to damage and loss, see:
9

Understanding Your Risks (FEMA 386-2), Steps 3 and 4.

9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 HAZUS MH http://www.fema.gov/plan/prevent/hazus/
Examples:
Original Submittal:
[For illustrative purposes, only the flood hazard vulnerability is included in
this example.]
Flood Hazard Vulnerability
As development has increased in and along floodplains, urban and
suburban areas of the State have been increasingly impacted by flash
flooding and flooding along streams and rivers. Across the State, an
estimated 1.5 million people live within areas designated as 100-year
floodplains.

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PART 1 – STANDARD STATE MITIGATION PLANS
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(2)
(ii)

REVIEWER’S COMMENTS

ƒ

The plan did not differentiate areas of
the State that have greater vulnerability
to flooding than others.

Required Revisions:
For a “Satisfactory” score, the plan must detail the factors determining
vulnerability to the State. While not required by the Rule, the plan should
provide information at the local/County level to the extent possible,
allowing the State to contrast areas of higher and lower vulnerability.
Revised Submittal:
Flood Hazard Vulnerability
As development has increased in and along floodplains, urban and
suburban areas of the State have been increasingly impacted by flash
flooding and flooding along streams and rivers. Across the State, an
estimated 1.5 million people live within areas designated as 100-year
floodplains.
The State Department of the Environment used GIS technology to
overlay aerial photographs with the 100-year floodplain. The
Department determined that some Counties have a higher
percentage of structures located within the 100-year floodplain, and
therefore have a higher vulnerability to the flooding hazard than
other Counties. In addition, using FIRMs, FISs, and topographic
mapping, the Department identified areas where steep slopes could
increase flood velocity. By reviewing the flood hazard assessments
provided in local mitigation plans (including FMA and CRS plans),
the HMC identified exacerbating circumstances that may lead to
greater flood vulnerability, including stormwater management
issues and a high percentage of impervious surfaces in or near the
floodplain. A detailed analysis of the flood hazard and related map
are provided for each County of the State in Appendix XX. The
following table summarizes flood attributes by County.

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PART 1 – STANDARD STATE MITIGATION PLANS

No. of Critical
Facilities
Affected

Assessed
Relative
Vulnerability

Estimated No. of
People Affected

Impervious
Surfaces2

Stormwater
Management
1
Issues

Steep Slopes/High
Velocity Water

% of Structures in
Floodplain

County

Table XX: Flood Vulnerability by County

Allwater

50%

z

12,000

H

4

Bedlam

4%

z

1,000

L

1

Calmbeforethe-Storm

10%

z

3,000

M

3

Turmoil

1%

2,000

M

1

z

15%

1

Stormwater Management Issues encompass assessments by local governments, such as debris in
stormwater collectors, culvert sizes, etc. that lead to increased localized flooding during heavy rains.

2

Impervious Surfaces describe the percentage of acres of paved surfaces in or near floodplains.

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PART 1 – STANDARD STATE MITIGATION PLANS
ASSESSING VULNERABILITY OF STATE FACILITIES
Requirement
§201.4(c)(2)(ii):

[The State risk assessment shall include an overview and analysis of the
State’s vulnerability to the hazards described in this paragraph (c)(2),
based on estimates provided in] the State risk assessment. … State
owned critical or operated facilities located in the identified hazard areas
shall also be addressed … .

Explanation:

The plan shall describe the State-owned or operated buildings,
infrastructure, and critical facilities located in areas subject to hazards
described previously. The description should include the uses,
approximate sizes, types, and values of buildings, infrastructure, and
critical facilities.

Plan Update:

Resource:

The State shall update the overview and analysis of vulnerable State
owned or operated buildings, critical facilities, and infrastructure, based
on available data. The update should reflect acquisition or development
of new properties and infrastructure.
For an explanation on ways to determine what areas are at risk and
vulnerable, see:
9 Understanding Your Risks (FEMA 386-2), Steps 3 and 4.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 HAZUS MH http://www.fema.gov/plan/prevent/hazus/

Examples:
Original Submittal:
Vulnerable State Facilities
Using FIRMs, the Hazard Mitigation Committee (HMC) ascertained that
three State facilities are located in the floodplain.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.4(c)(2)
(ii)

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M I T I G A T I O N

REVIEWER’S COMMENTS

ƒ

The plan does not provide an analysis
of the vulnerability of these facilities in
the floodplain.

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Required Revisions:
For a “Satisfactory” score, the plan must document the process by which
the State developed its vulnerability assessment for State facilities and
also provide enough detail of the findings to make the relative
vulnerability of the structures evident. While not required by the Rule, the
analysis should include an assessment of the facilities’ first floor
elevations in relation to the base flood elevation, an indication of the
value of the buildings and contents, and a description of the buildings’
functions and how the buildings’ functions would be compromised if
flooded.
Revised Submittal:
Vulnerable Vulnerability of State Facilities to Flooding
Using FIRMs, the Hazard Mitigation Committee (HMC) ascertained that
three State facilities are located in the floodplain.
At the request of the Hazard Mitigation Committee (HMC), surveyors
and engineers from the State Department of the Environment and
the Department of Public Works conducted site assessments of all
State facilities located within the 100-year floodplain to determine
their vulnerability to flooding. First floor elevations, construction
types, square footages, content types, and approximate value of the
structures and contents were documented for each facility. The
table below summarizes these findings, including the location,
function, approximate value of the structure and its contents, and
the number of feet above or below base flood elevation.
Approximate values of structure and contents were estimated using
the judgment of the facilities managers of the respective structures
and following the guidelines detailed in the FEMA document,
Understanding Your Risks: Identifying Hazards and Estimating
Losses, Step 4. A detailed list of these findings can be found in
Appendix XX.

Approx.
Value of
Structure

Approx.
Value of
Contents

First Floor
Elevation
Above (+)
or Below
(-) BFE

Critical
Facility

Allwater

Offices

250

$1M

$1M

+5

z

Bedlam

State Emergency
Operations
Center

50

$1M

$1.5M

+3

z

Calmbeforethe-Storm

Warehouse/Gara
ge for Snow
Removal
Equipment

15

$1M

$1.5M

-2

z

County

Function

No. of
Affected
State
Employees

Table XX: State Facilities in the 100-Year Floodplain

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PART 1 – STANDARD STATE MITIGATION PLANS
ESTIMATING POTENTIAL LOSSES BY JURISDICTION
Requirement
§201.4(c)(2)(iii):

[The State risk assessment shall include an] overview and analysis of
potential losses to identified vulnerable structures, based on estimates
provided in local risk assessments … .

Update:

§201.4(d):

Plan must be reviewed and revised to reflect changes in development…

Explanation:

This requires States to incorporate the findings of local jurisdiction loss
estimates in the State plan. The plan shall describe the distribution of
losses across the State and should include specific reference to
quantifying losses to local critical facilities.

Plan Update:
The State shall incorporate any changes, clarifications, or refinements,
obtained from State-wide or local loss estimates. Recognizing the
differences in local risk assessments, information from local mitigation
plans allows the State to better understand or describe its vulnerability in
terms of the potential losses. However, the update should not attempt to
include the details provided in every local mitigation plan.
Comparable to the estimating vulnerability by jurisdiction, the state must
consider changes in development that may affect the statewide loss
estimates.
Special
Considerations:

Although the Rule requires that States only analyze losses to structures,
States are highly encouraged to analyze the potential economic and
human impact each hazard would have statewide.

Resource:

For more information on assessing vulnerability/estimating losses, see:
9 Understanding Your Risks (FEMA 386-2), Step 4.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 HAZUS MH http://www.fema.gov/plan/prevent/hazus/. FEMA has
developed the HAZUS-MH Risk Assessment Tool (RAT) to help
produce risk assessment outputs for earthquakes, floods, and
hurricanes. The summaries can support the presentation of data to
decision-makers and other stakeholders and can be used in the risk
assessment section of the mitigation plan.

Examples:
Original Submittal:
[For illustrative purposes, only the flood hazard is discussed.]
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PART 1 – STANDARD STATE MITIGATION PLANS
Flood Vulnerability
Across the State, an estimated 150,000 people and 40,000 structures are
located within the boundaries of the 100-year floodplain, putting at risk
the State’s revenue of $1 billion.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN
THE PLAN

§201.4(c)(2)
(iii)

REVIEWER’S COMMENTS

ƒ
ƒ

The plan does not describe the State’s
potential losses.
The plan does not explain how the State
developed the loss figures.

Required Revisions:
To receive a “Satisfactory” score, the plan must provide an overview and
analysis of losses to local jurisdictions. While not required by the Rule,
the plan should also document how it developed its loss estimations and
include information to assess relative losses across the State.
Revised Submittal:
Flood Vulnerability Potential Flood Losses by Jurisdiction
Across the State, an estimated 150,000 people and 40,000 structures
are located within the boundaries of the 100-year floodplain, putting at
risk the State’s revenue of $1 billion.
The table below represents the estimated losses to residential,
commercial, and critical facilities and buildings by County. The
estimates were taken from local hazard mitigation plans and are
added to provide an estimated total State loss for each category.
Except for Allwater County, which has not updated its plan, each
county determined losses using the procedures explained in the
FEMA document, Understanding Your Risks: Identifying Hazards
and Estimating Losses. The process used by the Hazard
Mitigation Committee (HMC) for determining Allwater County’s
potential losses is explained in the table’s footnote.

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PART 1 – STANDARD STATE MITIGATION PLANS
Estimated
Residential
Losses (in
Millions)

Estimated
Commercial
Losses (in
Millions)

Estimated
Losses to
Critical
Facilities (in
Millions)

Relative
Losses (in
Millions)

Allwater*

$75.0

$2.4

$2.0

H

Bedlam

$ 0.3

$0.1

$0.1

L

Calm-beforethe-Storm

$ 6.5

$ 3.0

$1.0

H

Turmoil

$2.2

$1.5

$0.5

M

Total Losses to
State

$84.0

$ 7.0

$3.6

94.6

County

* Because Allwater County has not yet submitted a plan that estimates losses to
residential, commercial, and critical facilities, all figures for this County were estimated
by multiplying the percentage of structures in the floodplain (50% of all structures) with
County economic data included in State demographic and tax information.
Estimated Residential Losses = 50% x No. of residences x median housing value.
Estimated Commercial Losses = 50% x No. of businesses x median building value x
median business revenue.
Estimated Critical Facilities = 50% x No. of police and fire stations, hospitals, schools x
median estimated losses to critical facilities of all other counties.
This method is not an accurate measure of vulnerability because depth of flooding for
each structure in the floodplain was not assessed.

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PART 1 – STANDARD STATE MITIGATION PLANS
ESTIMATING POTENTIAL LOSSES OF STATE FACILITIES
Requirement
§201.4(c)(2)(iii):

[The State risk assessment shall include an overview and analysis of
potential losses to identified vulnerable structures, based on estimates
provided in] the State risk assessment. The State shall estimate the
potential dollar losses to State-owned or operated buildings,
infrastructure, and critical facilities located in the identified hazard areas.

Explanation:

This requires States to estimate losses to State-owned or operated
facilities and infrastructure. The plan shall describe the distribution of
losses across the State, with specific reference to quantifying losses to
critical facilities.
States should also describe their approach for determining losses for
State-owned infrastructure and buildings.

Plan Update:

If there are changes to the hazard profile and/or to the State facilities and
infrastructure as described under Assessing Vulnerability of State
Facilities, this section must be updated to reflect potential losses to
identified vulnerable structures and infrastructure. If the approach for
determining these losses has changed since the first approval, the plan
should describe the new methodology.

Resource:

For more information on assessing vulnerability/estimating losses, see:
9

Understanding Your Risks (FEMA 386-2), Step 4.

9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 HAZUS MH http://www.fema.gov/plan/prevent/hazus/. FEMA has
developed the HAZUS-MH Risk Assessment Tool (RAT) to help
produce risk assessment outputs for earthquakes, floods, and
hurricanes. The summaries can support the presentation of data to
decision-makers and other stakeholders and can be used in the risk
assessment section of the mitigation plan.
Examples:
Original Submittal:
Vulnerability of State Facilities to Flood
Using FIRMs, the Hazard Mitigation Committee (HMC) ascertained that
three State facilities are located in the floodplain.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.4(c)(2)
(iii)
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M I T I G A T I O N

REVIEWER’S COMMENTS

ƒ

The plan does not discuss the actual
vulnerability and potential losses to the
facilities in the floodplains.

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PART 1 – STANDARD STATE MITIGATION PLANS
Required Revisions:
The plan must make clear the potential losses to State facilities and
infrastructure. These losses should be estimated as a function of the
vulnerability to the hazard (here, flood depth), with potential losses
calculated based on the estimated value of the structure.
Revised Submittal:
Vulnerability of State Facilities to Flood Potential Flood Losses to State
Facilities
Using FIRMs, the (Hazard Mitigation Committee) (HMC) ascertained that
three State facilities are located in the floodplain.

Approx. Value of
Structure

Approx. Value of
Contents

First Floor
Elevation Above (+)
or Below (-) BFE*

Estimated % Loss
to Structure

Estimated % Loss
to Contents

Estimated Structure
Losses

Estimated Content
Losses

Relative Losses

$1M

$1M

+5

0%

0%

$0

$0

L

1

$1M

$1M

+3

0%

0%

$0

$0

L

1

$1M

$1.5
M

-2

13%

19.5%

$130K

$292.5K

H

$130K

$292.5K

No. of Critical
Facility

Function

Location of State
Facility

Using the procedure detailed in the FEMA document, Understanding
Your Risks, to determine the estimated percentage loss to structure
and contents, the HMC determined that the warehouse/garage
housing snow removal supplies and equipment was the only critical
facility in the floodplain that would suffer damages in a 100-year flood
event. The facility would suffer approximately $422,500 in losses to
the structure and its contents.

Allwater

Offices

Bedlam

State Emergency
Operations Ctr.

Calm-beforethe-Storm

Warehouse/
Garage for Snow
Removal Equipment

Total Losses to
State Critical
Facilities
*BFE: Based Flood Elevation

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PART 1 – STANDARD STATE MITIGATION PLANS
MITIGATION

STRATEGY

According to §201.4(c)(3) the plan must include a mitigation strategy that provides the State’s
blueprint for reducing the losses identified in the risk assessment. The strategy shall include
goals that are based on the risk assessment and that should be consistent with goals from other
State and local jurisdictions’ plans and policies. While not required by the Rule, objectives could
also be included to define strategies or steps to achieve the identified goals. These goals and
objectives will guide the State’s strategies and selection of actions to achieve the desired, longterm hazard protection. The State must also assess its own as well as its local jurisdictions’
capabilities to staff programs or projects and fund actions to achieve the goals of the plan. The
State must also identify funding from Federal, local, and private sources to complement its own
resources.
Section 201.4(d) requires that plans be reviewed and revised to reflect progress in statewide
mitigation efforts and changes in priorities. This is reflected in the guidance language under
§201.4(c)(3)(i) and §201.4(c)(3)(iii). Fundamental to the mitigation strategy update is the
demonstration that progress has been made to implement the mitigation strategy identified in
the previously approved plan. The updated mitigation strategy provides an opportunity for the
State to discuss efforts to ensure consistency between the goals and objectives of the State
plan, and those of the local plans that have been approved.
This section includes the following five subsections:
ƒ

Hazard Mitigation Goals

ƒ

State Capability Assessment

ƒ

Local Capability Assessment

ƒ

Mitigation Actions

ƒ

Funding Sources

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PART 1 – STANDARD STATE MITIGATION PLANS
HAZARD MITIGATION GOALS
Requirement
§201.4(c)(3)(i):

[The State mitigation strategy shall include a] description of State goals to
guide the selection of activities to mitigate and reduce potential losses.

Update:

[The] plan must be reviewed and revised to reflect changes in
development, progress in statewide mitigation efforts and changes
in priorities…

§201.4(d):
Explanation:

The State’s goals as written in the plan reflect the State’s vision for longterm hazard mitigation and loss reduction. This section should describe
how the plan’s goals were developed.
These goals, along with their corresponding objectives, guide the
development and implementation of mitigation actions. Although the Rule
does not require a description of objectives, States are highly
encouraged to include a description of the objectives developed to
achieve the goals so that reviewers understand the connection between
goals, objectives, and actions.
The goals and objectives should:

Plan Update:

ƒ

Be based on the findings of the local and State risk assessments.

ƒ

Represent a long-term vision for hazard reduction or enhancement of
mitigation capabilities.

The plan update provides an opportunity for the State to reconsider the
goals and objectives adopted in the previously approved plan to guide
the selection of activities to mitigate and reduce potential losses. Goals
may be reaffirmed or updated based on more current information,
including updated or new risk assessments or changes in State mitigation
priorities. It is not necessary to change previous goals if they remain
valid but the plan must demonstrate that State goals were assessed and
that they still remain valid.
If the previously approved plan included objectives, the updated plan
should point out which objectives have been met and identify new
objectives.

Resources:

For more information on identifying and refining the State’s mitigation
goals and objectives, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 1.

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PART 1 – STANDARD STATE MITIGATION PLANS
Special
Considerations:

Goals are general guidelines that explain what you want to achieve.
They are usually long-term and represent global visions such as
“eliminate flood damage.”
Objectives define strategies or implementation steps to attain the
identified goals. Unlike goals, objectives are specific, measurable, and
may have a defined completion date. Objectives are more specific, such
as “upgrade State building code to meet the provisions of the National
Earthquake Hazards Reduction Program.”
(From Developing the Mitigation Plan (FEMA 386-3), Step 1.)

Examples:
Original Submittal:
The Hazard Mitigation Committee (HMC) identified the following goals for
the plan:
Goal 1: Document the hazards and vulnerabilities in the State.
Goal 2: Identify priority mitigation projects to fund.
Goal 3: Raise awareness of hazards and mitigation actions in the State.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(3)
(i)

REVIEWER’S COMMENTS

ƒ
ƒ

Goals 1 and 2 are what is to be
accomplished by the planning process.
No explanation is provided for how the
goals were developed.

Required Revisions:
To receive a “Satisfactory” score, the plan must tie the goals to the risk
assessment findings.
Revised Submittal:
The Hazard Mitigation Committee (HMC) identified the following goals for
the plan:
Goal 1: Document the hazards and vulnerabilities in the State.
Goal 2: Identify priority mitigation projects to fund.
Goal 3: Raise awareness of hazards and mitigation actions in the State.
The Hazard Mitigation Committee (HMC) participated in a 2-day
workshop to review the risk assessment findings and develop the
mitigation goals and objectives for the Hazard Mitigation Plan. The
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PART 1 – STANDARD STATE MITIGATION PLANS
risk assessment identified the following problems:
ƒ

Local communities in the State were unaware of the types of
assistance available to them for hazard mitigation planning.

ƒ

The State Division of Emergency Management often did not
coordinate with local communities or other State agencies in
hazard mitigation planning.

ƒ

Many State residents did not realize hazard mitigation planning
was occurring in their area.

ƒ

The State would benefit from incorporating GIS and other
technical information into their hazard mitigation planning
process.

ƒ

The State has one of the highest numbers of repetitive loss
properties in the country.

At the end of this session, the HMC identified the following goals,
objectives, and actions for the State of Emergency’s mitigation
strategy to address these issues.
Goal 1: Strengthen the Division of Emergency Management’s
capability and its coordination with other State agencies to reduce
hazard vulnerabilities throughout the State.
Goal 2: Increase technical assistance to and coordination with local
jurisdictions to build local capacity to further reduce vulnerabilities
at the local level.
Goal 3: Build public awareness of proven, cost-effective mitigation
actions.
Goal 4: Formulate strategies using state-of-the-art knowledge to
reduce vulnerabilities for identified hazards.
Goal 5: Reduce the number of repetitive loss structures by 50%.
(For the purposes of this example, the following description applies to all
hazards. For illustrative purposes, only one goal will be described in more
detail.)
Goal 2: Increase technical assistance to and coordination with local
jurisdictions to build local capacity to further reduce vulnerabilities
at the local level.
Objectives 2.1: The State will work with local communities to
improve their hazard mitigation planning process.
Short Term Action 2.2.1:
Note: “short term” is defined as those actions which agencies are
capable of implementing within their existing resources and
authorities in the current fiscal cycle.
Improve hazard mitigation technical assistance for local
governments.
Lead Agency: State Office of Emergency Management
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PART 1 – STANDARD STATE MITIGATION PLANS
Support Agency: State Department of the Environment
Timeline: 1 year
Resources: 1 Full Time Employee
Long Term Action 2.2.2:
Note: “long term” is defined as those actions which will require new
or additional resources or authorities to implement, and those
actions which cannot occur during the current fiscal cycle.
The State will develop and distribute local hazard mitigation
planning guidance.
Lead Agency: State Office of Planning
Support Agency: State Office of Emergency Management
Timeline: 3 years
Resources: 2 Full Time Employees

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PART 1 – STANDARD STATE MITIGATION PLANS
STATE CAPABILITY ASSESSMENT
Requirement
§201.4(c)(3)(ii):

Explanation:

[The State mitigation strategy shall include a] discussion of the State’s
pre-and post-disaster hazard management policies, programs, and
capabilities to mitigate the hazards in the area, including:
ƒ

an evaluation of State laws, regulations, policies, and programs
related to hazard mitigation as well as to development in hazardprone areas [and]

ƒ

a discussion of State funding capabilities for hazard mitigation
projects … .

The State shall include a discussion of its financial, legal, and
programmatic ability to carry out mitigation actions in the pre-and postdisaster setting to achieve its mitigation objectives and, ultimately, its
goals. The mitigation strategy should not only address the ways the
State’s existing capabilities can aid the mitigation effort, but also address
areas in which the State needs to strengthen its capabilities. Without an
assessment of the State’s capability, implementation of the plan could
stall from inadequate resources.
The State shall conduct an evaluation of State laws, regulations, policies,
and programs related to hazard mitigation as well as to development in
hazard-prone areas. The State should discuss existing and emerging
State policies and programs for both pre- and post-disaster mitigation.
The discussions should include: implementation opportunities and
problems (e.g., financial/staffing resources, lack of informed public, nonmandated improvements, etc.), opportunities for improving State
capabilities, conflicts created by public investment policies (e.g., policies
that have promoted public investment in hazard-prone areas), and
problems created by private development projects in hazard-prone areas.
The State should highlight implementation tools, policies, and programs
that have proven to be effective in achieving mitigation objectives (e.g.,
planning legislation requiring integration of mitigation actions in
comprehensive plans). The State should also identify those laws,
regulations, and policies that can be amended to integrate mitigation
actions or to remove provisions that hinder mitigation efforts.
The State shall describe its assessment of its funding capabilities for
hazard mitigation projects. The discussion should include positive
aspects, as well as problems encountered, and identify areas where the
State needs to seek outside funding sources.

Plan Update:

The plan update provides an opportunity for the State to re-evaluate its
pre- and post-disaster hazard management policies, programs, and
capabilities. The plan update must address any hazard management
capabilities of the State that have changed since approval of the previous
plan.
The State shall also provide an updated assessment of its funding
capabilities for hazard mitigation projects.

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PART 1 – STANDARD STATE MITIGATION PLANS
In the previously approved plan, the State may have identified laws,
regulations and policies that could be amended to integrate mitigation
actions or to remove provisions that hinder mitigation efforts. Where
applicable, the updated plan should describe progress in modifying these
policies and legislation or identify where opportunities for integration still
remain.
Resource:

For tips for assessing mitigation capabilities, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 2.

Examples:
Original Submittal:
The State Mitigation Plan has identified those pre- and post-disaster
State regulations, policies, and programs related to hazard mitigation.
For example, a major hazard the State faces is flooding. The State has
taken steps to become more proactive in its approach to flood hazard
mitigation planning. The Emergency Management Agency has instituted
the Comprehensive Flood Management Grant Program and Repetitive
Loss Project, while the State Department of the Environment has
instituted the Technical Assistance Program. These programs are geared
towards providing mitigation planning assistance to communities in the
State.
The State has many funding programs in place which are available to
municipalities that need assistance. These funds are primarily from
various Federal grant programs.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.4(c)(3)
(ii)

REVIEWER’S COMMENTS

ƒ
ƒ
ƒ
ƒ
ƒ

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The plan does not evaluate the laws,
regulations, policies, and programs.
The discussion on funding is too
general and incomplete to address the
requirement.
The plan did not indicate how State
programs were identified or how they
were beneficial.
There are no regulatory reviews or
regulations indicated that might be
improved for mitigation purposes.
The plan does not discuss programs or
policies the State can use to improve
capabilities.

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PART 1 – STANDARD STATE MITIGATION PLANS
Required Revisions:
To receive a “Satisfactory” score, the plan must evaluate the State’s
capability to reduce losses and discuss in more detail the State’s funding
resources. While not required by the Rule, the plan should include what
effort was made to identify programs and policies under consideration,
including executive orders or new legislation needed to implement the
plan recommendations.
Revised Submittal:
The State Mitigation Plan has identified those pre- and post-disaster
State regulations, policies, and programs related to hazard mitigation. As
a result of this, the State Hazard Mitigation Committee (HMC) held
several meetings with various State Agencies. Those programs
selected as most beneficial are described as follows.
For example, a major hazard the State faces is flooding. The State has
taken steps to become more proactive in its approach to flood hazard
mitigation planning. The Emergency Management Agency has instituted
the Comprehensive Flood Management Grant Program and Repetitive
Loss Project, while our State Department of the Environment has
instituted the Technical Assistance Program. These programs are geared
towards providing mitigation planning assistance to communities in the
State.
The State Emergency Management Agency identified the
Comprehensive Flood Management Grant Program and Repetitive
Loss Projects as the most beneficial programs. The Comprehensive
Flood Management Grant Program has allowed the State to assist
communities in all aspects of floodplain management, including the
development of local floodplain plans, the provision of funding for
various flood control and watershed studies, and the acquisition of
flood-prone properties. The Repetitive Loss Project uses GIS
software to map repetitive loss structures and areas in an effort to
determine which types of mitigation actions are most appropriate.
The State Department of the Environment indicated that the
Technical Assistance Program has been very beneficial. The
Technical Assistance Program provides help to communities on a
variety of topics and acts as a clearinghouse for information on
mitigation planning, including such things as providing guidance on
the planning process and funding sources available to
communities.
The State has many funding programs in place which are available to
municipalities that need assistance. These funds are primarily from
various Federal grant programs. Currently, the State uses HMGP,
FMA, and Community Development Block Grants (CDBG) funds to
promote mitigation activities. The State supplements these sources
with funding from its State Office for Mitigation Funding and
partnerships with the private sector (see Table XX for a list of
projects funded by these programs).
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PART 1 – STANDARD STATE MITIGATION PLANS
The State Legislature recently passed the State Resource Protection
and Hazard Mitigation Planning Act. This act gives the State the
authority to make certain that State government activities are
consistent with the policies of the State Mitigation Plan. Although
this is a new act and agencies are just beginning to implement it, it
is expected to have a significant positive impact on hazard
mitigation planning within the State (see Section XX, Goals, for
more details on the expected results of this act).

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PART 1 – STANDARD STATE MITIGATION PLANS
LOCAL CAPABILITY ASSESSMENT
Requirement
§201.4(c)(3)(ii):

[The State mitigation strategy shall include] a general description and
analysis of the effectiveness of local mitigation policies, programs, and
capabilities.

Explanation:

The plan shall include a general description of local mitigation policies,
programs, and capabilities. The State shall also describe how local preand post-disaster mitigation policies, programs, and capabilities, such as
building codes, zoning, or land use policies, were evaluated to determine
their effectiveness. This should include existing and emerging
capabilities. The description can be kept general and does not need to be
detailed for all localities.
The State should include in its description the following: implementation
opportunities and problems (e.g., financial /staffing resources, lack of
informed public, non-mandated improvements, etc.), opportunities for
building local capabilities, and problems created by public investment
policies (e.g., policies that may have inadvertently promoted public
investments in hazard-prone areas). The State should highlight local
implementation tools, policies, and programs that have proven to be
effective in achieving mitigation objectives (e.g., adoption of planning
legislation requiring integration of mitigation actions in comprehensive
plans).

Plan Update:

The updated plan shall include an updated general description and
analysis of the effectiveness of current local mitigation policies,
programs, and capabilities.

Resource:

For tips on how to assess mitigation capabilities, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 2.

Examples:
Original Submittal:
The State has a history of being a strong property rights State. Therefore,
local governments have taken a longer time implementing some hazard
mitigation actions. The State, however, has provided guidance to the
local communities.
The mitigation actions most local governments already have in place are
zoning regulations and building codes. Many local governments are
currently working on adopting the most recent International Building Code
(IBC) and rewriting their zoning regulations so they have more “teeth” to
them to allow enforcement of the regulations.
New approaches that local governments are working on, with help from
the State, are restrictive zoning, capital improvements planning, land use
planning, and subdivision regulations. It is believed that local hazard
mitigation will be more effective once these actions are implemented.
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PART 1 – STANDARD STATE MITIGATION PLANS
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(3)
(ii)

REVIEWER’S COMMENTS

ƒ
ƒ

The State did not identify why the
policies mentioned are believed to be
beneficial to hazard mitigation.
The State did not mention how they are
helping the local communities to adopt
the recommended policies.

Required Revisions:
To receive a “Satisfactory” score, the plan must include what effort was
made to assess the effectiveness of programs and policies under
consideration.
Revised Submittal:
The State Hazard Mitigation Committee (HMC) has been actively
working with its local governments to identify those actions most
effective for hazard mitigation planning. The State has a history of
being a strong property rights State. Therefore, local governments have
had a longer time implementing the hazard mitigation actions. but
support is growing for policies that will help with hazard mitigation.
Through working with local governments, the HMC has identified
policies currently in place and their effectiveness with hazard
mitigation. The HMC has also identified policies that local
communities are interested in adopting and how they can benefit
mitigation. The State, however, has provided guidance to the local
communities. The State does provide guidance to the communities
by providing model ordinances and example plans, and even has
funds available to communities interested in adopting hazard
mitigation actions.
The mitigation actions most local governments already have in place are
zoning regulations and building codes. Many local governments are
currently working on adopting the most recent International Building Code
(IBC) and rewriting their zoning regulations so they have more “teeth” to
them to allow enforcement of the regulations.
New approaches that local governments are working on, with help from
the State, are restrictive zoning, capital improvements planning, land use
planning, and subdivision regulations.
The existing and planned future policies of local governments are
indicated in the following table. It is believed that local hazard
mitigation will be more effective once these actions are implemented. It is
expected that their implementation will make local mitigation more
effective.

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PART 1 – STANDARD STATE MITIGATION PLANS
Existing Local Policies
Policy

Description

Applicability

Effectiveness

Building Codes

The State has adopted a
building code and local
governments are required to
adopt and enforce this code.

All structures built after 1999
comply with the new building
code, which includes special
provisions for building in the
floodplain.

Zoning

Laws and ordinances regulate
development by dividing the
community into zones and by
setting development criteria for
each zone.

The adoption and enforcement
of building codes relates the
design and construction of
structures to standards
established for withstanding
high winds and flooding.
Zoning can keep inappropriate
development out of hazardprone areas and can designate
certain areas for such things as
conservation, public use, or
agriculture. Zoning can also be
used to control construction by
dedicating areas for cluster
development or planned unit
development. The State is
currently working with local
governments on implementing
these last two policies.

Eight out of 12 counties have
passed open space ordinances
that have preserved over 20%
percent of hazard-prone and
environmentally sensitive areas
(wetlands, aquifer recharge
zones, and hillsides) in the
State. These ordinances are
based on local land use plans.

Future Planned Local Policies
Policy

Description

Applicability

Effectiveness

Land Use Planning

Comprehensive land use
planning provides a mechanism
to prevent development in
hazardous areas or allows
development in a manner that
minimizes damage from
hazards. Land use planning
gives local governments “the
big picture” of what is
happening in their jurisdiction.
Sets construction and location
standards for subdivision layout
and infrastructure.

Local governments can use
land use planning to identify
those areas subject to damage
from hazards and work to keep
inappropriate development out
of these areas. Land use
planning can also be used for a
more regional approach when
local governments work
together.
Contains standards for such
things as stormwater
management and erosion
control.

Under the new local planning
legislation, new development
can be minimized in identified
hazard areas.

Identifies where major public
expenditures will be made over
the next 5 to 10 years.

Capital Improvement Plans can
secure hazard-prone areas for
low risk uses, identify roads or
utilities that need
strengthening, replacement, or
realignment, and can prescribe
standards for the design and
construction of new facilities.

Subdivision
Regulations

Capital
Improvements
Planning

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New subdivisions in flood
hazard areas will be required to
cluster homes outside of the
floodplain, and will be given
more flexibility in using varied
densities within the subdivision.
Realigned utilities in highest
earthquake risk area.

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PART 1 – STANDARD STATE MITIGATION PLANS
MITIGATION ACTIONS
Requirement
§201.4(c)(3)(iii):

[The State plans shall include an] identification, evaluation, and
prioritization of cost-effective, environmentally sound, and technically
feasible mitigation actions and activities the State is considering and an
explanation of how each activity contributes to the overall mitigation
strategy. This section should be linked to local plans, where specific local
actions and projects are identified.

Update:

§201.4(d):

[The] plan must be reviewed and revised to reflect changes in
development, progress in statewide mitigation efforts and changes
in priorities….

Explanation:

Based on the risk assessment portion of the plan, the State shall include
in its statewide mitigation strategy actions it has identified through its
planning process as well as those actions identified in Local Plans. The
State should describe what agencies and interested parties were
involved in identifying priorities, how actions were evaluated, and how
such actions correspond to the plan’s mitigation goals and objectives.
Mitigation actions should be directly tied to goals and objectives and
provide the means to achieve them. Actions can be:
ƒ

Statewide or property specific.

ƒ

Regulatory or programmatic.

ƒ

Targeted at government agencies or private industry.

ƒ

Construction activities or public outreach.

Plan Update:
The updated plan must identify the completed, deleted, or deferred
actions or activities from the previously approved plan as a benchmark
for progress. Further, the updated plan shall include in its evaluation and
prioritization any new mitigation actions identified since the previous plan
was approved or through the plan update process.
If the mitigation actions or activities remain unchanged from the
previously approved plan, the updated plan must indicate why changes
are not necessary.
The system identified under §201.4 (c)(5)(ii) and (iii), plan maintenance,
will be useful in demonstrating progress in statewide mitigation efforts.
Resources:

For more information on evaluating mitigation actions, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 2.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 3.

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PART 1 – STANDARD STATE MITIGATION PLANS

Examples:
Original Submittal:
The State has compiled a list of mitigation projects, listed here by
jurisdiction.

State
Repetitive
Loss
Reduction
Program
Allwater
County
Bedlam
County

State
Coastal
Zone
Management
Program
State Earthquake
Hazard
Reduction
Program

Comprehensive loss
reduction program
involving acquisition,
elevation, relocation,
and floodproofing of
structures
Increase culvert size
and retrofit bridge
along State Highway
101
Conduct site visits to
determine appropriate
best practices for
mitigating flooding of
flood- prone historic
structures
Review existing plans
to determine
effectiveness/ success
of coastal erosion
policies
Update the State
Building code to the
recommended
provisions of the
National Earthquake
Hazards Reduction
Program and promote
local adoption

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Funding Source

Budget

Lead/Support
Agency

Hazard

Project
Description

Statewide or
County Specific

Mitigation Projects

Flooding

State Dept. of Emergency/
State Dept. of Public
Works/Local Planning
Agencies

$50 Million

PDM/ HMGP

Flooding

Allwater Dept. of Highway
and Safety/ State Dept. of
Emergency

$6 Million

PDM (multiple
grant application
cycles)

Flooding

Bedlam Dept. of Historic
Preservation/ Bedlam
Dept. of Env.

$35,000

Coastal
Erosion

State Dept. of Env./State
Dept. of Emergency

$150,000

Heritage Fund,
Association for
Historic
Preservation,
Bedlam Historic
Society
Existing budget

Earthquakes

State Dept. of Planning/
State Dept. of Emergency/
Local Planning Depts.

$100,000

Existing Budget

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PART 1 – STANDARD STATE MITIGATION PLANS
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(3)
(iii)

REVIEWER’S COMMENTS

ƒ
ƒ

The plan does not describe how these
projects were evaluated and selected.
There is no indication as to the priority
for implementing these projects.

Required Revisions:
To receive a “Satisfactory” score, the plan must describe the approach
used to evaluate and prioritize mitigation actions.
Revised Submittal:
The State has compiled a list of mitigation projects, listed here by
jurisdiction. The Hazard Mitigation Committee (HMC) hired a
consultant to assist the HMC to evaluate potential projects and
prepare a capital improvement plan for mitigation actions to be
carried out over the next 10 years. The consultant met with the
HMC to review projects identified in local plans and by the HMC.
The consultant gathered relevant structure information (e.g.,
replacement value, square footage, percent of damage to structure
likely, etc.) and relevant hazard information (e.g., probability of
occurrence, magnitude of the event at the project site, etc.) and
then analyzed the costs and benefits for each project to generate a
cost-benefit estimate. The summary of results is included in the
plan as Appendix XX. Each project was then judged against these
three criteria: cost-benefit ratios greater than 1 (all projects
receiving a cost-benefit ratio less than 1 were not considered for
Federal funding), social benefits (or least negative impacts) to the
communities, and environmental benefits (or least negative
impacts) to the communities. The table below summarizes the
HMC’s findings. In cases where the probabilities, costs, or benefits
were difficult to calculate due to lack of data, the HMC considered
the amount of damage from past occurrences or the geographical
extent of the hazard area, to assign a rank.
Projects that had additional considerations, such as historic,
environmental, or social value, while not meeting the economic
criteria, have been included and indicated in the Capital
Improvement Plan (CIP) with an asterisk. Funding for such projects
will be pursued from private sources and State and local funds
allocated whenever possible.
The State is focusing its mitigation efforts on reducing floodrelated losses as a result of flooding hazards causing the highest
losses of all the natural hazards in the state. One of its innovative
programs is the comprehensive Repetitive Loss Reduction
Program. The goal of this program is to reduce repetitive loss
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PART 1 – STANDARD STATE MITIGATION PLANS
properties by 50% within 10 years. The state has the highest
number of repetitive loss properties in the country. While the focus
of mitigation efforts is flooding, the State will continue to support
other hazard mitigation activities such as those under the
Earthquake Hazard Reduction Program.

State Earthquake
Hazard
Reduction
Pro-gram

State Dept. of
Emergency/
State Dept. of
Public
Works/Local
Planning
Agencies

$50 Million

PDM/ HMGP

+

L

L

H

Flooding

$6 Million

PDM (multiple
grant
application
cycles)

+

L

M

H

Conduct site
visits to
determine
appropriate best
practices for
mitigating
flooding of floodprone historic
structures
Review existing
plans to
determine
effectiveness/
success of
coastal erosion
policies
Update the State
Building code to
the
recommended
provisions of the
National
Earthquake
Hazards
Reduction
Program and
promote local
adoption

Flooding

Allwater Dept.
of Highway and
Safety/ State
Dept. of
Emergency
Bedlam Dept. of
Historic
Preservation/
Bedlam Dept. of
Env.

$35,000

Heritage Fund,
Association for
Historic
Preservation,
Bedlam Historic
Society

N/A

L

L

M

Coastal
Erosion

State Dept. of
Env./State Dept.
of Emergency

$150,000

Existing budget

N/A

L

L

M

Earthquakes

State Dept. of
Planning/ State
Dept. of
Emergency/
Local Planning
Depts.

$100,000

Existing Budget

N/A

L

L

L

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Budget
P L A N N I N G

Funding Source

Flooding

Lead/Support
Agency

Comprehensive
loss reduction
program
involving
acquisition,
elevation,
relocation, and
floodproofing of
structures
Increase culvert
size and retrofit
bridge along
State Highway
101

Hazard

Rank

State
Coastal
Zone
Management Program

Negative Environmental Impact

Bedlam
County

Negative Social
Impact

Allwater
County

BC Review

State
Repetitive
Loss
Reduction
Program

Project Description

Statewide or County
Specific

Mitigation Projects

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PART 1 – STANDARD STATE MITIGATION PLANS
FUNDING SOURCES
Requirement
§201.4(c)(3)(iv):

Explanation:

[The State mitigation strategy shall include an] identification of current
and potential sources of Federal, State, local, or private funding to
implement mitigation activities.
The plan shall describe the current funding sources as well as potential
sources that will be pursued to fund proposed mitigation projects and
actions. It should also identify where funding is required to implement a
project/activity identified in the mitigation strategy. Funding alternatives
shall include Federal, State, local, and private sources.
The description can also include novel or alternative ways to fund
actions, such as:

Plan Update:

ƒ

Combining funding from various programs to implement a mitigation
project.

ƒ

Integrating mitigation actions in implementing agencies’ work plans.

ƒ

Identifying mitigation opportunities that may arise during scheduled
infrastructure improvements, maintenance, or replacement, or other
capital improvements.

ƒ

Building partnerships with businesses and non-profits whose
properties, employees, or clients may be affected by hazards.

ƒ

Combining funding from various Federal programs to fund a
comprehensive plan with a mitigation component.

The updated plan must describe current and potential sources of funding
to implement mitigation activities. The updated plan should associate
current and potential funding with identified mitigation actions in the
mitigation strategy, not just a general statement of funding.
The updated plan must identify the sources of mitigation funding used
since approval of the previous plan to implement activities in the
mitigation strategy.

Resource:

For more information on funding mitigation actions, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 3.
9 Bringing the Plan to Life (FEMA 386-4), Step 2.

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PART 1 – STANDARD STATE MITIGATION PLANS
Examples:
Original Submittal:
The State currently uses several funding sources to implement its hazard
mitigation actions. Funding sources include: FEMA’s Hazard Mitigation
Grant Program (HMGP), Flood Mitigation Assistance (FMA), HUD’s
Community Development Block Grant (CDBG) via the State’s Economic
and Community Development Administration, and Small Business
Administration (SBA) loans. These funds are used to implement a broad
range of hazard mitigation actions. The State is also planning to pursue
additional funding sources.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(3)
(iv)

REVIEWER’S COMMENTS

ƒ

ƒ
ƒ

The plan did not provide details about
the funding sources and how they are
used, including current funding levels,
eligible types of actions, and
current/past projects.
The plan did not mention which future
funding sources will be pursued.
The plan did not mention State, local, or
private funding sources.

Required Revisions:
To receive a “Satisfactory” score, the plan must include a description of
State and private sector partnerships in place or describe the strategy for
pursuing the private sector to take a more active role in implementing
mitigation actions.
Revised Submittal:
The State currently uses several funding sources to implement its hazard
mitigation actions. Funding sources include: FEMA’s Hazard Mitigation
Grant Program (HMGP), Flood Mitigation Assistance (FMA), HUD’s
Community Development Block Grant (CDBG) via the State’s Economic
and Community Development Administration, and Small Business
Administration (SBA) loans. These funds are used to implement a broad
range of hazard mitigation actions. The State is also going to pursue
additional funding sources. These funds primarily come from Federal
and State sources, and the State is interested in pursuing additional
private sources. These sources are listed in the following table.

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PART 1 – STANDARD STATE MITIGATION PLANS

Funding
Source
HMGP
Hazard
Mitigation Grant
Program
FMA
Flood Mitigation
Assistance
Program
CDBG
Community
Development
Block Grant

SBA
Small Business
Administration

SOF
State Office for
Mitigation
Funding
Manufactured
Homebuilders
Association
National
Association of
Homebuilders

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Description
Provides post-disaster funds to
communities to help implement longterm hazard mitigation strategies.
Provides pre-disaster funds. There are
three types of grants: planning grants,
project grants, and technical assistance
grants. Requires a 25% non-Federal
match and is based on the total number
of NFIP policies in the State.
Although this funding comes from HUD,
it is made available to communities
through the State Economic and
Community Development
Administration. The grants are used to
expand affordable housing and
economic opportunities, and to
revitalize communities by improving
community facilities and services.
Post-disaster low interest, long-term
loans given to homeowners, renters,
businesses, or private non-profit
organizations. Up to 20% of the loan
amount can be used for hazard
mitigation actions.
This newly created State Office was
authorized by a recent act of the State
Legislature. This Office will make funds
available to local communities for
hazard mitigation planning through an
increase in the State’s gasoline tax.
The State is interested in forming an
agreement with this association to
develop an earthquake-resistant homes
campaign.
The State is pursuing a relationship with
this association and is discussing how
the association can assist the State in
promoting construction of safe rooms.

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Estimated
Annual Funding
$15M (from three
past Presidential
disaster
declarations)
$500,000

$2M

$500,000 (based
on past disasters)

$5M

In-kind services

In-kind services

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PART 1 – STANDARD STATE MITIGATION PLANS
COORDINATION

OF

LOCAL

MITIGATION

PLANNING

§201.4(c)(4) requires that Standard State Mitigation Plans describe the process by which they
provide funding and technical assistance for the development of Local Plans. This section also
requires a description of the State’s processes for incorporating local planning efforts into the
statewide plan and prioritizing assistance to local jurisdictions.
When the State plans were originally prepared, there were few local plans that met FEMA’s
planning requirements under §201.6. Therefore, States had limited local information on which
to base their plans. Since then, many local plans have been approved and adopted, providing
States with the opportunity to better coordinate with local jurisdictions.
Section 201.4(d) requires that the State plan be updated regularly to address changes in
development and mitigation priorities. This is reflected in the guidance language under
§201.4(c)(4)(ii) and §201.4(c)(4)(iii).
This section includes the following three subsections:
ƒ

Local Funding and Technical Assistance

ƒ

Local Plan Integration

ƒ

Prioritizing Local Assistance

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PART 1 – STANDARD STATE MITIGATION PLANS
LOCAL FUNDING AND TECHNICAL ASSISTANCE
Requirement
§201.4(c)(4)(i):

[The section on the Coordination of Local Mitigation Planning must
include a] description of the State process to support, through funding
and technical assistance, the development of local mitigation plans.

Explanation:

With a new requirement for local mitigation plans in DMA 2000, many
communities will require additional assistance, particularly small
communities without adequate resources to develop a plan. Therefore,
the State must describe the process it has developed or will develop to
provide funding and technical assistance to local jurisdictions to prepare
mitigation plans. Funding sources may be Federal, State, or private (see
page 1-47 of the Mitigation Strategies section).
The description should include the departments or staff responsible for
providing funds, plan development assistance, and technical assistance
for developing risk assessments. This description could be included as
part of the goals, objectives, and actions in the Mitigation Strategy
section.

Plan Update:

The updated plan must describe:
• The funding and technical assistance the State has provided
since approval of the previous plan to assist local jurisdictions in
completing approvable mitigation plans; and
• How the State will continue to provide this funding and technical
assistance for new plans as well as local plan updates.
Recognizing the limitations of some States’ authorities, the update should
discuss how technical assistance will be used to improve the
effectiveness of local plans, particularly those of the more vulnerable
jurisdictions. Examples include but are not limited to:
•
•
•
•
•
•

Assistance to local jurisdictions to include in their mitigation
strategies effective an feasible mitigation projects;
Planning workshops/training;
Planning grant application development;
HAZUS technical assistance;
Improved risk assessment or hazard data;
Extensive plan review feedback.

If disasters have occurred, States should discuss what steps they have
taken or will take to encourage affected local jurisdictions to complete or
update their mitigation plans to reflect changes in vulnerability or revised
State priorities.

Resource:

For information about writing a detailed mitigation strategy, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 3.

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PART 1 – STANDARD STATE MITIGATION PLANS

Examples:
Original Submittal:
Technical Assistance to Local Jurisdictions
The Hazard Mitigation Committee (HMC) provides technical assistance
for plan development to local governments if requested by the
jurisdiction.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(4)
(i)

REVIEWER’S COMMENTS

ƒ
ƒ
ƒ

ƒ

The plan does not describe what
funding support is available to local
jurisdictions.
The plan did not indicate how and what
kind of technical assistance is provided
to local governments.
The plan did not indicate the staff or
departments tasked with the
responsibility of providing technical
assistance or funding.
Technical assistance should include an
outreach component.

Required Revisions:
For a “Satisfactory” score, the plan must document the process followed
to provide technical assistance and funding to local jurisdictions in the
development of Local Plans.
Revised Submittal:
Technical Assistance to Local Jurisdictions Plan Development
Assistance
The Hazard Mitigation Committee (HMC) provides technical assistance
and funding to local jurisdictions that request such assistance for
plan development to local governments if requested by the jurisdiction.
These resources are offered annually to local jurisdictions through
a brochure indicating: 1) the types of technical assistance provided
to jurisdictions (funding, planning process facilitation, risk
assessment study, capability assessment study, hazard analysis,
etc.); 2) the application procedure; and 3) the annual deadline for
applications. Using the information presented on the submitted
applications and the statewide risk assessment, the HMC
prioritized jurisdictions for assistance based on 1) their
vulnerability to hazards, 2) the lack of an updated hazard mitigation
plan, 3) their access to geographic information systems and
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PART 1 – STANDARD STATE MITIGATION PLANS
planning resources, and 4) the availability of local funds to conduct
a planning process. The Plan Development Assistance
Prioritization Matrix below summarizes this process.
Funds for planning assistance come from two Federal sources—
the State’s HMGP 7% planning assistance funds and the State’s
Pre-Disaster Mitigation Program funds — and one State source, the
State Mitigation Action Fund. As a condition of having
representation on the HMC, all member agencies have the
responsibility to provide expertise to the local governments
approved to receive assistance.

H

H

L

H

Bedlam

H

M

L

H

z

Calmbeforethe-Storm

M

L

H

L

z

Turmoil

L

M

H

L

z

2 0 0 8

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P L A N N I N G

Tech.
Assistance
Rank

County
Funds
Available

County
Planning
Dept.?

County
GIS Dept?

Updated
Plan?

Wildfire
Risk

Hurricane
Risk

Flood Risk

Allwater

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Drought
Risk

County

Plan Development Assistance Prioritization Matrix

1
z
z

z

z

G U I D A N C E

2
z

4

3

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PART 1 – STANDARD STATE MITIGATION PLANS
LOCAL PLAN INTEGRATION
Requirement
§201.4(c)(4)(ii):

[The section on the Coordination of Local Mitigation Planning must include
a] description of the State process and timeframe by which the local plans
will be reviewed, coordinated, and linked to the State Mitigation Plan.

Update:

[The] plan must be reviewed and revised to reflect changes in
development, progress in statewide mitigation efforts, and changes in
priorities…

§201.4(d):
Explanation:

Plan Update:

The plan must include a description, as well as a timeline, of the State’s
approach for reviewing, coordinating, and integrating Local Plans into the
statewide mitigation plan. An established process will streamline the review
and approval of Local Plans, coordinate local and State planning efforts,
and create a common knowledge base. While not required by the Rule,
FEMA recommends listing the offices or departments responsible for these
activities.
The plan update process provides the opportunity for the State to assess
how it reviews local plans and adjusts for any challenges or constraints to
implementing its review process. The plan update must describe the
process and timeframe by which the State reviews new and updated local
plans for compliance with the Local Mitigation Plan requirements under 44
CFR Part 201.6.
The plan update must describe the process by which the State coordinates
and links local plans to the State plan. The State plan update should
identify areas where local jurisdictions utilized State plan information (e.g.,
risk assessment data) to complete their plans, or alternatively where local
plan data were integrated into the State plan (e.g. local development
trends). The State plan update should describe how the State reviewed
local mitigation plans to ensure that State goals and objectives were
supportive of local strategies. In this case, the State should coordinate with
locals to ensure that identified mitigation goals are coordinated so that
resulting hazard mitigation projects and actions result in similar ends.

Resource:

For more information about writing a detailed mitigation strategy, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 3.

Examples:
See page 1-22 for how local plan risk assessment findings, when available,
were reviewed and integrated into the statewide plan.
See page 1-43 for how locally identified mitigation actions are integrated
into the statewide plan.

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PART 1 – STANDARD STATE MITIGATION PLANS
PRIORITIZING LOCAL ASSISTANCE
Requirement
§201.4(c)(4)(iii):

[The section on the Coordination of Local Mitigation Planning must
include] criteria for prioritizing communities and local jurisdictions that
would receive planning and project grants under available funding
programs which should include:
ƒ

consideration for communities with the highest risks,

ƒ

repetitive loss properties, and

ƒ

most intense development pressures.

Further that for non-planning grants, a principal criterion for prioritizing
grants shall be the extent to which benefits are maximized according to a
cost benefit review of proposed projects and their associated costs.
Update:

§201.4(d):
Explanation:

[The] plan must be reviewed and revised to reflect changes in
development, progress in statewide mitigation efforts, and changes
in priorities…
The plan shall describe the criteria the State has developed for
prioritizing local jurisdictions to receive planning and project grant
assistance. Prioritization will assist the State in targeting the most at risk
communities. The criteria for selecting communities should include those
communities that are at highest risk, have repetitive loss properties, or
are facing intense development pressure. The description can also
include how assisting communities with their mitigation projects will
achieve the plan’s goals and objectives.
For project grants, States shall explain how they will use benefit-cost
reviews to determine which projects maximize benefits relative to their
costs. These projects would have the highest priority for available
funding.

Plan Update:
The State must evaluate its approach to prioritizing local jurisdictions to
receive planning and project grant assistance and provide a current
description of its process. The plan should identify successes and
challenges in its approach.
Resource:

For more information on writing a detailed implementation strategy, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 3.
For information about performing benefit-cost analyses, call:
9 FEMA’s BCA Hotline at 866.222.3580 to order the Mitigation BCA
Toolkit (July 2003) CD.

Examples:
See page 1-22 for how the most vulnerable jurisdictions were identified,
and page 1-43 for how mitigation actions were prioritized.
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PART 1 – STANDARD STATE MITIGATION PLANS

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PART 1 – STANDARD STATE MITIGATION PLANS
PLAN

MAINTENANCE

PROCESS

The plan maintenance process section requires that States implement a mechanism to keep the
plan updated to reflect current conditions. §201.4(c)(5) requires States to have an established
method and schedule for monitoring, evaluating, and updating the plan. This includes a review
of goals, objectives, and actions the State is undertaking.
The Standard State Plan must be updated and resubmitted to FEMA for approval every three
years, as required in §201.4(d). While the Rule does not require the plan to be updated after a
disaster declaration, FEMA highly encourages States to review it and determine if the goals,
objectives, and actions still meet the needs of the State. If deemed necessary, these should be
reprioritized to reflect current conditions. It is especially important to update the plan if the
disaster is the result of a new hazard or is not addressed in the plan. This post-disaster update
can be an annex to the plan.
The updated plan assesses how the State’s plan maintenance process worked and identifies
whether any changes to the process are needed. Taking into consideration future updates, the
State may find that adjustments to the method and schedule for maintaining the plan are
necessary to ensure its value for comprehensive risk reduction.
Since the plan is an evolving document, the plan maintenance process identified in any State
plan serves as the basis for the next update. The process of updating the plan provides the
State the opportunity to document its progress in achieving its mitigation goals.
This section includes the following two subsections:
ƒ

Monitoring, Evaluating, and Updating the Plan

ƒ

Monitoring Progress of Mitigation Activities

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PART 1 – STANDARD STATE MITIGATION PLANS
MONITORING, EVALUATING, AND UPDATING THE PLAN
Requirement
§201.4(c)(5)(i):

Explanation:

[The Standard State Plan Maintenance Process must include an]
established method and schedule for monitoring, evaluating, and
updating the plan.
The plan maintenance process provides a framework for gauging
progress and adjusting to new conditions, such as new policies, Federal
requirements, and new initiatives.
The State must describe how, when, and by whom the plan will be
monitored. For example, its monitoring system may consist of the
submittal of periodic reports by agencies involved in implementing
projects or actions; site visits, phone calls, and meetings conducted by
the person responsible for overseeing the plan; and the preparation of an
annual report that captures the highlights of the previously mentioned
activities.
The State plan must also include a description of how, when, and by
whom it will be evaluated. The description should include the criteria
used to evaluate the plan, such as whether:
ƒ

The goals and objectives still address current and expected
conditions.

ƒ

The nature and magnitude of hazard problems and/or development
have changed.

ƒ

The current resources are appropriate for implementing the plan.

ƒ

There are implementation problems, such as technical, political, legal,
or coordination with other agencies.

ƒ

The outcomes of actions have been as expected.

ƒ

The agencies participated as originally proposed.

Ideally, the plan should be evaluated on an annual basis to determine the
effectiveness of programs, policies, and projects, as well as to reflect
changes in priorities and regulations.
The plan must describe how, when, and by whom it will be updated.
FEMA recommends identifying the interested parties to be included in the
process.
Plan Update:

In the previously approved plan, the State identified procedures to
monitor, evaluate, and update its mitigation plan and track mitigation
activities. The results of this evaluation and monitoring will assist the
State in updating each section of the plan as part of the established
update schedule. In particular, the plan maintenance section of the
previously approved plan should assist in establishing the process for
updating the plan.
The updated plan must include:

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PART 1 – STANDARD STATE MITIGATION PLANS
•

•
Resource:

An analysis of whether the previously approved plan’s method
and schedule for monitoring, evaluating, and updating the plan
worked, and what elements or processes, if any, were changed;
and
The method and schedule to be used over the next three years to
monitor, evaluate, and update the plan.

For information on the plan maintenance process, see:
9 Bringing the Plan to Life (FEMA 386-4), Steps 2 - 4.

Examples:
Original Submittal:
The State recognizes that the Hazard Mitigation Plan is not a static
document and requires regular review and evaluation. The State will
review the Plan annually to ensure that the plan is being properly
implemented and is achieving the objectives set forth in the plan. If
necessary, the Plan will be reviewed after a disaster declaration has
been made in the State. FEMA will be notified of any changes the plan,
or will be given a justification of why no changes were deemed
necessary.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(5)
(i)

REVIEWER’S COMMENTS

ƒ

ƒ

The plan does not present a schedule
for monitoring, evaluating, and updating
the plan, nor does it designate a
responsible agency.
The plan does not describe how the
mitigation plan will be updated.

Required Revisions:
The plan must include a schedule or timeline for monitoring, evaluating,
and updating the plan. This section must also include a description of
how the plan will be updated. Include specific agencies responsible for
the monitoring, evaluation, and update of the plan.
Revised Submittal:
The State recognizes that the Hazard Mitigation Plan is not a static
document and requires regular review and evaluation. The State will
review the Plan annually to ensure that the plan is being properly
implemented and is achieving the objectives set forth in the plan. If
necessary, the Plan will be reviewed after a disaster declaration has
been made in the State.
The State has formed a Hazard Mitigation Plan Evaluation
Committee that will be responsible for reviewing and evaluating the
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PART 1 – STANDARD STATE MITIGATION PLANS
Mitigation Plan. This committee consists of representatives from
State, County, and municipal government; regional planning
councils; independent special districts; and non-profit
organizations. This committee will meet once a year, in March, and
all members will be asked to analyze the overall success and
progress in implementing the Plan.
The committee will review each goal and objective to determine
their appropriateness with respect to changing situations in the
State as well as changes in policy, and to ensure they are
addressing current and expected conditions. The committee will
also review the risk assessment and capabilities portion of the Plan
to determine if this information needs to be updated or modified.
Each strategy and the associated actions will be reported on by the
party responsible for its implementation, and will include which
implementation processes worked well, any difficulties
encountered, how coordination efforts were proceeding, and which
strategies or processes need to be revised or strengthened.
The committee will then create a list of recommendations that
suggests ways to bring the Plan up to date, and any enhancements
that can be made. The State Office of Planning will be responsible
for making the necessary changes to the Plan, and the revised Plan
must be submitted for approval by the State legislature no later than
three months after the conclusion of the committee meeting.
FEMA will be notified of any changes to the plan, or will be given a
justification of why no changes were deemed necessary.
In the case of a disaster declaration in the State, the Hazard
Mitigation Plan can be updated if the State Office of Emergency
Management believes this is necessary.

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PART 1 – STANDARD STATE MITIGATION PLANS
MONITORING PROGRESS OF MITIGATION ACTIVITIES
Requirement
§201.4(c)(5)(ii)
and (iii):

Explanation:

[The Standard State Plan Maintenance Process must include a]
ƒ

system for monitoring implementation of mitigation measures and
project closeouts.

ƒ

system for reviewing progress on achieving goals as well as activities
and projects in the Mitigation Strategy.

The plan must describe the State’s monitoring system for tracking the
initiation and status of projects as well as project closeouts, indicating
who will be responsible for implementing and maintaining this system.
This is important because without regular monitoring, mitigation actions
may not be implemented as planned.
The plan must also describe how the State reviews the progress made
on actions and projects and how well these contribute to achieving the
plan’s goals. The description must also include who is involved in the
review and what the timeframe is for carrying out the review.

Plan Update:

The update must:
• Describe any modifications to the State’s system used to track
the initiation, status, and completion of mitigation activities;
• Discuss if mitigation actions were implemented as planned; and
• Indicate who will be responsible for continued management and
maintenance of the monitoring system, including the timeframe
for carrying out future reviews.
The system identified in this section of the plan will support
demonstration of progress in statewide mitigation efforts under §201.4
(c)(3)(iii).
The update should:
• Describe any challenges that hindered implementation of
mitigation measures and project close-outs and how these will be
dealt with in the future. These could include technical, political,
financial, legal, or agency coordination issues; and
• Describe any factors that contributed to successful
implementation of mitigation measures.

Resource:

For information on the plan maintenance process, see:
9 Bringing the Plan to Life (FEMA 386-4), Steps 3 and 4.

Examples:

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PART 1 – STANDARD STATE MITIGATION PLANS
Original Submittal:
Mitigation Division staff are responsible for the monitoring and tracking
of progress of mitigation actions. The Division has an established
quantifiable approach for measuring outcomes.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.4(c)(5)
(ii) and (iii)

REVIEWER’S COMMENTS

ƒ

ƒ

While the plan indicates who is
responsible for monitoring progress,
the plan does not describe the
approach being used.
The plan does not describe the
Division’s approach for measuring
outcomes nor how these are tied to the
plan’s overall goals.

Required Revisions:
To receive a “Satisfactory” score, the State must set up a schedule and
assign responsibility and resources for monitoring and evaluating
mitigation actions and project close-outs as well as progress on goals
and projects. While not required by the Rule, special attention should
also be given as to when baseline data would be updated to keep the
plan current.
Revised Submittal:
Mitigation Division staff are responsible for the monitoring and tracking
of progress of mitigation actions. The Division has an established
quantifiable approach for measuring outcomes. The Division chief has
assigned one person to follow-up with other agency staff on a
quarterly basis. The person collects quarterly reports on
measurable outcomes, which are then input into a database
accessible to all participating agencies. Once a year these staff
meet to review overall progress on achieving the plan’s goals. This
team has developed an evaluation form (see Appendix XX) that
addresses outcomes or the success of projects; assesses new
information provided through research and disaster assessment
reports to update the baseline data; verifies project close-outs; and
reviews the level of coordination among agencies, a key to the
success in implementing the plan. A subcommittee of State
University professors convenes once a year to review the new
information and make recommendations to the HMC for updating
the baseline data used in the risk analysis. This information is used
to reassess project prioritization as necessary.
Goals, objectives, and projects will be reviewed in the event of a
disaster to determine whether they need to be modified to reflect
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PART 1 – STANDARD STATE MITIGATION PLANS
the new conditions and the findings appended to the existing plan.
The Mitigation Division regularly updates the State mitigation Web
site with mitigation actions that have been successfully completed.

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PART 1 – STANDARD STATE MITIGATION PLANS

SEVERE

REPETITIVE

LOSS

STRATEGY

On June 30, 2004, the National Flood Insurance Act (42 U.S.C. 4001 et seq.) was
amended to introduce a mitigation plan requirement as a condition of receiving a
reduced local cost share for activities that mitigate severe repetitive loss properties
under the Flood Mitigation Assistance (FMA) and Severe Repetitive Loss (SRL) grant
programs. The October 31, 2007, interim final rule established this requirement under
44 CFR §201.4(c)(3)(v) to allow a State to request the reduced cost share under the
FMA and SRL programs if it has an approved State Mitigation Plan that also includes an
approved Severe Repetitive Loss Strategy.
Severe repetitive loss properties are defined as single or multifamily residential
properties that are covered under a National Flood Insurance Program (NFIP) flood
insurance policy and:
(1) That have incurred flood-related damage for which 4 or more separate claims
payments have been made, with the amount of each claim (including building and
contents payments) exceeding $5,000, and with the cumulative amount of such
claims payments exceeding $20,000; or
(2) For which at least 2 separate claims payments (building payments only) have
been made under such coverage, with cumulative amount of such claims exceeding
the market value of the building.
(3) In both instances, at least 2 of the claims must be within 10 years of each other,
and claims made within 10 days of each other will be counted as 1 claim.
In order to be eligible for a reduced cost share under the FMA or SRL grant programs,
the State must have at the time of project application a FEMA-approved State or Tribal
Standard Mitigation Plan that also meets the requirement described in the two sections
below.
•

Repetitive Loss Mitigation Strategy

•

Coordination with Repetitive Loss Jurisdictions

Special Considerations: States and Federally recognized Indian Tribes are not
required to meet the requirements of 44 CFR §201.4(c)(3)(v) to be eligible for mitigation
assistance under any FEMA mitigation grant programs at the standard 75 percent
Federal cost share. However, they are encouraged to amend their plans to include a
strategy for mitigating severe repetitive loss properties in order to be eligible to receive
an increased Federal cost share of up to 90 percent for grants under the FMA and SRL
grant programs. States may address the severe repetitive loss strategy through either
an amendment to their existing FEMA approved State or Tribal Mitigation Plan, or during
the review and update of their Plan.

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PART 1 – STANDARD STATE MITIGATION PLANS
REPETITIVE LOSS MITIGATION STRATEGY
Requirement 44 C.F.R. §201.4(c)(3)(v): A State may request the reduced cost share
authorized under §79.4(c)(2) of this chapter for the FMA and SRL programs, if it has an
approved State Mitigation Plan … that also identifies specific actions the State has taken
to reduce the number of repetitive loss properties, which must include properties
identified as severe repetitive loss, and specifies how the State intends to reduce the
number of such repetitive loss properties.
Explanation:

This requirement supplements the risk assessment and mitigation
strategy portions of the plan required under §§ 201.4(c)(2) and (3) by
specifically identifying goals, capabilities and actions that will reduce the
number of repetitive loss properties, including severe repetitive loss
properties.
The mitigation strategy is based on the State’s Risk Assessment as
required under §201.4(c)(3)(ii). Therefore, the State must address
repetitive loss structures in its risk assessment, where applicable. For
example, in its overview of Estimating Potential Losses by Jurisdiction
under §201.4(c)(2)(iii), the State may analyze potential losses to
identified repetitive loss properties based on estimates provided in local
risk assessments. The Plan should refer generally to geographic areas
where concentrations of repetitive loss properties are located for the
purpose of identifying and prioritizing areas for mitigation projects, or the
plan may list the number of repetitive loss properties with aggregate
repetitive loss data.
The State Hazard Mitigation Goals under §201.4(c)(3)(i) must support
the selection of activities to mitigate and reduce potential losses to
structures susceptible to flood damage, including repetitive loss
properties. In addition, the State and Local Capability Assessments
required under §201.4(c)(3)(ii) must include an evaluation of policies,
programs, and capabilities that allow the mitigation of repetitive losses
from flood damage.
The State must describe specific actions that it has implemented to
mitigate repetitive loss properties, and specifically actions taken to
reduce the number of severe repetitive loss properties as a subset of all
repetitive loss properties in the State. If the State cannot show that any
action has ever been taken to reduce the number of such properties, this
criteria cannot be met.
Based on the findings of the risk assessment, the State must identify
actions in the statewide mitigation strategy that specifically address
repetitive loss properties, including those that are severe repetitive loss
properties. This supplements the mitigation actions requirement under
§201.4(c)(3)(iii). Mitigation actions should be tied to goals and
objectives and provide the means to achieve them. Actions should have
been identified in the planning process, and local plans should be
consistent with state-wide actions.
As part of the mitigation strategy, the plan must also describe the
current funding sources as well as potential sources that will be pursued

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PART 1 – STANDARD STATE MITIGATION PLANS
to fund proposed mitigation actions for repetitive loss properties. This
supplements the identification of funding requirement under
§201.4(c)(3)(iv).
Plan
Update:

The updated plan must specifically address repetitive loss properties,
including severe repetitive loss properties, in accordance with the Plan
Update requirements for the State’s Risk Assessment under
§201.4(c)(2) and under each of the criteria under the State’s Mitigation
Strategy under section 201.4(c)(3).
In addition, the updated plan must identify the completed actions or
activities since the previously adopted plan as a benchmark for
progress. If no mitigation actions or activities have been taken since the
previously approved plan, the updated plan must indicate why the State
has not been able to complete these actions.

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PART 1 – STANDARD STATE MITIGATION PLANS
COORDINATION WITH REPETITIVE LOSS JURISDICTIONS
Requirement 44 C.F.R. §201.4(c)(3)(v): In addition, the plan must describe the
strategy the State has to ensure that local jurisdictions with severe repetitive loss
properties take actions to reduce the number of these properties, including the
development of local mitigation plans.

Explanation:

The State is required to identify strategies that encourage local
communities to mitigate severe repetitive loss properties, including the
development of local mitigation plans. This supplements the
Coordination of Local Mitigation Planning portion of the plan under
§201.4(c)(4). At a minimum, the State must include severe repetitive
loss in the description of its process for providing funding and technical
assistance to prepare mitigation plans (§201.4(c)(4)(i)), and in its criteria
for prioritizing communities that have such properties for planning and
project grant assistance (§201.4(c)(4)(iii)). Other strategies for
encouraging local communities to mitigate severe repetitive loss
properties should be demonstrated through specific actions identified in
the Mitigation Strategy.

Plan
Update:

The updated plan must specifically address repetitive loss properties,
including severe repetitive loss properties, in accordance with the Plan
Update requirements for the State’s Coordination of Local Mitigation
Planning under §§201.4(c)(4)(i) and (iii).

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PART 2 – ENHANCED STATE MITIGATION PLANS
An Enhanced State Mitigation Plan documents the State’s demonstrable and sustained
commitment to the objectives of hazard mitigation. This designation recognizes the State as a
proactive leader in implementing a comprehensive statewide program. The enhanced status
acknowledges the extra effort a State has made to reduce losses, protect its resources, and
create safer communities. For mitigation plans to receive this designation, the State must obtain
a ”Satisfactory” score on all of the Standard State Plan requirements as described in Part 1 of
this manual. In addition, it must receive a “Satisfactory” score on each of the Enhanced State
requirements.
The June 2007 revisions to this Guidance provide important new information regarding
compliance with the Standard State Mitigation Plan requirements as discussed at 44 CFR
201.5(b). This change applies to both new and updated Enhanced State Mitigation Plans.
The sections covered in Part 2 – Enhanced State Mitigation Plans include:
ƒ

Prerequisite

ƒ

Comprehensive State Hazard Mitigation Planning Program

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PART 2 - ENHANCED STATE MITIGATION PLANS
PREREQUISITE
The State submitting a mitigation plan for designation as an Enhanced State Mitigation Plan
must meet the following prerequisite before FEMA can approve the plan.
1. COMPLIANCE WITH STANDARD STATE PLAN REQUIREMENTS
Requirement
§201.5(b):

Enhanced State Mitigation Plans must include all elements of the
Standard State Mitigation Plan identified in §201.4 … .

Explanation:

In order to be considered for Enhanced Plan status, the plan must contain
all the elements of the Standard Plan (per §201.4), in addition to meeting
all the requirements listed in §201.5. All the elements required for the
Standard Plan must receive a score of “Satisfactory” before the plan is
reviewed for compliance with the Enhanced State requirements.

(Rev. June 2007)

All Enhanced State Mitigation Plans submitted for FEMA’s approval on or
after January 1, 2008, must include a current update of their Standard
Plan elements. Each State should submit its draft Mitigation Plan to
FEMA’s Regional Office early enough to allow sufficient time for:
1. Region’s review of all required elements (Standard and Enhanced
portions);
2. Region’s review of the State’s program management capability;
3. National Evaluation Panel’s review;
4. State completion of any required revisions to the plan; and
5. Adoption of the plan by the State and approval by FEMA before
the existing plan expires.
Plan Update:

If the Enhanced elements of the State Mitigation Plan are not approved
prior to the expiration of the existing plan, but the Standard requirements
have been met, the FEMA Region may approve the plan as a Standard
Plan. This will ensure continued program eligibility for the State, while still
allowing the Enhanced review process and any required revisions to be
completed. The approved Plan will be held to the initial three-year
approval timeframe, and will not be extended as a result of any additional
time needed for review, revision or approval of the Enhanced portion of
the plan. This requirement is intended to ensure that (1) all plans are
based on the most current information and (2) that there is a single
approval date for each State Mitigation Plan.
To provide consistency between the Standard and Enhanced sections of
the plan, the updated Enhanced portion of the Plan must be revised as
necessary to be consistent with all updates to the Standard portion of the
Plan.

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PART 2 - ENHANCED STATE MITIGATION PLANS
Resource:

For more information on preparing and implementing a mitigation plan,
see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 3.
9 Bringing the Plan to Life (FEMA 386-4), Step 2.

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PART 2 - ENHANCED STATE MITIGATION PLANS
COMPREHENSIVE STATE HAZARD MITIGATION PLANNING
PROGRAM
44 CFR §201.5 addresses Enhanced State Mitigation Plans. This is FEMA’s effort to recognize
those States that go above and beyond the minimum mitigation requirements by making them
eligible to receive an increased amount of mitigation grant funding. Strong State and local
mitigation planning processes and comprehensive mitigation program management at the State
level are important elements in reducing vulnerability to future disaster losses. It is hoped that
the Enhanced Plan option will encourage more States to take their planning to a higher level.
For the Enhanced State Plan, States must meet all of the requirements of the Standard Plan,
plus be able to demonstrate that the State already has a comprehensive mitigation program,
demonstrate that they effectively use available mitigation funding, and demonstrate that they are
capable of managing the increased funding.
The plan update process provides States the opportunity to revisit the information they originally
provided to demonstrate these capabilities. Any improvement, reduction, or other changes to
these capabilities should be noted in the plan.
This section includes the following six subsections:
ƒ

Integration with Other Planning Initiatives

ƒ

Project Implementation Capability

ƒ

Program Management Capability

ƒ

Assessment of Mitigation Actions

ƒ

Effective Use of Available Mitigation Funding

ƒ

Commitment to a Comprehensive Mitigation Program

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2. INTEGRATION WITH OTHER PLANNING INITIATIVES
Requirement
§201.5(b)(1):

[An Enhanced Plan must demonstrate] that the plan is integrated to the
extent practicable with other State and/or regional planning initiatives
(comprehensive, growth management, economic development, capital
improvement, land development, and/or emergency management plans)
and FEMA mitigation programs and initiatives that provide guidance to
State and regional agencies.

Explanation:

This requirement is similar to §201.4(b) for the Standard Plan, which is
discussed previously in Program Integration (page 1–11), except that it
also requires the State to detail how the Enhanced Plan is specifically
integrated into other State, regional, and FEMA initiatives that provide
primary guidance for hazard mitigation-related activities.

(Rev. June 2007)

States might demonstrate that they have integrated the plan with
planning initiatives that provide guidance by describing such activities as
coordinating with developers of State plans (e.g., statewide economic
development, capital improvement, or public works plans) to incorporate
hazard mitigation priorities; passing State laws or regulations that
mandate integration of mitigation considerations with other planning
initiatives at the State level; and/or working with Regional Planning
Authorities or Councils of Government.
When applying this requirement, reviewers should keep in mind the
differences in planning conditions among States. For example, in States
with extensive planning resources, integration with other plans may be
more comprehensive. However, States with limited resources and little
tradition of collaboration across agencies should receive credit for
demonstrating measurable progress towards integration of efforts.
Examples of demonstrated integration with State and/or regional planning
initiatives could include:
•

How the State currently influences or coordinates with other
State and regional agencies to incorporate hazard mitigation into
their own programs, regulations and activities.

•

How other agencies incorporate mitigation data or resources into
their planning initiatives;

•

How other State or regional agencies’ planning initiatives are
linked to or support specific hazard mitigation strategies;

•

How other State or Regional planning initiatives promote
mitigation as part of their authorities and responsibilities.

Examples of demonstrated integration with FEMA programs and
initiatives that provide guidance to State and Regional agencies could
include FEMA mitigation grant programs, as well as:
•

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Use of HAZUS within the State Plan and/or a description of how
the State encourages or supports the use of HAZUS in the
development of local mitigation plans;
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•

Discussion of how the mitigation plan is linked to Flood Map
Modernization activities within the State;

•

How the State utilizes information provided in FEMA technical
documents related to building construction, codes and standards
to incorporate mitigation into retrofitting existing buildings and/or
strengthening new development;

•

How the Enhanced Plan guides activities funded by Emergency
Management Program Grants (EMPG); and/or

•

How the Enhanced Plan encourages and supports local
government participation in the Community Rating System (CRS)
of the National Flood Insurance Program (NFIP).

Plan Update:

States must demonstrate continued integration of the mitigation plan with
other state and/or regional planning initiatives as well as FEMA mitigation
programs. The update must include any planning initiatives that have
been established since approval of the previous plan and describe how
those initiatives help achieve progress toward the overall goals and
objectives of mitigation planning.

Resource:

For more information on integrating hazard mitigation activities in other
initiatives, see:
9

Getting Started (FEMA 386-1), Step 1.

9 Bringing the Plan to Life (FEMA 386-4), Step 2.
Examples:
Original Submittal:
Integration with Other Planning Initiatives
In furthering the concept and practice of hazard mitigation across the
State, the Hazard Mitigation Committee (HMC) created a subcommittee to
explore the feasibility of integrating State hazard mitigation planning with
other statewide planning initiatives such as the State Smart Growth
initiative and the State economic development plan.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.5(b)(1)

COMMENTS
REVIEWER’S COMMENTS

ƒ

While it is encouraging that the HMC
created a subcommittee to explore
integration with other planning initiatives,
a strategy to promote integration has not
yet been developed.

Required Revisions:
The submittal must explain the steps that the planning committee has
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taken or intends to take to integrate hazard mitigation.

Revised Submittal:
Integration with Other Planning Initiatives
In furthering the concept and practice of hazard mitigation across the
State, the Hazard Mitigation Committee (HMC) created a subcommittee to
explore the feasibility of integrating State hazard mitigation planning with
other statewide planning initiatives such as the State Smart Growth
initiative and the State economic development plan. The subcommittee
developed the following strategy to further this work:
ƒ

The State Hazard Mitigation Officer met with the Director and
Assistant Director of the State Economic Development Agency to
discuss integration of hazard mitigation concepts into economic
development initiatives. The meeting produced a commitment
from the Director to invite HMC representatives to participate in
upcoming strategic planning sessions. The strategic plan is to be
completed before the next budget cycle.

ƒ

The Governor’s Authorized Representative, who co-chairs the
HMC, has agreed to have the Governor’s office develop an
executive order directing State agencies to work with the HMC to
integrate hazard mitigation concepts into State operations where
feasible.

ƒ

The HMC is developing a presentation and training program to
educate State workers about the need for hazard mitigation and
the ways that mitigation can be integrated into everyday
operations.

ƒ

The State Smart Growth Office, a strong supporter of hazard
mitigation, and with representation on the HMC, has developed a
new position, Hazard Reduction Policy Coordinator. The
Coordinator is the first paid hazard mitigation employee hired by
the State who is outside the State Office of Emergency
Preparedness.

These new initiatives will create a comprehensive approach to
reducing losses in the State. The State’s CRS and FMA programs
have been in place since these programs were created. Additionally,
the State received PDM funding for all planning and project grant
applications it submitted in fiscal year 2004.

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3. PROJECT IMPLEMENTATION CAPABILITY
Requirement
§201.5(b)(2)(i)
and (ii):

Explanation:
(Rev. June 2007)

[The Enhanced Plan must document] the State’s project implementation
capability, identifying and demonstrating the ability to implement the plan,
including:
ƒ

Established eligibility criteria for multi-hazard mitigation measures.

ƒ

A system to determine the cost effectiveness of mitigation measures,
consistent with OMB Circular A-94, Guidelines and Discount Rates
for Benefit-Cost Analysis of Federal Programs, and

ƒ

[A system] to rank the measures according to the State’s eligibility
criteria.

These requirements build on §201.4(c)(3)(ii), which is discussed in the
sections on State and local capability assessment on pages 1-37 through
1-42. However, while §201.4(c)(3)(ii) requires that the State demonstrate
its capabilities to implement policies and programs to mitigate hazards,
§201.5(b)(2)(i) requires that States identify their eligibility criteria for
mitigation actions during the planning process.
Development of such criteria was formerly undertaken during the grant
application process. These eligibility criteria should be integral to
developing a State’s mitigation strategy where, ideally, mitigation actions
would be categorized by short, medium, and long-term timeframes and
then further prioritized as high, medium, or low.
Per §201.5(b)(2)(ii), States must also describe their approach to
evaluating the cost-effectiveness of identified actions and explain or
demonstrate how this approach is consistent with OMB Circular A-94.
The description should include the agency and staff responsible for
conducting benefit-cost analyses, reviews, or any other assessment
method used.
For all State and FEMA mitigation programs, the plan must describe how
the State ranks mitigation measures according to its eligibility criteria.
The system must include a process for prioritizing projects among
jurisdictions and among proposals that address different or multiple
hazards. The system does not have to be a point system or grading
scale but should clearly explain how projects are prioritized.

Plan Update:

The documentation of project implementation capability must explain any
changes to eligibility criteria, including any that have been added or
eliminated since the approval of the previous plan, and any changes to
the system of determining the cost effectiveness of mitigation measures
consistent with OMB Circular A-94.
States must, at a minimum, ensure their Mitigation Plan includes
eligibility criteria and a system for cost effectiveness determination for all
State and FEMA mitigation grant programs (HMGP, FMA, PDM, SRL,
RFC). Project implementation procedures for HMGP may be directly
included in the State Mitigation Plan or referenced back to the HMGP

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Administrative Plan.

Resource:

For information on prioritizing actions and determining eligibility, and for a
discussion about methods to determine cost effectiveness, see
respectively:
9

Developing the Mitigation Plan (FEMA 386-3), Step 2.

9

Mitigation Benefit Cost Analysis (BCA) Toolkit Compact Disc (CD).

9 OMB Circular A-94: See
http://www.whitehouse.gov/omb/circulars/a094/a094.html
Examples:
Original Submittal:
During the formation of its Mitigation Strategy, the State developed
eligibility criteria for determining how hazard mitigation projects will be
addressed. These criteria were initially developed for the HMGP
application and have been revised.
Each County within the State provided a prioritized list of mitigation
projects for their municipalities. These projects included such things as
buyouts for repetitive flood loss properties, the building of tornado
shelters, the application of certain communities to the CRS program, and
the development of new routes for the transportation of hazardous
materials. The State then categorized these projects by their priority to the
County, their cost, and the timeframe for implementation.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.5(b)(2)
(i) and (ii)

REVIEWER’S COMMENTS

ƒ

The plan does not list the eligibility
criteria, the method used to determine
cost effectiveness, or the system for
ranking actions.

Required Revisions:
The plan must list its eligibility criteria and address how cost-benefit
analysis, review, or other methods were used to determine cost
effectiveness of actions. It must also describe the system for ranking
eligible actions.
Revised Submittal:
During the formation of its Mitigation Strategy, the State developed
eligibility criteria for determining how hazard mitigation projects will be
addressed. These criteria were initially developed for the HMGP
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application and have been revised. This was done through the State
Hazard Mitigation Planning Committee in regular meetings with the
Counties. The eligibility criteria requires projects to:
ƒ

Be cost effective.

ƒ

Address repetitive loss properties.

ƒ

Be located in the most vulnerable areas identified in the State
Hazard Mitigation Plan.; and

ƒ

Have local matching funds (including in-kind contributions).

Each County within the State provided a prioritized list of mitigation
projects for their municipalities. These projects included such things as
buyouts for repetitive flood loss properties, the building of tornado
shelters, the application of certain communities to the CRS program, and
the development of new routes for the transportation of hazardous
materials. The State then categorized these projects by their priority to the
County, their cost, and the time frame for implementation.
The State helped the Counties apply a cost-benefit analysis to their
proposed mitigation projects. The Counties used this analysis to
prioritize their projects. Projects were prioritized by such items as
frequency of the disaster being mitigated, financial impact to the
community, human losses, and timeframe for completion. For
example, flooding is the biggest concern in certain areas of the
State, whereas in the “flats” tornadoes are the major concern. Each
County has a different prioritization for hazard mitigation projects
within its jurisdiction (see Appendix XX for a list of criteria provided
by County).
The State is then responsible for prioritizing each of the County’s
projects with respect to how much and when State help will be
available. The State takes the number one priority for each County
and then ranks these projects by giving a certain number of points to
as follows:
ƒ

Cost effectiveness (i.e., those projects that demonstrate that they
are the most cost effective) (20 to 35 points).

ƒ

Listing on the Repetitive Loss Property List (40 points).

ƒ

Location within the most vulnerable areas in the State (10 to 25
points).

In addition to funding, the State provides support to the Counties in
several ways, including actual project implementation, seeking
additional funding, project support, public involvement activities,
and the provision of additional information (see Appendix XX for a
list of ranked projects).
The State Hazard Mitigation Committee (HMC) tracks when and how
projects are being implemented, as well as how their funding is
being used (see Section XX of the plan for more details). If there is a
problem or conflict with a project, the State acts as a mediator to
resolve the problem as quickly and efficiently as possible. The State
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also conducts “lessons learned” meetings with Counties as
necessary. As projects are completed, the State makes note of this in
each County’s file and maintains records on every project.

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4. PROGRAM MANAGEMENT CAPABILITY
Requirement
§201.5(b)(2)(iii
A-D):

Explanation:
(Rev. June 2007)

[The Enhanced Plan must demonstrate] that the State has the capability
to effectively manage the HMGP as well as other mitigation grant
programs, [and provide] a record of the following:
ƒ

Meeting HMGP and other mitigation grant application timeframes and
submitting complete, technically feasible, and eligible project
applications with appropriate supporting documentation;

ƒ

Preparing and submitting accurate environmental reviews and
benefit-cost analyses;

ƒ

Submitting complete and accurate quarterly progress and financial
reports on time; and

ƒ

Completing HMGP and other mitigation grant projects within
established performance periods, including financial reconciliation.

Because approval of an Enhanced Plan results in increased HMGP grant
funding, this section requires States to demonstrate their capabilities to
effectively manage the HMGP and other mitigation grant funds, including
funds from the Pre-Disaster Mitigation (PDM), Flood Mitigation
Assistance (FMA) and Repetitive Flood Claims (RFC) programs, they
have previously received. FEMA Regional offices will evaluate and certify
that the State has the capability to effectively manage FEMA mitigation
grant programs. The State is currently not required to document this in
their plan.
The criteria that are used for this evaluation are currently being refined
and will be revised with State input. FEMA has been utilizing an
Enhanced State Multi-Hazard Mitigation Plan Program Information
Worksheet, dated May 2005, to evaluate the requirements under
§201.5(b)(2)(iii A-D). This worksheet will continue to be utilized until the
revised criteria are issued. The revised criteria will not be implemented
immediately upon release, but will be effective a sufficient interval of time
after publication to allow the State to demonstrate capability under the
revised criteria.

Plan Update:

Any update of this element will be successfully met through the State’s
continued demonstration that, for the past 3-year period, it has
maintained the capability to effectively manage the HMGP as well as
other mitigation grant programs. FEMA regional offices will re-evaluate
and re-certify that, for the past 3-year period, the State has demonstrated
the capability to effectively manage the HMGP and other mitigation grant
programs.

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5. ASSESSMENT OF MITIGATION ACTIONS
Requirement
§201.5(b)(2)(iv):

[The Enhanced Plan must document the] system and strategy by which
the State will conduct an assessment of the completed mitigation actions
and include a record of the effectiveness (actual cost avoidance) of each
mitigation action.

Explanation:

§201.5(b)(2)(iv) builds on §201.4(c)(5)(ii) and (iii), which were discussed
previously in Monitoring Progress of Mitigation Activities (page 1-59).
States must describe how they would assess the effectiveness of each
completed mitigation action, what agency or agencies will be involved in
the assessment, and indicate the timeframe for carrying out this
assessment. The results of this assessment will be necessary during the
next plan update to verify achievement of the plan’s goals and objectives,
and to fine-tune or revise the mitigation strategy.
The State must describe how it will track potential losses avoided for each
action taken (e.g., by developing a database or GIS system) since, in
many cases, losses avoided cannot be accurately determined until a
disaster occurs and damages are assessed.

Plan Update:

States must describe how they assessed, and how they will continue to
assess, the effectiveness of completed mitigation actions, including
discussion of those agencies whose involvement was initially proposed
and those who actually participated in the assessment, and the timeframe
required to complete the assessment.
The State must describe how it tracked, and will continue to track,
potential losses avoided for each action taken. Where disasters have
occurred since the approval of the previous plan, the update must include
a record of the actual cost avoidance of each completed mitigation action.
FEMA recognizes that there may be unforeseeable situations where, due
to the timing, magnitude of one or more disaster(s) and/or the large
number of completed mitigation actions for which losses avoided must be
assessed, it is impracticable for the State to complete the assessment of
losses avoided within the timeframe by which the updated plan must be
submitted to FEMA for approval. If such a situation exists, the plan must:

Resource:

•

Include a discussion of the unforeseeable circumstances (including
timing of the event or events and the number of mitigation actions
for which losses avoided must be assessed);

•

The system or approach that will be used to assess losses
avoided, and

•

A proposed timeframe for completing this work.

For information on how to evaluate the effectiveness of mitigation actions
see:
Bringing the Plan to Life (FEMA 386-4), Step 3.

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Examples:
Original Submittal:
The State has established a method to determine the effectiveness of
mitigation actions being undertaken in the State. During the preparation of
the State Hazard Mitigation Plan, the State partnered with the State
University to develop several economic analysis models to determine the
economic feasibility of various past mitigation actions. One of these
models considered reductions in physical damages and financial losses
that helped determine the effectiveness of mitigation actions by showing
the resulting reduction in damages and losses. Other models showed
various cost-benefit analyses to help communities decide which mitigation
activities to implement.
Several of the State’s communities currently have hazard mitigation plans
in place. The economic models can be applied to those existing plans as
well as help communities who are in the process of developing hazard
mitigation plans. The State will provide help to the local communities in
running and analyzing the economic models.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.5(b)(2)
(iv)

COMMENTS
REVIEWER’S COMMENTS

ƒ

ƒ

The State is active in trying to assess
the effectiveness of its mitigation
actions; however, no specifics are
given.
It is not clear what agency or agencies
will be responsible for developing and
implementing the economic modeling
analyses or how the local communities
will benefit.

Required Revisions:
The plan must provide specific information about how the effectiveness of
mitigation actions will be assessed. Specific agency or agencies must be
mentioned and a timeframe for conducting these assessments must be
developed.
Revised Submittal:
The State has established a method to determine the effectiveness of
mitigation actions being undertaken in the State. During the preparation of
the State Hazard Mitigation Plan, the State partnered with the State
University to develop several economic analysis models to determine the
economic feasibility of various past mitigation actions. One of these
models considered reductions in physical damages and financial losses
that helped determine the effectiveness of mitigation actions by showing
the resulting reduction in damages and losses. Other models showed
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various cost-benefit analyses to help communities decide which mitigation
activities to implement.
As part of the State Hazard Mitigation Plan, the State Office of
Economic Development partnered with the State University to
develop several economic models to assess the losses avoided by
various mitigation actions. These models used hazard data from
recent events to determine the likely damages to structures had
mitigation actions not taken place. The models then used the
probability of the event to calculate the avoided damages based on
the net present value of the benefits.
Several of the State’s communities currently have hazard mitigation plans
in place. The economic models can be applied to those existing plans as
well as help communities who are in the process of developing hazard
mitigation plans. The State will provide help to the local communities in
running and analyzing the economic models.
The Office of Economic Development is working with local
communities to help them apply these analyses. A majority of the
State’s communities already have implemented some mitigation
actions, and these models can be applied to quantify the benefits of
mitigation activities identified in previous mitigation plans. The State
Office of Planning is working with the remainder of the communities
to develop hazard mitigation plans, whereupon economic feasibility
analyses can be applied to specific mitigation strategies.
Following hazard events in the areas receiving mitigation action,
communities will be required to show what damages and losses
have been avoided (e.g., structural damages prevented, business
inventory damages prevented, rental income losses avoided,
personal property losses prevented) by implementing their
mitigation strategies. The communities are allowed discretion in
determining how they will track losses avoided (e.g., utilizing GIS or
database technology).
The Office will review these analyses and provide feedback to the
communities. The Office of Economic Development will conduct
yearly checks on the communities to ensure that they are using
these analyses effectively. It is recognized that non-economic factors
are a major consideration and are difficult to incorporate into
economic modeling.

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6. EFFECTIVE USE OF AVAILABLE MITIGATION FUNDING
Requirement
§201.5(b)(3):

[The Enhanced Plan must demonstrate] that the State effectively uses
existing mitigation programs to achieve its mitigation goals.

Explanation:

In order for FEMA to increase the amount of HMGP funding available to a
State in subsequent disasters, it is important that the State document that
it has fully and effectively made use of FEMA and other funding already at
its disposal. States must demonstrate how they have taken advantage of
FEMA programs, such as FMA, HMGP, PDM, SRL and RFC to fund
mitigation actions. If States have used other FEMA and non-FEMA
funding to support mitigation, they should include this documentation as
well. The State should also discuss how it leveraged its own funds (i.e., to
provide match or cost share) with FEMA or other federal programs to
implement mitigation.

(Rev. June 2007)

If the State has not made full use of existing mitigation programs, the plan
must explain the reasons why. Acceptable reasons include, but are not
limited to, unavailable non-federal match, uninterested property owners, or
insufficient program funds to implement prioritized mitigation actions.
Limited staff resources is not considered an acceptable reason, and would
invalidate §201.5(b)(2)(iii) that requires the State to demonstrate program
management capability (see pages 2-12 and 2-13, Part 1, items A.1.
through A.4.).
In addition to describing actions and projects that have been implemented,
the plan must link the projects to specific State goals and objectives and
assess the effectiveness of the projects in achieving the goals.
The plan should also describe the State’s strategy for ensuring continued
effective use of resources (e.g., forming partnerships to leverage funding).
Plan Update:

The updated plan must document how the State has fully made use of
funding available through FEMA mitigation programs, including the
HMGP, PDM, FMA, SRL and RFC programs.
The updated plan must also document how the State effectively uses
existing mitigation programs to achieve its mitigation goals.

Resource:

For information on how to evaluate the effectiveness of mitigation actions
in achieving the plan’s goals, see:
9 Bringing the Plan to Life (FEMA 386-4), Step 3.

Examples:
Original Submittal:
The State uses a variety of funds and programs to achieve its mitigation
goals, including the Flood Mitigation Assistance Program (FMA), the
Hazard Mitigation Grant Program (HMGP), and the State Hazard
Mitigation Assistance Initiative (HMAI).
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REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.5(b)(3)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The plan needs to explain how the
State has taken advantage of all of the
hazard mitigation opportunities currently
available to them.

Required Revisions:
The revised plan must explain how the State uses Federal and State
hazard mitigation funds and programs to achieve its goals, including the
possible combination of two or more funding programs.
Revised Submittal:
The State uses a variety of funds and programs to achieve its mitigation
goals, including the Flood Mitigation Assistance Program (FMA), the
Hazard Mitigation Grant Program (HMGP), and the State Hazard
Mitigation Assistance Initiative (HMAI). These are described below:
Flood Mitigation Assistance Program (FMA): The State has facilitated
the use of FMA funds by local governments for the development of
local hazard mitigation plans and projects. The State Hazard
Mitigation Grant Coordinator visits each County yearly to develop
local project applications and provides project management
oversight for the grant. The State’s goal is to have one-quarter of its
communities using FMA project, planning, or technical assistance
funds each year to help fund planning initiatives, projects, or flood
hazard studies.
Hazard Mitigation Grant Program (HMGP): The State has facilitated
the use of HMGP funds for post-disaster hazard mitigation projects.
Because HMGP funds are post-disaster funds and their availability
from year to year is uncertain and limited, the State only allows
funding for local projects that are captured in existing local hazard
mitigation strategies. Also, the State uses its 5% HMGP set-aside to
help fund State technical assistance to local governments.
State Hazard Mitigation Assistance Initiative (HMAI): The State can
provide up to 12.5% matching funds through the HMAI to help fund
local hazard mitigation projects implemented through HMGP or FMA.
These funds are provided to localities based first on need (i.e., there
are few local resources to meet the 25% match requirement for
Federal grants), and then on a competitive basis that compares
benefit-cost analyses, environmental compatibility and justice, and
political viability across jurisdictions.

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7. COMMITMENT TO A COMPREHENSIVE MITIGATION PROGRAM
Requirement
§201.5(b)(4)(i-vi):

Explanation:

[The Enhanced Plan must demonstrate] that the State is committed to a
comprehensive state mitigation program, which might include any of the
following:
ƒ

A commitment to support local mitigation planning by providing
workshops and training, State planning grants, or coordinated
capability development of local officials, including Emergency
Management and Floodplain Management certifications.

ƒ

A Statewide program of hazard mitigation through the development of
legislative initiatives, mitigation councils, formation of public/private
partnerships, and /or other executive actions that promote hazard
mitigation.

ƒ

The State provides a portion of the non-Federal match for HMGP
and/or other mitigation projects.

ƒ

To the extent allowed by State Law, the State requires or encourages
local governments to use a current version of a nationally applicable
model building code or standard that addresses natural hazards as a
basis for design and construction of State sponsored mitigation
projects.

ƒ

A comprehensive, multi-year plan to mitigate the risks posed to the
existing buildings that have been identified as necessary for postdisaster response and recovery operations.

ƒ

A comprehensive description of how the State integrates mitigation
into its post-disaster recovery operations.

The intent of this requirement is to allow States to describe mitigationrelated activities that do not necessarily have a basis in a program or
regulation. These activities truly show State commitment to reducing
losses from hazards. States may demonstrate this commitment by
describing how they have successfully implemented programs or projects
that have reduced their exposure to hazards and how they will build on
these past successes. Each State’s mitigation strategy may include, but
is not limited to, any of those elements mentioned above. Other actions
that go “above and beyond” the requirements of the Standard Plan will be
considered. If a State has no previous experience with mitigation
initiatives, then the plan may only contain the various elements that the
State proposes to implement. In either case, States should provide a
timeframe for implementing these initiatives.
If the documentation to satisfy this plan requirement is not included in its
own section of the plan, the plan review crosswalk accompanying the
plan should identify where in the plan these various commitments are
described.

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PART 2 - ENHANCED STATE MITIGATION PLANS
Plan Update:

The plan update process includes the review of those mitigation-related
initiatives identified in the previously approved plan. The update must
demonstrate progress in implementing a comprehensive state mitigation
program. Any additional mitigation initiatives that have been developed
and/or implemented in the intervening period must be described in the
updated plan.

Special
Considerations:

Although the Rule requirements do not specifically mention the
development of a statewide risk assessment as a means to facilitate
better coordination and detail in local mitigation planning, carrying out
such an activity is a good way to meet this particular requirement.

Resource:

For information on implementing a hazard mitigation program, see:
9

Bringing the Plan to Life (FEMA 386-4), Step 2.

For ideas and examples of mitigation programs, policies, and projects,
see:
9 Developing the Mitigation Plan (FEMA 386-3), Steps 1 and 2.
Examples:
Original Submittal:
The State has developed a program by which it provides hazard mitigation
training workshops for local governments. The State advertises the
availability of the program through a brochure mailing that details the
procedures for requesting the workshop.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.5(b)(4)
(i-vi)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The description of providing assistance
is very brief; it does not include such
details as the duration of the workshops,
the staff or agencies providing training,
or sources of funding.

Required Revisions:
The plan must document in detail the process by which the State
implements its hazard mitigation programs and initiatives. If the program
has been in place for some time, the plan should provide details about the
results or performance of the program.
Revised Submittal:
The State has developed a program by which it provides hazard mitigation
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PART 2 - ENHANCED STATE MITIGATION PLANS
training workshops for local governments. The State advertises the
availability of the program through a brochure mailing that details the
procedures for requesting the workshop. After a local government
requests the training workshop, the State coordinates the logistical
details with the local government for holding the workshop.
The following State HMC representatives have been trained and
authorized to conduct training for local governments on hazard
mitigation planning:
ƒ

The State Hazard Mitigation Officer, State Office of Emergency
Preparedness

ƒ

The Hazard Reduction Policy Coordinator, State Smart Growth
Office

ƒ

The Environmental Stewardship Officer, State Division of
Environmental Protection

Funding for the two-day workshop is provided through the State
Hazard Mitigation Assistance Initiative (HMAI) and local funds. Each
County government receives up to $1,500 to arrange the location,
audio/visual equipment, invitations to interested staff and other local
interested parties, and food. Any shortfall is made up through local
funds. Since the training workshop program’s initiation in 1999, five
workshops have been conducted, and each of these localities has
submitted a compliant hazard mitigation plan within one year of the
workshop, as required.

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PART 3 – LOCAL MITIGATION PLANS
Local Mitigation Plan requirements in §201.6 of the Interim Final Rule (the Rule) apply to both
local jurisdictions and Tribal governments that elect to participate in FEMA mitigation grant
programs as a subapplicant or subgrantee (henceforth referred to as local jurisdictions). The
local mitigation planning requirements in this section encourage agencies at all levels, local
residents, businesses, and the non-profit sector to participate in the mitigation planning and
implementation process. This broad public participation enables the development of mitigation
actions that are supported by these various stakeholders and reflect the needs of the
community. Private sector participation, in particular, may lead to identifying local funding that
would not otherwise have been considered for mitigation activities.
As with State plans, the DMA 2000 requirements for local plans require that communities
address only natural hazards. FEMA recommends, however, that local comprehensive
mitigation plans address manmade and technological hazards if possible. In many instances,
natural disasters have secondary effects, such as dams breaking due to floods, or hazardous
material releases due to tornadoes. Multi-hazard plans will better serve communities in the
event of such disasters.
States are required to coordinate with local governments in the formation of hazard mitigation
strategies, and the local strategies combined with initiatives at the State level form the basis for
the State Mitigation Plan. With the information contained in Local Mitigation Plans, States are
better able to identify technical assistance needs and prioritize project funding. Furthermore, as
communities prepare their plans, States can continually improve the level of detail and
comprehensiveness of statewide risk-assessments.
For the Pre-Disaster Mitigation (PDM) program, local jurisdictions must have an approved
mitigation plan to receive a project grant. Local jurisdictions must have approved plans by
November 1, 2004, to be eligible for Hazard Mitigation Grant Program (HMGP) funding for
Presidentially declared disasters after this date. Plans approved at any time after November 1,
2004, will make communities eligible to receive PDM and HMGP project grants.
The sections covered in Part 3 – Local Mitigation Plans include:
ƒ

Prerequisites

ƒ

Planning Process

ƒ

Risk Assessment

ƒ

Mitigation Strategy

ƒ

Plan Maintenance Process

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PART 3 – LOCAL MITIGATION PLANS
PREREQUISITES
The local jurisdictions submitting the plan must satisfy the following prerequisites before the
plan can be approved by FEMA.
ADOPTION BY THE LOCAL GOVERNING BODY
Requirement
§201.6(c)(5):

[The local hazard mitigation plan shall include] documentation that the
plan has been formally adopted by the governing body of the jurisdiction
requesting approval of the plan (e.g., City Council, County
Commissioner, Tribal Council).

Explanation:

Adoption by the local governing body demonstrates the jurisdiction’s
commitment to fulfilling the mitigation goals and objectives outlined in the
plan. Adoption legitimizes the plan and authorizes responsible agencies
to execute their responsibilities. The plan shall include documentation of
the resolution adopting the plan.

Resource:

For more information about adopting the mitigation plan, see:
9 Bringing the Plan to Life (FEMA 386-4), Step 1.

Scoring:

‰

Not Met. The plan has not been formally adopted by the local
governing body.

‰

Not Met. The plan has been formally adopted by the local governing
body, but a copy of the signed plan adoption resolution is not
included.

‰

Met. The plan has been formally adopted by the local governing
body and a copy of the signed plan adoption resolution is included.

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PART 3 – LOCAL MITIGATION PLANS
MULTI-JURISDICTIONAL PLAN ADOPTION
Requirement
§201.6(c)(5):

For multi-jurisdictional plans, each jurisdiction requesting approval of the
plan must document that it has been formally adopted.

Explanation:

In order for multi-jurisdictional plans to be approved, each jurisdiction
that is included in the plan must have its governing body adopt the plan
before submission to the State and FEMA, even when a regional agency
has the authority to prepare such plans in the name of the respective
jurisdictions.

Resource:

For more information about adopting the mitigation plan, see:
9 Bringing the Plan to Life (FEMA 386-4), Step 1.

Scoring:

‰

Not Met. The plan has not been formally adopted by any local
governing body.

‰

Met. The plan has been formally adopted by at least one local
governing body and a copy of each of the signed plan adoption
resolutions is included. Alternatively, the agency responsible for
submitting the plan may certify that each of the local governing
bodies has adopted the plan and that resolutions are available for
review at its office.

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PART 3 – LOCAL MITIGATION PLANS
MULTI-JURISDICTIONAL PLANNING PARTICIPATION
Requirement
§201.6(a)(3):

Multi-jurisdictional plans (e.g., watershed plans) may be accepted, as
appropriate, as long as each jurisdiction has participated in the
process … Statewide plans will not be accepted as multi-jurisdictional
plans.

Explanation:

A multi-jurisdictional plan, as prepared by regional planning and
development authorities (e.g., watershed/river basin commission), is
acceptable as a Local Mitigation Plan under DMA 2000. However, those
jurisdictions within the planning area that do not participate in its
development will not be eligible for future mitigation project grant
assistance from FEMA. Therefore, the plan must document how each
jurisdiction requesting FEMA recognition of the plan participated in the
planning process.

Resource:

For more information on initiating a comprehensive local mitigation
planning process, see:
9 Getting Started (FEMA 386-1), Steps 1 – 4.

Scoring:

‰

Not Met. The plan does not describe how each jurisdiction
requesting FEMA recognition actively participated in the planning
process.

‰

Met. The plan describes how each jurisdiction requesting FEMA
recognition actively participated in the planning process.

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PART 3 – LOCAL MITIGATION PLANS

PLANNING

PROCESS

§201.6(b) requires that there be an open public involvement process in the formation of a plan.
This process shall provide an opportunity for the public to comment on the plan during its
formation as well as an opportunity for any neighboring communities, businesses, and other
interested parties to participate in the planning process. This public involvement, along with the
review of any existing plans, studies, reports, and technical information and incorporation of
these in the plan, will assist in the development of a comprehensive approach to reducing
losses from natural disasters.
§201.6(c)(1) requires the documentation of the planning process, including how the plan was
prepared, who was involved in the process, and how the public was involved.
This section includes the following subsection:
ƒ

Documentation of the Planning Process

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PART 3 – LOCAL MITIGATION PLANS
DOCUMENTATION OF THE PLANNING PROCESS
Requirements
§201.6(b) and
§201.6(c)(1):

An open public involvement process is essential to the development of
an effective plan. In order to develop a more comprehensive approach to
reducing the effects of natural disasters, the planning process shall
include:
(1) An opportunity for the public to comment on the plan during the
drafting stage and prior to plan approval;
(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
(3) Review and incorporation, if appropriate, of existing plans, studies,
reports, and technical information.
[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.

Explanation:

The description of the planning process shall:
ƒ

Indicate how the public (residents, businesses, and other interested
parties) was given the opportunity to comment on the plan during the
drafting stage and prior to plan approval (e.g., public meetings, Web
pages, storefronts, toll-free telephone lines, etc.).

ƒ

Include a discussion of the opportunity provided for neighboring
communities, agencies involved in hazard mitigation, and
businesses, academia, and other relevant private and non-profit
interests to be involved.

ƒ

Describe the review of any existing plans, studies, reports, and
technical information and how these are incorporated into the plan.

The plan shall document how the plan was prepared (e.g., the time
period to complete the plan, the type and outcome of meetings), who
was involved in the planning process (e.g., the composition of the
planning team), and how the public was involved.
The plan should also document how the planning team was formed and
how each party represented contributed to the process. Ideally, the local
mitigation planning team is composed of local, State, and Federal
agency representatives, as well as community representatives, local
business leaders, and educators.

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PART 3 – LOCAL MITIGATION PLANS
Special
Considerations:

The planning team should consider adding a general description of the
jurisdiction in this section or in the introduction of the plan. The
description can include a socio-economic, historic, and geographic
profile to provide a context for understanding the mitigation actions that
will be implemented to reduce the jurisdiction’s vulnerability.

Resource:

For more information on the planning process; ideas on identifying
stakeholders and building the planning team, generating public interest,
enlisting partners, and choosing an appropriate public participation
model; and advice to local governments seeking to initiate a
comprehensive local mitigation planning process, see:
9 Getting Started (FEMA 386-1), Steps 1 – 3.

Examples:
Original Submittal:
The Pleasant County Planning Department has developed a local
hazard mitigation plan. The Planning Department formed a planning
team composed of representatives from State government, local City
governments, community groups, local businesses, and the State
University, which is located in Pleasant County. The plan was developed
over one year.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(b)
and
§201.6(c)(1)

COMMENTS
REVIEWER’S COMMENTS

ƒ

ƒ

ƒ

The planning process included
representatives from many
organizations, but there is no mention
of opportunities for the public to
comment on the plan.
The plan does not indicate that an
opportunity was provided for
neighboring communities, agencies,
etc. to be involved in the planning
process.
The plan does not indicate whether
any appropriate existing plans,
studies, reports, and technical
information were reviewed and
incorporated.

Required Revisions:
To receive a “Satisfactory” score, the plan must include more specific
details on the planning process and discuss opportunities provided to
the public to comment on the plan.
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PART 3 – LOCAL MITIGATION PLANS

Revised Submittal:
The Pleasant County Planning Department has developed a local
hazard mitigation plan. The County Planning Department was
responsible for development of the plan. The Planning Department
formed a planning team composed of representatives from State
government, local City governments, community groups, local
businesses, and the State University, which is located in Pleasant
County (see Appendix XX for a list of team members). This team met
every two weeks for three months and once a month thereafter. The
team also held two meetings with adjacent counties to obtain their
involvement in the planning process. The plan was developed over
one year.
An effort was made to solicit public input during the planning
process and four public meetings were held during the formation of
the plan: one at the beginning, one after a first draft was produced,
one after a final draft was produced, and one public hearing that
was held two weeks before the plan was adopted. Citizens could
also access the County Hazard Mitigation Plan Web site to provide
input.
The State University assisted greatly in the development of the plan
by providing graduate students from the Urban Studies and
Planning Department to help County Planning Department Staff.
The students were very helpful in collecting existing plans, studies,
and reports as well as interviewing officials to obtain the latest
status on projects identified in plans. The planning team used the
information to create a report on upcoming and current projects
designed to reduce Pleasant County’s vulnerability. The list of
documents reviewed is included in Appendix XX. These students
helped organize the public meetings and maintained the Web site.
Feedback received from the public proved valuable in the
development of the plan. Several comments were received that led
to the rethinking of some proposed priority mitigation actions,
including some from residents of the rural southern portion of the
County that illustrated the need for assistance with maintaining
drainage channels. As access to this very rural area is by one-lane
or gravel roads, it is often overlooked by the County Public Works
Office. During the last heavy rainfall several of the small creeks
were blocked by debris, causing backup flooding of several of the
properties. Maintenance and clearing of channels are activities that
are now included in the flood hazard portion of the Hazard
Mitigation Plan.

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PART 3 – LOCAL MITIGATION PLANS

RISK ASSESSMENT
§201.6(c)(2) of the Rule requires local jurisdictions to provide sufficient information from which
to develop and prioritize appropriate mitigation actions to reduce losses from identified hazards.
This includes detailed descriptions of all the hazards that could affect the jurisdiction along with
an analysis of the jurisdiction’s vulnerability to those hazards. Specific information about
numbers and types of structures, potential dollar losses, and an overall description of land use
and development trends should be included in this analysis. For multi-jurisdictional plans, any
risks that affect only certain sections of the planning areas must also be assessed in the context
of the affected area.
Recognizing that data may not be readily available to complete the risk assessment at this time,
FEMA recommends that plans identify any data limitations. Actions to obtain the data to
complete and improve future risk analysis efforts should be included in the mitigation strategy.
While the Rule does not require the use or inclusion of maps as part of the plan, FEMA
recommends the use of maps, where appropriate, to illustrate the required risk assessment
information. Additionally, addressing manmade hazards in the plan is not necessary to meet the
Rule requirements, but is encouraged.
For helpful definitions of risk assessment and related terms, please refer to Understanding Your
Risks (FEMA 386-2), Appendix A, Glossary.
This section includes the following six subsections as follows:
ƒ

Identifying Hazards

ƒ

Profiling Hazards

ƒ

Assessing Vulnerability: Overview

ƒ

Assessing Vulnerability: Identifying Structures

ƒ

Assessing Vulnerability: Estimating Potential Losses

ƒ

Assessing Vulnerability: Analyzing Development Trends

ƒ

Multi-jurisdictional Risk Assessment

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PART 3 – LOCAL MITIGATION PLANS
IDENTIFYING HAZARDS
Requirement
§201.6(c)(2)(i):

[The risk assessment shall include a] description of the type … of all
natural hazards that can affect the jurisdiction … .

Explanation:

The local risk assessment shall identify and describe the hazards likely
to affect the area. It is critical that the plan identify all the natural hazards
that can affect the jurisdiction, because the hazard identification is the
foundation for the plan’s risk assessment, which in turn is the factual
basis for the mitigation strategy. If the hazard identification omits (without
explanation) any hazards commonly recognized as threats to the
jurisdiction, this part of the plan cannot receive a “Satisfactory” score.
While not required by the Rule, the plan should describe the sources
used to identify hazards, and provide an explanation for eliminating any
hazards from consideration. The process for identifying hazards could
involve the following:

Resource:

ƒ

Reviewing the State hazard mitigation plan, reports, plans, flood
ordinances, and land use regulations, among others;

ƒ

Talking to experts from Federal, State, and local agencies and
universities;

ƒ

Searching the Internet and newspapers; and

ƒ

Interviewing long-time residents.

For more information on identifying hazards, see:
9 Understanding Your Risks (FEMA 386-2), Step 1, Worksheet #1
Identify the Hazards.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2.
9 Multi-Hazard Identification and Risk Assessment.
9 HAZUS-MH at www.fema.gov/HAZUS/.
9 Firewise at www.firewise.org.

Examples:
Original Submittal:
Pleasant County has identified several hazards to be addressed in the
County’s Hazard Mitigation Plan. These hazards were identified during
the development of the County’s plan based on input from Planning
Committee members, and were determined to be the hazards that

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PART 3 – LOCAL MITIGATION PLANS
present the highest risk for the County.
The Pleasant County Mitigation Plan addresses the following hazards:
ƒ

Hurricanes

ƒ

Flooding

ƒ

Terrorism
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(2)
(i)

COMMENTS
REVIEWER’S COMMENTS

ƒ
ƒ

It is not clear if the County identified
all relevant hazards.
The County did not indicate how the
hazards were identified.

Required Revisions:
To receive a “Satisfactory” score, the plan must include coastal erosion
as a hazard since a portion of the County lies along the coast.
Revised Submittal:
Pleasant County has identified several hazards to be that are
addressed in the County’s Hazard Mitigation Plan (Table 1). These
hazards were identified during the development of the County’s plan
based on input from Planning Committee members, and were
determined to be the hazards that present the highest risk for the
County. through an extensive process that utilized input from
Planning Committee members (comprised of representatives
from County agencies, City governments, local businesses,
community groups, State Emergency Management Offices, and
the State University), public input, researching past disaster
declarations in the County, a review of current FIRMs, and risk
assessments completed by the County Emergency Management
Agency.
The Pleasant County Mitigation Plan addresses the following hazards:
ƒ

Hurricanes

ƒ

Flooding

ƒ

Terrorism

In addition, the County Planning Agency is developing a GIS
database that will map the County’s infrastructure, critical
facilities, and land uses. Initial data from this study was also used
to determine those hazards that present the greatest risk to the
County.
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Table 1: Hazards in Pleasant County
Hazard
How identified
Hurricanes • Review of past disaster
declarations
• Input from County Department
of Natural Resources
• Input from residents
• Risk Assessments
Flooding
(Riverine
and
Coastal)

•
•
•
•
•
•

Coastal
Erosion

•
•
•
•

Terrorism

•
•

•
•

Review of FIRMs
Input from County Planning
Office
Risk Assessments
Public input
Review of past disaster
declarations
Identification of NFIP repetitive
loss properties in the County

•

Input from County Planning
Office
Input from County Department
of Natural Resources
Input from the State University
(conducting shoreline
research)
Public input

•

Input from local utility
company
Public input

•

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•
•

•
•

•

Why identified
The County is hit almost every
year by a hurricane
Hurricanes have caused
damage (personal and
property), flooding, and
evacuation situations
Associated with the effects of
hurricanes, which hit the
County frequently
Several repetitive loss
properties are located in the
County
The County contains many
rivers and streams, and is
located along the coast
The County is undergoing
development pressure along
the coast
Coastline stabilization
measures have been
implemented in the past year
Related to hurricane
frequency
Nuclear power plant is located
in the County
Heightened sense of security
since September 2001

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PROFILING HAZARDS
Requirement
§201.6(c)(2)(i):

[The risk assessment shall include a] description of the … location 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.

Explanation:

The description of each hazard shall include the following information:
ƒ

The location or geographical areas in the community that would be
affected.

ƒ

The hazard extent (i.e., magnitude or severity) of potential hazard
events. For those hazards not geographically determined, plans shall
indicate their applicable intensity. For example, in areas where
tornadoes occur, plans should indicate the recorded intensities of
previous events.

ƒ

The probability, likelihood, or frequency that the hazard event would
occur in an area.

The plan shall also provide a discussion of past occurrences of hazard
events in or near the community. This discussion should include:
ƒ

Information on the damages that occurred (e.g., costs of recovery,
property damage, and lives lost) to the extent practicable.

ƒ

Level of severity (i.e., flood depth or extent, wind speeds, earthquake
intensity, etc.).

ƒ

Duration of event.

ƒ

Date of occurrence.

ƒ

Sources of information used or consulted for assembling a history of
past occurrences.

When appropriate, the hazard analysis should also identify on a map the
areas affected by each identified hazard. Additionally, a composite map
(i.e., a map showing combined information from different thematic map
layers) should be provided for hazards with a recognizable geographic
boundary (i.e., hazards that are known to occur in particular areas of the
jurisdiction, such as floods, coastal storms, wildfires, tsunamis, and
landslides).
The characterization of hazards should describe the conditions, such as
topography, soil characteristics, meteorological conditions, etc., in the
area that may exacerbate or mitigate the potential effects of hazards.
The hazard analysis should be detailed enough to allow identification of
the areas of the jurisdiction that are most severely affected by each
hazard.
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PART 3 – LOCAL MITIGATION PLANS
The plan should describe the analysis or sources used to determine the
probability, likelihood, or frequency of occurrence as well as the severity or
magnitude of future hazard events.
The plan should note any data limitations and identify and include in the
mitigation strategy actions for obtaining the data to complete and improve
future risk analysis efforts.
Special
Considerations:

Although not required by the Rule, a discussion of repetitive flood loss
properties is appropriate to include in the plan. A repetitive loss property is
a property that is currently insured through the NFIP, for which two or
more losses (occurring more than 10 days apart) of at least $1,000 each
have been paid within any 10-year period since 1978.

Resource:

For more information on profiling hazards, see:
9 Understanding Your Risks (FEMA 386-2), Step 2.
9 HAZUS-MH at www.fema.gov/HAZUS/.
9 Firewise at www.firewise.org.

Examples:
Original Submittal:
Sandy County is subject to riverine and flash flooding throughout large
sections of the County. There have been several flooding incidents in the
County. A severe flash flood occurred in June of 2000, and the Mud River
reached 100-year flood levels in 1996.
Many factors within the County affect the type and severity of flooding,
including the mountains, the location of development, the amount of snow
and rainfall received, and the large, wide floodplain of the Mud River.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(2)
(i)

REVIEWER’S COMMENTS

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COMMENTS

The hazard location is very general.
There is no information on the hazard
extent and probability of future events.
A limited history of flooding was
discussed.
While not required, the County did not
provide a map identifying areas affected
by flooding.

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PART 3 – LOCAL MITIGATION PLANS
Required Revisions:
For a “Satisfactory” score, the plan must describe the floodplain
boundaries and the magnitude or severity of floods; include the probability
for floods; and expand on the history of flooding. While the Rule does not
require a map, it is useful to provide one with the identified hazard areas.
Revised Submittal:
Sandy County is subject to riverine and flash flooding. throughout large
sections of the County. There have been several flooding incidents in the
County. A severe flash flood occurred in June of 2000, and the Mud River
reached 100-year flood levels in 1996. The County Planning
Department has reviewed the County’s Flood Insurance Rate Maps
(FIRMs) and Flood Insurance Study (FIS), and has worked with the
local college to compile a profile of the flooding hazard in the
County. The college provided support by completing research on
flooding history in the County and entering the data into a GIS
database. The GIS program shows the extent and areas affected by
past flooding, and is overlain by County tax maps. This, along with
the County’s FIRMs and FIS, provides a clear picture of areas and
structures most vulnerable to flooding (see attached Map X.X, Areas
of Sandy County Subject to Flood Hazards).
Riverine Flooding
The central and eastern sections of the County are subject to riverine
flooding. This is usually caused by extensive rainfall over a period of
several days and can be worsened by snowmelt conditions. The Mud
River located in Sandy County has flooded 12 times in the past 75
years; one was a 500-year flood, four were 100-year floods, three
were 50-year floods, and four were 10-year floods. The 500-year flood
occurred in 1952 and resulted in significant damage to Iron City and
Silvertown. The most recent flood was a 100-year flood that occurred
in 1996.
The probability of occurrence is expressed as the percent chance
that a flood of a specific magnitude will occur in any given year.
Table 2 summarizes the associated chance of occurrence for each
type of flood the County may experience.
Table 2: Flood Probability of Occurrence
Chance of
Flood Return
Occurrence in Any
Intervals
Given Year
10-Year
10%
50-Year
2%
100-Year
1%
500-Year
0.2%

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PART 3 – LOCAL MITIGATION PLANS
Many factors within the County affect the type and severity of flooding,
including the mountains, the location of development, the amount of snow
and rainfall received, and the large, wide floodplain of the Mud River.
The area surrounding the Mud River is subject to flood damage
because of the large amounts of rainfall and snowmelt it receives;
the wide, flat floodplain; and the large numbers of structures located
in the floodplain.
Flash Flooding
The western section of the County is very mountainous with steep
slopes and stream valleys. This area receives several large
thunderstorms per year that cause intense rainfall for short periods
of time, resulting in water flowing down from the mountains,
collecting in, and sometimes overtopping the valley streams. There
have also been issues with the maintenance and clearing of drainage
channels in this area that have resulted in obstructions restricting
the flow of water during a storm. Although this area is fairly rural,
many of the residents live in the 100-year floodplain because of the
steep slopes. These conditions make response and evacuation
operations very difficult, adversely affecting the safety of residents.
The most recent incident occurred in June of 2000. A severe
thunderstorm produced significant localized rainfall. Two small
bridges were washed out and many County residents were stranded.
Although no one was injured, several structures were flooded and
many residents were cut off from the rest of the County. This event
was estimated at a 50-year flood frequency return interval.

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PART 3 – LOCAL MITIGATION PLANS
ASSESSING VULNERABILITY: OVERVIEW
Requirement
§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.

Explanation:

An overview of the community’s vulnerability assessment is a summary
of the hazard’s impact to the community’s vulnerable structures. This
summary shall include, by type of hazard, a general description of the
types of structures (e.g., buildings, infrastructure, and critical facilities)
affected by the hazard.
The overview shall also include a general description of the extent of the
hazard’s impact to the vulnerable structures. This information can be
presented in terms of dollar value or percentages of damage. The Plan
should note any data limitations and identify and include in the mitigation
strategy actions for obtaining the data necessary to complete and
improve future vulnerability assessments.

Special
Considerations:

While the Rule does not require a discussion about the number of
people or special populations at risk, such as the elderly, disabled, or
others with special needs, FEMA recommends their consideration in the
risk assessment to enable the development of appropriate actions to
assist such populations during or after a disaster.

Resource:

For a discussion on preparing a vulnerability assessment, see:
9

Understanding Your Risks (FEMA 386-2), Step 3, Worksheet #3a
Inventory Assets.

9

HAZUS-MH at www.fema.gov/HAZUS/.

9

Firewise at www.firewise.org.

Examples:
Original Submittal:
Lake County is mostly susceptible to flooding and fire hazards. Based on
Planning Department data, the structures at risk are those located within
the 100-year and 500-year floodplain areas, which are the communities of
Rocky Lake and Grandview. Structures susceptible to damage from
flooding include five storm shelters, one hospital, the local communication
utility company, one wastewater treatment plant, and an old industrial site
containing hazardous waste.
The structures that could be damaged by fire include one school and one
hospital located in the rural, wooded portion of the County.

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PART 3 – LOCAL MITIGATION PLANS
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(2)
(ii)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The plan did not describe the potential
damages by hazard.

Required Revisions:
The plan must provide information on the potential impact of floods and
wildfires. This information may be provided in general terms and estimates
to give an idea of how significant the hazard is.
Revised Submittal:
Lake County is mostly susceptible to flooding and fire hazards. Based on
Planning Department data, the structures at risk are those located within
the 100-year and 500-year floodplain areas, which are the communities of
Rocky Lake and Grandview. It is estimated that a total of 30 homes are
at risk, which is 16% of the residential structures in the County.
Structures susceptible to damage from flooding include five storm
shelters, one hospital, the local communication utility company, one
wastewater treatment plant, and an old industrial site containing
hazardous waste. These structures are considered critical facilities for
the County, and structural flood damages for these sites could cost
up to $1 million for a 100-year flood. However, when considering the
impact of loss of service provided by these facilities, the damages
can exceed $5 million.
The structures that could be damaged by fire include one school and one
hospital located in the rural, wooded portion of the County. However,
these two sites provide shelter and emergency health services to the
County as well. Fire damages to these structures could greatly
impact emergency response operations and result in potential loss
of lives and damages of approximately of $2 million.

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PART 3 – LOCAL MITIGATION PLANS
ASSESSING VULNERABILITY: IDENTIFYING STRUCTURES
Requirement
§201.6(c)(2)(ii)
(A):

The plan should describe vulnerability in terms of the types and numbers
of existing and future buildings, infrastructure, and critical facilities
located in the identified hazard areas … .

Explanation:

This information list should be based on an inventory of existing and
proposed buildings, infrastructure, and critical facilities (structures)
located within identified hazard area boundaries. Buildings can include
residential, commercial, industrial, and municipal buildings; infrastructure,
such as roadways, water utilities, and communication systems; and
critical facilities, such as shelters and hospitals. The structure description
can also include construction characteristics (e.g., year built). The
community should determine how best to indicate structures that are
vulnerable to more than one hazard.
The community should determine how far into the future they wish to go
in considering proposed buildings, infrastructure, and critical facilities,
including planned and approved development. The information on future
structures may be based on their comprehensive plan or land use plan.
The Plan should document the process and sources used to identify
existing and future structures. If data are not readily available for
buildings and infrastructure, the Plan should provide information on
critical facilities within the identified hazard areas and identify the
collection of data for buildings and infrastructure as an action item in the
mitigation strategy.

Special
Considerations:

While not required by the Rule, structures located within areas that have
repeatedly flooded should be inventoried and information collected on
past flood insurance claims. The plan should describe the repetitive loss
neighborhoods without identifying specific properties.

Resource:

For a discussion on identifying vulnerable structures and preparing a
detailed inventory, see:
9 Understanding Your Risks (FEMA 386-2), Step 3, Worksheets #3a
and #3b Inventory Assets.
9 HAZUS-MH at www.fema.gov/HAZUS/.
9 Firewise at www.firewise.org.

Examples:
Original Submittal:
The Hazard Mitigation Plan for Rocky County identified critical facilities
located in the County and the hazards to which these facilities are
susceptible. A critical facility is defined as a facility in either the public or
private sector that provides essential products and services to the general
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PART 3 – LOCAL MITIGATION PLANS
public, is otherwise necessary to preserve the welfare and quality of life in
the County, or fulfills important public safety, emergency response, and/or
disaster recovery functions.
The critical facilities identified in the County are storm shelters; hospitals
and other health care facilities; gas, electric, and communication utilities;
water and wastewater treatment plants; hazardous waste sites; and
schools (see attached Map XX - Critical Facilities and Hazard
Vulnerability).
The Rocky County Planning Department used GIS and other modeling
tools to map the County’s critical facilities and determine which are most
likely to be affected by hazards. The two hazards most likely to impact the
County are flooding and wildfires. The analysis revealed the following:
Flooding Hazard: A 100-year flood would have an impact on five storm
shelters, one hospital, one elderly housing project, the local
communication utility company, one wastewater treatment plant, and an
old industrial site containing hazardous waste.
Fire Hazard: Brush fires could have an impact on one school and one
hospital located in the rural, wooded portion of the County.
In addition to critical facilities, the County contains at risk populations that
were factored into a vulnerability assessment. These include a relatively
large population of elderly residents with limited mobility.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(2)
(ii)(A)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The plan did not discuss future
vulnerability.

Required Revisions:
For a “Satisfactory” score, the vulnerability assessment must address
future planned development. Although not a requirement, it would be
useful for the plan to address the presence of any special populations and
describe how the critical facilities were identified.
Revised Submittal:
The Hazard Mitigation Plan for Rocky County identified critical facilities
located in the County and the hazards to which these facilities are
susceptible. A critical facility is defined as a facility in either the public or
private sector that provides essential products and services to the general
public, is otherwise necessary to preserve the welfare and quality of life in
the County, or fulfills important public safety, emergency response, and/or
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PART 3 – LOCAL MITIGATION PLANS
disaster recovery functions.
The critical facilities identified in the County are storm shelters; hospitals
and other health care facilities; gas, electric, and communication utilities;
water and wastewater treatment plants; hazardous waste sites; and
schools (see attached Map XX - Critical Facilities and Hazard
Vulnerability).
The Rocky County Planning Department used GIS and other modeling
tools to map the County’s critical facilities and determine which are most
likely to be affected by hazards. The two hazards most likely to impact the
County are flooding and wildfires. The analysis revealed the following:
Flooding Hazard: A 100-year flood would have an impact on five storm
shelters, one hospital, one elderly housing project, the local
communication utility company, one wastewater treatment plant, and an
old industrial site containing hazardous waste.
Fire Hazard: Brush fires could have an impact on one school and one
hospital located in the rural, wooded portion of the County.
In addition to critical facilities, the County contains at risk populations that
were factored into a vulnerability assessment. These include a relatively
large population of elderly residents with limited mobility.
An analysis of the County Comprehensive Plan indicates that there is
a slight but constant increase in residents expected over the next 20
years. By comparing the existing land use map and the land use plan
map found in Appendix XX, it is apparent that most of the residential
development is expected to occur in the already developed areas
outside of the 100-year floodplain. Some areas of future growth are
in the urban-wildland interface. The Comprehensive Plan identifies
two future planned developments of 100 units each near the Old
Growth National Forest.

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ASSESSING VULNERABILITY: ESTIMATING POTENTIAL LOSSES
Requirement
§201.6(c)(2)(ii)
(B):

[The plan should describe vulnerability in terms of an] estimate of the
potential dollar losses to vulnerable structures identified in paragraph
(c)(2)(i)(A) of this section and a description of the methodology used to
prepare the estimate … .

Explanation:

Describing vulnerability in terms of dollar losses provides the community
and the State with a common framework in which to measure the effects
of hazards on vulnerable structures. The Plan should include an estimate
of losses for the identified vulnerable structures. An estimate should be
provided for each hazard, and should include, when resources permit,
structure, contents, and function losses to present a full picture of the
total loss for each asset. Where data are limited, the planning team can
select the most likely event for each hazard and estimate the losses for
that event. In this way, the planning team can identify parts of the
jurisdiction that could suffer the greatest losses.
The methodology used to determine losses should also be provided. The
Plan should note any data limitations and identify and include in the
implementation strategy actions for obtaining the data to complete and
improve future risk assessment analysis efforts.

Special
Considerations:

Use of maps is not required by the Rule. However, a composite loss map
depicting high potential loss areas will help the community develop its
mitigation priorities based on residential and economic loss potential.

Resource:

For a step-by-step method for estimating losses, see:
9 Understanding Your Risks (FEMA 386-2), Step 4.
9 HAZUS-MH at www.fema.govj/HAZUS/.
For information regarding U.S. Forest Service guidelines see:
9 www.fs.fed.us.
For further information regarding wildland/urban interface see:
9 Firewise at www.firewise.org.

Examples:
Original Submittal:
The Rocky County Planning Department has used GIS modeling, field
inspections, and historical data to estimate the potential dollar losses if the
County were to experience flooding and wildfires, the two most likely
hazards to occur in the County. The vulnerable structures were identified
earlier in the planning process.
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The County will have an estimated $10 million of damage during a major
flood, and an estimated $3 million of damage in a severe wildfire.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(2)
(ii)(B)

COMMENTS
REVIEWER’S COMMENTS

ƒ
ƒ
ƒ

The plan did not specify which structures
would be damaged, and by what hazard.
The costs were not broken down for
each type of structure likely to be
damaged.
The plan does not describe the
methodology used.

Required Revisions:
To receive a “Satisfactory” score, the plan must include an estimate for
each structure likely to be damaged and the methodology used. Although
not a requirement, a map showing the structures likely to be damaged,
along with estimates of damage, would be helpful.
Revised Submittal:
The Rocky County Planning Department has used GIS modeling, field
inspections, and historical data to estimate the potential dollar losses if the
County were to experience flooding and wildfires, the two most likely
hazards to occur in the County. The vulnerable structures were identified
earlier in the planning process.
The County will have a more detailed inventory of buildings and
facilities when it completes its update of the County Asset Database.
Further, historical data regarding erosion, debris buildup, substantial
damage, and repetitive loss and flood high water marks can be
plotted (see Table 2.1) once that data are complete. This information
can then be added to GIS data sets for plotting on map products.
From the flood estimation tables described on pages 4-12 and 4-15 in
the FEMA document Understanding Your Risks: Identifying Hazards
and Estimating Losses (FEMA 386-2), the County can plot loss
estimation values and provide them for use for each political
jurisdiction along with corresponding GIS map products. See the
Mitigation Strategy section for implementation details.

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Table 2.1: Infrastructure Flood Loss History Impacts
Substantial
Category
Erosion Debris
Damage
Residential
Agriculture
Banking/Financial
Chemical
Public Bldgs
Public Health
Telecom
Transportation

Repetitive
Loss

High Water
Mark

The County will have an estimated $10 million dollars damage during a
major flood, and an estimated $3 million dollars damage in a severe
wildfire. The County used the guidelines in Understanding Your Risks
to develop a cost estimate for damages. The estimated costs are as
follows:
Potential flood losses:
Residential properties (including senior citizens home): $2.5 million
Local hospital: $3 million
Schools: $2 million
Communication utility company: $1 million
Waste water treatment plant: $1.5 million
See attached Map XX, Estimated Flood Losses by Location and Type
of Structure.
In speaking with the State Forest Ranger area office, the County
Planning Department can obtain valuable risk assessment data and
historical loss data regarding wildland areas in the County. As with
the plotting of infrastructure data described above, wildland-urban
fire risk data can be plotted and added to GIS data sets for mapping
wildfire risks. See the implementation details of the data gathering
effort in the Mitigation Strategy section.
The planning team used the methodology for estimating wildfire
damages found on pages 4-36 to 4-37 of Understanding Your Risks
(FEMA 386-2). See Appendix XX for the Wildfire Hazard Rating Form
completed for each jurisdiction. The following summarized the
results of the loss estimate.
Potential Wildfire losses:
Residential properties: $1 million
Hospital: $1.5 million
Secondary school: $500,000
See attached Map XY, Estimated Wildfire Losses by Location and
Type of Structure.

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ASSESSING VULNERABILITY: ANALYZING DEVELOPMENT TRENDS
Requirement
§201.6(c)(2)(ii)
(C):

[The plan should describe vulnerability in terms of] 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.

Explanation:

The plan should provide a general overview of land uses and types of
development occurring within the community. This can include existing
and proposed land uses as well as development densities in the identified
hazard areas and any anticipated future changes. This information
provides a basis for making decisions on the type of mitigation
approaches to consider, and the locations in which these approaches
should be applied. This information can also be used to influence
decisions regarding future development in hazard areas. A land use map
would be useful to depict the descriptive information.
The Plan should note any data limitations and identify and include in the
mitigation strategy actions for obtaining the data necessary to complete
and improve the risk assessment in the future.

Resource:

For more information on development trends, consult with your local or
regional planning officials.

Examples:
Original Submittal:
Friendly County is centrally located in the State and is largely rural; the
main land use is farming. Jasperville City is located along the northern
border of the County along the Big River.
Other land uses within the County consist of: industrial and commercial
areas, residential areas, park land and open space, and specialized land
use designations (institutional, mixed-use).
The County has been dealing with some residential development pressure
in the region surrounding Jasperville. Otherwise, the County does not
expect any significant changes in land use or development pressure.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(2)
(ii)(C)

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does not indicate whether there is any
anticipated change in land uses that
would increase vulnerability to
hazards.

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Required Revisions:
To receive a “Satisfactory” score, the plan must indicate if there are any
planned land use changes, or anticipated development, particularly in or
near hazard areas.
Revised Submittal:
Friendly County is centrally located in the State and is largely rural; the
main land use is farming. The largest city, Jasperville City, is located
along the northern border of the County along the Big River. Other land
uses within the County consist of: industrial and commercial areas,
located in and around Jasperville; residential areas, located in the
suburbs surrounding Jasperville; park land and open space, located
largely in the eastern section of the County; farmland, which is a
majority of the County; and specialized land use designations
(institutional, mixed-use) located in the City. These are generally in
conformance with current zoning and are expected to remain in the
current use for the foreseeable future.
The County has been dealing with some residential development pressure
in the region surrounding Jasperville. The suburbs of Jasperville have
recently undergone residential development pressure as several
large companies have opened offices in the City within the past year,
attracting new residents to the area. The County Planning Office has
indicated that the residential development pressure surrounding
Jasperville is the largest concern with respect to future land use
decisions and hazard mitigation planning. The Big River floods
periodically and many of the newly developing residential areas are
located in close proximity to the Big River. The current County
Comprehensive Plan shows future growth in these areas at a rate of
3% annually in the residential areas and 1% annually in the nonresidential areas. The zoning of these areas allows this growth to
occur with no zoning changes for the next 20 years, which is the
horizon for the Comprehensive Plan.
County Planners indicate that there is a current inventory of vacant
or re-developable land that can accommodate the projected growth
with no additional zoning changes, so the areas likely to experience
growth are the areas now zoned for development. Table XXX shows
the projected amount of growth by category and intensity of land use
for the next 20 years and Map XXX shows the amount of land that
corresponds to the growth. The areas of anticipated growth are
those identified by County Planning Staff as the most likely to be
developed in this planning horizon.
Otherwise, the County does not expect any significant changes in land
use or development pressure. The remainder of the County is not
expected to undergo development pressure, and the Planning Office
does not anticipate any significant changes in land use.
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MULTI-JURISDICTIONAL RISK ASSESSMENT
Requirement
§201.6(c)(2)(iii):

For multi-jurisdictional plans, the risk assessment must assess each
jurisdiction’s risks where they vary from the risks facing the entire
planning area.

Explanation:

The multi-jurisdictional plan must present information for the general
planning area as a whole as described in the previous paragraphs.
However, where hazards and associated losses occur in only part of the
planning area, this information must be attributed to the particular
jurisdiction in which they occur. Further, where unique construction
characteristics occur, they should be indicated on the plan so that
appropriate mitigation actions are considered.

Resource:

For more information on creating a detailed risk assessment, see:
9 Understanding Your Risks (FEMA 386-2), Steps 1 – 4.
9 HAZUS-MH at www.fema.govj/HAZUS/.
9 Firewise at www.firewise.org.

Examples:
Original Submittal:
Rumble County is a large County centrally located in the State. Within the
County, there are several municipalities. All of these jurisdictions
contributed to the risk assessment analyses performed for the County
Hazard Mitigation Plan (see preceding Section XX).
All jurisdictions within the County are subject to riverine flooding, which
has been determined to be the greatest risk for the County.
REVIEWER’S
RULE SECTION

COMMENTS

LOCATION IN THE
PLAN

§201.6(c)(2)
(iii)

REVIEWER’S COMMENTS

ƒ

The plan does not indicate if and how
each participating jurisdiction’s risk
varies from that of the overall County.

Required Revisions:
To receive a “Satisfactory” score, the plan must document if any particular
jurisdictions are subject to additional risks or if they have unique situations
that require special consideration.

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Revised Submittal:
Rumble County is a large County centrally located in the State. Within the
County, there are several municipalities. All of these jurisdictions
contributed to the risk assessment analyses performed for the County
Hazard Mitigation Plan (see preceding Section XX).
All jurisdictions within the County are subject to riverine flooding, which
has been determined to be the greatest risk for the County.
Riverine flooding was identified as the most significant risk to the
County and is addressed in the Mitigation Plan. However, two
jurisdictions within the County have unique situations that require
additional mitigation actions. Separate risk assessments were
performed for each jurisdiction.
Rocky Township has been recognized by the State Historic
Preservation Office as being a Heritage Preservation and Tourism
Area because of its distinct, historic character. The township’s
downtown appears much as it did in the early 1900’s. However, the
township has several threatened historic structures, some of which
lie in the town’s 100-year floodplain. One such structure is the Rocky
Mining Company Shipping Office, which now serves as a museum
chronicling the township’s mining past. The elevation of the
structure’s first floor lies 5 ft. below the 100-year flood elevation.
Quartz City contains a nuclear power plant that supplies power to the
entire County. This power plant presents additional risks due to
terrorism or malfunction of the plant’s safety controls. The increased
security and radiation control actions identified in the Mitigation Plan
are limited to Quartz City.

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MITIGATION

STRATEGY

§201.6(c)(3) of the Rule requires jurisdictions to develop a mitigation strategy. Specifically, the
Local Hazard Mitigation Plan must “include a mitigation strategy that 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.” This entails the development of goals from which specific mitigation actions and
projects will be derived. These goals and actions should be based on the jurisdiction’s existing
capabilities and its ability to enhance these capabilities. All mitigation actions must be prioritized
according to a cost-benefit review, with a focus on how effective the actions are expected to be
with respect to their cost. For multi-jurisdictional plans, each jurisdiction must show the specific
actions they will undertake.
This section includes the following four subsections:
ƒ

Local Hazard Mitigation Goals

ƒ

Identification and Analysis of Mitigation Actions

ƒ

Implementation of Mitigation Actions

ƒ

Multi-jurisdictional Mitigation Actions

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PART 3 – LOCAL MITIGATION PLANS
LOCAL HAZARD MITIGATION GOALS
Requirement
§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.

Explanation:

The community’s hazard reduction goals, as described in the plan, along
with any corresponding objectives, guide the development and
implementation of mitigation actions. This section shall list the goals
intended to reduce or avoid the effects of the identified hazards
addressed in the risk assessment.
The description should include how goals were developed. The goals
could be developed early in the planning process and refined based on
the risk assessment findings, or developed entirely after the risk
assessment is completed. They should also be compatible with the goals
of the community as expressed in other community plan documents.
Although the Rule does not require a description of objectives,
communities are highly encouraged to include objectives developed to
achieve the goals so that reviewers understand the connection between
goals, objectives, and activities.
The goals and objectives should:

Resource:

ƒ

Be based on the findings of the local and State risk assessments; and

ƒ

Represent a long-term vision for hazard reduction or enhancement of
mitigation capabilities.

For more information on developing local mitigation goals and objectives,
see:
ƒ

Special
Considerations:

Developing the Mitigation Plan (FEMA 386-3), Step 1.

Goals are general guidelines that explain what you want to achieve.
They are usually long-term and represent global visions, such as
“eliminate flood damage.”
Objectives define strategies or implementation steps to attain the
identified goals. Unlike goals, objectives are specific, measurable, and
may have a defined completion date. Objectives are more specific, such
as “adopt a zoning ordinance prohibiting new development in the
floodplain.”
(From Developing the Mitigation Plan [FEMA 386-3], Step 1.)

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PART 3 – LOCAL MITIGATION PLANS
Examples:
Original Submittal:
The Rumble County Hazard Mitigation Planning Committee identified the
following goal to guide the implementation of the County’s hazard
mitigation strategies:
Minimize future damage due to hazards.

ƒ

REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(3)
(i)

COMMENTS
REVIEWER’S COMMENTS

ƒ
ƒ

While the plan includes a goal, it is very
general and does not reflect the findings
of the risk assessment.
Although not required, the plan does not
mention objectives that will be used to
achieve the goals.

Required Revisions:
To receive a “Satisfactory” score, the plan must describe goals to reduce
or avoid losses from the identified hazards. Additionally, it would be helpful
to include the objectives that will be used to achieve the goals.
Revised Submittal:
The Rumble County Hazard Mitigation Planning Committee identified the
following goal to guide the implementation of the County’s hazard
mitigation strategies. held a 2-day workshop to review and analyze the
risk assessment studies that were performed for the County. The
Committee developed goals and objectives based on the risk
assessment studies and selected those that were determined to be
of greatest benefit in hazard reduction to the County. The goals and
objectives are as follows:
ƒ

Minimize future damage due to hazards.

ƒ

Goal 1: Reduce flood damage in the County.
o

ƒ

Goal 2: Reduce economic impact of droughts.
o

ƒ

Objective 2.1: Minimize damage to local crops due to drought
situations.

Goal 3: Reduce threat of contamination from the nuclear power
plant.
o

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Objective 1.1: Minimize future damage due to flooding of the Big
River.

Objective 3.1: Maintain the safe operation of the nuclear power
plant located in the County.

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IDENTIFICATION AND ANALYSIS OF MITIGATION ACTIONS
Requirement
§201.6(c)(3)(ii):

[The 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.

Explanation:

The local jurisdiction shall list potential loss reduction actions it has
identified in its planning process and evaluate various actions that
achieve the community’s goals and objectives to reduce or avoid the
effects of the identified hazards. Mitigation actions shall address
existing and new buildings and infrastructure.
Not all of the mitigation actions identified may ultimately be included in
the community’s plan due to limited capabilities, prohibitive costs, low
benefit/cost ratio, or other concerns. The process by which the
community decides on particular mitigation actions should be described.
This description can include who participated in the evaluation and
selection of actions. The information will also be valuable as part of the
alternative analysis for the National Environmental Policy Act (NEPA)
review required if projects are Federally funded.

Special
Considerations:

While the Rule does not require a discussion of capabilities, FEMA
recommends that jurisdictions, as part of this section, assess their own
existing capabilities to implement mitigation actions. This assessment
should include a discussion of existing mitigation activities in the
community, existing regulatory standards, projects that have already
been planned, integration with comprehensive planning and capital
improvement programs, etc., as well as the jurisdiction’s ability to expand
on and improve these existing tools.

Resource:

For more information on identifying and evaluating mitigation actions and
preparing a capability assessment, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 2, Worksheet #1
Identify Alternative Mitigation Actions, Job Aid #1: Alternative
Mitigation Actions by Hazard, Worksheet #2 State Mitigation
Capability Assessment, Worksheet #3 Local Mitigation Capability
Assessment, Job Aid #2: Local Hazard Mitigation Capabilities, and
Worksheet #4 Evaluate Alternative Mitigation Actions.
9 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 3.
9 Mitigation Resources for Success CD (FEMA 372).
9 Mitigation Success Stories and Case Studies at
www.fema.gov/fima/success.shtm.
9 Rebuilding for a More Sustainable Future: An Operational Framework
(FEMA 365).
9 The Natural Hazards Center at www.colorado.edu/hazards.

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9 Flood mitigation success stories from the Association of State Floodplain Managers at www.floods.org.
Examples:
Original Submittal:
Rumble County has identified a number of hazard mitigation actions and
projects. The Planning Committee has selected the following actions for
Rumble County:
ƒ

Revise the County Ordinance to prohibit development in the floodway.

ƒ

Work with property owners to implement deed restrictions for open
lots/vacant properties along the Big River to prevent development.

ƒ

Elevate or floodproof structures.

ƒ

Develop water-rationing actions.

ƒ

Update radiation safety protocols at the nuclear power plant.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(3)
(ii)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The plan did not describe whether a
range of various actions were
considered.

Required Revisions:
To receive a “Satisfactory” score, the plan must describe the approach or
analysis used for evaluating a range of actions.

Revised Submittal:
Rumble County has identified a number of hazard mitigation actions and
projects. The Planning Committee, with input from local government
agencies, the local college, and residents, has selected the following
actions as the most beneficial for Rumble County. These actions are
listed following the goals and objectives. What follows are the most
vulnerable areas identified in the risk assessment and the highest
priority mitigation actions identified for those areas.
ƒ

Revise the County Ordinance to prohibit development in the floodway.

ƒ

Work with property owners to implement deed restrictions for open
lots/vacant properties along the Big River to prevent development.

ƒ

Elevate or floodproof structures.

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PART 3 – LOCAL MITIGATION PLANS
ƒ

Develop water-rationing actions.

ƒ

Update radiation safety protocols at the nuclear power plant.

ƒ

Eastern Neighborhood: Located along the Big River and prone to
overbank flooding. The Planning Committee recommends
embarking on an elevation and floodproofing program, amending
the County Ordinance to prohibit development in the Big River
floodway, and working with property owners to turn deed
restrictions for open lots/vacant properties along the Big River
into deed restricted open space.

ƒ

Quartz City lies within 25 miles of the nuclear power plant. The
Planning Committee recommends the creation of radiation safety
protocols to be used in case of an emergency at the nuclear
power plant and education of the community on the use of these
protocols.

ƒ

All of Rumble County is susceptible to drought. The Planning
Committee recommends the development of water-rationing
actions that will be implemented during a drought situation.

The list below documents the steps we followed in identifying and
evaluating mitigation actions. Appendix XX contains a description of
actions and their pros and cons by hazard.
ƒ

We checked the library of Developing the Mitigation Plan (FEMA
386-3) to find sources of mitigation success stories.

ƒ

We sought the opinions of residents and State and local officials.

ƒ

We reviewed the State capability assessment in the State Hazard
Mitigation Plan.

ƒ

We conducted a local capability analysis using the worksheets in
Developing the Mitigation Plan (FEMA 386-3) to ascertain what
actions could most readily be accomplished by existing
programs, plans, personnel, and funds.

The following are the most appropriate actions by goal:
ƒ

Goal 1: Reduce flood damage in the County.
o

Objective 1.1: Minimize future damage due to flooding of
the Big River.
ƒ

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Action 1.1.1: Place a restrictive clause in the
County Ordinance that will prohibit development in
the Big River floodway.

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PART 3 – LOCAL MITIGATION PLANS

ƒ

ƒ

Action 1.1.3: Work with property owners to
implement deed restrictions for open lots/vacant
properties along the Big River to prevent
development.

Objective 2.1: Minimize damage to local crops due to
drought situations.
ƒ

Action 2.2.1: Develop water-rationing actions that
will be implemented during a drought situation.

ƒ

Action 2.2.2: Educate residents on the benefits of
conserving water at all times, not just during a
drought.

ƒ

Action 2.2.3: Work with local farmers to investigate
the use of more drought-resistant crops.

Goal 3: Reduce the threat of contamination from the nuclear power
plant.
o

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Action 1.1.2: Work with existing floodplain residents
to elevate or floodproof their structures, including
obtaining funding assistance and technical
guidance.

Goal 2: Reduce economic impact of droughts.
o

ƒ

ƒ

Objective 3.1: Maintain the safe operation of the nuclear
power plant located in the County.
ƒ

Action 3.3.1: Work with power plant administrators
to increase security actions necessary to prevent a
terrorist attack.

ƒ

Action 3.3.2: Develop radiation safety protocols to
be used in case of an emergency and educate the
community on the use of these protocols.

ƒ

Action 3.3.3: Work with power plant safety
inspectors to ensure that the power plant is meeting
or exceeding all safety requirements and develop a
plan for enforcing these requirements if necessary.

ƒ

Action 3.3.4: Conduct a local public relations
campaign to educate residents about the power
plant, clearly delineating real threats from imagined.

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PART 3 – LOCAL MITIGATION PLANS
IMPLEMENTATION OF MITIGATION ACTIONS
Requirement:
§201.6(c)(3)(iii):

[The mitigation strategy section shall include] an action plan describing
how the actions identified in section (c)(3)(ii) 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.

Explanation:

After outlining the mitigation actions to be included in the mitigation
strategy, the local jurisdiction shall describe the method for prioritizing
the order in which actions will be implemented. Considerations that may
be used to prioritize actions include: social impact, technical feasibility,
administrative capabilities, and political and legal effects, as well as
environmental issues.
When prioritizing mitigation actions, local jurisdictions shall consider the
benefits that would result from the mitigation actions (including projects)
versus the cost of those actions. Note that the Rule does not require a
cost-benefit analysis for actions. However, an economic evaluation is
essential for selecting one or more actions from among many competing
ones. This (and other considerations) should be debated and discussed
as part of the planning team’s and/or larger community’s decision-making
process. A possible result of these local discussions could be the
decision to complete a formal cost-benefit evaluation of the various
mitigation approaches that are technically appropriate for the situation.
However, this is not required to be included in the plan. The requirement
of 44 CFR 201.6 (c)(3)(iii) is met as long as the economic considerations
are summarized in the plan as part of the community’s analysis of “the
comprehensive range of specific mitigation actions and projects being
considered … .” Among ways to address this requirement are:
ƒ

Assessing the economic impact of one action compared to another.

ƒ

Showing how one type of action costs more than another to achieve
the same benefit.

ƒ

Showing that funding is available for one type of action but not
another.

ƒ

Demonstrating that the economic goals of your community are better
served by one action instead of another.

This section shall also include how actions will be implemented and
administered. The plan shall include the agency or personnel
responsible for carrying out the actions, the funding sources, and the
implementation timeline. This section can also include a cost estimate or
budget for each action, when available.

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PART 3 – LOCAL MITIGATION PLANS
Resource:

For a detailed description of the development of the action plan, see:
9 Developing the Mitigation Plan (FEMA 386-3), Step 3.
9 Mitigation Benefit Cost Analysis (BCA) Toolkit Compact Disc (CD) –
this CD includes all of the FEMA BCA software, technical manuals,
BCA training course documentation, and other supporting material
and BCA guidance. Copies can be obtained by calling FEMA’s tollfree BC Hotline at 866.222.3580.

Examples:
Original Submittal:
The City of Sandytown has identified several hazard mitigation actions to
be included in the Hazard Mitigation Plan. These actions are as follows:
Table 3: Priority Actions
Hazard
Flooding

Landslides

Tornado

Action

Priority

Acquire and relocate flood-prone structures
and repetitive loss properties.

High

Preserve and expand open space along the
river.

Medium

Determine best management practices
(BMPs) regarding slope excavation,
drainage conveyance, and grading practices
that reduce the risk of landslides.

High

Incorporate BMP findings into City
ordinance.

High

Study shelter design, and reinforcement and
anchoring of manufactured homes.
Disseminate the information to residents.

Low

Provide funding to residents to help them
comply with the above recommendations.

Low

REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(3)
(iii)

REVIEWER’S COMMENTS

ƒ
ƒ

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The plan does not describe how
actions are prioritized.
The plan does not indicate the
responsible party, funding sources,
and timeframe.

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PART 3 – LOCAL MITIGATION PLANS
Required Revisions:
The plan must describe how the mitigation actions are prioritized. The
agencies responsible for implementation of the projects must be
identified, along with the respective funding sources and implementation
timeframe.
Revised Submittal:
The City of Sandytown has identified several hazard mitigation actions to
be included in the Hazard Mitigation Plan. These actions are as follows:
Table 3: Priority Actions lists actions by hazard. Table 4:
Implementation Strategy contains these actions, along with the
responsible agency, the funding source, and implementation
timeframe.
The Mitigation Planning Team prioritized the actions using the
STAPLE+E criteria, a planning tool used to evaluate alternative
actions. The following table explains the STAPLE+E criteria.
STAPLE+E

Criteria Explanation

S – Social

Mitigation actions are acceptable to the community if they do not
adversely affect a particular segment of the population, do not cause
relocation of lower income people, and if they are compatible with the
community’s social and cultural values.

T – Technical

Mitigation actions are technically most effective if they provide longterm reduction of losses and have minimal secondary adverse
impacts.

A – Administrative

Mitigation actions are easier to implement if the jurisdiction has the
necessary staffing and funding.

P – Political

Mitigation actions can truly be successful if all stakeholders have been
offered an opportunity to participate in the planning process and if
there is public support for the action.

L – Legal

It is critical that the jurisdiction or implementing agency have the legal
authority to implement and enforce a mitigation action.

E – Economic

Budget constraints can significantly deter the implementation of
mitigation actions. Hence, it is important to evaluate whether an
action is cost-effective, as determined by a cost benefit review, and
possible to fund.

E – Environmental

Sustainable mitigation actions that do not have an adverse effect on
the environment, that comply with Federal, State, and local
environmental regulations, and that are consistent with the
community’s environmental goals, have mitigation benefits while
being environmentally sound.

Each team member had an equal number of votes to use toward the
actions that met the criteria best, based on their knowledge and
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PART 3 – LOCAL MITIGATION PLANS
expertise. The mitigation actions with highest priority were the most
cost effective and most compatible with the communities’ social
and cultural values.
As a high priority, we selected the action “Determine best
management practices (BMPs) regarding slope excavation, drainage
conveyance, and grading practices that reduce the risk of
landslides” for a number of reasons. First, amending the ordinance
can be done with existing staff, with little extra expense, and
relatively quickly. Second, these BMPs can make new construction
much less susceptible to landslides and can also be used to
improve the site conditions of existing construction; the cost is just
a fraction of what engineering solutions or structural retrofits would
cost. A summary for the other priority actions selected is included
in Appendix XX.

Table 3: Priority Actions
Hazard
Flooding

Landslides

Tornado

Action

Priority

Acquire and relocate flood-prone structures
and repetitive loss properties.

High

Preserve and expand open space along the
river.

Medium

Determine best management practices
(BMPs) regarding slope excavation,
drainage conveyance, and grading practices
that reduce the risk of landslides.

High

Incorporate BMP findings into City
ordinance.

High

Study shelter design, and reinforcement and
anchoring of manufactured homes.
Disseminate the information to residents.

Low

Provide funding to residents to help them
comply with the above recommendations.

Low

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Table 4: Implementation Strategy
Action/Priority

Responsible Agency

Funding and Timeframe/
Deadline

Determine best management
practices (BMPs) regarding slope
excavation, drainage conveyance,
and grading practices that reduce
the risk of landslides. (HIGH)

City of Sandytown
Department of Planning
and Department of the
Environment

ƒ

Existing staff

ƒ

Fall 2004 – Spring
2005

Acquire and relocate flood-prone
structures and repetitive loss
properties. (HIGH)

City of Sandytown
Department of Planning,
Department of
Environmental
Protection, Legal
Department

ƒ

PDM and HMGP
Grants

ƒ

Fall 2004 – Fall 2009

City of Sandytown
Department of Planning,
City Council

ƒ

Existing staff

ƒ

Spring 2005 – Fall
2005

City of Sandytown
Department of Planning
and Department of the
Environment

ƒ

Green Fund and
existing staff

ƒ

Ongoing

Study shelter design, and
reinforcement and anchoring of
manufactured homes. Disseminate
the information to residents. (LOW)

City of Sandytown
Department of Planning

ƒ

Capital Improvement
Funding

ƒ

Winter 2005 –
Summer 2006

Provide funding to residents to
help them comply with the above
recommendations. (LOW)

City of Sandytown Mayor
and City Council

ƒ

Special Assistance
Program

ƒ

Ongoing

Incorporate BMP findings into City
ordinance. (HIGH)

Preserve and expand open space
along the river. (MEDIUM)

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MULTI-JURISDICTIONAL MITIGATION ACTIONS
Requirement
§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 plan.

Explanation:

The multi-jurisdictional plan must contain a section that links the
proposed mitigation actions to the applicable jurisdictions. Any
jurisdiction within the planning area requesting approval or credit for the
Mitigation Plan must be able to point to at least one specific action to
be pursued. Actions by individual jurisdictions may be part of or
contribute to an area-wide mitigation action. The scope of this action
may be entirely within the jurisdiction or may be part of a larger action
involving some or all of the other jurisdictions covered in the plan.

Resource:

For more information on the development of the action plan, see:
9 Developing the Mitigation Plan (386-3), Step 3.

Examples:
Original Submittal:
Rumble County’s Mitigation Plan encompasses several jurisdictions.
Strategies for hazard mitigation within the County were identified to reduce
overall damage in the County. These activities will be implemented by the
County and participating jurisdictions.
Action

Timeframe /
Deadline

Place a restrictive clause in the
County Ordinance that will prohibit
development in the Big River
floodway.

Fall 2004

Work with existing floodplain residents
to elevate or floodproof their structures
(especially historic structures),
including obtaining funding assistance
and technical guidance.

Spring 2005 through
Spring 2007

Develop water-rationing actions that
will be implemented during a drought
situation.

Spring 2004 through
Winter 2004

Develop radiation safety protocols to
be used in case of an emergency and
educate the community on the use of
these protocols.

Fall 2004

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REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(3)
(iv)

COMMENTS
REVIEWER’S COMMENTS

ƒ
ƒ

The plan does not identify which actions
apply to each jurisdiction.
The plan does not indicate who will be
responsible for implementing the actions
or the funding source.

Required Revisions:
For a “Satisfactory” score, the plan must list specific actions by jurisdiction,
the responsible parties, and the funding sources.
Revised Submittal:
Rumble County’s Mitigation Plan encompasses several jurisdictions.
Strategies for hazard mitigation within the County were identified to reduce
overall damage in the County. These activities will be implemented by the
County and the participating jurisdictions. Although these actions are
aimed at reducing overall damage in the County, each jurisdiction
will be responsible for pursuing the actions that are relevant to that
jurisdiction. The jurisdictions, along with the specific actions they
will pursue, are listed as follows:

Table 5: Implementation Strategy
Jurisdiction

Action

Responsible Agency

Funding Source and
Timeframe/ Deadline

Rumble County

Place a restrictive clause in the
County Ordinance that will prohibit
development in the Big River
floodway.

Rumble County Planning
Department

ƒ

Staff time

ƒ

Fall 2004

Work with existing floodplain
residents to elevate or floodproof
their structures (especially historic
structures), including obtaining
funding assistance and technical
guidance.

Rocky Township Department
of Emergency Services, NFIP
Coordinator

ƒ

PDM and HMGP
Funding

ƒ

Spring 2005
through Spring
2007

Develop water-rationing actions that
will be implemented during a
drought situation.

Department of Environment,
Rocky Township, Quartz
City, and Rumble County

ƒ

Staff time

ƒ

Spring 2004
through Winter
2004

Develop radiation safety protocols
to be used in case of an emergency
and educate the community on the
use of these protocols.

Quartz City, Department of
Planning and Community
Development

ƒ

Staff time

ƒ

Fall 2004

Rocky Township

Rumble County

Quartz City

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PART 3 – LOCAL MITIGATION PLANS
PLAN

MAINTENANCE

PROCESS

§201.6(c)(4) requires a formal plan maintenance process to ensure that the Mitigation Plan
remains an active and relevant document. The plan maintenance process must include a
method and schedule for monitoring, evaluating, and updating the plan at least every five years.
This section must also include an explanation of how local governments intend to incorporate
their mitigation strategies into any existing planning mechanisms they have, such as
comprehensive or capital improvement plans, or zoning and building codes. Lastly, this section
requires that there be continued public participation throughout the plan maintenance process.
This section includes the following three subsections:
ƒ

Monitoring, Evaluating, and Updating the Plan

ƒ

Incorporation into Existing Planning Mechanisms

ƒ

Continued Public Involvement

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PART 3 – LOCAL MITIGATION PLANS
MONITORING, EVALUATING, AND UPDATING THE PLAN
Requirement
§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.

Explanation:

The local jurisdiction shall describe the how, when, and by whom the plan
will be monitored. Monitoring may include periodic reports by agencies
involved in implementing projects or activities; site visits, phone calls, and
meetings conducted by the person responsible for overseeing the plan;
and the preparation of an annual report that captures the highlights of the
previously mentioned activities.
The plan shall also include a description of how, when, and by whom the
plan will be evaluated, and should include the criteria used to evaluate the
plan. The evaluation should assess, among other things, whether:
ƒ

The goals and objectives address current and expected conditions.

ƒ

The nature, magnitude, and/or type of risks has changed.

ƒ

The current resources are appropriate for implementing the plan.

ƒ

There are implementation problems, such as technical, political, legal,
or coordination issues with other agencies.

ƒ

The outcomes have occurred as expected.

ƒ

The agencies and other partners participated as originally proposed.

The plan shall describe how, when, and by whom the plan will be
updated. The Rule requires that the plan be updated within five years
from the date of FEMA approval. FEMA recommends that the plan be
reviewed and updated on an annual basis to determine the effectiveness
of programs, and to reflect changes in land development or programs that
may affect mitigation priorities.
Special
Considerations:

If the plan also satisfies the CRS requirements, the flood section may
need to be updated more frequently than every five years. States may
also have additional requirements. Consult with your FEMA Regional
Office or State Hazard Mitigation Officer.

Resource:

For guidance on monitoring, evaluating, and updating the plan, see:
9 Bringing the Plan to Life (FEMA 386-4), Steps 2 – 4.

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PART 3 – LOCAL MITIGATION PLANS
Examples:
Original Submittal:
Rocky County has developed a method to ensure that regular monitoring,
evaluation, and update of the Hazard Mitigation Plan occurs. The County
Planning Department will be responsible for holding annual meetings with
local agencies and other concerned parties to evaluate the Mitigation
Plan. The Planning Department will then update the plan as necessary. If
no changes are required, the County will give the State Hazard Mitigation
Officer justification as to why no changes were deemed necessary.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(4)
(i)

COMMENTS
REVIEWER’S COMMENTS

ƒ
ƒ
ƒ
ƒ

The plan does not identify who will be
monitoring the implementation of actions.
It is not clear how the plan will be
monitored.
Local agencies and concerned parties to
be included in the evaluation are not
identified.
This section does not describe how the
plan will be evaluated.

Required Revisions:
The plan must clearly indicate how, when, and by whom the plan will be
monitored, evaluated, and updated.
Revised Submittal:
Rocky County has developed a method to ensure that regular monitoring,
evaluation, and update of the Hazard Mitigation Plan occurs. The County
Planning Department will be responsible for holding annual meetings with
local agencies and other concerned parties to evaluate the Mitigation Plan.
The Planning Department will then update the plan as necessary. If no
changes are required, the County will give the State Hazard Mitigation
Officer justification as to why no changes were deemed necessary.
Rocky County has developed a method to ensure that an annual
review and update of the Hazard Mitigation Plan occurs, although
FEMA regulations only require an update every five years. The
County has formed a Hazard Mitigation Plan Evaluation Committee
that consists of members from local agencies and other concerned
parties, including elected officials, the County Department of Natural
Resources, the County Office of Economic Development, the County
Office of Emergency Services, the County DOT, the non-profit Mud
River Watershed Society, and representatives from the State
University Geography Department. The County Planning Department
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PART 3 – LOCAL MITIGATION PLANS
is responsible for contacting committee members and organizing the
annual meeting. The meeting will be held in March of each year, and
committee members will be responsible for monitoring and
evaluating the progress of the mitigation strategies in the plan.
The committee will review each goal and objective to determine their
relevance to changing situations in the County, as well as changes in
State or Federal policy, and to ensure that they are addressing
current and expected conditions. The committee will also review the
risk assessment portion of the plan to determine if this information
should be updated or modified. The parties responsible for the
various implementation actions will report on the status of their
projects and will include which implementation processes worked
well, any difficulties encountered, how coordination efforts were
proceeding, and which strategies should be revised.
The Planning Department will then have three months to update and
make changes to the plan before submitting it to the Committee
members and the State Hazard Mitigation Officer. If no changes are
necessary, the State Hazard Mitigation Officer will be given a
justification for this determination. Comments and recommendations
offered by Committee members and the State Hazard Mitigation
Officer will be incorporated into the plan.
In addition, Rocky County has a number of other plans that will
consider and integrate the Hazard Mitigation Plan as they undergo
their regular updates:
Comprehensive Plan—update due in 2005.
Capital Improvements Plan—update due in 2006.
Historic Preservation Plan—update due in 2007.
The Hazard Mitigation Plan will take into account any changes in
these plans and incorporate the information accordingly in its next
update.

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PART 3 – LOCAL MITIGATION PLANS
INCORPORATION INTO EXISTING PLANNING MECHANISMS
Requirement
§201.6(c)(4)(ii):

[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 improvement plans, when appropriate.

Explanation:

Jurisdictions shall indicate how mitigation recommendations will be
incorporated into comprehensive plans, capital improvement plans, zoning
and building codes, site reviews, permitting, job descriptions, staff training,
and other planning tools, where such tools are the appropriate vehicles for
implementation.
Communities that do not have a comprehensive plan, or other similar
planning mechanisms, should explain how the mitigation
recommendations would be implemented. Further, for certain mitigation
actions that may use other means of implementation, these other tools
should be described.

Resource:

For more information on incorporating hazard mitigation activities in other
initiatives, see:
9 Getting Started (FEMA 386-1), Step 2.

Examples:
Original Submittal:
Rocky County currently uses comprehensive land use planning, capital
improvements planning, and building codes. After the County officially
adopts the Hazard Mitigation Plan, these existing mechanisms will have
hazard mitigation strategies incorporated into them. This will be done so
that planning for hazard mitigation will become an essential part of all
County decisions and policies.
REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(4)
(ii)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The plan does not state how planning for
hazard mitigation will be incorporated
into existing mechanisms, only that it will
be done.

Required Revisions:
The plan must indicate how Mitigation Plan requirements will be
incorporated into existing planning mechanisms.

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PART 3 – LOCAL MITIGATION PLANS
Revised Submittal:
Rocky County currently utilizes comprehensive land use planning, capital
improvements planning, and building codes. After the County officially
adopts the Hazard Mitigation Plan, these existing mechanisms will have
hazard mitigation strategies incorporated into them. This will be done so
that planning for hazard mitigation will become an essential part of all
County decisions and policies.
The Hazard Mitigation Plan Evaluation Committee, which meets on
an annual basis, will provide a mechanism for ensuring that the
actions identified in the plans are incorporated into ongoing county
planning activities.
Rocky County currently utilizes comprehensive land use planning,
capital improvements planning, and building codes to guide and
control development in the County. After the County officially adopts
the Hazard Mitigation Plan, these existing mechanisms will have
hazard mitigation strategies integrated into them.
After adoption of the Mitigation Plan, the County will require that
local municipalities address hazards in their comprehensive plans
and land use regulations. Specifically, one of the goals in the
Mitigation Plan directs County and local governments to protect life
and property from natural disasters and manmade hazards. The
County Planning Department will conduct periodic reviews of the
County’s comprehensive plans and land use policies, analyze any
plan amendments, and provide technical assistance to other local
municipalities in implementing these requirements.
The County Building Department is responsible for administering the
building codes in local municipalities. After the adoption of the
Mitigation Plan, they will work with the State Building Code Office to
make sure that the County adopts, and is enforcing, the minimum
standards established in the new State Building Code. This is to
ensure that life/safety criteria are met for new construction.
The capital improvement planning that occurs in the future will also
contribute to the goals in the Hazard Mitigation Plan. The County
Natural Resources Department will work with capital improvement
planners to secure high-hazard areas for low risk uses.
Within six months of the formal adoption of the Mitigation Plan, the
policies listed above will be incorporated into the process of existing
planning mechanisms.

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PART 3 – LOCAL MITIGATION PLANS
CONTINUED PUBLIC INVOLVEMENT
Requirement
§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.

Explanation:

The plan shall describe what opportunities the broader public (i.e.,
stakeholders who are not part of the planning team) would have during the
plan’s periodic review to comment on the progress made to date and the
proposed plan revisions. Plans should describe the mechanisms for
keeping the public involved (e.g., holding strategic meetings, posting the
proposed changes to the plan on the Web, etc.).

Resource:

For more information on keeping the public involved, see:
9 Getting Started (FEMA 386-1), Step 3.
9 Bringing the Plan to Life (FEMA 386-4), Steps 2 and 3.

Examples:
Original Submittal:
Rocky County is dedicated to involving the public directly in the continual
reshaping and updating of the Hazard Mitigation Plan. The Hazard
Mitigation Plan Evaluation Committee members are responsible for the
annual review and update of the plan. Although they represent the public
to some extent, the public will be able to directly comment on and provide
feedback about the plan.

REVIEWER’S
RULE SECTION

LOCATION IN THE
PLAN

§201.6(c)(4)
(iii)

COMMENTS
REVIEWER’S COMMENTS

ƒ

The plan does not provide details about
how or when the public will provide
comments.

Required Revisions:
The plan must describe opportunities for keeping the public involved.
Revised Submittal:
Rocky County is dedicated to involving the public directly in the continual
reshaping and updating of the Hazard Mitigation Plan. The Hazard
Mitigation Plan Evaluation Committee members are responsible for the
annual review and update of the plan. Although they represent the public
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PART 3 – LOCAL MITIGATION PLANS
to some extent, the public will be able to directly comment on and provide
feedback about the plan.
Copies of the plan will be catalogued and kept on hand at all of the
public libraries in the County. The existence and location of these
copies will be publicized in the monthly newsletter sent out by the
County Chamber of Commerce. Contained in the plan is the address
and phone number of County Planning Department Staff Member(s)
responsible for keeping track of public comments on the plan.
In addition, copies of the plan and any proposed changes will be
posted on the County Government Website. This site will also
contain an email address and phone number to which people can
direct their comments or concerns. A link to this site will also be
provided on the local Sandy State College Department of Geography
and Department of Urban Planning Web pages.
A public meeting will also be held after each annual Mitigation Plan
Evaluation Committee meeting. This meeting will provide the public a
forum for which they can express concerns, opinions, or ideas about
the plan. The County Planning Department will publicize and host
this meeting. Following the meeting, the evaluation committee will
review the comments and make changes to the plan, as appropriate.

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PART 4 – PLAN REVIEW CROSSWALKS
This section contains blank Plan Review Crosswalks for Standard State Hazard Mitigation
Plans, Enhanced State Hazard Mitigation Plans, and Local Hazard Mitigation Plans. Plan writers
and reviewers working on Standard State Hazard Mitigation Plans will need the Standard State
Hazard Mitigation Plan Review Crosswalk. An Enhanced State Plan requires the Review
Crosswalk for the Standard State Plan and the Enhanced State Hazard Mitigation Plan Review
Crosswalk. Those working on Local Mitigation Plans will use the Local Hazard Mitigation Plan
Review Crosswalk.
Each section of the Plan Review Crosswalk is introduced by language from the Rule, stating the
plan requirements. The first column, headed “Element,” breaks down the requirements into their
individual provisions, rephrasing them as questions. The second column, headed “Location in
the Plan,” is for indicating where in the plan the element is addressed. The third column,
headed “Reviewer’s Comments,” is for indicating whether or not the plan has addressed the
requirement satisfactorily and any recommended required improvements.
Except for prerequisites, which are scored as “Not Met” or “Met,” the reviewer will score each
element as an N for “Needs Improvement” or S for “Satisfactory,” checking off the appropriate
box under “Score.” Any element that receives an N will result in an N summary score for the
requirement as a whole. At the end of the plan review, reviewers can fill out the Plan Summary
Worksheet to easily present the results on one page.
For ease of use or expanding the space available for comments, these crosswalks can be
downloaded off the FEMA Mitigation Planning Web site.

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(THIS PAGE IS INTENTIONALLY BLANK)

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STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Instructions for Using the Plan Review Crosswalk for Review of Standard State Hazard Mitigation Plans
Attached is a Plan Review Crosswalk based on the Multi-Hazard Mitigation Planning Guidance Under the Disaster Mitigation Act of 2000, published by FEMA, with
revisions dated November 2006. This Plan Review Crosswalk is consistent with the Disaster Mitigation Act of 2000 (P.L. 106-390), enacted October 30, 2000 and 44 CFR
Part 201 – Mitigation Planning, Interim Final Rule (the Rule), published February 26, 2002.
SCORING SYSTEM
N – Needs Improvement: The plan does not meet the minimum for the requirement. Reviewer’s comments must be provided.
S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are encouraged, but not required.
Each requirement includes separate elements. All elements of a requirement must be rated “Satisfactory” in order for the requirement to be fulfilled and receive a summary
score of “Satisfactory.” A “Needs Improvement” score on elements shaded in gray (recommended but not required) will not preclude the plan from passing.
Optional matrices for assisting in the review of sections on profiling hazards and assessing vulnerability are found at the end of the Plan Review Crosswalk.
The example below illustrates how to fill in the Plan Review Crosswalk.

Example
Assessing Vulnerability by Jurisdiction
Requirement §201.4(c)(2)(ii): [The State risk assessment shall include an] overview and analysis of the State’s vulnerability to the hazards described in
this paragraph (c)(2), based on estimates provided in local risk assessments … . The State shall describe vulnerability in terms of the jurisdictions most
threatened by the identified hazards, and most vulnerable to damage and loss associated with hazard event.
Element
A. Does the plan describe the State’s
vulnerability based on information from the
local risk assessments?
B. Does the plan present information on those
jurisdictions that face the most risk?

Location in the
Plan (section or
annex and page #)
Section III, pp. 1228
Section III, pp. 3036

SCORE
Reviewer’s Comments
The plan includes a description of local vulnerable structures. The plan
presented a vulnerability summary by regions in the state. This information
was collected from the approved plans on file.
The vulnerability description did not indicate which jurisdictions were the
most vulnerable.
Required Revisions:
• Use the information provided in the summaries to determine which
jurisdictions are most threatened by the identified hazards.
• Identify which jurisdictions have suffered or are likely to suffer the most
losses.
• If data are not readily available, note these data limitations in the plan.
Include actions in the mitigation strategy to obtain these data for the
plan update.
SUMMARY SCORE

January 2008

N

S
3

3

3

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Standard State Hazard Mitigation Plan Review and Approval Status
State Point of Contact:

Address:

Title:
Agency:
Phone Number:

E-Mail:

FEMA Reviewer:

Title:

Date:

Date Received in FEMA Region [Insert #]
Plan Not Approved
Plan Approved
Date Approved

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1

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:
ST AND ARD

ST ATE

H AZ ARD

MITIG ATION

PL AN

SUMM ARY

FEMA REGION [INSERT #]
Date of Plan:

CROSSW ALK

The plan cannot be approved if the plan has not been formally adopted.
Each requirement includes separate elements. All elements of the requirement must be rated
“Satisfactory” in order for the requirement to be fulfilled and receive a score of “Satisfactory.”
Elements of each requirement are listed on the following pages of the Plan Review Crosswalk.
A “Needs Improvement” score on elements shaded in gray (recommended but not required) will
not preclude the plan from passing. Reviewer’s comments must be provided for requirements
receiving a “Needs Improvement” score.

N – Needs Improvement: The plan does not meet the minimum for the requirement.
Reviewer’s comments must be provided.
S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are
encouraged, but not required.
NOT MET

MET

N

S

Documentation of the Planning Process: §201.4(c)(1)
Coordination Among Agencies: §201.4(b)

Profiling Hazards: §201.4(c)(2)(i)
Assessing Vulnerability by Jurisdiction: §201.4(c)(2)(ii)
Assessing Vulnerability of State Facilities:
§201.4(c)(2)(ii)
Estimating Potential Losses by Jurisdiction:
§201.4(c)(2)(iii)
Estimating Potential Losses of State Facilities:
§201.4(c)(2)(iii)

S

N

S

N

S

Funding Sources: §201.4(c)(3)(iv)
Coordination of Local Mitigation Planning
Local Funding and Technical Assistance:
§201.4(c)(4)(i)
Local Plan Integration: §201.4(c)(4)(ii)

Severe Repetitive Loss Mitigation Strategy
(only required for 90/10 under FMA & SRL)
Repetitive Loss Mitigation Strategy:
§201.4(c)(3)(v)
Coordination with Repetitive Loss Jurisdictions
§201.4(c)(3)(v)

Program Integration: §201.4(b)

Identifying Hazards: §201.4(c)(2)(i)

N

State Capability Assessment: §201.4(c)(3)(ii)

Prioritizing Local Assistance: §201.4(c)(4)(iii)

Adoption by the State: §201.4(c)(6) and §201.4(c)(7)

Risk Assessment

S

Mitigation Actions: §201.4(c)(3)(iii)

Please check one of the following for each requirement.

Planning Process

N

Hazard Mitigation Goals: §201.4(c)(3)(i)

Local Capability Assessment: §201.4(c)(3)(ii)

SCORING SYSTEM

Prerequisite

Mitigation Strategy

N

S
Plan Maintenance Process
Monitoring, Evaluating, and Updating the Plan:
§201.4(c)(5)(i)
Monitoring Progress of Mitigation Activities:
§201.4(c)(5)(ii) and (iii)
STANDARD STATE HAZARD MITIGATION PLAN APPROVAL STATUS
PLAN NOT APPROVED
PLAN APPROVED

See Reviewer’s Comments

January 2008

2

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

PREREQUISITE
Adoption by the State
Requirement §201.4(c)(6): The plan must be formally adopted by the State prior to submittal to [FEMA] for final review and approval.
Requirement §201.4(c)(7): The plan must include assurances that the State will comply with all applicable Federal statutes and regulations in effect with
respect to the periods for which it receives grant funding, in compliance with 44 CFR 13.11(c). The State will amend its plan whenever necessary to reflect
changes in State or Federal laws and statutes as required in 44 CFR 13.11(d).
Element

Location in the
Plan (section or
annex and page #)

SCORE
NOT
MET
MET

Reviewer’s Comments

A. Has the State formally adopted the new or updated plan?
B. Does the plan provide assurances that the State will
continue to comply with all applicable Federal statutes and
regulations during the periods for which it receives grant
funding, in compliance with 44 CFR 13.11(c), and will amend
its plan whenever necessary to reflect changes in State or
Federal laws and statutes as required in 44 CFR 13.11(d)?

SUMMARY SCORE

PLANNING PROCESS: §201.4(b): An effective planning process is essential in developing and maintaining a good plan.
Documentation of the Planning Process
Requirement §201.4(c)(1): [The State plan must include a] description of the planning process used to develop the plan, including how it was prepared, who
was involved in the process, and how other agencies participated.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the plan provide a narrative description of how the new
or updated plan was prepared?
B. Does the new or updated plan indicate who was involved in
the current planning process?
C. Does the new or updated plan indicate how other agencies
participated in the current planning process?
D. Does the updated plan document how the planning team
reviewed and analyzed each section of the plan?
E. Does the updated plan indicate for each section whether
or not it was revised as part of the update process?

SUMMARY SCORE

January 2008

3

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Coordination Among Agencies
Requirement §201.4(b): The [State] mitigation planning process should include coordination with other State agencies, appropriate Federal agencies,
interested groups, and … .
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.
Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.

A. Does the new or updated plan describe how Federal and State
agencies were involved in the current planning process?
B. Does the new or updated plan describe how interested groups
(e.g., businesses, non-profit organizations, and other interested
parties) were involved in the current planning process?
C. Does the updated plan discuss how coordination among
Federal and State agencies changed since approval of the
previous plan?

SUMMARY SCORE

Program Integration
Requirement §201.4(b): [The State mitigation planning process should] be integrated to the extent possible with other ongoing State planning efforts as well
as other FEMA mitigation programs and initiatives.
Element
A. Does the new or updated plan describe how the State mitigation
planning process is integrated with other ongoing State planning
efforts?
B. Does the new or updated plan describe how the State mitigation
planning process is integrated with FEMA mitigation programs
and initiatives?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.
Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.

SUMMARY SCORE

January 2008

4

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

RISK ASSESSMENT: §201.4(c)(2): [The State plan must include a risk assessment] that provides the factual basis for activities proposed in the strategy portion
of the mitigation plan. Statewide risk assessments must characterize and analyze natural hazards and risks to provide a statewide overview. This overview will
allow the State to compare potential losses throughout the State and to determine their priorities for implementing mitigation measures under the strategy, and
to prioritize jurisdictions for receiving technical and financial support in developing more detailed local risk and vulnerability assessments.
Identifying Hazards
Requirement §201.4(c)(2)(i): [The State risk assessment shall include an] overview of the type … of all natural hazards that can affect the State … .
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan provide a description of the type
of all natural hazards that can affect the State?
If the hazard identification omits (without explanation) any hazards
commonly recognized as threats to the State, this part of the plan
cannot receive a Satisfactory score.

SUMMARY SCORE

Profiling Hazards
Requirement §201.4(c)(2)(i): [The State risk assessment shall include an overview of the] location of all natural hazards that can affect the State, including
information on previous occurrences of hazard events, as well as the probability of future hazard events, using maps where appropriate … .
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the risk assessment identify the location (i.e., geographic
area affected) of each natural hazards addressed in the new or
updated plan?
B. Does the new or updated plan provide information on previous
occurrences of each hazard addressed in the plan?
C. Does the new or updated plan include the probability of future
events (i.e., chance of occurrence) for each hazard addressed in
the plan?

SUMMARY SCORE

January 2008

5

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Assessing Vulnerability
Requirement §201.4(c)(2)(ii): [The State risk assessment shall include an] overview and analysis of the State’s vulnerability to the hazards described in this
paragraph (c)(2), based on estimates provided in local risk assessments as well as the State risk assessment. The State shall describe vulnerability in terms of
the jurisdictions most threatened by the identified hazards, and most vulnerable to damage and loss associated with hazard events. State owned critical or
operated facilities located in the identified hazard areas shall also be addressed … .
Requirement §201.4(d): Plan must be reviewed and revised to reflect changes in development…
Assessing Vulnerability by Jurisdiction
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan describe the State’s vulnerability
based on estimates provided in local risk assessments as well as
the State risk assessment?
B. Does the new or updated plan describe the State’s vulnerability
in terms of the jurisdictions most threatened and most vulnerable
to damage and loss associated with hazard event(s)?
C. Does the updated plan explain the process used to analyze
the information from the local risk assessments, as
necessary?
D. Does the updated plan reflect changes in development for
jurisdictions in hazard prone areas?

SUMMARY SCORE

Assessing Vulnerability of State Facilities
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan describe the types of State owned
or operated critical facilities located in the identified hazard
areas?

SUMMARY SCORE

January 2008

6

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Estimating Potential Losses
Requirement §201.4(c)(2)(iii): [The State risk assessment shall include an] overview and analysis of potential losses to the identified vulnerable structures,
based on estimates provided in local risk assessments as well as the State risk assessment. The State shall estimate the potential dollar losses to State owned
or operated buildings, infrastructure, and critical facilities located in the identified hazard areas.
Requirement §201.4(d): Plan must be reviewed and revised to reflect changes in development…
Estimating Potential Losses by Jurisdiction
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan present an overview and analysis
of the potential losses to the identified vulnerable structures?
B. Are the potential losses based on estimates provided in local risk
assessments as well as the State risk assessment?
C. Does the updated plan reflect the effects of changes in
development on loss estimates?

SUMMARY SCORE

Estimating Potential Losses of State Facilities
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan present an estimate of the
potential dollar losses to State owned or operated buildings,
infrastructure, and critical facilities in the identified hazard areas?

SUMMARY SCORE

January 2008

7

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

MITIGATION STRATEGY: §201.4(c)(3) [To be effective the plan must include a] Mitigation Strategy that provides the State’s blueprint for reducing the losses
identified in the risk assessment.
Hazard Mitigation Goals
Requirement §201.4(c)(3)(i): [The State mitigation strategy shall include a] description of State goals to guide the selection of activities to mitigate and
reduce potential losses.
Requirement §201.4(d): Plan must be reviewed and revised to reflect changes in development, progress in statewide mitigation efforts, and changes in
priorities…

Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan provide a description of State
mitigation goals that guide the selection of mitigation activities?
B. Does the updated plan demonstrate that the goals were
assessed and either remain valid or have been revised?

SUMMARY SCORE

State Capability Assessment Requirement §201.4(c)(3)(ii): [The State mitigation strategy shall include a] discussion of the State’s pre-and post-disaster
hazard management policies, programs, and capabilities to mitigate the hazards in the area, including: an evaluation of State laws, regulations, policies, and
programs related to hazard mitigation as well as to development in hazard-prone areas [and] a discussion of State funding capabilities for hazard mitigation
projects … .

Element

Location in the
Plan (section or
annex and page #)

SCORE
Reviewer’s Comments

N

S

A. Does the new or updated plan include an evaluation of the
State’s pre-disaster hazard management policies, programs, and
capabilities?
B. Does the new or updated plan include an evaluation of the
State’s post-disaster hazard management policies, programs,
and capabilities?
C. Does the new or updated plan include an evaluation of the
State’s policies related to development in hazard prone areas?
D. Does the new or updated plan include a discussion of State
funding capabilities for hazard mitigation projects?
E. Does the updated plan address any hazard management
capabilities of the State that have changed since approval of
the previous plan?
January 2008

8

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:
SUMMARY SCORE

Local Capability Assessment
Requirement §201.4(c)(3)(ii): [The State mitigation strategy shall include] a general description and analysis of the effectiveness of local mitigation policies,
programs, and capabilities.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan present a general description of
the local mitigation policies, programs, and capabilities?
B. Does the new or updated plan provide a general analysis of the
effectiveness of local mitigation policies, programs, and
capabilities?

SUMMARY SCORE

Mitigation Actions
Requirement §201.4(c)(3)(iii): [State plans shall include an] identification, evaluation, and prioritization of cost-effective, environmentally sound, and
technically feasible mitigation actions and activities the State is considering and an explanation of how each activity contributes to the overall mitigation
strategy. This section should be linked to local plans, where specific local actions and projects are identified.
Requirement §201.4(d): Plan must be reviewed and revised to reflect changes in development, progress in statewide mitigation efforts, and changes in
priorities…

Element
A. Does the new or updated plan identify cost-effective,
environmentally sound, and technically feasible mitigation actions
and activities the State is considering?
B. Does the new or updated plan evaluate these actions and
activities?
C. Does the new or updated plan prioritize these actions and
activities?
D. Does the new or updated plan explain how each activity
contributes to the overall State mitigation strategy?
E. Does the mitigation strategy in the new or updated section
reflect actions and projects identified in local plans?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.

SUMMARY SCORE
January 2008

9

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Funding Sources
Requirement §201.4(c)(3)(iv): [The State mitigation strategy shall include an] identification of current and potential sources of Federal, State, local, or
private funding to implement mitigation activities.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan identify current sources of
Federal, State, local, or private funding to implement mitigation
activities?
B. Does the new or updated plan identify potential sources of
Federal, State, local, or private funding to implement mitigation
activities?
C. Does the updated plan identify the sources of mitigation
funding used to implement activities in the mitigation
strategy since approval of the previous plan?

SUMMARY SCORE

COORDINATION OF LOCAL MITIGATION PLANNING
Local Funding and Technical Assistance
Requirement §201.4(c)(4)(i): [The section on the Coordination of Local Mitigation Planning must include a] description of the State process to support,
through funding and technical assistance, the development of local mitigation plans.

Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan provide a description of the State
process to support, through funding and technical assistance, the
development of local mitigation plans?
B. Does the updated plan describe the funding and technical
assistance the State has provided in the past three years to
assist local jurisdictions in completing approvable mitigation
plans?

SUMMARY SCORE

January 2008

10

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Local Plan Integration
Requirement §201.4(c)(4)(ii): [The section on the Coordination of Local Mitigation Planning must include a] description of the State process and timeframe
by which the local plans will be reviewed, coordinated, and linked to the State Mitigation Plan.
Requirement §201.4(d): Plan must be reviewed and revised to reflect changes in development, progress in statewide mitigation efforts, and changes in
priorities…
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan provide a description of the
process and timeframe the State established to review local
plans?
B. Does the new or updated plan provide a description of the
process and timeframe the State established to coordinate and
link local plans to the State Mitigation Plan?

SUMMARY SCORE

January 2008

11

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Prioritizing Local Assistance
Requirement §201.4(c)(4)(iii): [The section on the Coordination of Local Mitigation Planning must include] criteria for prioritizing communities and local
jurisdictions that would receive planning and project grants under available funding programs, which should include consideration for communities with the
highest risks, repetitive loss properties, and most intense development pressures.
Further, that for non-planning grants, a principal criterion for prioritizing grants shall be the extent to which benefits are maximized according to a cost
benefit review of proposed projects and their associated costs.
Requirement §201.4(d): Plan must be reviewed and revised to reflect changes in development, progress in statewide mitigation efforts, and changes in
priorities…
Element
A. Does the new or updated plan provide a description of the
criteria for prioritizing those communities and local jurisdictions
that would receive planning and project grants under available
mitigation funding programs?
B. For the new or updated plan, do the prioritization criteria
include, for non-planning grants, the consideration of the extent to
which benefits are maximized according to a cost benefit review
of proposed projects and their associated cost?
C. For the new or updated plan, do the criteria include
considerations for communities with the highest risk?
D. For the new or updated plan, do the criteria include
considerations for repetitive loss properties?
E. For the new or updated plan, do the criteria include
considerations for communities with the most intense
development pressures?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.
Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.
Note: A “Needs Improvement” score on this requirement will not
preclude the plan from passing.

SUMMARY SCORE

January 2008

12

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

PLAN MAINTENANCE PROCESS
Monitoring, Evaluating, and Updating the Plan Requirement §201.4(c)(5)(i): [The Standard State Plan Maintenance Process must include an] established
method and schedule for monitoring, evaluating, and updating the plan.

Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the new or updated plan describe the method and
schedule for monitoring the plan? (e.g., identifies the party
responsible for monitoring, includes schedule for reports, site
visits, phone calls, and/or meetings)
B. Does the new or updated plan describe the method and
schedule for evaluating the plan? (e.g., identifies the party
responsible for evaluating the plan, includes the criteria used to
evaluate the plan)
C. Does the new or updated plan describe the method and
schedule for updating the plan?
D. Does the updated plan include an analysis of whether the
previously approved plan’s method and schedule worked,
and what elements or processes, if any, were changed?

SUMMARY SCORE

Monitoring Progress of Mitigation Activities Requirement §201.4(c)(5)(ii): [The Standard State Plan Maintenance Process must include a] system for
monitoring implementation of mitigation measures and project closeouts. Requirement §201.4(c)(5)(iii): [The Standard State Plan Maintenance Process
must include a] system for reviewing progress on achieving goals as well as activities and projects in the Mitigation Strategy.

Element
A. Does the new or updated plan describe how mitigation
measures and project closeouts will be monitored?
B. Does the new or updated plan identify a system for reviewing
progress on achieving goals in the Mitigation Strategy?
C. Does the updated plan describe any modifications, if any, to
the system identified in the previously approved plan to track
the initiation, status, and completion of mitigation activities?
D. Does the new or updated plan identify a system for reviewing
progress on implementing activities and projects of the Mitigation
Strategy?
E. Does the updated plan discuss if mitigation actions were
implemented as planned?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: Related to §201.4 (c)(3)(iii)

SUMMARY SCORE
January 2008

13

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

SEVERE REPETITIVE LOSS STRATEGY (only required for 90/10 under FMA & SRL)
Repetitive Loss Mitigation Strategy
Requirement §201.4(c)(3)(v): A State may request the reduced cost share authorized under §79.4(c)(2) of this chapter for the FMA and SRL programs, if it
has an approved State Mitigation Plan … that also identifies specific actions the State has taken to reduce the number of repetitive loss properties (which
must include severe repetitive loss properties), and specifies how the State intends to reduce the number of such repetitive loss properties.

Element
A. Does the new or updated plan describe State mitigation
goals that support the selection of mitigation activities for
repetitive loss properties (see also Part 201.4(c)(3)(i))?
B. Does the new or updated plan consider repetitive loss
properties in its evaluation of the State’s hazard
management policies, programs, and capabilities and its
general description of the local mitigation capabilities (see
also Part 201.4(c)(3)(ii))?
C. Does the new or updated plan address repetitive loss
properties in its risk assessment (see also Part
201.4(c)(2))?
D. Does the new or updated plan identify, evaluate and
prioritize cost-effective, environmentally sound, and
technically feasible mitigation actions for repetitive loss
properties (see also Part 201.4(c)(3)(iii))?
E. Does the new or updated plan describe specific actions
that have been implemented to mitigate repetitive loss
properties, including actions taken to reduce the number of
severe repetitive loss properties?
F. Does the new or updated plan identify current and potential
sources of Federal, State, local, or private funding to
implement mitigation activities for repetitive loss properties
(see also Part 201.4(c)(3)(iv))?

Location in the
Plan (section or
annex and page #)

SCORE
NOT
MET
MET

Reviewer’s Comments
[Note: Only required for SRL 90/10 under FMA & SRL]
[Note: Only required for SRL 90/10 under FMA & SRL]

[Note: Only required for SRL 90/10 under FMA & SRL]
[Note: Only required for SRL 90/10 under FMA & SRL]

[Note: Only required for SRL 90/10 under FMA & SRL]

[Note: Only required for SRL 90/10 under FMA & SRL]

SUMMARY SCORE

January 2008

14

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Coordination with Repetitive Loss Jurisdictions
Requirement §201.4(c)(3(v): In addition, the plan must describe the strategy the State has to ensure that local jurisdictions with severe repetitive loss
properties take actions to reduce the number of these properties, including the development of local mitigation plans.

Element
A. Does the new or updated plan provide a description of the
State process to support, through funding and technical
assistance, the development of local mitigation plans in
communities with severe repetitive loss properties (see
also Part 201.4(c)(4)(i))?
B. Does the new or updated plan include considerations for
repetitive loss properties in its criteria for prioritizing
communities and local jurisdictions that would receive
planning and project grants under available mitigation
funding programs (see also Part 201.4(c)(3)(iii))?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

[Note: Only required for SRL 90/10 under FMA & SRL]

[Note: Only required for SRL 90/10 under FMA & SRL]

SUMMARY SCORE

January 2008

15

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Matrix A: Profiling Hazards
This matrix can assist FEMA in scoring each hazard. States may find the matrix useful to ensure that their plan addresses each natural hazard that can affect the
State. Completing the matrix is not required.
Note: First, check which hazards are identified in requirement §201.4(c)(2)(i). Then, place a checkmark in either the N or S box for each applicable hazard. An
“N” for any element of any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its related shortcoming in the
comments section of the Plan Review Crosswalk.

Hazard Type

Hazards Identified
Per Requirement

§201.4(c)(2)(i)
Yes

A. Location
N

S

B. Previous
Occurrences
N

S

C. Probability of
Future Events
N

S

Avalanche
Coastal Erosion
Coastal Storm

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Dam Failure
Drought
Earthquake
Expansive Soils
Extreme Heat
Flood
Hailstorm
Hurricane
Land Subsidence
Landslide
Levee Failure
Severe Winter Storm
Tornado
Tsunami
Volcano
Wildfire
Windstorm
Other
Other
Other
Legend:
§201.4(c)(2)(i) Profiling Hazards
A. Does the risk assessment identify the location (i.e., geographic area affected) of each natural hazard addressed in the new or updated plan?
B. Does the plan provide information on previous occurrences of each hazard addressed in the new or updated plan?
C. Does the plan include the probability of future events (i.e., chance of occurrence) for each hazard addressed in the new or updated plan?

January 2008

16

STANDARD STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

FEMA REGION [INSERT #]
Date of Plan:

Matrix B: Assessing Vulnerability
This matrix can assist FEMA in scoring each hazard. States may find the matrix useful to ensure that their plan addresses each requirement. Note
that this matrix only includes items for Requirements §201.4(c)(2)(ii) and §201.4(c)(2)(iii) that are related to specific natural hazards that can affect
the State. Completing the matrix is not required.
Note: First, check which hazards are identified in requirement §201.4(c)(2)(i). Then, place a checkmark in either the N or S box for each applicable hazard. An
“N” for any element of any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its related shortcoming in the
comments section of the Plan Review Crosswalk.

N

S

2. Vulnerability
to State
Facilities
N

3. Loss Estimate 4. Loss Estimate
by Jurisdiction of State Facilities

S

N
§201.4(c)(2)(iii) Estimating Potential Losses

Avalanche
Coastal Erosion
Coastal Storm
Dam Failure
Drought
Earthquake
Expansive Soils
Extreme Heat
Flood
Hailstorm
Hurricane
Land Subsidence
Landslide
Levee Failure
Severe Winter Storm
Tornado
Tsunami
Volcano
Wildfire
Windstorm
Other
Other
Other

1. Vulnerability
by Jurisdiction

§201.4(c)(2)(ii) Assessing Vulnerability

Hazard Type

Hazards
Identified Per
Requirement
§201.4(c)(2)(i)
Yes

Legend
§201.4(c)(2)(ii) Assessing Vulnerability by Jurisdiction (see element B)
1. Does the new or updated plan describe the State’s vulnerability in terms of the
jurisdictions most threatened and most vulnerable to damage and loss associated with
hazard event(s)?
§201.4(c)(2)(ii) Assessing Vulnerability to State Facilities (see element A)
2. Does the new or updated plan describe the types of State owned or operated critical
facilities located in the identified hazard areas?

January 2008

S

N

S

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§201.4(c)(2)(iii) Estimating Potential Losses by Jurisdiction (see element A)
3. Does the new or updated plan present an overview and analysis of the potential losses
to the identified vulnerable structures?
§201.4(c)(2)(iii) Estimating Potential Losses of State Facilities (see element A)
4. Does the new or updated plan present an estimate of the potential dollar losses to
State owned or operated buildings, infrastructure, and critical facilities in the identified
hazard areas?

17

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State

Date of Plan:

Instructions for Using the Attached Plan Review Crosswalk for Review of Enhanced State Hazard Mitigation Plans
Attached is a Plan Review Crosswalk based on the Multi-Hazard Mitigation Planning Guidance Under the Disaster Mitigation Act of 2000, published by FEMA, dated
March 2004, and revised June 2007. This Plan Review Crosswalk is consistent with the Disaster Mitigation Act of 2000 (P.L. 106-390), enacted October 30, 2000 and 44
CFR Part 201 – Mitigation Planning (the Rule).
SCORING SYSTEM
N – Needs Improvement: The plan does not meet the minimum for the requirement. Reviewer’s comments must be provided.
S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are encouraged, but not required.
Each requirement includes separate elements. All elements of a requirement must be rated “Satisfactory” in order for the requirement to be fulfilled and receive a
summary score of “Satisfactory.”
The example below illustrates how to fill in the Plan Review Crosswalk.

Example

6. Effective Use of Available Mitigation Funding
Requirement §201.5(b)(3): [The Enhanced Plan must demonstrate] that the State effectively uses existing mitigation programs to achieve its mitigation
goals.
Element
A. Does the new or updated Enhanced
Plan document how the State has
made full use of funding available
from FEMA mitigation grant
programs, and if the State has not
made full use of this funding, does
the plan explain the reasons why?

Location in the
Plan (section or
annex and page #)
Section VI, pp. 23

SCORE
Reviewer’s Comments
The plan contains information that the State has not made full use of
funding from FEMA grant programs, without explaining why this is the
case.

3
Required Revision:
• Discuss why all available funding from FEMA grant programs was
not used.
SUMMARY SCORE

June 2007

N

3

S

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State

Date of Plan:

Enhanced State Hazard Mitigation Plan Review and Approval Status
Address:
State Point of Contact:
Title:
Agency:
Phone Number:

E-Mail:

FEMA Reviewer:

Title:

Date:

Date Received in FEMA Region [insert #]
Plan Not Approved
Plan Approved
Date Approved

June 2007

1

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

–
Date of Plan:

ENHANCED STATE HAZARD MITIGATION PLAN SUMMARY CROSSWALK
The plan cannot be approved if the plan has not been formally adopted.
Each requirement includes separate elements. All elements of the requirement must be rated “Satisfactory” in order for the requirement to be fulfilled and receive a
score of “Satisfactory.” Elements of each requirement are listed on the following pages of the Plan Review Crosswalk. Reviewer’s comments must be provided for
requirements receiving a “Needs Improvement” score.
SCORING SYSTEM
Please check one of the following for each requirement:
N – Needs Improvement: The plan does not meet the minimum for the requirement. Reviewer’s comments must be provided.
S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are encouraged, but not required.

Prerequisite
1. Compliance with Standard State Plan Requirements:
§201.5(b)
Comprehensive State Hazard Mitigation Planning
Program

NOT MET

MET

N

S

2. Integration with Other Planning Initiatives: §201.5(b)(1)
3. Project Implementation Capability: §201.5(b)(2)(i) and
(ii)
4. Program Management Capability: §201.5(b)(2)(iii A-D)
5. Assessment of Mitigation Actions: §201.5(b)(2)(iv)
6. Effective Use of Available Mitigation Funding:
§201.5(b)(3)
7. Commitment to a Comprehensive Mitigation Program:
§201.5(b)(4)(i-vi)
ENHANCED STATE HAZARD MITIGATION PLAN APPROVAL STATUS
PLAN NOT APPROVED
PLAN APPROVED
See Reviewer’s Comments
June 2007

2

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

–
Date of Plan:

PREREQUISITE
1. Compliance with Standard State Plan Requirements
Requirement §201.5(b): Enhanced State Mitigation Plans must include all elements of the Standard State Mitigation Plan identified in §201.4 … .
Element
A. Does the new or updated Enhanced Plan meet all
the Standard State Mitigation Plan requirements?

Location in the
Plan (section or
annex and page #)

SCORE
NOT
MET
MET

Reviewer’s Comments

SUMMARY SCORE
COMPREHENSIVE STATE HAZARD MITIGATION PLANNING PROGRAM

2. Integration with Other Planning Initiatives
Requirement §201.5(b)(1): [An Enhanced Plan must demonstrate] that the plan is integrated to the extent practicable with other State and/or regional planning initiatives
(comprehensive, growth management, economic development, capital improvement, land development, and/or emergency management plans) and FEMA mitigation
programs and initiatives that provide guidance to State and regional agencies.
Location in the
SCORE
Plan (section or
N
S
annex and page #) Reviewer’s Comments
Element
A. Does the new or updated Enhanced Plan
demonstrate how it is integrated to the extent
practicable with other State and regional planning
initiatives (comprehensive, growth management,
economic development, capital improvement, land
development, and/or emergency management
plans)?
B. Does the new or updated Enhanced Plan
demonstrate how it has been integrated to the extent
practicable with FEMA mitigation programs and
initiatives that provide guidance to State and regional
agencies?
SUMMARY SCORE

June 2007

3

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

–
Date of Plan:

3. Project Implementation Capability
Requirement §201.5(b)(2)(i) and (ii): [The Enhanced Plan must document] the State’s project implementation capability, identifying and demonstrating the
ability to implement the plan, including:
ƒ Established eligibility criteria for multi-hazard mitigation measures.
ƒ A system to determine the cost effectiveness of mitigation measures, consistent with OMB Circular A-94, Guidelines and Discount Rates for Benefit-Cost
Analysis of Federal Programs, and
ƒ [A system] to rank the measures according to the State’s eligibility criteria.
Element
A. Does the new or updated Enhanced Plan
demonstrate that the State has established eligibility
criteria for multi-hazard mitigation measures? Does
the updated Plan describe changes, if any, to
those criteria?
B. Does the new or updated Enhanced Plan describe
the State’s system for determining the cost
effectiveness of mitigation measures, consistent with
OMB Circular A-94? Does the updated Plan
describe changes, if any, to this system?
C. Does the new or updated Enhanced Plan describe
the State’s system to rank the measures according to
the State’s eligibility criteria, including a process to
prioritize projects between jurisdictions and
between proposals that address different or
multiple hazards?

Location in the
Plan (section or
annex and page #)

SCORE
Reviewer’s Comments

N

S

SUMMARY SCORE

June 2007

4

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

–
Date of Plan:

4. Program Management Capability
Requirement §201.5(b)(2)(iii A-D): [The Enhanced Plan must demonstrate] that the State has the capability to effectively manage the HMGP as well as
other mitigation grant programs, [and provide] a record of the following:
ƒ Meeting HMGP and other mitigation grant application timeframes and submitting complete, technically feasible, and eligible project applications with
appropriate supporting documentation;
ƒ Preparing and submitting accurate environmental reviews and benefit-cost analyses;
ƒ Submitting complete and accurate quarterly progress and financial reports on time; and
ƒ Completing HMGP and other mitigation grant projects within established performance periods, including financial reconciliation.
Element
A. Does the new or updated Enhanced Plan describe the
State’s capability to effectively manage the HMGP as well
as other mitigation grant programs?
B. Does the new or updated Enhanced Plan provide a record
for meeting HMGP and other mitigation grant application
timeframes and submitting complete, technically feasible,
and eligible project applications with appropriate supporting
documentation?
C. Does the new or updated Enhanced Plan provide a record
for preparing and submitting accurate environmental
reviews and benefit-cost analyses?
D. Does the new or updated Enhanced Plan provide a record
for submitting complete and accurate quarterly progress
and financial reports on time?
E. Does the new or updated Enhanced Plan provide a record
for completing HMGP and other mitigation grant projects
within established performance periods, including financial
reconciliation?
SUMMARY SCORE

June 2007

Location in the
Plan (section or
annex and page #)

SCORE
Reviewer’s Comments
[See Regional Certification to Determine Score]

N

S

[See Regional Certification to Determine Score]

[See Regional Certification to Determine Score]
[See Regional Certification to Determine Score]
[See Regional Certification to Determine Score]

5

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

–
Date of Plan:

5. Assessment of Mitigation Actions
Requirement §201.5(b)(2)(iv): [The Enhanced Plan must document the] system and strategy by which the State will conduct an assessment of the completed
mitigation actions and include a record of the effectiveness (actual cost avoidance) of each mitigation action.

Element
A. Does the new or updated Enhanced Plan describe
the system and strategy by which the State will
conduct an assessment of the completed mitigation
actions?
B. Does the new or updated Enhanced Plan include the
record of the effectiveness (i.e., actual cost
avoidance) of each mitigation actions, including how
the assessment was completed?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

6. Effective Use of Available Mitigation Funding
Requirement §201.5(b)(3): [The Enhanced Plan must demonstrate] that the State effectively uses existing mitigation programs to achieve its mitigation goals.

Element
A. Does the new or updated Enhanced Plan
document how the State has made full use of
funding available from FEMA mitigation grant
programs, and if the State has not made full use of
this funding, does the plan explain the reasons
why?
B. Does the new or updated Enhanced Plan document
how the State is effectively using existing programs to
achieve its mitigation goals?

Location in the
Plan (section or
annex and page
#)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

June 2007

6

ENHANCED STATE HAZARD MITIGATION PLAN REVIEW CROSSWALK
State:

–
Date of Plan:

7. Commitment to a Comprehensive Mitigation Program
Requirement §201.5(b)(4)(i-vi): [The Enhanced Plan must demonstrate] that the State is committed to a comprehensive state mitigation program, which
might include any of the following:
ƒ A commitment to support local mitigation planning by providing workshops and training, State planning grants, or coordinated capability development of
local officials, including Emergency Management and Floodplain Management certifications.
ƒ A Statewide program of hazard mitigation through the development of legislative initiatives, mitigation councils, formation of public/private partnerships,
and/or other executive actions that promote hazard mitigation.
ƒ The State provides a portion of the non-Federal match for HMGP and/or other mitigation projects.
ƒ To the extent allowed by State Law, the State requires or encourages local governments to use a current version of a nationally applicable model building
code or standard that addresses natural hazards as a basis for design and construction of State sponsored mitigation projects.
ƒ A comprehensive, multi-year plan to mitigate the risks posed to the existing buildings that have been identified as necessary for post-disaster response and
recovery operations.
ƒ A comprehensive description of how the State integrates mitigation into its post-disaster recovery operations.
Element
A. Does the new or updated Enhanced Plan
demonstrate that the State is committed to a
comprehensive State mitigation program?
B. Does the updated Enhanced Plan demonstrate
progress in implementing a comprehensive
State mitigation program, including new
mitigation initiatives developed or implemented
by the State?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

June 2007

7

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Instructions for Using the Plan Review Crosswalk for Review of Local Mitigation Plans
Attached is a Plan Review Crosswalk based on the Multi-Hazard Mitigation Planning Guidance Under the Disaster Mitigation Act of 2000, published by FEMA, dated March
2004. This Plan Review Crosswalk is consistent with the Disaster Mitigation Act of 2000 (P.L. 106-390), enacted October 30, 2000 and 44 CFR Part 201 – Mitigation Planning,
Interim Final Rule (the Rule), published February 26, 2002.
SCORING SYSTEM
N – Needs Improvement: The plan does not meet the minimum for the requirement. Reviewer’s comments must be provided.
S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are encouraged, but not required.
Each requirement includes separate elements. All elements of a requirement must be rated “Satisfactory” in order for the requirement to be fulfilled and receive a summary score
of “Satisfactory.” A “Needs Improvement” score on elements shaded in gray (recommended but not required) will not preclude the plan from passing.
When reviewing single jurisdiction plans, reviewers may want to put an N/A in the boxes for multi-jurisdictional plan requirements. When reviewing multi-jurisdictional plans,
reviewers may want to put an N/A in the prerequisite box for single jurisdiction plans.
States that have additional requirements can add them in the appropriate sections of the Multi-Hazard Mitigation Planning Guidance or create a new section and modify this Plan
Review Crosswalk to record the score for those requirements.
Optional matrices for assisting in the review of sections on profiling hazards, assessing vulnerability, and identifying and analyzing mitigation actions are found at the end of the
Plan Review Crosswalk.
The example below illustrates how to fill in the Plan Review Crosswalk.

Example
Assessing Vulnerability: Overview
Requirement §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.
Location in the
SCORE
Plan (section or
N
S
Element
annex and page #)
Reviewer’s Comments
A. Does the plan include an overall
Section II, pp. 4-10
The plan describes the types of assets that are located within geographically defined
3
summary description of the jurisdiction’s
hazard areas as well as those that would be affected by winter storms.
vulnerability to each hazard?
B. Does the plan address the impact of
Section II, pp. 10The plan does not address the impact of two of the five hazards addressed in the plan.
each hazard on the jurisdiction?
20
Required Revisions:
• Include a description of the impact of floods and earthquakes on the assets.
Recommended Revisions:

3

• This information can be presented in terms of dollar value or percentages of damage.

SUMMARY SCORE

March 2004

3

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Local Mitigation Plan Review and Approval Status
Jurisdiction:

Title of Plan:

Local Point of Contact:

Date of Plan:
Address:

Title:
Agency:
Phone Number:

E-Mail:

State Reviewer:

Title:

Date:

FEMA Reviewer:

Title:

Date:

Date Received in FEMA Region [Insert #]
Plan Not Approved
Plan Approved
Date Approved
NFIP Status*
Y

Jurisdiction:

N

N/A

CRS
Class

1.
2.
3.
4.
5.

[ATTACH PAGE(S) WITH ADDITIONAL JURISDICTIONS]

* Notes:
March 2004

Y = Participating

N = Not Participating

N/A = Not Mapped
1

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:
LOCAL

MITIG ATION

PLAN

REVIEW

FEMA REGION [INSERT #]

SUMM ARY

The plan cannot be approved if the plan has not been formally adopted.
Each requirement includes separate elements. All elements of the requirement must be rated
“Satisfactory” in order for the requirement to be fulfilled and receive a score of “Satisfactory.”
Elements of each requirement are listed on the following pages of the Plan Review Crosswalk.
A “Needs Improvement” score on elements shaded in gray (recommended but not required) will
not preclude the plan from passing. Reviewer’s comments must be provided for requirements
receiving a “Needs Improvement” score.
SCORING SYSTEM
Please check one of the following for each requirement.
N – Needs Improvement: The plan does not meet the minimum for the requirement.
Reviewer’s comments must be provided.
S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are
encouraged, but not required.
Prerequisite(s) (Check Applicable Box)

NOT MET

MET

Adoption by the Local Governing Body:
§201.6(c)(5) OR

Identifying Hazards: §201.6(c)(2)(i)

S

N

S

N

S

Local Hazard Mitigation Goals: §201.6(c)(3)(i)
Identification and Analysis of Mitigation Actions:
§201.6(c)(3)(ii)
Implementation of Mitigation Actions:
§201.6(c)(3)(iii)
Multi-Jurisdictional Mitigation Actions:
§201.6(c)(3)(iv)
Plan Maintenance Process
Monitoring, Evaluating, and Updating the Plan:
§201.6(c)(4)(i)
Incorporation into Existing Planning Mechanisms:
§201.6(c)(4)(ii)

Additional State Requirements*
Insert State Requirement
N

S

Documentation of the Planning Process: §201.6(b)
and §201.6(c)(1)
Risk Assessment

N

Continued Public Involvement: §201.6(c)(4)(iii)

Multi-Jurisdictional Plan Adoption: §201.6(c)(5)
AND
Multi-Jurisdictional Planning Participation:
§201.6(a)(3)
Planning Process

Mitigation Strategy

Insert State Requirement
Insert State Requirement

N

S

LOCAL MITIGATION PLAN APPROVAL STATUS

Profiling Hazards: §201.6(c)(2)(i)

PLAN NOT APPROVED

Assessing Vulnerability: Overview: §201.6(c)(2)(ii)
Assessing Vulnerability: Identifying Structures:
§201.6(c)(2)(ii)(A)
Assessing Vulnerability: Estimating Potential
Losses: §201.6(c)(2)(ii)(B)
Assessing Vulnerability: Analyzing Development
Trends: §201.6(c)(2)(ii)(C)
Multi-Jurisdictional Risk Assessment:
§201.6(c)(2)(iii)

March 2004

PLAN APPROVED
*States that have additional requirements can add them in the appropriate sections of
the Multi-Hazard Mitigation Planning Guidance or create a new section and modify
this Plan Review Crosswalk to record the score for those requirements.
See Reviewer’s Comments
2

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

PREREQUISITE(S)
Adoption by the Local Governing Body
Requirement §201.6(c)(5): [The local hazard mitigation plan shall include] documentation that the plan has been formally adopted by the governing body of
the jurisdiction requesting approval of the plan (e.g., City Council, County Commissioner, Tribal Council).
Element
A. Has the local governing body adopted the plan?
B. Is supporting documentation, such as a resolution,
included?

Location in the
Plan (section or
annex and page #)

SCORE
NOT
MET
MET

Reviewer’s Comments

SUMMARY SCORE

Multi-Jurisdictional Plan Adoption
Requirement §201.6(c)(5): For multi-jurisdictional plans, each jurisdiction requesting approval of the plan must document that it has been formally adopted.
Element
A. Does the plan indicate the specific jurisdictions
represented in the plan?
B. For each jurisdiction, has the local governing body
adopted the plan?
C. Is supporting documentation, such as a resolution,
included for each participating jurisdiction?

Location in the
Plan (section or
annex and page #)

SCORE
NOT
MET
MET

Reviewer’s Comments

SUMMARY SCORE

Multi-Jurisdictional Planning Participation
Requirement §201.6(a)(3): Multi-jurisdictional plans (e.g., watershed plans) may be accepted, as appropriate, as long as each jurisdiction has participated
in the process … Statewide plans will not be accepted as multi-jurisdictional plans.
Element

Location in the
Plan (section or
annex and page #)

SCORE
NOT
MET
MET

Reviewer’s Comments

A. Does the plan describe how each jurisdiction
participated in the plan’s development?

SUMMARY SCORE

March 2004

3

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

PLANNING PROCESS: §201.6(b): An open public involvement process is essential to the development of an effective plan.
Documentation of the Planning Process
Requirement §201.6(b): In order to develop a more comprehensive approach to reducing the effects of natural disasters, the planning process shall include:
(1) An opportunity for the public to comment on the plan during the drafting stage and prior to plan approval;
(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
(3) Review and incorporation, if appropriate, of existing plans, studies, reports, and technical information.
Requirement §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.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the plan provide a narrative description of the
process followed to prepare the plan?
B. Does the plan indicate who was involved in the
planning process? (For example, who led the
development at the staff level and were there any
external contributors such as contractors? Who
participated on the plan committee, provided
information, reviewed drafts, etc.?)
C. Does the plan indicate how the public was involved?
(Was the public provided an opportunity to comment
on the plan during the drafting stage and prior to the
plan approval?)
D. Was there an opportunity for neighboring
communities, agencies, businesses, academia,
nonprofits, and other interested parties to be involved
in the planning process?
E. Does the planning process describe the review and
incorporation, if appropriate, of existing plans, studies,
reports, and technical information?

SUMMARY SCORE

March 2004

4

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

RISK ASSESSMENT: §201.6(c)(2): The plan shall include a risk assessment that provides the factual basis for activities proposed in the strategy to reduce
losses from identified hazards. Local risk assessments must provide sufficient information to enable the jurisdiction to identify and prioritize appropriate
mitigation actions to reduce losses from identified hazards.
Identifying Hazards
Requirement §201.6(c)(2)(i): [The risk assessment shall include a] description of the type … of all natural hazards that can affect the jurisdiction.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the plan include a description of the types of all
natural hazards that affect the jurisdiction?
If the hazard identification omits (without explanation)
any hazards commonly recognized as threats to the
jurisdiction, this part of the plan cannot receive a
Satisfactory score.
Consult with the State Hazard Mitigation Officer to
identify applicable hazards that may occur in the
planning area.

SUMMARY SCORE

Profiling Hazards
Requirement §201.6(c)(2)(i): [The risk assessment shall include a] description of the … location 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.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the risk assessment identify the location (i.e.,
geographic area affected) of each natural hazard
addressed in the plan?
B. Does the risk assessment identify the extent (i.e.,
magnitude or severity) of each hazard addressed in
the plan?
C. Does the plan provide information on previous
occurrences of each hazard addressed in the plan?
D. Does the plan include the probability of future events
(i.e., chance of occurrence) for each hazard addressed
in the plan?

SUMMARY SCORE

March 2004

5

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Assessing Vulnerability: Overview
Requirement §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.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the plan include an overall summary description
of the jurisdiction’s vulnerability to each hazard?
B. Does the plan address the impact of each hazard on
the jurisdiction?

SUMMARY SCORE

Assessing Vulnerability: Identifying Structures
Requirement §201.6(c)(2)(ii)(A): The plan should describe vulnerability in terms of the types and numbers of existing and future buildings, infrastructure,
and critical facilities located in the identified hazard area … .
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will
not preclude the plan from passing.

A. Does the plan describe vulnerability in terms of the
types and numbers of existing buildings,
infrastructure, and critical facilities located in the
identified hazard areas?
B. Does the plan describe vulnerability in terms of the
types and numbers of future buildings, infrastructure,
and critical facilities located in the identified hazard
areas?

Note: A “Needs Improvement” score on this requirement will
not preclude the plan from passing.

SUMMARY SCORE

Assessing Vulnerability: Estimating Potential Losses
Requirement §201.6(c)(2)(ii)(B): [The plan should describe vulnerability in terms of an] estimate of the potential dollar losses to vulnerable structures
identified in paragraph (c)(2)(i)(A) of this section and a description of the methodology used to prepare the estimate … .
Element
A. Does the plan estimate potential dollar losses to
vulnerable structures?
B. Does the plan describe the methodology used to
prepare the estimate?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will
not preclude the plan from passing.
Note: A “Needs Improvement” score on this requirement will
not preclude the plan from passing.

SUMMARY SCORE
March 2004

6

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Assessing Vulnerability: Analyzing Development Trends
Requirement §201.6(c)(2)(ii)(C): [The plan should describe vulnerability in terms of] 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.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

Note: A “Needs Improvement” score on this requirement will
not preclude the plan from passing.

A. Does the plan describe land uses and development
trends?

SUMMARY SCORE

Multi-Jurisdictional Risk Assessment
Requirement §201.6(c)(2)(iii): For multi-jurisdictional plans, the risk assessment must assess each jurisdiction’s risks where they vary from the risks facing
the entire planning area.
Element
A. Does the plan include a risk assessment for each
participating jurisdiction as needed to reflect unique
or varied risks?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

MITIGATION STRATEGY: §201.6(c)(3): The plan shall include a mitigation strategy that 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.
Local Hazard Mitigation Goals
Requirement §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.
Element
A Does the plan include a description of mitigation
goals to reduce or avoid long-term vulnerabilities to
the identified hazards? (GOALS are long-term;
represent what the community wants to achieve,
such as “eliminate flood damage”; and are based on
the risk assessment findings.)

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE
March 2004

7

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Identification and Analysis of Mitigation Actions
Requirement §201.6(c)(3)(ii): [The 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.
Element
A. Does the plan identify and analyze a
comprehensive range of specific mitigation actions
and projects for each hazard?
B Do the identified actions and projects address
reducing the effects of hazards on new buildings
and infrastructure?
C. Do the identified actions and projects address
reducing the effects of hazards on existing
buildings and infrastructure?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

Implementation of Mitigation Actions
Requirement: §201.6(c)(3)(iii): [The mitigation strategy section shall include] an action plan describing how the actions identified in section (c)(3)(ii) 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.
Element
A. Does the mitigation strategy include how the actions
are prioritized? (For example, is there a discussion
of the process and criteria used?)
B. Does the mitigation strategy address how the
actions will be implemented and administered?
(For example, does it identify the responsible
department, existing and potential resources, and
timeframe?)
C. Does the prioritization process include an emphasis
on the use of a cost-benefit review (see page 3-36
of Multi-Hazard Mitigation Planning Guidance) to
maximize benefits?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE
March 2004

8

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Multi-Jurisdictional Mitigation Actions
Requirement §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 plan.

Element
A Does the plan include at least one identifiable
action item for each jurisdiction requesting FEMA
approval of the plan?

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

PLAN MAINTENANCE PROCESS
Monitoring, Evaluating, and Updating the Plan
Requirement §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.

Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the plan describe the method and schedule for
monitoring the plan? (For example, does it identify
the party responsible for monitoring and include a
schedule for reports, site visits, phone calls, and
meetings?)
B. Does the plan describe the method and schedule for
evaluating the plan? (For example, does it identify the
party responsible for evaluating the plan and include
the criteria used to evaluate the plan?)
C. Does the plan describe the method and schedule for
updating the plan within the five-year cycle?

SUMMARY SCORE

March 2004

9

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Incorporation into Existing Planning Mechanisms
Requirement §201.6(c)(4)(ii): [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 improvement plans, when appropriate.
Element

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

A. Does the plan identify other local planning mechanisms
available for incorporating the requirements of the
mitigation plan?
B. Does the plan include a process by which the local
government will incorporate the requirements in other
plans, when appropriate?

SUMMARY SCORE

Continued Public Involvement
Requirement §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.
Element
A. Does the plan explain how continued public
participation will be obtained? (For example, will
there be public notices, an on-going mitigation plan
committee, or annual review meetings with
stakeholders?)

Location in the
Plan (section or
annex and page #)

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

March 2004

10

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Matrix A: Profiling Hazards
This matrix can assist FEMA and the State in scoring each hazard. Local jurisdictions may find the matrix useful to ensure that their plan addresses each natural
hazard that can affect the jurisdiction. Completing the matrix is not required.
Note: First, check which hazards are identified in requirement §201.6(c)(2)(i). Then, place a checkmark in either the N or S box for each applicable hazard. An
“N” for any element of any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its related shortcoming in the
comments section of the Plan Review Crosswalk.

Hazard Type

Hazards Identified
Per Requirement

§201.6(c)(2)(i)
Yes

A. Location
N

S

C. Previous
Occurrences

B. Extent
N

S

N

Avalanche
Coastal Erosion
Coastal Storm

S

D. Probability of
Future Events
N

S

To c
he
clic ck box
chan k on th es, dou
e bo
ble
ge t
x
he
to “c defaul and
tv
heck
ed.” alue

Dam Failure
Drought
Earthquake
Expansive Soils
Extreme Heat
Flood
Hailstorm
Hurricane
Land Subsidence
Landslide
Severe Winter Storm
Tornado
Tsunami
Volcano
Wildfire
Windstorm
Other
Other
Other
Legend:
§201.6(c)(2)(i) Profiling Hazards
A. Does the risk assessment identify the location (i.e., geographic area affected) of each hazard addressed in the plan?
B. Does the risk assessment identify the extent (i.e., magnitude or severity) of each hazard addressed in the plan?
C. Does the plan provide information on previous occurrences of each natural hazard addressed in the plan?
D. Does the plan include the probability of future events (i.e., chance of occurrence) for each hazard addressed in the plan?

March 2004

11

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Matrix B: Assessing Vulnerability
This matrix can assist FEMA and the State in scoring each hazard. Local jurisdictions may find the matrix useful to ensure that their plan addresses each
requirement. Completing the matrix is not required.
Note: First, check which hazards are identified in requirement §201.6(c)(2)(i). Then, place a checkmark in either the N or S box for each applicable hazard. An
“N” for any element of any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its related shortcoming in the
comments section of the Plan Review Crosswalk.

A. Overall
Summary
Description of
Vulnerability

N
§201.6(c)(2)(ii) Assessing Vulnerability: Overview

Yes
Avalanche
Coastal Erosion
Coastal Storm
Dam Failure
Drought
Earthquake
Expansive Soils
Extreme Heat
Flood
Hailstorm
Hurricane
Land Subsidence
Landslide
Severe Winter Storm
Tornado
Tsunami
Volcano
Wildfire
Windstorm
Other
Other
Other

S

B. Hazard
Impact

N

S

§201.6(c)(2)(ii) Assessing Vulnerability: Identifying Structures

Hazard Type

Hazards
Identified Per
Requirement
§201.6(c)(2)(i)

A. Types and
Number of
Existing
Structures in
Hazard Area
(Estimate)

N

S

Legend:
§201.6(c)(2)(ii) Assessing Vulnerability: Overview
A. Does the plan include an overall summary description of the jurisdiction’s vulnerability to
each hazard?
B. Does the plan address the impact of each hazard on the jurisdiction?
§201.6(c)(2)(ii)(A) Assessing Vulnerability: Identifying Structures
A. Does the plan describe vulnerability in terms of the types and numbers of existing buildings,
infrastructure, and critical facilities located in the identified hazard areas?

March 2004

B. Types and
Number of
Future
Structures in
Hazard Area
(Estimate)

N

S

§201.6(c)(2)(ii) Assessing Vulnerability: Estimating Potential Losses

Note: Receiving an N in the shaded columns will not preclude the plan from passing.

A. Loss Estimate

N

S

B. Methodology

N

To c
he
clic ck box
chan k on th es, dou
e bo
ble
ge t
x
he
to “c defaul and
t val
heck
ue
ed.”

S

B. Does the plan describe vulnerability in terms of the types and numbers of future buildings,
infrastructure, and critical facilities located in the identified hazard areas?
§201.6(c)(2)(ii)(B) Assessing Vulnerability: Estimating Potential Losses
A. Does the plan estimate potential dollar losses to vulnerable structures?
B. Does the plan describe the methodology used to prepare the estimate?

12

LOCAL HAZARD MITIGATION PLAN REVIEW CROSSWALK
Jurisdiction:

FEMA REGION [INSERT #]

Matrix C: Identification and Analysis of Mitigation Actions
This matrix can assist FEMA and the State in scoring each hazard. Local jurisdictions may find the matrix useful to ensure consideration of a range of actions for
each hazard. Completing the matrix is not required.
Note: First, check which hazards are identified in requirement §201.6(c)(2)(i). Then, place a checkmark in either the N or S box for each applicable hazard. An
“N” for any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its related shortcoming in the comments section
of the Plan Review Crosswalk.

Hazard Type

Hazards Identified
Per Requirement
§201.6(c)(2)(i)
Yes

A. Comprehensive
Range of Actions
and Projects
N
S

Avalanche
Coastal Erosion
Coastal Storm

To c
he
click ck box
es,
o
cha
nge n the b double
ox a
the
nd
de
to “
che fault va
cked
lue
.”

Dam Failure
Drought
Earthquake
Expansive Soils
Extreme Heat
Flood
Hailstorm
Hurricane
Land Subsidence
Landslide
Severe Winter Storm
Tornado
Tsunami
Volcano
Wildfire
Windstorm
Other
Other
Other
Legend:
§201.6(c)(3)(ii) Identification and Analysis of Mitigation Actions
A. Does the plan identify and analyze a comprehensive range of specific mitigation actions and projects for each hazard?

March 2004

13


File Typeapplication/pdf
File TitleMicrosoft Word - bluebookcover1-10-08.doc
Authorksmith35
File Modified2012-02-07
File Created2008-01-09

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