Local Multi-Hazard Mitigation Planning Guidance

Local Multi-Hazard
Mitigation Planning
Guidance
July 1, 2008

This guidance represents FEMA’s interpretation of a statutory or regulatory requirement. The guidance
itself does not impose legally enforceable rights and obligations, but sets forth a standard operating
procedure or agency practice that FEMA employees follow to be consistent, fair, and equitable in the
implementation of the agency’s authorities.

INTRODUCTION

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE

TABLE OF CONTENTS..................................................................................................1

INTRODUCTION .............................................................................................................3
Purpose ..............................................................................................................3
Using the Mitigation Planning Guidance..........................................................6
Plan Submittal and Review Procedures ...........................................................7
Planning Resources ........................................................................................10
Flood Mitigation Planning ...............................................................................12
Multi-Jurisdiction & Other Local Organizations ............................................14

PREREQUISITES .........................................................................................................17
Adoption by the Local Governing Body .........................................................17
Multi-Jurisdictional Plan Adoption .................................................................19
Multi-Jurisdictional Planning Participation ....................................................21

PLANNING PROCESS .................................................................................................25
Documentation of the Planning Process........................................................26

RISK ASSESSMENT ....................................................................................................29
Identifying Hazards..........................................................................................30
Profiling Hazards .............................................................................................32
Assessing Vulnerability: Overview.................................................................36
Assessing Vulnerability: Identifying Structures ............................................39
Assessing Vulnerability: Addressing Repetitive Loss Properties ..............42
Assessing Vulnerability: Estimating Potential Losses .................................45
Assessing Vulnerability: Analyzing Development Trends............................47
Multi-Jurisdictional Risk Assessment ............................................................50

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

1

INTRODUCTION

MITIGATION STRATEGY .............................................................................................52
Local Hazard Mitigation Goals ........................................................................53
Identification and Analysis of Mitigation Actions..........................................56
Implementation of Mitigation Actions.............................................................61
Implementation of National Flood Insurance Program (NFIP) ......................63
Multi-Jurisdictional Mitigation Actions...........................................................65

PLAN MAINTENANCE .................................................................................................67
Monitoring, Evaluating, and Updating the Plan .............................................68
Incorporation Into Existing Planning Mechanisms........................................70
Continued Public Involvement ........................................................................73

LOCAL MITIGATION PLAN REVIEW CROSSWALK................................................. A-1

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

2

INTRODUCTION
PURPOSE
Hazard mitigation is any sustained action taken to reduce or eliminate the long-term risk to
human life and property from hazards. Mitigation activities may be implemented prior to, during,
or after an incident. However, it has been demonstrated that hazard mitigation is most effective
when based on an inclusive, comprehensive, long-term plan that is developed before a disaster
occurs.
This publication is one of three guidance documents on implementing the Federal Emergency
Management Agency’s (FEMA) Mitigation Planning regulations under Code of Federal
Regulations (CFR), Title 44, Part 201. Separate documents are available for the State MultiHazard Mitigation Planning Guidance (Standard and Enhanced, 44 CFR §201.4 and §201.5)
and Tribal Multi-Hazard Mitigation Planning Guidance (44 CFR §201.7).
The purpose of this Local Multi-Hazard Mitigation Planning Guidance is to provide guidance to
local governments to meet the requirements of 44 CFR §201.6, Local Mitigation Plans. This
Local Multi-Hazard Mitigation Planning Guidance was designed with three major objectives:
•
•
•

To help local jurisdictions develop and adopt new mitigation plans or revise existing
mitigation plans to meet the requirements of 44 CFR Part 201;
To help Federal and State reviewers evaluate mitigation plans from different jurisdictions
in a fair and consistent manner; and
To help local jurisdictions conduct comprehensive reviews and prepare updates to their
plans to meet the requirements of 44 CFR Part 201.

This Local Multi-Hazard Mitigation Planning Guidance, as interpretation and explanation for the
Local Mitigation Plan regulations at 44 CFR Part 201, is FEMA’s official source for defining the
requirements of original and updated Local Mitigation Plans. It includes references to specific
language in 44 CFR Part 201 and descriptions of the relevant requirement to meet the
mitigation planning requirements.
This guidance addresses Local Mitigation Plan requirements for local governments, which are
defined at 44 CFR §201.2 as:
any county, municipality, city, town, township, public authority, school district, special
district, intrastate district, council of governments (regardless of whether the council of
governments is incorporated as a nonprofit corporation under State law), regional or
interstate government entity, or agency or instrumentality of a local government; any
Indian tribe or authorized tribal organization, or Alaska Native village or organization;
and any rural community, unincorporated town or village, or other public entity.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

3

INTRODUCTION
Authorities
Section 322 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford
Act), 42 U.S.C. 5165, as amended by the Disaster Mitigation Act of 2000 (DMA) (P.L. 106-390),
provides for States, Tribes, and local governments to undertake a risk-based approach to
reducing risks to natural hazards through mitigation planning. The National Flood Insurance Act
of 1968, as amended, 42 U.S.C. 4001 et seq, reinforced the need and requirement for mitigation
plans, linking flood mitigation assistance programs to State, Tribal and Local Mitigation Plans.
FEMA has implemented the various hazard mitigation planning provisions through regulations at
44 CFR Part 201. These reflect the need for States, Tribal, and local governments to closely
coordinate mitigation planning and implementation efforts, and describes the requirement for a
State Mitigation Plan as a condition of pre- and post-disaster assistance, as well as the
mitigation plan requirement for local and Tribal governments as a condition of receiving FEMA
hazard mitigation assistance.
The regulations governing the mitigation planning requirements for local mitigation plans are
published under 44 CFR §201.6. Under 44 CFR §201.6, local governments must have a
FEMA-approved Local Mitigation Plan in order to apply for and/or receive project grants under
the following hazard mitigation assistance programs:
•
•
•
•

Hazard Mitigation Grant Program (HMGP)
Pre-Disaster Mitigation (PDM)
Flood Mitigation Assistance (FMA)
Severe Repetitive Loss (SRL)

FEMA may require a Local Mitigation Plan under the Repetitive Flood Claims (RFC) program, at
which time this policy will apply to those governments that apply for and/or receive assistance
under the RFC program as well.
Special Consideration: Extraordinary Circumstances
Under 44 CFR §201.6 (a)(3), FEMA Regional Administrators may grant an exception to the
Local Mitigation Plan requirement in extraordinary circumstances, such as in a small and
impoverished community, when justification is provided. In these cases, a plan must be
completed within 12 months of award of the project grant.

Key Concepts
Several key concepts are reflected throughout the mitigation planning regulations at 44 CFR
Part 201, and are reflected in each of the State, Tribal and Local Mitigation Plan requirements
and corresponding guidance. The most successful of mitigation plans — where practical,
meaningful mitigation actions resulted — have two common elements:
•
•

Comprehensive risk and capability assessments that form a solid foundation for
decision making; and
Participation by a wide range of stakeholders who play a role in identifying and
implementing mitigation actions.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

4

INTRODUCTION
The mitigation plan requirements in 44 CFR Part 201 emphasize greater interaction between
State and local mitigation activities, and highlight the need for improved linkage between State
and Local Mitigation Plans. Under 44 CFR §201.4(c)(4), States are required to coordinate
mitigation planning with Indian Tribal and local jurisdictions, and document funding and
technical assistance they will provide to these jurisdictions. The information contained in Local
Mitigation Plans is also useful for States developing their State Mitigation Plans. That is, States
refer to Local Mitigation Plans to improve the level of detail and comprehensiveness of
statewide risk assessments and coordinate State hazard mitigation goals and objectives with
local goals and objectives. Similarly, local governments may refer to their State’s mitigation
plan where information may be useful for local mitigation strategy development.
FEMA also has a continuing interest in streamlining the mitigation planning and implementation
process. In hazard mitigation planning, as with most other planning efforts, the actual process
of planning is as important as the plan itself. Therefore, FEMA considers the plan as the written
record, or documentation, of the planning process. This is why some of the plan requirements
ask for a “discussion” or “description” of a process or development of a planning product (such
as goals, or hazard identification). 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.
Special Considerations:
In reading the mitigation planning regulations at 44 CFR Part 201, 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 within five (5) 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 regulation
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 the Multi-Hazard Mitigation Planning
Guidance documents is consistent with the use of those words in mitigation planning regulations
at 44 CFR Part 201. In the Plan Review Crosswalk, the “should” requirements are shaded as a
reminder that they are not required for plan approval.
To emphasize the importance of the process, FEMA has 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. It also
enables the State, Tribal or local government the flexibility to integrate the mitigation plan into
other daily and long-term planning initiatives and programs.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

5

INTRODUCTION
USING THE MITIGATION PLANNING GUIDANCE
Organization
The Local Multi-Hazard Mitigation Planning Guidance is divided into six sections following this
Introduction:
•
•
•
•
•
•

Prerequisites
Planning Process
Risk Assessment
Mitigation Strategy
Plan Maintenance
Local Mitigation Plan Review Crosswalk

The first five sections contain the language of the mitigation planning regulations, an
explanation clarifying the intent of the requirements, and references to a series of resources that
address particular planning issues in more detail. The last section contains the Local Mitigation
Plan Review Crosswalk for evaluating plans.
The regulation is published at 44 CFR Part 201. Language in brackets does not appear in the
regulation, but has been added to provide the proper context. For example: “[The plan must
include] a description of the planning process.” An ellipsis has been used to indicate that other
phrases precede or follow the requirement language.
Plan Updates
The mitigation planning regulation at 44 CFR §201.6(d)(3) states:
A local jurisdiction must review and revise its plan to reflect changes in development,
progress in local mitigation efforts, and changes in priorities, and resubmit it for approval
within five (5) years in order to continue to be eligible for mitigation project grant funding.
This Local Multi-Hazard Mitigation Planning Guidance describes elements of the five-year plan
updates as required at 44 CFR §201.6(d)(3). The Local Mitigation Plan Review Crosswalk also
reflects both new and updated plan submittals.
Local Mitigation Plan Review Crosswalk
This Local Multi-Hazard Mitigation Planning Guidance outlines a process for the review of Local
Mitigation Plans based on the requirements described in the mitigation planning regulations
under 44 CFR §201.6. The Local Mitigation Plan Review Crosswalk included in this document
is an important tool in both the review and development of complete plans, as they mirror the
requirements in the mitigation planning regulations at 44 CFR §201.6.
Special Considerations:
States may insert additional State mitigation planning requirements, tailoring the Local MultiHazard Mitigation Planning Guidance to account for State specific requirements. FEMA
reviewers will not consider these additional State requirements in their evaluation nor
disapprove a plan based on any additional information included in a plan.
LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

6

INTRODUCTION
PLAN SUBMITTAL AND REVIEW PROCEDURES
Plan Submittal Procedures
The mitigation planning regulations under 44 CFR Part 201 require that local jurisdictions submit
mitigation plans to the State Hazard Mitigation Officer (SHMO) for initial review and
coordination, with the State then forwarding the plans to FEMA for formal review and approval.
Local mitigation plans should be submitted in an electronic format, either through email, or
through the mail on CD/DVD. The following recommended submission approaches may also be
helpful:
•
•

•

•

States and communities should coordinate with each other to identify procedures and
schedules that will facilitate State support of local mitigation planning efforts and initial
review of Local Mitigation Plans.
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.
Local jurisdictions are encouraged to submit a final draft of the mitigation plan 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), the jurisdiction can then proceed with the adoption
process, knowing the adopted plan will be approved. If FEMA determines the plan is not
approvable, the responsible parties will be able to address deficiencies before taking the
plan through adoption, therefore avoiding unnecessary delays in plan approval.
Local jurisdictions should consult with their SHMO early enough to ensure that they will
be able to obtain FEMA review and approval of their plans in time to meet established
deadlines.

Plan Evaluation Methodology
As required at 44 CFR §201.6(d), Local Mitigation Plans must be submitted to the SHMO for
initial review and coordination, and then the SHMO may submit the mitigation plan to the
appropriate FEMA Regional Office for formal review and approval. FEMA reviewers document
their evaluation of the plan using the Local Mitigation Plan Review Crosswalk.
Local Mitigation Plans are approved when they receive a “Satisfactory” for all requirements
under 44 CFR §201.6. Except for prerequisites that are met before the plan can be approved,
the reviewer evaluates requirements based on the following system:
•
•

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

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

7

INTRODUCTION
The final, completed Local Mitigation Plan Review Crosswalk provides the local jurisdiction with:
•
•
•
•

a determination for each requirement;
FEMA reviewer comments for requirements that need improvement;
FEMA reviewer “recommended revisions” that are not required but offer suggestions on
areas to enhance the mitigation plan; and,
a determination of whether the plan is approved by the State and FEMA.

In those cases where FEMA reviewers provided “recommended revisions”, 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:
The Local Mitigation Plan Review Crosswalk includes a column (second from left), “Location in
the Plan,” that the State or jurisdiction submitting the plan can complete to assist reviewers in
determining where in the plan the requirements are addressed. When reviewing plans, the
evaluator may find it helpful to first read the plan and identify the appropriate sections that
correspond to the Local Mitigation Plan requirements.

Plan Updates
The mitigation planning regulations at §201.6(d)(3) directs the update of Local Mitigation Plans:
A local jurisdiction must review and revise its plan to reflect changes in development,
progress in local mitigation efforts, and changes in priorities, and resubmit it for approval
within 5 years in order to continue to be eligible for mitigation project grant funding.
Local Mitigation Plans must be updated and resubmitted to FEMA for approval every five (5)
years in order to continue eligibility for FEMA hazard mitigation assistance programs. Plan
updates must demonstrate that progress has been made in the past 5 years for Local Mitigation
Plans to fulfill commitments outlined in the previously approved plan. This involves a
comprehensive review and update of each section of the Local Mitigation Plan and a discussion
of the results of evaluation and monitoring activities detailed in the Plan Maintenance section of
the previously approved plan. Plan updates may validate the information in the previously
approved plan, or may involve a major plan rewrite. A plan update is NOT an annex to the
previously approved plan; it stands on its own as a complete and current plan.
Local jurisdictions should develop a schedule that allows a plan update and approval to occur
within 5 years from the last approval date. All jurisdictions should consider the time needed
prior to the expiration of the Local Mitigation Plan. Sufficient time should be allotted for all
activities up to and including adoption, such as:
•
•
•
•

Application and award for mitigation planning grants (if applicable);
Contracting for technical or professional services (if applicable);
Review of mitigation plan;
Planning process to develop the update;

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

8

INTRODUCTION
•
•
•

State and/or FEMA reviews;
Revising the updated plan, if necessary based on FEMA review comments; and
Plan adoption procedures.

It should be noted that States could choose to establish a schedule for more frequent Local
Mitigation Plan updates.
Indian Tribal Governments with Expiring Local Mitigation Plans
On October 31, 2007 FEMA published amendments to 44 CFR Part 201 at 72 Fed. Reg. 61720
that created a new type of hazard mitigation plan specific to Indian Tribal governments. Under
44 CFR §201.7(a), Indian Tribal governments with mitigation plans approved by FEMA on or
before October 1, 2008, under §201.4 or§201.6 will continue to meet the planning requirements
in order to be eligible for FEMA assistance. The approval timeframes for these State or Local
Mitigation Plan types will continue to be recognized, and updates as Tribal Mitigation Plans will
be required after the approved three years (for plans approved as State Mitigation Plans) or five
years (for plans approved as Local Mitigation Plans).
All Indian Tribal governments with mitigation plans approved after October 1, 2008 must follow
the criteria identified in 44 CFR §201.7, Tribal Mitigation Plans in order to be eligible for FEMA
assistance. Tribal Mitigation Plans follow the criteria established in 44 CFR §201.7 as a
condition of receiving non-emergency Stafford Act assistance as a grantee, and the Tribal
Mitigation Plan also allows an Indian Tribal government to apply through the State as a
subgrantee for any FEMA mitigation project grant (See the programs affected under the
Authorities section). In addition, an Indian Tribal government may choose to address severe
repetitive loss properties as a condition of receiving the reduced cost share for the FMA and
SRL programs. Tribal Mitigation Plans approved under 44 CFR §201.7 will be approved for a
period of five years.
Indian Tribal governments should consult with their FEMA Regional Office early to ensure that
they will be able to obtain FEMA review and approval of their plans in time to meet established
deadlines. The separate Tribal Multi-Hazard Mitigation Planning Guidance (44 CFR §201.7)
document provides guidance for the development, adoption, review and update of Tribal
Mitigation Plans.
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 FEMA Regional Office will provide comments on the areas that need improvement. FEMA
will complete the review of each re-submittal of the Local Mitigation Plan within 45 days from the
day it is received, whenever possible, as well.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y

1 ,

2 0 0 8

9

INTRODUCTION
PLANNING RESOURCES
Planning Guidance, Tools & Training
To help States, Tribes, and local governments better understand the mitigation planning
requirements under 44 CFR Part 201, FEMA prepared the Multi-Hazard Mitigation Planning
Guidance under the Disaster Mitigation Act of 2000 (March 2004 with revisions November 2006,
June 2007 & January 2008). This document, Local Multi-Hazard Mitigation Planning Guidance,
supersedes that previous guidance document for all Local Mitigation Plan requirement under 44
CFR §201.6.
In addition to this document, FEMA provides a number of planning tools to assist localities in
developing a comprehensive, multi-hazard approach to mitigation planning, and in preparing
plans that will meet the mitigation planning requirements. These tools include:
•

•

•

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 through -8); available on the FEMA Web site through
http://www.fema.gov/plan/mitplanning/planning_resources.shtm#1.
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 through
http://www.fema.gov/plan/mitplanning/planning_resources.shtm#1.
Multi-Hazard Identification and Risk Assessment (MHIRA), available on the FEMA
Web site at http://www.fema.gov/plan/prevent/fhm/ft_mhira.shtm.

These publications 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.
•

•
•

Mitigation Benefit Cost Analysis (BCA) Toolkit Compact Disc includes all the FEMA
BCA software, technical manuals, BCA training course documentation, and other
supporting material and BCA guidance. The BCA Toolkit is available through FEMA’s
toll-free Benefit-Cost Analysis Technical Assistance Helpline: 1-866-222-3580 or email: [email protected] .
HAZUS-MH (Hazards U.S. – Multi- Hazard), a risk assessment software program,
available to order on the FEMA Web site at http://www.fema.gov/plan/prevent/hazus/.
Community Rating System Coordinator’s Manual (FIA-15/2007), available to order
from NFIP/CRS PO Box 501016, Indianapolis, IN 46250-1016, or by email at
[email protected], or for download at http://training.fema.gov/EMIWeb/CRS/.

In addition, FEMA’s Emergency Management Institute (EMI) also provides mitigation training to
help Federal, State, local, and tribal governments understand mitigation planning through its
Mitigation Planning Workshop for Local Governments (G318) for the development and review of
Local Mitigation Plans.
EMI’s curriculum also includes training in BCA, NFIP, HAZUS, the National Hurricane Program
and the National Earthquake Hazards Reduction Program. The curriculum includes training
courses of varying lengths offered in residence, through field courses, and on-line training
through the independent study program. Information on EMI’s program can be obtained at
http://www.training.fema.gov/.
LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
10

INTRODUCTION

Special Considerations:
Both the Stafford Act and the National Flood Insurance Act of 1968 specifically require
mitigation planning for natural hazards, but not for manmade hazards. However, FEMA supports
jurisdictions that choose to consider technological and manmade hazards in their respective
mitigation plans. While it is true that a Local Mitigation Plan does not require manmade hazards
to be addressed in order to be approved, the Local 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.

Funding for Plan Development
A Local Mitigation Plan as defined in 44 CFR §201.6 is required for local jurisdictions that elect
to participate in FEMA hazard mitigation assistance programs as a subapplicant or subgrantee.
The Stafford Act authorizes up to 7 percent of available HMGP funds for State, Tribal, or local
mitigation planning purposes. Also, funds from the PDM program may be used to develop
mitigation plans, and the FMA program provides annual grant funds for flood mitigation
planning.
Funding for hazard mitigation planning may be available from other Federal agencies. For
example, the National Oceanic and Atmospheric Administration’s Coastal Zone Management
(CZM) Program has funded coastal hazard mitigation activities, including planning.
The Local Mitigation Plan requirements encourage agencies at all levels, local residents,
businesses, and the nonprofit 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.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
11

INTRODUCTION
FLOOD MITIGATION PLANNING
Flood Mitigation Plans
In order to be eligible for project funds under the Flood Mitigation Assistance (FMA) program
authorized by the National Flood Insurance Act of 1968, as amended, communities are required
under 44 CFR §79.6(d)(1) to have a mitigation plan that addresses flood hazards. Although
communities are not required to have a multi-hazard mitigation plan for the FMA program, they
are encouraged to consider all hazards that could impact their community. First, a multi-hazard
risk assessment may reveal effects or relationships between different hazards. For example,
hurricanes have a combination of flood and wind impacts. Second, addressing all hazards will
allow a community to be eligible for a wider range of federal mitigation assistance programs.
On October 31, 2007 FEMA published amendments to the 44 CFR Part 201 at 72 Fed.l Reg.
61720 to incorporate mitigation planning requirements for the FMA program. The amendments
impacted 44 CFR §201.6, Local Mitigation Plans, as follows:
•
•
•

Combined the Local Mitigation Plan requirement for all hazard mitigation assistance
programs under 44 CFR §201.6 to include the FMA as well as the HMGP, PDM and
SRL programs, thus eliminating duplicative mitigation plan regulations;
Incorporated the requirement for communities with National Flood Insurance
Program (NFIP) insured properties that have been repetitively damaged from floods
to address such properties in their risk assessment and mitigation strategy; and
Incorporated the requirement for communities that participate in the NFIP to include
a strategy for continued compliance with the NFIP.

The Local Multi-Hazard Mitigation Planning Guidance includes these new requirements.

Community Rating System
The Community Rating System (CRS) is a part of the NFIP. When communities go beyond the
NFIP’s minimum standards for floodplain management and participate in the CRS, discounts
may be available on flood insurance premiums for policy holders in those communities.
One of the activities that communities can take to improve their CRS rating (and subsequently
lower premiums) is to develop a CRS plan. The CRS 10-step planning process is consistent
with the multi-hazard planning regulations under 44 CFR Part 201. However, CRS provides
additional points for activities that communities can take during their planning process that go
above the minimum described below, thus possibly lowering insurance rates. At a minimum,
an approved multi-hazard mitigation plan under 44 CFR Part 201 that addresses floods could
qualify for CRS credit. Although communities are not required to participate in CRS in order to
receive approval of a Local Mitigation Plan, FEMA encourages jurisdictions to integrate the CRS
planning steps into their multi-hazard mitigation plans.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
12

INTRODUCTION

Special Consideration: Communities interested in receiving CRS credit for their Local
Mitigation Plan submit a separate review request to the ISO/ CRS Specialist. The ISO/CRS
Specialist is an employee of the Insurance Services Office, Inc. (ISO). ISO works on behalf of
FEMA and the insurance companies to review CRS applications, verify the communities' credit
points, and perform program improvement tasks, including the review of plans for CRS credit.
The table below illustrates how the CRS 10-step planning process relates to the four phases of
multi-hazard mitigation planning process. The Local Multi-Hazard Mitigation Planning Guidance
also provides basic guidance on working toward increased CRS points by integrating the CRS
10-step planning process into the four phases of the multi-hazard mitigation plan. More detailed
information can be found in Activity 510 of the CRS Coordinator’s Manual or in CRS Example
Plans which can be accessed on the web at http://training.fema.gov/EMIWeb/CRS/.
Mitigation Plan
Requirements

CRS Planning Steps

CRS Maximum Points

44 CFR §201.6
Prerequisites
201.6 (c)(5)

9. Adopt the plan

2

201.6(c)(1)

1. Organize

10

201.6(c)(1)

2. Involve the Public

85

201.6(b) (2) & (3)

3. Coordinate

25

201.6 (c)(2)(i)

4. Assess the hazard

20

201.6 (c)(2) (ii) & (iii)

5. Assess the problem

35

201.6 (c)(3) (i)

6. Set Goals

2

201.6 (c)(3) (ii)

7. Review possible activities

30

201.6 (c)(3) (iii)

8. Draft an action plan

70

10. Implement, evaluate, revise

15

Phase 1: Planning Process

Phase 2: Risk Assessment

Phase 3: Mitigation Strategy

Phase 4: Plan Maintenance
201.6 (c)(4)

Total:

294

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
13

INTRODUCTION
MULTI-JURISDICTION & OTHER LOCAL ORGANIZATIONS
Section 201.2 of 44 CFR defines Local Government as:
any county, municipality, city, town, township, public authority, school district, special
district, intrastate district, council of governments (regardless of whether the council of
governments is incorporated as a nonprofit corporation under State law), regional or
interstate government entity, or agency or instrumentality of a local government.
FEMA recognizes that local governance structures vary, and that the authority to implement
mitigation strategies (e.g., land use planning and zoning, building code enforcement,
infrastructure improvements, floodplain management, etc.) may not reside within a single
governmental entity. In addition, certain FEMA hazard mitigation assistance programs accept
applications from private, nonprofit organizations and other quasi-governmental entities that do
not necessarily align with traditional geopolitical boundaries. To ensure these potential
subapplicants to FEMA mitigation assistance programs meet the eligibility requirements for
mitigation plans under 44 CFR §201.6, FEMA has identified procedures for several of these
entities.
Multi-Jurisdictional Mitigation Plans
FEMA’s Local Mitigation Plan requirements under 44 CFR §201.6 specifically identify criteria
that allow for multi-jurisdictional mitigation plans. Many issues are better resolved by evaluating
hazards more comprehensively by coordinating at the county, regional, or watershed level.
Although economy-of-scale efforts are apparent and encouraged with multi-jurisdictional plans,
FEMA requires that all participating jurisdictions meet the requirements for mitigation plans
identified in 44 CFR §201.6. While certain elements are common to all participating jurisdictions
(e.g., planning process, hazards, goals, and maintenance), there are some elements that are
unique to each participating jurisdiction, including:
•
•
•
•

risks, where they differ from the general planning area;
mitigation actions (actions must be identified for each jurisdiction);
participation in the planning process (examples of participation include attending
meetings, contributing research, data, or other information, commenting on drafts of the
plan, etc.); and
adoption (each jurisdiction must formally adopt the plan).

Universities
Under 44 CFR 201, a public college or university may be an active participant in a FEMAapproved State, Tribal or Local Mitigation Plan, or have an approved plan of their own that
meets the requirements of 44 CFR §201.6 to be eligible for mitigation project grants.
If a college or university has fully participated in the development and review of a plan in
accordance with 44 CFR §201.6(b), Documentation of the Planning Process, it is not necessary
for them to approve/adopt the plan, as long as it is adopted by the appropriate State, Tribal or
local government.
LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
14

INTRODUCTION

If a college or university chooses to develop their own plan, adoption of the plan can be
accomplished through a resolution or letter from the institution President, Board of Directors or
recognized governing body.
In a large and complex State university system, there may be several component universities,
each with multiple campuses, extension offices, and other sites. The various universities may
be subject to different risks, and each individual university may be best served by developing a
stand-alone, single-jurisdiction plan, or be a participant in the planning process for their local
government. However, the State university system's Board of Regents or other top-level entity
may determine that the State would be best served if planning for all of its component
institutions and campuses were coordinated at the highest possible level in order to facilitate
capital improvement planning. In such a case, the top-level entity could develop a multijurisdictional plan to which the participating component institutions would then be signatories.
Regardless of whether planning is distributed or centralized, however, the plans developed will
be Local Mitigation Plans, not State Mitigation Plans, even if they are developed by and for
State institutions.
Similarly, private institutions may opt to participate in local or regional multi-jurisdictional plans,
or they may develop plans of their own. Either way, the key to success is to ensure that all of
the requirements established by regulation are met. This includes coordinating the planning
activities of each campus with those of the surrounding community and, in the case of a multiinstitution plan, ensuring that each institution's unique risks are addressed in addition to those
risks affecting the entire university system.
School Districts
School districts or independent school districts, or other special districts are defined as local
governments at 44 CFR Part 201.2, and are therefore required to have a FEMA-approved local
mitigation plan to be eligible for project grants under FEMA hazard mitigation assistance
programs. A school district may also demonstrate their participation as a separate government
entity in another local government’s approved mitigation plan to be eligible for project grants
under FEMA hazard mitigation assistance programs.
School districts do not fall under the definition of private nonprofit organizations (See the
definition of private nonprofit organization under the Private Nonprofit (PNP) Organizations
section below.)
Private Nonprofit (PNP) Organizations
Private nonprofit organizations are not considered governmental entities. This distinction is
important, because current regulations under 44 CFR Part 201 provide only for governments
(State, Tribal or Local), not PNPs, to meet the planning requirement for having a FEMAapproved Mitigation Plan in order to receive project grant funds. For mitigation planning
purposes, PNPs are defined consistently with 44 CFR 206.2(a)(19) as:
Any nongovernmental agency or entity that currently has: (i) An effective ruling letter
from the U.S. Internal Revenue Service granting tax exemption under section 501 (c),
(d), or (e) of the Internal Revenue Code of 1954; or (ii) Satisfactory evidence from the
LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
15

INTRODUCTION
State that the organization or entity is a nonprofit one organized or doing business under
State law.
Under HMGP regulations at 206.434(a)(1), certain PNPs are eligible subapplicants; however, in
those cases, the jurisdiction in which the PNP project is located must have a FEMA-approved
Mitigation Plan to be eligible for grant funds. FEMA strongly recommends that PNPs participate
in the development of the Local or Tribal Mitigation Plan to ensure that projects funded are
consistent with the mitigation strategies of the jurisdiction. If they have fully participated in the
development and review of the Local or Tribal Mitigation Plan, it is not necessary for them to
approve/adopt the plan, as long as it is adopted by the jurisdiction.
Multi-Jurisdictional Private Nonprofit (PNP) Utilities
Multi-jurisdictional utility private nonprofit organizations (PNPs), including Rural Electric
Cooperatives (RECs), are considered PNPs for the purposes of disaster assistance provided by
FEMA under the Stafford Act. For PNPs such as RECs, special utility districts, or other multijurisdictional utilities, FEMA identifies two ways in which they may meet the mitigation planning
requirement that ensure that projects funded by the HMGP are consistent with the mitigation
strategies of the State, Tribal, and/or local jurisdiction in which the project is located.
First, the local jurisdiction(s) within which the REC mitigation project is located must have a
FEMA-approved Local or Tribal Mitigation Plan under 44 CFR §201.6. FEMA strongly
encourages PNPs in general, especially those that may be eligible sub-applicants for mitigation
projects, such as RECs, to participate in the development of Local or Tribal Mitigation Plans.
Second, under 44 CFR §201.4, the FEMA approved State Mitigation Plan must address RECs.
In the State option, the State may prepare an annex to its State Mitigation Plan specific to RECs
and/or other multi-jurisdictional utilities that provide a critical function. The RECs and similar
entities must participate with the State in the development of this annex, specifically in the
identification of hazards potentially affecting their infrastructure, assessment of the
vulnerabilities of the infrastructure to these hazards and identification of mitigation measures to
reduce these vulnerabilities. The level of detail of the risk assessment and mitigation strategy of
the annex must follow the requirements for Local Mitigation Plans (44 CFR §201.6(c)(2) and
(3)), rather than the requirements for Standard State Mitigation Plans, in order to provide sitespecific information. Coordination with local jurisdictions within which REC infrastructure is
located must be documented in the annex, whether or not they have FEMA approved Local
Mitigation Plans. Coordination with these jurisdictions will help ensure that the mitigation
measures identified in the plan will be acceptable, and not in conflict with development or other
plans of these jurisdictions. The annex must be approved by the State and FEMA, and the REC
must participate in future updates of the Plan with respect to the annex.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
16

PREREQUISITES
PREREQUISITES
The local jurisdictions submitting the plan satisfies the following prerequisites before the plan
can receive approval by FEMA. The official approval date is indicated on the signed FEMA
approval letter. As well as providing the approval date, it also indicates the expiration date of
the plan.
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 plan adoption, usually a resolution.
If the local jurisdiction has not passed a formal resolution, or used some
other documentation of adoption, the clerk or city attorney must provide
written confirmation that the action meets their community’s legal
requirements for official adoption and/or the highest elected official or
their designee must submit written proof of the adoption. The signature
of one of these officials is required with the explanation or other proof of
adoption.
Minutes of a council or other meeting during which the plan is adopted
may be sufficient if local law allows meeting records to be submitted as
documentation of adoption. The clerk of the governing body, or city
attorney, must provide a copy of the law and a brief, written explanation
such as, “in accordance with section ___ of the city code/ordinance, this
constitutes formal adoption of the measure,” with an official signature.
Formal adoption of the plan may be completed prior to submission to
FEMA for review. However, if adopted after FEMA review, adoption
must take place within one calendar year of receipt of FEMA’s “Approval
Pending Adoption.” If the plan is not adopted within one calendar year
of FEMA’s “Approval Pending Adoption” the jurisdiction must update the
entire plan and resubmit it for FEMA review.
Approval Pending Adoption is a recommended and potentially timesaving process by which jurisdictions submit the final draft mitigation
plan for a review prior to formal jurisdictional adoption. If the plan meets
all of the Local Mitigation Plan requirements, the plan would then be
returned to the jurisdiction with an approvable pending adoption status.
When the approval pending adoption plan is adopted by the jurisdiction,
and FEMA has received the documentation of adoption, it would then be
formally approved through a signed FEMA approval letter.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
17

PREREQUISITES

Note: The plan’s crosswalk may contain recommended revisions,
suggesting improvements to the plan. If the jurisdiction opts to
incorporate all or some of the recommendations then the plan would be
resubmitted for another review.
If the plan is not adopted, the jurisdiction would not be eligible to apply
for and/or receive project grants under the following hazard mitigation
assistance programs: Hazard Mitigation Grant Program (HMGP), PreDisaster Mitigation (PDM), Flood Mitigation Assistance FMA), and
Severe Repetitive Loss (SRL).
Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
Therefore, the updated plan shall include a copy of the resolution or
other documentation of formal adoption of the updated plan dated within
one year of FEMA’s “approval pending adoption”, regardless of the
degree of modification. The resolution or adoption for the previously
approved plan will not be accepted for plan updates.

Resources:

For more information about adopting the mitigation plan, See:

Bringing the Plan to Life (FEMA 386-4), Step 1.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 1: Adopt the
Plan
The plan shall include
documentation of plan
adoption, usually a
resolution.

Difference?
CRS: The documentation must say that
the plan was adopted rather than
approved for CRS and the documentation
must be either a resolution or ordinance.

Step 9: Adopt the Plan
Documentation that the plan
has been formally adopted by
the governing body of the
jurisdiction requesting
approval of the plan. The
adoption must be either a
resolution or ordinance.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
18

PREREQUISITES
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:

Each jurisdiction that is included in the plan must have its governing
body adopt the plan prior to FEMA approval, even when a regional
agency has the authority to prepare such plans.
As with single jurisdictional plans, in order for FEMA to give approval to
a multi-jurisdictional plan, at least one participating jurisdiction must
formally adopt the plan within one calendar year of FEMA’s designation
of the plan as “approvable pending adoption” (See page 15 for an
explanation of this process).
The plan approval date begins the five-year approval period and sets the
expiration date for the plan. The official approval date is indicated on the
signed FEMA approval letter. As well as providing the approval date, it
also indicates the expiration date of the plan. Plans must be reviewed,
revised and resubmitted for approval within five years in order to
continue to be eligible for grant project funding (44 CFR §201.6(d)(3)).
Participants of a multi-jurisdictional plan will assume the expiration date
five years from the first jurisdiction’s approval date regardless of the
other participant’s subsequent adoption date(s). FEMA recommends
that all participating jurisdictions coordinate the adoption process as
soon as the plan has received “approvable pending adoption” status to
ensure that all participants are covered by a plan for the full five years.
The five-year approval period does not get “re-set” each time another
participating jurisdiction adopts the plan. For example, if jurisdiction #1,
the first jurisdiction to formally adopt the Blue County Multi-Jurisdictional
Hazard Mitigation Plan, receives FEMA’s “approval” of the plan on
January 15, 2008, the plan will also expire on January 15, 2013, exactly
5-years later. If jurisdiction #2 does not formally adopt the plan until July
15, 2008, its eligibility would expire on January 15, 2013, the same exact
date that Blue County’s plan received “approval” when the plan was first
approved. Thus, jurisdiction #2 does not benefit from the full five-year
window, but only 4½ years.
If the plan is not adopted by a participating jurisdiction, that jurisdiction
would not be eligible for project grants under the following hazard
mitigation assistance programs: HMGP, PDM, FMA, and SRL.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
Each jurisdiction that is seeking approval for the plan must have its
governing body adopt the updated plan, regardless of the degree of

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
19

PREREQUISITES

modifications. The resolution or adoption for the previously approved
plan will not be accepted for plan updates.
Resources:

For more information about adopting the mitigation plan, See:

Bringing the Plan to Life (FEMA 386-4), Step 1.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 4.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 1: Prerequisites:
Multi-Jurisdictional
Plan Adoption
Each jurisdiction
requesting approval of
the plan must document
that the plan has been
formally adopted.

Difference?

Step 9: Adopt the Plan

CRS Step is consistent with Multi-Hazard
Planning Phase.

When a multi-jurisdictional
plan is prepared, it must be
adopted by the governing body
of each community seeking
CRS credit.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
20

PREREQUISITES
MULTI-JURISDICTIONAL PLANNING PARTICIPATION
Requirement
§201.6(a)(4):

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 areas,
development authorities (e.g. watershed/river basin commission),
counties or special districts, is acceptable as a Local Mitigation Plan.
However, those jurisdictions within the planning area that do not
participate in its development and adopt the mitigation plan will not be
eligible for project grants. Therefore, the local mitigation plan must
document how each jurisdiction that is requesting FEMA approval of the
plan participated in the planning process.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
The updated plan must identify the following:
•

All participating jurisdictions, new or continuing; and,

•

Jurisdictions that no longer participate in the plan

If jurisdictional participation has changed since approval of the previous
plan, changes should be discussed in the planning process section of
the updated plan.
Resources:

For more information on initiating a comprehensive local mitigation
planning process, See:

Getting Started (FEMA 386-1), Steps 1-3

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 8

Special
Considerations:

After a multi-jurisdictional Mitigation Plan has been adopted, and
approved by FEMA, additional jurisdictions may wish to become part of
the planning process, or “join” the mitigation plan. Additional
jurisdictions may be added to an existing, FEMA-approved, mitigation
plan, only if the conditions below are met (if all three conditions are not
met, the jurisdiction may develop its own mitigation plan).

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
21

PREREQUISITES
1.

The jurisdiction(s) asking to be included is located within the
boundaries of, or adjacent to, the area covered by the multijurisdictional mitigation plan.

2.

The organization that was responsible for preparing and
submitting the multi-jurisdictional mitigation plan to the State and
FEMA agrees with the addition of the requesting jurisdiction(s) to
the mitigation plan.

3.

When the multi-jurisdictional mitigation plan was developed, the
risk assessment included an analysis of the major hazards,
specifically the natural hazards that have the potential to impact
the additional jurisdiction(s).

If these conditions can be met, there are two options that can be used to
add additional jurisdictions to a FEMA-approved mitigation plan.
Regardless of the option chosen, each jurisdiction joining a multi-hazard
planning process and seeking to receive credit from FEMA for an
approved mitigation plan must satisfy all of the Local Mitigation Plan
requirements identified at 44 CFR §201.6.
Option 1 - Approved Plan with Additional Annex or Appendix. This
option is best suited to situations in which the multi-jurisdictional
mitigation plan has been recently approved by FEMA and the majority of
the mitigation plan's five-year lifespan remains. In these cases, the
jurisdictions that participated in the multi-jurisdictional planning process
would not be required to take any action. Plan content specific to any
new jurisdiction is included in a new annex or appendix to the existing
mitigation plan, and no other changes are made to the previously
approved mitigation plan.
The following actions must be taken to add new jurisdictions to the
existing multi-jurisdictional mitigation plan and enable them to receive
approval as part of the mitigation plan:
1.

The requesting jurisdiction(s) must review the multi-jurisdictional
hazard analysis and determine if there are any additional hazards
that have not been addressed and threaten the jurisdiction(s). If
none exist, the jurisdiction(s) must document their review process
and state that no additional hazards exist. If the review reveals
additional hazards, the jurisdiction(s) must analyze the risks
it/they face associated with those hazards and include this
analysis in their written appendix to the multi-jurisdictional
mitigation plan. The existing risk assessment cannot be
resubmitted without this additional documentation.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
22

PREREQUISITES

Special
Considerations:

2.

The requesting jurisdiction(s) must document agreement with the
stated mitigation goals of the multi-jurisdictional mitigation plan.
Additional goals specific to the requesting jurisdiction may be
added. Each additional jurisdiction must also develop a list of
proposed mitigation actions appropriate for that jurisdiction.
These can include the common actions outlined in the multijurisdictional mitigation plan, but must include specific mitigation
actions for each profiled hazard the jurisdiction itself.

3.

The requesting jurisdiction(s) must document the involvement of
both the general public and the local government in the planning
process in accordance with 44 CFR §201.6. The level of
participation in the multi-jurisdictional mitigation plan must be
consistent for the additional jurisdictions.

4.

The annex or appendix, along with the multi-jurisdictional
mitigation plan, and a letter of concurrence from the agency or
organization responsible for the mitigation plan, must be
submitted to the State for formal review. When the State finds
the mitigation plan approvable, it will forward it to FEMA. When
FEMA's review finds the mitigation plan "approvable pending
adoption," the new jurisdiction can formally adopt the full
mitigation plan and its jurisdiction-specific annex or appendix and
submit the mitigation plan in final form through the State to FEMA
for approval.

The mitigation plan approval date for the added jurisdictions will continue
to be the date given by FEMA for the multi-jurisdictional mitigation plan.
This means that the additional jurisdictions will have less than the entire
5-year plan approval window before they will need to engage in the
required update for the full multi-jurisdictional mitigation plan.
Option 2 - Revise and Update Full Plan. This option is best suited to
situations in which the addition of new jurisdictions to the multijurisdictional mitigation plan is occurring far enough along in the fiveyear lifespan of the original mitigation plan that a full review and revision
will begin in the very near future. In these cases, the responsible
agency or jurisdiction for the mitigation plan determines that it is an
appropriate time for the mitigation plan update process to begin, and the
new jurisdiction(s) can participate in a mitigation plan update with the
original jurisdictions.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
23

PREREQUISITES

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 1: Prerequisites:
Multi-Jurisdictional
Plan Participation
Multi-jurisdictional plans
(e.g., watershed plans)
may be accepted, as
appropriate, as long as
each jurisdiction has
participated in the
process … State-wide
plans will not be
accepted as multijurisdictional plans.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 1: Step 1: Organize to
Prepare the Plan.
Multi-jurisdictional plans are
encouraged in CRS. Credit is
based on each jurisdiction’s
full participation in the planning
process.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
24

PLANNING PROCESS
PLANNING PROCESS
The planning process is as important as the plan itself. Hence, the mitigation planning
regulation at 44 CFR Part 201 requires a narrative description of the process used to develop
the mitigation plan—a systematic account about how the mitigation plan evolved from the
moment the planning team was created and the public participated, to how each section of the
plan was developed, to what plans or studies were incorporated into the plan, to how it will be
implemented.
Any successful planning activity, such as the development of a comprehensive plan, involves
bringing together a cross-section of the public to reach consensus on how to achieve a desired
outcome or resolve a community problem. Using this inclusive process, the public gains a
better understanding of the problem or issue and strives to develop a vision along with goals,
priorities, and actions. The result is a common set of community values and widespread support
for directing financial, technical, and human resources to an agreed upon course of action,
usually identified in a plan. The same is true for mitigation planning. An effective and open
public involvement process ensures that all citizens understand risks and vulnerability so that
they will work with the jurisdiction and support policies, actions, and tools that over the long-term
will lead to a reduction in future losses.
A comprehensive description of the planning process informs citizens and other readers about
the plan’s development. Leadership, staffing, and in-house knowledge in local government may
fluctuate over time. Therefore, the description of the planning process serves as a permanent
record that explains how decisions were reached on a strategy to reduce losses, and that it was
developed with stakeholder input in a methodical and reasonable way. Leaders can then
continue to make decisions in a pre- and post-disaster environment to decrease vulnerability to
community hazards.
Section 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:


Documentation of the Planning Process

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
25

PLANNING PROCESS
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:
•

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, interactive Web pages, storefronts, toll-free
telephone lines, etc.);

•

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

•

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 and nonprofit leaders, and educators.
LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
26

PLANNING PROCESS

The plan should describe how public comments and concerns were
considered and incorporated into the plan.
Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
Therefore, the updated plan shall describe the process used to review
and analyze each section of the plan (i.e., Planning Process, Risk
Assessment, Mitigation Strategy, and Plan Maintenance). 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.
The plan maintenance section requires a description about how the
community was kept involved during the plan maintenance process (44
CFR §201.6(c)(4)(iii)) over the previous five years. Since this
contributes to the continued planning process, the community may
choose to describe this within the planning process section of the plan
update rather than the plan maintenance section. The plan maintenance
section is intended to be forward-thinking and emphasize future
community involvement.

Special
Considerations:

The planning team should consider including a current description of the
jurisdiction in this section or in the introduction of the plan. The general
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.

Resources:

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:

Getting Started (FEMA 386-1), Steps 1 – 3.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 17

Integrating Manmade Hazards into Mitigation Planning (FEMA 386),
Phase 3, Step 4.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
27

PLANNING PROCESS

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 1: Documentation
of the Planning Process
Documentation of the
planning process
includes: A description of
the process used to
prepare the plan and an
indication of who was
involved in the process.
It must also document
how the public was
involved and
demonstrate that an
opportunity was given for
neighboring
communities, local and
other interested parties
to be involved in the
planning process. This
phase also requires a
description of the review
and incorporation of
existing plans, studies,
reports, and technical
information, if
appropriate.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 1: Organize to Prepare
the Plan, Step 2: Involve the
Public and Step 3:
Coordinate with other
Agencies
Credit is based on how the
community organizes to prepare
its floodplain management plan.
Describe who is involved in the
planning process and what their
roll is in the development of the
plan. The planning process must
include an opportunity for the
public, neighboring communities
and local and regional agencies to
comment on the plan during the
drafting stage and before plan
approval. The term public means
residents, businesses, property
owners, and tenants in the
floodplain and other known
hazards areas as well as other
stakeholders in the community,
such as business leaders, civic
groups, academia, non-profit
organizations and major
employers. The plan must also
incorporate and document a
review of existing studies, reports,
and technical information into the
community’s needs, goals and
plans for the area.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1
2 0 0 8
28

RISK ASSESSMENT
RISK ASSESSMENT
Section 201.6(c)(2) of the mitigation planning regulation requires local jurisdictions to provide
sufficient hazard and risk information from which to identify 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. Local risk assessments do not need to be based on the most sophisticated
technology, but do need to be accurate, current, and relevant. Local risk assessments coupled
with the local mitigation strategies are the basis for the State’s evaluation of its resources and
facilitate the establishment of statewide goals.
Data needed to complete risk assessments may not be readily available in order for jurisdictions
to meet the planning requirements with the submission of their initial plan. Therefore, FEMA
recommends that plans identify any data limitations and include actions in the mitigation
strategy of the plan to tell how the data will be obtained. The data would then be included in the
risk assessment in the next plan update.
During an update to the risk assessment, local jurisdictions consider current and expected
future vulnerability to all hazards and to integrate new hazard data such as flood studies. Local
jurisdictions are encouraged to incorporate updated estimates of cost of living and replacement
costs for vulnerable buildings, reduced vulnerability due to the completed mitigation actions or
projects, and impacts of population growth or loss in vulnerable areas.
Even though maps are generally not required as part of the plan, FEMA recommends the use of
maps to illustrate the required risk assessment information. To assist communities in hazard
vulnerability analysis, FEMA has developed HAZUS (HAZUS-MH), a nationally standardized
geographic information system (GIS) software that can be used to assess vulnerability by
estimating losses from floods, earthquakes and hurricane wind events. Even though HAZUS is
not required in Local Mitigation Plans, communities are encouraged to use HAZUS to form a
scientific basis from which the mitigation strategy is developed.
Even though the mitigation planning regulation does not require that plans address manmade
hazards, jurisdictions are encouraged to assess risk to these hazards by using FEMA’s
Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7). This guide is designed to
help jurisdictions identify specific actions to reduce loss of life and property from manmade
hazards by modifying the built environment. It is not intended to help jurisdictions establish
procedures to respond to disasters, write an emergency operations plan, or create a counterterrorism program. In this context, the goal of mitigation is to decrease the need for response
as opposed to simply increasing response capability.
This section includes the following eight (8) subsections as follows:









Identifying Hazards
Profiling Hazards
Assessing Vulnerability: Overview
Assessing Vulnerability: Identifying Structures
Assessing Vulnerability: Addressing Repetitive Loss Properties
Assessing Vulnerability: Estimating Potential Losses
Assessing Vulnerability: Analyzing Development Trends
Multi-jurisdictional Risk Assessment

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
29

RISK ASSESSMENT
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 planning 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 mitigation planning regulation at 44 CFR Part
201, the plan should describe the sources used to identify hazards. The
process for identifying hazards could involve the following:




Reviewing the State hazard mitigation plan and local or regional
reports, plans, flood ordinances, and land use regulations, among
others;
Talking to experts from Federal, State, and local agencies and
universities;



Reviewing past events and declared disasters;



Searching the Internet and newspapers; and



Interviewing long-time residents and consulting historical societies or
museums.

Events which contain multiple hazards should describe each hazard
separately to provide sufficient information to enable the jurisdiction to
identify and prioritize appropriate mitigation actions. It is important to
consider the multiple aspects of each identified hazard. For instance,
hurricanes and tsunamis have distinctly different types of impacts from
high winds than flooding and storm surges; severe storms also include
both flooding and high winds; and wildfires have immediate fire hazards,
but may also produce mudslide hazards when followed by rain. When
considering how to approach hazard identification, jurisdictions should
refer to the State’s risk assessment and approach hazard identification
similarly.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
30

RISK ASSESSMENT

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
Therefore, the local risk assessment update shall address any newly
identified hazards that have been determined to pose a threat. If
improved descriptions of hazards are available, they should be
incorporated into this section.

Special
Consideration:
Using HAZUSMH to Estimate
Potential Losses

To assist communities in hazard vulnerability analysis, FEMA has
developed HAZUS (HAZUS-MH), a nationally standardized geographic
information system (GIS) software that can be used to assess
vulnerability by estimating losses from floods, earthquakes and hurricane
wind events. While HAZUS is not required in Local Mitigation Plans,
communities are encouraged to use HAZUS to form a scientific basis
from which the mitigation strategy is developed.
HAZUS can be used to define the area at risk (the planning area) as well
as the degree of risk from potential flood, earthquake, and wind hazards.
HAZUS is based on a geographic information system platform; therefore,
it is possible to overlay information about other hazards on HAZUS maps
in order to better understand risk from those hazards.

Resources:

For more information on identifying hazards, See:

Understanding Your Risks (FEMA 386-2), Step 1.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
[The risk assessment
shall include a]
description of the type …
of all natural hazards
that can affect the
jurisdiction …

Difference?

Step 4: Assess the Hazard

All appropriate hazards must be identified
and described in the multi-hazard
mitigation plan, while the plan for CRS
must only identify and describe the flood
hazard.

CRS requires at the minimum
that the flood hazard be
identified including addressing
the repetitive loss areas.
However, additional credit can
be earned for including
discussion of all other natural
hazards.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
31

RISK ASSESSMENT
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 a narrative (and an optional
map) of the following information:






The location or geographical areas in the community that would be
affected. If a hazard location cannot be geographically determined,
such as tornados that can strike anywhere in the community, the plan
must describe the entire planning area that can be affected by the
hazard. However, hazards with known geographic boundaries (e.g.,
flood, earthquake) must specifically identify where the hazard can
occur. For example: floodplains indicate areas potentially affected by
flooding; inundation areas represent the boundary on a Flood
Insurance Rate Map (FIRM) that shows the rising of a body of water
and its overflowing onto normally dry land; wildland urban interface
(WUI) are areas potentially affected by wildfire where improved
property and wildland fuels meet at a well-defined boundary1.
The extent (i.e., magnitude or severity) of potential hazard events.
Magnitude is a measure of the strength of a hazard event. The
magnitude (also referred to as severity) of a given hazard event is
usually determined using technical measures specific to the hazard2.
For each identified hazard, plans shall indicate the range of
magnitude or severity that could be experienced. Discussion of what
the community could anticipate should be enhanced with scientific
scales, such as the Fujita Scale, TORRO Hail Scale, Richter Scale,
Beaufort Wind Scale, Saffir-Simpson Scale, and the Palmer Index or
by using quantitative measurements such as: miles per hour, flood
depth, inches of rain, fire danger rating, and acres burned. Others
classify hazards using terms like high, medium, or low (or major,
minor, minimum). The plan must clearly define any classification
methods used to illustrate extent.
The probability is a statistical measure of the likelihood that the
hazard event would occur in an area2.

The plan shall also provide a discussion of past occurrences of hazard
events in or near the community. For example, in areas where tornadoes
occur, plans should indicate the recorded intensities and dates of previous
events. This discussion should include:

1

Source: National Fire Protection Agency (NFPA) 299, Standard for Protection of Life & Property from
Wildfire, 1991.
2
Source: FEMA 433: Using HAZUS-MH for Risk Assessment.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
32

RISK ASSESSMENT

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

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

Duration of event;

Date of occurrence; and

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

The hazard analysis should also identify on a map the areas affected by
each identified hazard. Additionally, a composite map (i.e., 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.
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.
Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
Therefore, the plan update shall continue to describe occurrences of
hazards included in the previously approved plan, and discuss new
occurrences of hazard events. As required under §201.6(d)(3) the
updated plan shall incorporate any new (i.e., since the previous plan was
approved) historical records, or hazard data related to profiling hazards,
such as NFIP maps or studies, HAZUS studies, or reports from other
Federal or State agencies that describe location, extent, probability, or
previous occurrences of hazards.
FEMA recommends that previously approved plans point out any data
limitations, and identify actions to obtain the data in the mitigation strategy.
If the previously approved plan identified data deficiencies that would be
addressed at a later time, then the deficiencies shall be incorporated in

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
33

RISK ASSESSMENT
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.
Any maps included in the updated plan must be consistent with the
updated information.
Special
Consideration:
Using HAZUSMH to Estimate
Potential Losses

Special
Considerations:

While HAZUS is not required in Local Mitigation Plans, communities are
encouraged to use HAZUS to form a scientific basis from which the
mitigation strategy is developed.
•

HAZUS establishes a base map for both single- and multijurisdictional boundaries and includes important features such as
critical/essential facilities, lifeline facilities, high potential loss
facilities, bridges, hazardous materials facilities and limited utilities
and road segment data. It is based on the geographic area that
the risk assessment will address.

•

HAZUS includes historical information about earthquake and
hurricane hazards.

While the mitigation planning regulation at 44 CFR Part 201 does not
require the inclusion of maps as part of the mitigation plan, they can be a
valuable tool to illustrate the information provided in the risk assessment.
If the jurisdiction does not have digital mapping capability (Geographic
Information System, Internet maps), paper maps can be scanned and
manipulated manually to include in the plan.
Maps should address hazards in the planning area specific to the
jurisdiction(s) or planning area represented in the plan. For example,
maps at a State or regional scale may not adequately show information
relevant on the local or County/Parish level. It may be useful to consider
the following when determining the usefulness of maps:
•

Avoid using state or national scale maps;

•

Maps can have multiple layers to clarify each hazard. This is
effective for hazards such as flood and hazmat;

•

Maps should clearly show all participating jurisdictional boundaries;

•

Maps should be readable at an 8 ½ by 11 inch letter size;

•

Maps should include a readable legend and scale;

•

Documentation on the limitations of the data used on the map
should be described the plan.

Refer to Understanding Your Risks, (FEMA 386-2) for more information on
maps and mapping techniques.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
34

RISK ASSESSMENT

Resources:

For more information on profiling hazards, See:

Understanding Your Risks (FEMA 386-2)

Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7,
Phase 2, Step 2.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 23.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
[[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.

Difference?

Step 4: Assess the Hazard

For CRS, the plan must identify and
describe the flood hazard, including the
repetitive loss areas. Whereas the multihazard plan must describe the location
and extent of all natural hazards that can
affect the jurisdiction. The multi-hazard
plan must also include information on
previous occurrences and on the
probability of future hazard events. (This
is an option for CRS credit)

Credit is based on what the
community includes in its
assessment of the hazard.
The minimum requirement is
for the flood hazard only.
However, additional credit can
be earned by identifying and
including a description of all
other natural hazards.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
35

RISK ASSESSMENT
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 is a summary of the
hazard’s impact on the community and its vulnerable structures. This
summary shall include, by type of hazard, a general description of the
types of structures affected by the hazards. Examples include, but are
not limited to, buildings, infrastructure, critical facilities, structures that
house the elderly or disabled, and areas where low-income populations
reside.
The overview shall also include a general description of the hazard’s
impact to the vulnerable structures. Vulnerable structures include those
located within geographic areas susceptible to a particular hazard.
However, keep in mind that certain hazards may affect the entire
community or planning area.
The summary can be presented in terms of dollar value or percentages
of damage. If there are any data limitations, 44 CFR §201.6(c)(2)(ii) may
be met by identifying the particular limitations and including mitigation
strategy actions for obtaining the data necessary to complete and
improve future vulnerability assessments.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, progress in local
mitigation efforts, and changes in priorities, and resubmit it for approval
within 5 years in order to continue to be eligible for mitigation project
grant funding
Therefore, the vulnerability overview in the updated plan shall describe
any changes, clarifications, or refinements to the overview summary
described in the previously approved plan. It shall continue to include,
by type of hazard, a general description of the types of structures
affected by the hazard.
The community should take into account the following when updating its
vulnerability assessment:
•

Updates to inventories of existing structures in hazard areas,
including new development, redeveloped areas or structures
located in annexed areas.

•

Potential impacts of future land development, including areas
that may be annexed in the future.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
36

RISK ASSESSMENT
•

New buildings that house special high-risk populations (i.e.,
elderly, low-income, disabled)

•

Completed mitigation actions that reduced overall
vulnerability.

If the previously approved plan noted data limitations related to the
vulnerability summary and identified in the mitigation strategy actions to
resolve the data deficiency, then the updated plan shall discuss how the
data was collected and incorporated into the updated risk assessment.
If data deficiencies still remain unresolved, the plan must discuss in the
mitigation strategy what action will be taken to collect the data for the
next update.
Special
Considerations:

The mitigation planning regulation at 44 CFR Part 201 does not require
a discussion about facilities that house special populations at risk, such
as the elderly, disabled, or others with special needs. However, FEMA
recommends their consideration in the risk assessment to enable the
development of appropriate actions to reduce vulnerability to these
facilities during and after a disaster, thereby potentially saving lives.

Special
Consideration:
Using HAZUSMH to Estimate
Potential Losses

HAZUS outputs tables and maps of inventory data and allows the
incorporation of local data to consider the assets that can be impacted
by the prioritized hazards. HAZUS includes information compiled from
national databases to describe the distribution of buildings by their use,
construction material, replacement cost, and other characteristics. It
also includes data about the location and characteristics of utilities,
transportation, populations, and other information that can help
communities understand their risk from hazards. It is also possible to
use HAZUS to incorporate locally developed hazard data and
information about the built and social environment into the risk
assessment process. It is recommended that communities take
advantage of this capability in order to produce loss estimations that
reflect their local conditions as accurately as possible.

Resources:

For a discussion on preparing a vulnerability assessment, See:

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

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 25.

HAZUS-MH at www.fema.gov/plan/prevent/hazus.

Integrating Manmade Hazards into Mitigation Planning (FEMA 3867), Phase 2, Step 2.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
37

RISK ASSESSMENT

A Comparison of the Community
Rating System &
Multi-Hazard Planning
Phase
Phase 3: Risk
Assessment
[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.

CRS Step

Hazard Mitigation Planning
Difference?

Step 5: Assess the Problem

CRS Step is consistent with Multi-Hazard
Planning Phase.

Credit is based on what is
included in the assessment of
vulnerability to the hazards
identified. At a minimum the
plan must include an overall
summary of each hazard and
its impact on the community.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
38

RISK ASSESSMENT
ASSESSING VULNERABILITY: ADDRESSING REPETITIVE LOSS PROPERTIES
Requirement
§201.6(c)(2)(ii):

[The risk assessment in all] plans approved after October 1, 2008 must
also address National Flood Insurance Program (NFIP) insured
structures that have been repetitively damaged by floods.

Explanation:

Repetitive loss properties are those for which two or more losses of at
least $1,000 each have been paid under the National Flood Insurance
Program (NFIP) within any 10-year period since 1978. Local
governments may obtain information on repetitive loss properties
within their jurisdiction by contacting their State NFIP Coordinator. Use
of flood insurance claim and disaster assistance information is subject
to The Privacy Act of 1974, as amended, which prohibits public release
of the names of policy holders or recipients of financial assistance and
the amount of the claim payment or assistance. However, maps
showing areas where claims have been paid can be made public. The
data should be used for planning purposes and can be very helpful in
identifying problem areas that may not be apparent on a floodplain or
drainage map.
After October 1, 2008, all Local Mitigation Plans approved by FEMA
must address repetitive loss structures in the risk assessment by
describing the types (residential, commercial, institutional, etc.) and
estimate the numbers of repetitive loss properties located in identified
flood hazard areas.
The plan should describe vulnerability in terms of an estimate of the
potential dollar losses to repetitive loss properties and a description of
the methodology used to prepare the estimate.
The plan should describe vulnerability in terms of providing a general
description of land uses and development trends within repetitive loss
areas so that mitigation options can be considered in future land use
decisions.
The plan should include a map of the known flood hazards, where
“known flood hazards” means the floodplain shown on the FIRM,
repetitive loss areas, areas not mapped on the FIRM that have flooded
in the past, and surface flooding identified in existing studies. No new
studies need to be conducted for this assessment.
Along with flood protection and floodplain management, mitigation
plans should discuss the unique natural features, natural areas, and
other environmental and aesthetic attributes that may be present in the
floodplain. Protecting and preserving these natural and beneficial
floodplain functions yield flood mitigation benefits and also help
integrate floodplain management efforts with other community goals
and objectives.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
39

RISK ASSESSMENT

Special
Considerations:

States and Tribes are encouraged to include a repetitive loss strategy
in their plans that, if approved, would make them eligible under 44 CFR
§201.4(c)(3)(v) for a reduced non-Federal cost share under the FMA
and SRL hazard mitigation assistance programs. In particular, States
address severe repetitive loss properties, which are a subset of
repetitive loss. Local jurisdictions are encouraged to also identify and
address this subset of properties. Severe repetitive loss properties are
defined as single or multifamily residential properties that are covered
under an 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 property.
(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.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, progress in local
mitigation efforts, and changes in priorities, and resubmit it for approval
within 5 years in order to continue to be eligible for mitigation project
grant funding. Therefore, the plan update must continue to address
repetitive loss structures in the risk assessment.

Resources:

For information on repetitive loss properties, See:

Understanding Your Risks (FEMA 386-2).

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
40

RISK ASSESSMENT

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
[The risk assessment]
must also address
National Flood Insurance
Program (NFIP) insured
structures that have
been repetitively flooded.

Difference?

Step 5: Assess the Problem

CRS Step is consistent with Multi-Hazard
Planning Phase.

The risk assessment must also
address National Flood
Insurance Program (NFIP)
insured structures that have
been repetitively flooded. The
community must also address
all properties identified in the
repetitive loss areas as
defined by the community.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
41

RISK ASSESSMENT
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 should be based on an inventory of existing and proposed
buildings, infrastructure, and critical facilities (structures) located within
identified hazard area boundaries. The inventory may include but is not
limited to the following:
•

Building Stock broadly includes residential, commercial,
industrial, and institutional buildings.

•

Critical Facilities are essential to the health and welfare of the
whole population and are especially important following hazard
events. Since vulnerability is based on service losses as well as
building structure integrity and content value, assess the effects on
the service function interruption of critical facilities as well as their
physical aspects. For purposes of this mitigation planning
guidance, critical facilities may include emergency service facilities
such as hospitals and other medical facilities, jails and juvenile
detention centers, police and fire stations, emergency operations
centers, public works facilities, evacuation shelters, schools, and
other uses that house special needs populations.

•

Transportation Systems include airways (including airports,
heliports, etc.), roadways (including highways, bridges, tunnels,
roadbeds, overpasses, transfer centers, etc.), railways and public
transit (including trackage, tunnels, bridges, rail yards, depots,
etc.), and waterways (including canals, locks, seaports, ferries,
harbors, dry-docks, piers, etc.).

•

Lifeline Utility Systems such as potable water, wastewater, oil,
natural gas, electric power, substations, power lines, etc.

•

Communications Systems and Networks such as telephones,
emergency service radio systems, repeater sites and base
stations, television and radio stations, etc.

•

High Potential Loss Facilities include facilities that would have a
high loss associated with them, such as nuclear power plants or
dams.

•

Hazardous Material Facilities include facilities housing
industrial/hazardous materials, such as corrosives, explosives,
flammable materials, radioactive materials, and toxins.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
42

RISK ASSESSMENT
•

Economic Elements include major employers, financial centers,
and other business or retail districts in the community that could
significantly affect the local or regional economy if interrupted.

•

Special Consideration Areas include areas of high density
residential, commercial, institutional, and industrial development
that, if damaged, could result in economic and functional losses
and in high death tolls and injury rates.

•

Historic, Cultural, and Natural Resource Areas may include
buildings, structures, objects, sites, national and local historic or
significant districts, and historical archival storage facilities.

The structure description should also include construction characteristics
(e.g., year built, building materials (e.g., light wood frame, concrete frame),
freeboard, foundation types (e.g., piers, piles, basement, slab-on-grade)).
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 and timed with the data gathering phase of
their comprehensive plan or land use plan.
If a local comprehensive plan is not available, State agencies or Regional
Planning Commissions may be able to provide regional data about
anticipated growth that may affect the community’s vulnerability to
hazards.
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.
Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, and resubmit it for
approval within 5 years in order to continue to be eligible for mitigation
project grant funding.
Therefore, the updated plan should include a current inventory of existing
and proposed buildings, infrastructure, and critical facilities located within
identified hazard area boundaries.

Special
Considerations:

In addition to reviewing and incorporating data from comprehensive and
long-range plans, some communities may opt to conduct a build-out
analysis. The analysis involves a projection based on full development of
all land in accordance with existing land use regulations such as the
zoning ordinance or subdivision regulations. Within this context, the impact
of growth on vulnerability could be assessed and included in the risk

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
43

RISK ASSESSMENT
assessment as a means to develop future actions to mitigate the risk.3
Special
Consideration:
Using HAZUSMH to Estimate
Potential Losses

While HAZUS is not required in Local Mitigation Plans, communities are
encouraged to use HAZUS to form a scientific basis from which the
mitigation strategy is developed.

Resources:

For a discussion on identifying vulnerable structures and preparing a
detailed inventory, See:

To consider the assets that can be impacted by the prioritized hazards,
HAZUS outputs tables and maps of inventory data and allows the
incorporation of local data. It provides a means by which the user can
document the populations, buildings, transportation infrastructure, utilities,
and other elements of the built environment that can be impacted by
different hazard events.

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

HAZUS-MH at www.fema.gov/plan/prevent/hazus .

Integrating Manmade Hazards into Mitigation Planning, (FEMA 386-7),
Phase 2, Step 3.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS
Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
For multi-jurisdictional
plans, the risk
assessment must
assess each
jurisdiction’s risks where
they vary from the risks
facing the entire
planning area.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 4: Step 4: Assess the
Hazard& Step 5: Assess the
Problem
For multi-jurisdictional plans,
the risk assessment must
assess each jurisdiction’s risks
where they vary from the risks
facing the entire planning area.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

3

Source: United States Environmental Protection Agency,
http://www.epa.gov/greenkit/build_out.htm

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
44

RISK ASSESSMENT
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. A monetary 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.
Structure loss is defined as a percentage of the Replacement Value x
Percentage of Damage. Content loss is defined as a percentage of the
Replacement Value x Percentage of Damage. Functional Losses are
indirect effects that usually involve interruptions in asset operations.
Functional downtime is the average time (in days) during which functions
(business or service) is unable to provide its service due to a hazard
event.
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. In addition, the estimated dollar losses as a result of
hazard events can also be used to assess the benefits and costs of
proposed mitigation actions.
The methodology used to determine losses should also be provided in
the plan. It should note any data limitations and identify and include in
the implementation strategy actions for obtaining the data to complete
and improve the future risk assessment analysis efforts.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, and resubmit it for
approval within 5 years in order to continue to be eligible for mitigation
project grant funding.
The loss estimate should be updated to reflect changes to the hazard
profile and/or to the inventory of structures. The plan should describe
any new methodology if the approach for determining the losses has
changed since the previous plan approval. The updated plan should
include, when resources permit, estimates of current structure, contents,
and function losses to present a full picture of the total loss for each
asset.
If the previously approved plan noted data deficiencies in estimating
potential losses and new data is available , then the new information

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
45

RISK ASSESSMENT
should be incorporated into the updated plan. However, if the data
deficiencies have not been resolved, the updated plan should explain
why the data deficiencies remain and a schedule to resolve the issue.
Special
Considerations:

Creating a composite loss map depicting high potential loss areas (and
identifying the location of critical facilities within the high potential loss
areas) from multiple hazards will help the community develop its
mitigation priorities based on loss potential.

Special
Consideration:
Using HAZUSMH to Estimate
Potential Losses

While HAZUS is not required in Local Mitigation Plans, communities are
encouraged to use HAZUS to form a scientific basis from which the
mitigation strategy is developed.

Resources:

For a step-by-step method for estimating losses, See:

The most important purpose of HAZUS is the ability to estimate losses
from natural hazards. Descriptions of losses include both social and
economic considerations and they describe both the location and extent
of losses.

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

HAZUS-MH at www.fema/gov/plan/prevent/hazus .

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 27.

Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 2, Step 4.
Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
[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.

Difference?

Step 5: Assess the Problem

CRS Step is consistent with Multi-Hazard
Planning Phase.

CRS credit is given for an
assessment that includes a
review of all properties that
received flood insurance
claims (in addition to repetitive
loss properties) or an estimate
of the potential dollar losses to
vulnerable structures. This is
optional.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
46

RISK ASSESSMENT
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 each community participating in the plan.
This can include existing land uses and development densities in the
identified hazard areas, as well as any anticipated future/proposed land
uses, including anticipated new development, and redevelopment, and
anticipated annexation areas.
An analysis of development trends provides a basis for making decisions
on the type of mitigation approaches to consider, and the locations where
these approaches can be implemented. 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.
The Local Mitigation Plan should consider any or all of the following when
analyzing development trends:
•

•
•
•

Plan Update:

Describe trends in terms of the amount of change over time (for
example, projecting trends based on increases of numbers of
permits, including demolition, issued per year) and identify where
the development is occurring;
Differentiate land uses of similar types that have distinctly different
densities (for example, single-family homes, attached housing, and
multifamily housing);
Where the future land uses are likely to occur based on
comprehensive plans, zoning, redevelopment plans, or proposed
annexation areas; or
The expected growth or redevelopment for some reasonable future
timeframe (for example, 10 years). The timeframe could be
coordinated with that of a local comprehensive or long-range plan
review and update.

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, and resubmit it for
approval within 5 years in order to continue to be eligible for mitigation
project grant funding.
The updated plan should include a general overview of land uses and
types of development occurring within the community, highlighting any
changes since the previously approved plan. The update should

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
47

RISK ASSESSMENT

specifically include existing and future land uses in identified hazard
areas.
If the previously approved plan noted data deficiencies in analyzing
development trends and identified actions in the mitigation strategy to
address them at a later time, then the new information should be
incorporated. However, if the data deficiencies have not been resolved,
they should be addressed in the updated plan, accompanied by an
explanation of why they remain and an updated schedule to resolve the
issue.
Special
Considerations:

To ascertain which jurisdictions statewide are the most vulnerable and to
establish priorities for mitigation funding and technical assistance, the
State is required under 44 CFR §201.4(c)(2)(ii) to review local risk
assessments and information provided in Local Mitigation Plans regarding
current and future land uses and anticipated or proposed development.
Following the review of Local Mitigation Plans, the State may adjust their
own risk assessment to more accurately reflect vulnerability using more
detailed data provided in Local Mitigation Plans. States may use this
information to prioritize mitigation programming and funding. The
integration includes the analysis of:
•

Areas of the State that have experienced significant population
increases or decreases and/or shifts in population;

•

Changes in land use or land use activities in vulnerable areas;

•

Implementation of mitigation actions that have ultimately reduced
vulnerability.

Special
Consideration:
Using HAZUSMH to Estimate
Potential Losses

While HAZUS is not required in Local Mitigation Plans, communities are
encouraged to use HAZUS to form a scientific basis from which the
mitigation strategy is developed.

Resources:

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

The HAZUS provided inventory reflects current conditions within a
community based on best available national data sources. It is possible
for the HAZUS user to replace the out-of-the-box inventory with data that
reflects projected community change. While this process can be
potentially time consuming and costly depending on the scale of the area
under study, it could provide a valuable means by which to assess the risk
from anticipated development. This information can then be applied
toward making better informed decisions which can guide development
within the community.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 29.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
48

RISK ASSESSMENT

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
[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.

Difference?

Step 5: Assess the Problem

CRS Step is consistent with Multi-Hazard
Planning Phase.

The CRS gives credit for a
description of the
development, redevelopment,
and population trends as well
as a discussion of what the
future brings for development
in the community. This is
optional..

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
49

RISK ASSESSMENT
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 risk assessment information for
the planning area as a whole as described in sections 201.6(c)(2)(i) and
(ii). 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.
The larger the planning area and the more communities participating in a
plan, the more likely that unique and varied risk will occur. Consulting the
State hazard mitigation plan can help identify the hazards that affect each
jurisdiction in the planning area.
Further, where unique construction characteristics or development trends
occur, they should be indicated in the plan so that appropriate mitigation
actions are considered.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, and resubmit it for
approval within 5 years in order to continue to be eligible for mitigation
project grant funding.
If new hazards and risks have been identified in the multi-jurisdictional
risk assessment, the information must be attributed to the appropriate
jurisdiction (s) or to the whole planning area, whichever applies.
Where vulnerability to previously identified hazards has changed, the
plan must incorporate this information into the updated multijurisdictional risk assessment and it must be attributed to the appropriate
jurisdiction (s) or to the whole planning area, whichever applies.

Resources:

For more information on creating a detailed risk assessment, See:

Understanding Your Risks (FEMA 386-2), Steps 1 – 4.

HAZUS-MH at www.fema.gov/plan/prevent/hazus.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 21-29.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
50

RISK ASSESSMENT

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 3: Risk
Assessment
For multi-jurisdictional
plans, the risk
assessment must
assess each
jurisdiction’s risks where
they vary from the risks
facing the entire
planning area.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 4. Assess the Hazard &
Step 5: Assess the Problem
For multi-jurisdictional plans,
the risk assessment must
assess each jurisdiction’s risks
where they vary from the risks
facing the entire planning area

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
51

MITIGATION STRATEGY
MITIGATION STRATEGY
Section 201.6(c)(3) of the mitigation planning regulation requires jurisdictions to develop a
mitigation strategy. The mitigation strategy serves as the long-term blueprint for reducing the
potential losses identified in the risk assessment. The mitigation strategy includes the
development of goals, objectives, and prioritized mitigation actions.
The development of goals from which specific actions and projects will be derived is based on
the community’s existing authorities, policies, programs, and resources and its capability to use
local tools to reduce losses and vulnerability from profiled hazards. Goals are long-term policy
statements and global visions that support the mitigation strategy. An example of a goal for a
wildfire hazard is, “Minimize wildfire losses in the wildland urban interface area.” Many
communities take an extra step and identify objectives that more narrowly define
implementation steps to attain the goals. Unlike goals, objectives are specific and measurable,
such as, “Increase educational opportunities for citizens about wildfire defensible space
actions.”
Following the identification of goals and objectives, the mitigation planning regulation at 44 CFR
Part 201 requires that communities identify, analyze, and prioritize alternative actions by profiled
hazard. The actions are even more specific than objectives. An example of an action for a
wildfire hazard is “Sponsor a booth at the community fair to promote wildfire defensible space.”
Local jurisdictions will benefit by reviewing the State’s mitigation strategy to ensure locally
identified actions are supported by the State’s policies, regulations and programs.
For multi-jurisdictional plans, each participating jurisdiction identifies the specific actions they
will undertake for each hazard profiled. Some actions may apply to more than one jurisdiction,
but specific mitigation actions are identified for each jurisdiction.
Communities are encouraged to develop actions that can be implemented by using local tools,
such as capital improvement budgets, special district funds, or implementing changes in
ordinances, policies, or procedures. In addition, communities are encouraged to consider
mitigation actions that may not be currently feasible, but may become a realistic possibility
following a disaster event. Access to State or Federal funds may enable communities to
accomplish actions during post-disaster recovery.
After five years of implementing the mitigation strategy, communities update their goals and
actions. In the plan update, goals and objectives may be reaffirmed or updated based on
current conditions, including the completion of mitigation initiatives, an updated or new risk
assessment, or changes in State priorities. It is useful to review the changes in the community
since the previous plan was approved to determine whether goals have been met or if they
remain consistent with current conditions.
This section includes the following five (5) subsections:







Local Hazard Mitigation Goals
Identification and Analysis of Mitigation Actions
Implementation of Mitigation Actions
Implementation of National Flood Insurance Program (NFIP)
Multi-jurisdictional Mitigation Actions

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
52

MITIGATION STRATEGY
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:

Goals are broad policy statements that explain what is to be achieved.
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 profiled 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,
such as a comprehensive plan.
Although the mitigation planning regulation does not require a description
of objectives, communities are encouraged to include objectives
developed to achieve the goals so that reviewers understand the
connection between goals, objectives, and actions.
The goals and objectives should:



Plan Update:

Be based on the findings of the local and State risk assessments; and
Represent a long-term vision for hazard reduction or enhancement of
mitigation capabilities.

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect progress in local mitigation efforts and changes in
priorities, and resubmit it for approval within 5 years in order to continue
to be eligible for mitigation project grant funding.
The plan update provides an opportunity for local jurisdictions to
reconsider the goals and objectives identified in the previously approved
plan. Goals should be reaffirmed or updated based on current
conditions, including the completion of mitigation initiatives, an updated
or new risk assessment, or changes in State priorities.
It is not necessary to change goals from the previous plan if they remain
valid; however, the plan must document that goals were re-evaluated
and that they were determined to remain valid and effective. If the
previously approved plan included objectives, the updated plan should
document which objectives have been met, and identify new objectives.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
53

MITIGATION STRATEGY

The planning team should address the following questions when updating
the mitigation strategy:





Special
Considerations:

Do the goals and objectives identified in the previously approved plan
reflect the updated risk assessment?
Did the goals and objectives identified in the previously approved plan
lead to mitigation projects and/or changes in policy that helped the
jurisdiction(s) to reduce vulnerability?
Do the goals and objectives identified in the previously approved plan
support any changes in mitigation priorities?
Are goals identified in the updated Local Mitigation Plan reflective of
current State goals?

Goals are general guidelines that explain what you want to achieve.
They are broad policy statements and are usually long-term and
represent global visions, such as “Protect Existing Property.”
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 “Increase the number of buildings protected from flooding.”
The development of effective goals and objectives enables the planning
team to evaluate the merits of alternative mitigation actions and the local
conditions in which these activities would be pursued. A potential
mitigation action that would support the goal and objective goal example
above is “Acquire repetitive flood loss properties in the Acadia Woods
Subdivision.”

Resources:

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

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

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 30.

Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 3, Step 1.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
54

MITIGATION STRATEGY

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 4: Mitigation
Strategy
[The hazard mitigation
strategy shall include a]
description of mitigation
goals to reduce or avoid
long-term vulnerabilities
to the identified hazards.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 6: Set Goals
Credit is based on a statement of
goals to reduce or avoid long term
vulnerability to the identified
hazards.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information
on participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
55

MITIGATION STRATEGY
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 analyze various actions that achieve
the community’s goals and objectives to reduce or avoid the effects of the
identified hazards. A comprehensive range of specific mitigation actions
consists of multiple mitigation actions for each profiled hazard. “No
Action” does not qualify as a mitigation action. Mitigation actions shall
address existing and new buildings and infrastructure.
Prior to analyzing and prioritizing mitigation actions, it may be useful for
communities to sort identified mitigation actions into the following groups:
•

•

•

•

•

Prevention: Government administrative or regulatory actions or
processes that influence the way land and buildings are
developed and built. These actions also include public activities to
reduce hazard losses. Examples include planning and zoning,
building codes, capital improvement programs, open space
preservation, and storm water management regulations.
Property Protection: Actions that involve the modification of
existing buildings or infrastructure to protect them from a hazard,
or removal from the hazard area. Examples include acquisition,
elevation, relocation, structural retrofits, flood proofing, storm
shutters, and shatter-resistant glass.
Public Education & Awareness: Actions to inform and educate
citizens, elected officials, and property owners about potential
risks from hazards and potential ways to mitigate them. Such
actions include outreach projects, real estate disclosure, hazard
information centers, and school-age and adult education
programs.
Natural Resource Protection: Actions that, in addition to
minimizing hazard losses also preserve or restore the functions of
natural systems. These actions include sediment and erosion
control, stream corridor restoration, watershed management,
forest and vegetation management, and wetland restoration and
preservation.
Structural Projects: Actions that involve the construction of
structures to reduce the impact of a hazard. Such structures
include storm water controls (e.g., culverts), floodwalls, seawalls,
retaining walls, and safe rooms.

The plan should describe the process by which the community decides
on particular mitigation actions. This description should include who
participated in the analysis and selection of actions. Some of the
mitigation actions initially identified may ultimately be eliminated in the
community’s action plan due to limited capabilities, prohibitive costs, low
LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
56

MITIGATION STRATEGY
benefit/cost ratio, or other concerns. 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.
With regard to analyzing mitigation actions, FEMA’s Developing the
Mitigation Plan (FEMA 386-3) highlights the STAPLEE method—a
technique for identifying, evaluating, and prioritizing mitigation actions
based on existing local conditions.
S Social

T Technical

A Administrative

P Political

L Legal

The public must support the overall implementation
strategy and specific mitigation actions. Therefore,
the projects will have to be evaluated in terms of
community acceptance.
It is important to determine if the proposed action is
technically feasible, will help to reduce losses in the
long term, and has minimal secondary impacts.
Determine whether the alternative action is a whole
or partial solution, or not a solution at all.
Under this part of the evaluation criteria, examine
the anticipated staffing, funding, and maintenance
requirements for the mitigation action to determine
if the jurisdiction has the personnel and
administrative capabilities necessary to implement
the action or whether outside help will be needed.
Understanding how your current community and
State political leadership feels about issues related
to the environment, economic development, safety,
and emergency management. This will provide
valuable insight into the level of political support
have for mitigation activities and programs.
Proposed mitigation objectives sometimes fail
because of a lack of political acceptability.
Without the appropriate legal authority, the action
cannot lawfully be undertaken. When considering
this criterion, determine whether your jurisdiction
has the legal authority at the State, or local level to
implement the action, or whether the jurisdiction
must pass new laws or regulations. Each level of
government operates under a specific source of
delegated authority. As a general rule, most local
governments operate under enabling legislation
that gives them the power to engage in different
activities. Identify the unit of government
undertaking the mitigation action, and include an
analysis of the interrelationships between local,
regional, State, and Federal governments. Legal
authority is likely to have a significant role later in

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
57

MITIGATION STRATEGY
the process when your State, or community will
have to determine how mitigation activities can best
be carried out, and to what extent mitigation
policies and programs can be enforced.
E Economic

E Environmental

Every local and State government experiences
budget constraints at one time or another. Costeffective mitigation actions that can be funded in
current or upcoming budget cycles are much more
likely to be implemented than mitigation actions
requiring general obligation bonds or other
instruments that would incur long-term debt to a
community. States and local communities with tight
budgets or budget shortfalls may be more willing to
undertake a mitigation initiative if it can be funded,
at least in part, by outside sources. “Big ticket”
mitigation actions, such as large-scale acquisition
and relocation, are often considered for
implementation in a post-disaster scenario when
additional Federal and State funding for mitigation
is available.
Impact on the environment is an important
consideration because of public desire for
sustainable and environmentally healthy
communities and the many statutory
considerations, such as NEPA, to keep in mind
when using Federal funds. You will need to
evaluate whether, when implementing mitigation
actions, there would be negative consequences to
environmental assets such as threatened and
endangered species, wetlands, and other protected
natural resources.

Using criteria such as STAPLEE, local communities can weigh the pros
and cons of implementing a particular mitigation action. Jurisdictions
should evaluate actions based on local conditions that may impact
whether or not the actions identified in the mitigation action plan could be
accomplished. When identifying and evaluating mitigation actions, the
following considerations may also be useful:
•

Compatibility with goals and objectives identified in the current
State hazard mitigation plan;

•

Compatibility with goals and objectives identified in the local
mitigation strategy;

•

An assessment of the impact of identified actions on other
jurisdictions within the entire planning area or region (e.g. No
Adverse Impact4 watershed area plans)

•

Cost/benefit reviews of potential actions;

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
58

MITIGATION STRATEGY

Plan Update:

•

Funding priorities identified in the current State hazard mitigation
plan; and

•

Compatibility with other local or regional plans and programs.

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect progress in local mitigation efforts and changes in
priorities, and resubmit it for approval within 5 years in order to continue
to be eligible for mitigation project grant funding.
The plan update provides an opportunity for local jurisdictions to
reconsider the range of specific actions. If the mitigation actions or
activities remain unchanged from the previously approved plan the
updated plan should indicate why changes are not necessary.

Special
Considerations:

In the course of developing the local hazard mitigation plan, your
community may discover and build consensus on preparedness,
response, and recovery actions. Although FEMA will not deny a plan for
including these types of actions, they do not substitute for the mitigation
action requirements of a Local Mitigation Plan. In addition, even though
actions are listed in the plan, they may not all meet eligibility
requirements for FEMA’s mitigation grant programs. FEMA encourages
communities to formally agree upon mitigation actions that will make the
community safer from natural and man-made hazards.
Hazard mitigation is defined as sustained action taken to reduce or
eliminate long-term risk to people and property from hazards and their
effects. A mitigation action, such as voluntary acquisition and conversion
to open space in a floodplain protects the property and the removes the
people from harm’s way for the long-term. A response action that would
not qualify as a mitigation action would be, “Update Emergency
Operations Plan” or “Purchase fire trucks.”

Special
Considerations:

The community may review the sections on “State and Local Capability
Assessment” in their State’s hazard mitigation plan to assess their own
existing and planned capabilities to implement the identified mitigation
actions. This assessment should include a discussion of existing
mitigation activities in the community, existing regulatory standards (e.g.
building codes, zoning ordinances), 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.

Resources:

For more information on identifying and evaluating mitigation actions and
preparing a capability assessment, See:

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

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
59

MITIGATION STRATEGY
Assessment, Job Aid #2: Local Hazard Mitigation Capabilities, and
Worksheet #4 Evaluate Alternative Mitigation Actions.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 31.

Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 3, Step 2.

Rebuilding for a More Sustainable Future: An Operational Framework
(FEMA 365).

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 4: Mitigation
Strategy
[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.

Difference?
The CRS plan must discuss why some
activities are appropriate for
implementation and also discuss why
certain activities are not appropriate for
implementation.

Step 7. Review Possible
Activities
Credit is based on a
comprehensive evaluation
of hazard mitigation
measures reviewed in the
plan. The review must
include a description of why
certain activities were
recommended and why
others were not.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
60

MITIGATION STRATEGY
IMPLEMENTATION OF NATIONAL FLOOD INSURANCE PROGRAM (NFIP)
Requirement
§201.6(c)(3)(ii):

[The mitigation strategy] must also address the jurisdiction’s participation
in the NFIP, and continued compliance with NFIP requirements, as
appropriate.

Explanation:

Participation in the NFIP is based on an agreement between
communities and FEMA. The NFIP has three basic aspects: 1) floodplain
identification and mapping; 2) floodplain management; and 3) flood
insurance. First, NFIP participation requires community adoption of flood
maps. Mapping flood hazards creates broad-based awareness of the
flood hazards and provides the data needed to administer floodplain
management programs and to actuarially rate new construction for flood
insurance. Second, to be a participant, the NFIP requires communities to
adopt and enforce minimum floodplain management regulations that help
mitigate the effects of flooding on new and improved structures. Third,
community participation in the NFIP enables property owners to purchase
insurance as a protection against flood losses in exchange for State and
community floodplain management regulations that reduce future flood
damages.
All Local Mitigation Plans approved by FEMA after October 1, 2008 must
describe each jurisdiction’s participation in the NFIP and must identify,
analyze and prioritize actions related to continued compliance with the
NFIP. Simply stating an action such as, “The community will continue to
comply with NFIP,” will not meet this requirement. Basic compliance
NFIP actions could include, but are not limited to:
•

Adoption and enforcement of floodplain management
requirements, including regulating all and substantially improved
construction in Special Flood Hazard Areas (SFHAs);

•

Floodplain identification and mapping, including any local
requests for map updates, if needed; or,

•

Description of community assistance and monitoring activities.

Not all jurisdictions participate in the NFIP either because the community
has not been identified with Special Flood Hazard Area (SFHA), has not
been issued a Flood Hazard Boundary Map (FHBM) or a Flood Insurance
Rate Map (FIRM), or because the community has not adopted the FEMAissued flood maps. NFIP participation is voluntary for communities.
Jurisdictions that are currently not participating in the NFIP may meet this
requirement by describing the reasons why the community does not
participate, particularly where a FHBM or FIRM has been issued.
Communities are encouraged to take on additional activities that go
above and beyond the minimum requirements of NFIP participation and
these are described in the Community Rating System Coordinator’s
Manual (FIA-15/2007) (See http://training.fema.gov/EMIWeb/CRS/ ).

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
61

MITIGATION STRATEGY

Another innovative program is FEMA’s Cooperating Technical Partners
Program (CTP). The main objective of CTP is to increase local
involvement in the flood mapping process. With over 20,000
communities in the NFIP, the CTP encourages collaboration with NFIP
communities and regional and State agencies who wish to become more
active participants in the FEMA flood hazard mapping program.
Special
Consideration:

NFIP participation is a basic eligibility requirement for funding under
certain hazard mitigation grant programs, including FMA, SRL and PDM.
Jurisdictions that meet the NFIP requirement under §201.6(c)(3)(ii) in
their local mitigation plans do not automatically qualify for funding.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect progress in local mitigation efforts and changes in
priorities, and resubmit it for approval within 5 years in order to continue
to be eligible for mitigation project grant funding.
Therefore, the plan update must describe each jurisdiction’s participation
in the NFIP, including any changes since the previously approved plan
was adopted, and must identify, analyze and prioritize actions related to
continued compliance with the NFIP.

Resources:

For additional information on the NFIP, See:

National Flood Insurance Program Description
http://www.fema.gov/about/programs/nfip/index.shtm

Community Rating Resource Center,
http://training.fema.gov/EMIWeb/CRS/.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 4: Mitigation
Strategy

[The mitigation
strategy] must also
address the
jurisdiction’s
participation in the
NFIP, and continued
compliance with NFIP
requirements, as
appropriate.

Difference?
If the community participates in CRS, they
are already in full compliance with NFIP
requirements.

Step 8: Action Plan
CRS credits regulations that
go above and beyond the
minimum of the NFIP.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information
on participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
62

MITIGATION STRATEGY
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 describing 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 the action plan include: social impact, technical
feasibility, administrative capabilities, political and legal effects, and
economic, as well as environmental issues. The STAPLEE method may
be used to evaluate potential actions for the mitigation strategy, but also
to prioritize those that the community selects as its mitigation actions.
When prioritizing mitigation actions, local jurisdictions shall consider the
benefits that would result from the mitigation actions versus the cost of
those actions. Note that the mitigation planning regulation does not
require plans to include a benefit cost analysis for projects. However, an
economic evaluation is essential for selecting one or more actions from
among many competing ones. The requirement is met as long as the
economic considerations are summarized in the plan as part of the
community’s analysis. Among ways to address this requirement are:





Assessing the economic impact of one action compared to another.
Showing how one type of action costs more than another to achieve
the same benefit.
Showing that funding is available for one type of action but not
another.
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, including the department or agency responsible for
carrying out the actions, the potential funding sources, and the
implementation timeline. This section should also include a cost estimate
or budget for each action, when available. If cost estimates are not
available, jurisdictions may provide comparative costs (such as high,
medium, or low) with defined scales among actions.
Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect progress in local mitigation efforts and changes in
priorities, and resubmit it for approval within 5 years in order to continue
to be eligible for mitigation project grant funding.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
63

MITIGATION STRATEGY

Therefore, the updated plan must identify the completed, deleted, or
deferred actions or activities from the previously approved plan as a
benchmark for progress. If the mitigation actions or activities remain
unchanged from the previously approved plan, the updated plan must
indicate why changes are not necessary. Further, the updated plan shall
include in its prioritization any new mitigation actions identified since the
previous plan was approved or through the plan update process.
Resources

For more information on the development of the action plan, See:

Developing the Mitigation Plan (386-3), Phase 3.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 32.

Using Benefit-Cost Review in Mitigation Planning (FEMA 386-5)

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 4:
Mitigation Strategy
[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.

Difference?
For CRS credit, the action plan must
identify for each action item who does
what (what department or agency), when
it will be done (deadline), and how it will
be financed (community or outside
funding).

Step 8: Draft an Action Plan
Credit is based on an action
plan that identifies who does
what, when it will be done, and
how it will be financed.
The actions must be prioritized
and include a review of the
benefits of the proposed
projects and their associated
costs.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information
on participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
64

MITIGATION STRATEGY
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 link the proposed mitigation actions to
the applicable jurisdictions. Any jurisdiction within the planning area
requesting approval for the plan must be able to point to specific
actions to be pursued. Actions by individual jurisdictions may be part of
or contribute to an area-wide mitigation action. The scope of any 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.
Each jurisdiction must have participated in identifying and analyzing a
comprehensive range of mitigation actions for each profiled hazard,
which can result in an achievable mitigation action plan (See
§201.6(c)(3)(ii)). As with single-jurisdictional plans, a comprehensive
range of specific mitigation actions consists of multiple mitigation
actions for each profiled hazard and for each jurisdiction participating in
the plan.
This section must also include how actions will be implemented and
administered. The plan must include the jurisdiction, department
responsible for carrying out the actions, the potential funding sources,
and the implementation timeline. This section should also include a cost
estimate or budget for each action, when available.

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect progress in local mitigation efforts and changes in
priorities, and resubmit it for approval within 5 years in order to continue
to be eligible for mitigation project grant funding.
The updated multi-jurisdictional plan must identify the completed,
deleted or deferred actions from the previously approved plan as a
benchmark for progress. Further, the updated plan shall include any
new mitigation actions identified in its evaluation and prioritization since
the previous plan was approved or through the plan update process.
If the mitigation actions remain unchanged from the previously
approved plan, the updated plan must indicate why changes are not
necessary.

Resources:

For more information on the development of the action plan, See:

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

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 32.

Using Benefit-Cost Review in Mitigation Planning, (FEMA 386-5).

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
65

MITIGATION STRATEGY

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 4:
Mitigation Strategy
For multi-jurisdictional
plans, there must be
identifiable action items
specific to the jurisdiction
requesting FEMA
approval or credit of the
plan

Difference?
The CRS requires that an Action Plan
must include mitigation measures from at
least two of the six floodplain
management review categories.

Step 8: Draft an Action
Plan
For CRS credit, when a multijurisdictional plan is prepared,
it must have action items from
at least two of the six
categories that directly benefit
each community seeking CRS
credit.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
66

PLAN MAINTENANCE PROCESS
PLAN MAINTENANCE PROCESS
Section 201.6(c)(4) of 44 CFR requires a formal plan maintenance process to ensure that the
mitigation plan remains an active and relevant document. The plan maintenance process
includes a method and schedule for monitoring, evaluating, and updating the plan at least every
five (5) years. This also includes an explanation of how local governments intend to incorporate
their mitigation strategies into existing planning mechanisms, 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.
When the plan is updated, local jurisdictions assess how the Local Mitigation Plan maintenance
process worked and identify whether changes to the process are needed. Taking into
consideration future updates, adjustments to the method and schedule for maintaining the plan
may be necessary to ensure its value for comprehensive risk reduction.
As the mitigation plan evolves through updates, the plan maintenance process serves as the
basis for the next update, and the process of updating the plan provides local jurisdictions with
an opportunity to document progress in achieving mitigation goals.
When the community prepares a plan update, the mitigation planning regulation at 44 CFR Part
201 requires that the plan discuss how the community was kept involved during the plan
maintenance process over the previous five years. This discussion may take place within the
planning process section of the plan update rather than the plan maintenance section. The plan
maintenance section is intended to be forward-thinking and emphasize future plan maintenance.
This section includes the following three subsections:


Monitoring, Evaluating, and Updating the Plan



Incorporation into Existing Planning Mechanisms



Continued Public Involvement

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
67

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.

Explanation:

The local jurisdiction shall describe how, when, and by whom the plan
will be monitored. It is only necessary to provide the department or
agency responsible for carrying out the actions, not individuals.
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, or the
preparation of annual reports that capture 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:


The goals and objectives address current and expected conditions.



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



The current resources are appropriate for implementing the plan.





There are implementation problems, such as technical, political, legal,
or coordination issues with other agencies.
The outcomes have occurred as expected (a demonstration of
progress).
The agencies and other partners participated as originally proposed.

The plan shall describe how, when, and by whom the plan will be
updated. The mitigation planning regulation 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 or
after a hazard occurrence to determine the effectiveness of programs, and
to reflect changes in land development or programs that may affect
mitigation priorities. Monitoring, evaluation, and updating activities should
take place continuously within the five-year timeframe.
Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
The previously approved plan identified procedures to monitor, evaluate,
and update its mitigation plan and track mitigation activities. The results
of this evaluation and monitoring will assist local government in updating
each section of the plan as part of the established update schedule. In

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
68

PLAN MAINTENANCE PROCESS

particular, the plan maintenance section of the previously approved plan
should assist in establishing a process for updating the plan.
As a part of the planning process, the community reviews and analyzes
the previously approved plan’s method and schedule for monitoring and
updating the plan, such as strengths and weaknesses and what elements,
if any, have changed. The updated plan must include the method and
schedule to be used over the next five years to monitor, evaluate, and
update the plan.
For guidance on monitoring, evaluating, and updating the plan, See:

Resources:

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

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 35.

Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7),
Phase 4, Step 3.

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 5:
Plan Maintenance
[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.

Difference?
The CRS requires annual progress
reports as well as an update of the plan
every five years.

Step 10:
Draft an Action Plan
Credit is based on how a
community monitors and
evaluates its plan on an
annual basis and updates it on
a five-year cycle.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information
on participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
69

PLAN MAINTENANCE PROCESS
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 improvements, when appropriate.

Explanation:

The plan shall specify how the mitigation strategy, including the goals and
objectives, and mitigation actions will be incorporated into other planning
mechanisms. Jurisdictions shall also indicate how information contained
in the plan, including hazard identification and the risk assessment, will be
integrated into other planning mechanisms.
Communities that do not have comprehensive plans, capital improvement
plans or other long-range plans, should explain how the mitigation actions
would be implemented into zoning and building codes, subdivision
regulations, site reviews, permitting, job descriptions, staff training, or
other planning tools where such tools are the appropriate vehicle for
implementation. For mitigation actions that may use other means of
implementation, these other tools should be described.
Local government functions provide a myriad of methods in which to
implement actions identified in the mitigation strategy. Among them is the
comprehensive plan. Others include but are not limited to the following:

Plans
Local Comprehensive Plan
General Land Use Plan
Sustainability Plan
Capital Improvements Plan
Post-Disaster Redevelopment / Recovery Plan
Regional Development Plans
Watershed Protection/Enhancement Plan
Open Space Plan
Flood Mitigation Plan
Military Base Development/Redevelopment/Reuse Plan
College Campus Plans

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
70

Land Use

Redevelopment Plan

PLAN MAINTENANCE PROCESS

Evacuation Plan

Emergency
Operations

Comprehensive Emergency Management Plan

Codes, Regulations, & Procedures
Zoning Ordinance
Subdivision Regulations
Building Code / Permitting

Solid Waste & Hazardous Materials Waste Regulations
Property Deed Restrictions

Land Use

Landscape Code

Tree Protection Ordinance
Site Plan Review
Architectural/Design Review
Storm Water Management
Soil Erosion Ordinance
Programs
Beach Conservation & Restoration Program
Historic Preservation Program
Construction/Retrofit Program
Transportation Improvement/Retrofit Program
School District Facilities Plan
Long-Range Recreation Facilities Program
Economic Development Authority
Land Buyout Program
Downtown Redevelopment Authority
Local and/or Regional Evacuation Programs
“Firewise” and other Fire Mitigation
Fire Rescue Long-Range Programs
Mutual Aid Agreement
Temporary Animal Relocation Program

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
71

Land Use

Environmentally Sensitive Purchase / Protection Program

PLAN MAINTENANCE PROCESS

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan to reflect changes in development, progress in local
mitigation efforts, and changes in priorities, and resubmit it for approval
within 5 years in order to continue to be eligible for mitigation project grant
funding.
The updated plan must explain how the local government incorporated
the mitigation plan into other planning mechanisms, when appropriate, as
a demonstration of progress in local mitigation efforts.
The updated plan shall continue to describe how the mitigation strategy,
including the goals and objectives, and mitigation actions will be
incorporated into other planning mechanisms, and also indicate how
information contained in the plan, including hazard identification and the
risk assessment, will be integrated into other planning mechanisms.

Resources:

For more information on incorporating hazard mitigation activities in other
initiatives, See:

Getting Started (FEMA 386-1), Step 2

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 29.

Planning for a Sustainable Future: The Link Between Hazard
Mitigation and Livability (FEMA 364)

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 5:
Plan Maintenance
[The plan shall include a]
process by which local
governments incorporate
the requirements of the
mitigation plan into other
planning mechanisms
such as comprehensive
or capital improvements,
when appropriate.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 3: Coordination with
Other agencies.
If the plan includes a review of
existing studies, reports, and
technical information for the
needs goals and plan for that
area.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information
on participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
72

PLAN MAINTENANCE PROCESS
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) will have during the
mitigation 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.)

Plan Update:

The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and
revise its plan, and resubmit it for approval within 5 years in order to
continue to be eligible for mitigation project grant funding.
When the community prepares a plan update, the mitigation planning
regulation at 44 CFR Part 201 requires that the plan discuss how the
community was kept involved during the plan maintenance process over
the previous five years. It is suggested that this discussion take place
within the planning process section of the plan update rather than the plan
maintenance section. The plan maintenance section is intended to be
forward-thinking and emphasize future community involvement.
The updated plan shall describe how the community will involve the public
during the plan maintenance process over the next five years.

Resources:

For more information on keeping the public involved, See:

Getting Started (FEMA 386-1), Step 3.

Bringing the Plan to Life (FEMA 386-4), Steps 2 and 3.

Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 38.

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
73

PLAN MAINTENANCE PROCESS

Multi-Hazard Planning
Phase

A Comparison of the Community
Rating System &

CRS Step

Hazard Mitigation Planning
Phase 5:
Plan Maintenance
[The plan maintenance
process shall include a]
discussion on how the
community will continue
public participation in the
plan maintenance
process.

Difference?
CRS Step is consistent with Multi-Hazard
Planning Phase.

Step 10: Impalement,
evaluate and revise
The community must have
procedures for monitoring
implementation, reviewing
progress, and recommending
revisions to the plan in and
annual evaluation report.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on
participation in the Community Rating System.)

LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE
J U L Y 1 , 2 0 0 8
74

LOCAL MITIGATION PLAN REVIEW CROSSWALK
INSTRUCTIONS FOR USING THE PLAN REVIEW CROSSWALK FOR REVIEW OF LOCAL MITIGATION PLANS
Attached is a Plan Review Crosswalk based on the Local Multi-Hazard Mitigation Planning Guidance, published by FEMA in June, 2008. This Plan Review
Crosswalk is consistent with the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), as amended by Section 322 of the Disaster
Mitigation Act of 2000 (P.L. 106-390), the National Flood Insurance Act of 1968, as amended by the National Flood Insurance Reform Act of 2004 (P.L. 108-264)
and 44 Code of Federal Regulations (CFR) Part 201 – Mitigation Planning, inclusive of all amendments through October 31, 2007.
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 multijurisdictional plans, however, all elements apply. States that have additional requirements can add them in the appropriate sections of the Local 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.:
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
Element
annex and page #) Reviewer’s Comments
N
S
A. Does the new or updated plan include an
overall summary description of the
jurisdiction’s vulnerability to each
hazard?
B. Does the new or updated plan address
the impact of each hazard on the
jurisdiction?

Section II, pp. 4-10

The plan describes the types of assets that are located within geographically defined
hazard areas as well as those that would be affected by winter storms.

Section II, pp. 1020

The plan does not address the impact of two of the five hazards addressed in the plan.
Required Revisions:
• Include a description of the impact of floods and earthquakes on the assets.
Recommended Revisions:
This information can be presented in terms of dollar value or percentages of damage.
SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 1

LOCAL MITIGATION PLAN REVIEW CROSSWALK

LOCAL MITIGATION PLAN REVIEW SUMMARY
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.

Prerequisite(s) (Check Applicable Box)

NOT MET

MET

1. Adoption by the Local Governing Body:
§201.6(c)(5) OR

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.

Mitigation Strategy

3. Multi-Jurisdictional Planning Participation: §201.6(a)(3)

N

S

4. Documentation of the Planning Process: §201.6(b)
and §201.6(c)(1)

S

N

S

N

S

14. Identification and Analysis of Mitigation Actions:
§201.6(c)(3)(ii)
15. Identification and Analysis of Mitigation
Actions: NFIP Compliance. §201.6(c)(3)(ii)
16. Implementation of Mitigation Actions:
§201.6(c)(3)(iii)
17. Multi-Jurisdictional Mitigation Actions:
§201.6(c)(3)(iv)
Plan Maintenance Process

5. Identifying Hazards: §201.6(c)(2)(i)

18. Monitoring, Evaluating, and Updating the Plan:
§201.6(c)(4)(ii)
19. Incorporation into Existing Planning
Mechanisms: §201.6(c)(4)(ii)

6. Profiling Hazards: §201.6(c)(2)(i)

20. Continued Public Involvement: §201.6(c)(4)(iii)

Risk Assessment

N

13. Local Hazard Mitigation Goals: §201.6(c)(3)(i)

2. Multi-Jurisdictional Plan Adoption: §201.6(c)(5)
AND

Planning Process

SCORING SYSTEM

N

S

7. Assessing Vulnerability: Overview: §201.6(c)(2)(ii)
8. Assessing Vulnerability: Addressing Repetitive
Loss Properties. §201.6(c)(2)(ii)
9. Assessing Vulnerability: Identifying Structures,
Infrastructure, and Critical Facilities: §201.6(c)(2)(ii)(B)
10. Assessing Vulnerability: Estimating Potential Losses:
§201.6(c)(2)(ii)(B)

Additional State Requirements*
Insert State Requirement
Insert State Requirement
Insert State Requirement

11. Assessing Vulnerability: Analyzing Development
Trends: §201.6(c)(2)(ii)(C)
12. Multi-Jurisdictional Risk Assessment: §201.6(c)(2)(iii)

LOCAL MITIGATION PLAN APPROVAL STATUS
PLAN NOT APPROVED

*States that have additional requirements can add them in the appropriate sections of
the Local Multi-Hazard Mitigation Planning Guidance or create a new section and
modify this Plan Review Crosswalk to record the score for those requirements.
J U L Y

1 ,

2 0 0 8

See Reviewer’s Comments
PLAN APPROVED
A - 2

LOCAL MITIGATION PLAN REVIEW CROSSWALK
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:
J U L Y

Y = Participating
1 ,

2 0 0 8

N = Not Participating

N/A = Not Mapped
A - 3

LOCAL MITIGATION PLAN REVIEW CROSSWALK
PREREQUISITE(S)
1. 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).
SCORE
Location in the
NOT
Plan (section or
Element
Reviewer’s Comments
annex and page #)
MET
MET
A. Has the local governing body adopted new or
updated plan?
B. Is supporting documentation, such as a resolution,
included?
SUMMARY SCORE
2. 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.
SCORE
Location in the
NOT
Plan (section or
Element
Reviewer’s Comments
annex and page #)
MET MET
A. Does the new or updated plan indicate the
specific jurisdictions represented in the plan?
B. For each jurisdiction, has the local governing
body adopted the new or updated plan?
C. Is supporting documentation, such as a resolution,
included for each participating jurisdiction?
SUMMARY SCORE
3. 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.
SCORE
Location in the
NOT
Plan (section or
Element
Reviewer’s Comments
annex and page #)
MET
MET
A. Does the new or updated plan describe how each
jurisdiction participated in the plan’s development?
B. Does the updated plan identify all participating
jurisdictions, including new, continuing, and the
jurisdictions that no longer participate in the plan?
SUMMARY SCORE
J U L Y

1 ,

2 0 0 8

A - 4

LOCAL MITIGATION PLAN REVIEW CROSSWALK
PLANNING PROCESS: §201.6(b): An open public involvement process is essential to the development of an effective plan.
4. 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.
Location in the
SCORE
Element
A. Does the plan provide a narrative description of the
process followed to prepare the new or updated plan?
B. Does the new or updated plan indicate who was
involved in the current 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 new or updated 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. Does the new or updated plan discuss the
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?
F. Does the updated plan document how the planning
team reviewed and analyzed each section of the
plan and whether each section was revised as part
of the update process?

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 5

LOCAL MITIGATION PLAN REVIEW CROSSWALK
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.
5. 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
A. Does the new or updated plan include a description
of the types of all natural hazards that affect the
jurisdiction?

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

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE
6. 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
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 risk assessment identify the extent (i.e.,
magnitude or severity) of each hazard addressed in the
new or updated plan?
C. Does the plan provide information on previous
occurrences of each hazard addressed in the new or
updated plan?
D. Does the plan include the probability of future events
(i.e., chance of occurrence) for each hazard addressed in
the new or updated plan?

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

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 6

LOCAL MITIGATION PLAN REVIEW CROSSWALK
7. 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
Element
A. Does the new or updated plan include an overall
summary description of the jurisdiction’s vulnerability to
each hazard?
B. Does the new or updated plan address the impact of
each hazard on the jurisdiction?

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE
8. Assessing Vulnerability: Addressing Repetitive Loss Properties
Requirement §201.6(c)(2)(ii): [The risk assessment] must also address National Flood Insurance Program (NFIP) insured structures that have been
repetitively damaged floods.
Location in the
SCORE
Element
A. Does the new or updated plan describe vulnerability
in terms of the types and numbers of repetitive loss
properties located in the identified hazard areas?

Plan (section or
annex and page #)

Reviewer’s Comments
Note: This requirement becomes effective for all local
plans approved after October 1, 2008.

N

S

SUMMARY SCORE
9. 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 … .
Location in the
SCORE
Element
A. Does the new or updated 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 new or updated plan describe vulnerability in
terms of the types and numbers of future buildings,
infrastructure, and critical facilities located in the
identified hazard areas?

Plan (section or
annex and page #)

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

N

S

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

SUMMARY SCORE
J U L Y

1 ,

2 0 0 8

A - 7

LOCAL MITIGATION PLAN REVIEW CROSSWALK
10. 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)(ii)(A) of this section and a description of the methodology used to prepare the estimate … .
Location in the
SCORE
Element
A. Does the new or updated plan estimate potential
dollar losses to vulnerable structures?
B. Does the new or updated plan describe the
methodology used to prepare the estimate?

Plan (section or
annex and page #)

Reviewer’s Comments
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.

N

S

SUMMARY SCORE
11. 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.
Location in the
SCORE
Element
A. Does the new or updated plan describe land uses and
development trends?

Plan (section or
annex and page #)

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

N

S

SUMMARY SCORE
12. 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.
Location in the
SCORE
Element
A. Does the new or updated plan include a risk
assessment for each participating jurisdiction as
needed to reflect unique or varied risks?

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 8

LOCAL MITIGATION PLAN REVIEW CROSSWALK
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.
13. 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.
Location in the
SCORE
Element
A Does the new or updated plan include a description
of mitigation goals to reduce or avoid long-term
vulnerabilities to the identified hazards?

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE
14. 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.
Location in the
SCORE
Element
A. Does the new or updated 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?

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 9

LOCAL MITIGATION PLAN REVIEW CROSSWALK
15. Identification and Analysis of Mitigation Actions: National Flood Insurance Program (NFIP) Compliance
Requirement: §201.6(c)(3)(ii): [The mitigation strategy] must also address the jurisdiction’s participation in the National Flood Insurance Program (NFIP), and
continued compliance with NFIP requirements, as appropriate.
SCORE
Location in the
Element
A. Does the new or updated plan describe the
jurisdiction (s) participation in the NFIP?
B. Does the mitigation strategy identify, analyze and
prioritize actions related to continued compliance
with the NFIP?

Plan (section or
annex and page #)

Reviewer’s Comments
Note: This requirement becomes effective for all local
mitigation plans approved after October 1, 2008.
Note: This requirement becomes effective for all local
mitigation plans approved after October 1, 2008.

N

S

SUMMARY SCORE
16. 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.
SCORE
Location in the
Element
A. Does the new or updated mitigation strategy include
how the actions are prioritized? (For example, is there
a discussion of the process and criteria used?)
B. Does the new or updated mitigation strategy address
how the actions will be implemented and administered,
including the responsible department , existing and
potential resources and the timeframe to complete
each action?
C. Does the new or updated prioritization process include
an emphasis on the use of a cost-benefit review to
maximize benefits?
D. Does the updated plan identify the completed, deleted
or deferred mitigation actions as a benchmark for
progress, and if activities are unchanged (i.e.,
deferred), does the updated plan describe why no
changes occurred?

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 10

LOCAL MITIGATION PLAN REVIEW CROSSWALK
17. 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 new or updated plan include identifiable action
items for each jurisdiction requesting FEMA approval of
the plan?
B. Does the updated plan identify the completed, deleted or
deferred mitigation actions as a benchmark for progress,
and if activities are unchanged (i.e., deferred), does the
updated plan describe why no changes occurred?

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

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

PLAN MAINTENANCE PROCESS
18. 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
A. Does the new or updated plan describe the method and
schedule for monitoring the plan, including the responsible
department?
B. Does the new or updated plan describe the method and
schedule for evaluating the plan, including how, when and by
whom (i.e. the responsible department)?
C. Does the new or updated plan describe the method and
schedule for updating the plan within the five-year cycle?

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

SCORE
N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 11

LOCAL MITIGATION PLAN REVIEW CROSSWALK
19. 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
A. Does the new or updated plan identify other local planning
mechanisms available for incorporating the mitigation
requirements of the mitigation plan?
B. Does the new or updated plan include a process by which
the local government will incorporate the mitigation strategy
and other information contained in the plan (e.g., risk
assessment) into other planning mechanisms, when
appropriate?
C. Does the updated plan explain how the local government
incorporated the mitigation strategy and other information
contained in the plan (e.g., risk assessment) into other
planning mechanisms, when appropriate?

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

SCORE
N

Reviewer’s Comments

S

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.
Location in the
SCORE
Element
A. Does the new or updated 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?)

Plan (section or
annex and page #)

N

Reviewer’s Comments

S

SUMMARY SCORE

J U L Y

1 ,

2 0 0 8

A - 12

LOCAL MITIGATION PLAN REVIEW CROSSWALK
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

S

D. Probability of
Future Events
N

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

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

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 new or updated plan?
B. Does the risk assessment identify the extent (i.e., magnitude or severity) of each hazard addressed in the new or updated plan?
C. Does the plan provide information on previous occurrences of each natural hazard addressed in the new or updated plan?
D. Does the plan include the probability of future events (i.e., chance of occurrence) for each hazard addressed in the plan?

J U L Y

1 ,

2 0 0 8

A - 13

LOCAL MITIGATION PLAN REVIEW CROSSWALK
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 the new or updated plan addresses
each requirement. Completing the matrix is not required.

Hazard Type

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
Levee Failure
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

Hazards
Identified Per
Requirement
§201.6(c)(2)(i)

A. Types and Number
of Existing Structures
in Hazard Area
(Estimate)

N

Legend:
§201.6(c)(2)(ii) Assessing Vulnerability: Overview
A. Does the new or updated plan include an overall summary description of the jurisdiction’s
vulnerability to each hazard?
B. Does the new or updated plan address the impact of each hazard on the jurisdiction?
§201.6(c)(2)(ii)(A) Assessing Vulnerability: Identifying Structures
A. Does the new or updated plan describe vulnerability in terms of the types and numbers of
existing buildings, infrastructure, and critical facilities located in the identified hazard areas?

J U L Y

1 ,

2 0 0 8

S

B. Types and
Number of Future
Structures in Hazard
Area (Estimate)

N

S

§201.6(c)(2)(ii) Assessing Vulnerability: Estimating Potential Losses

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. Note: Receiving an N in the shaded columns will not preclude the plan from passing.

To c
he
clic ck box
chan k on th es, dou
e bo
ble
ge t
x
he
to “c defaul and
A. Loss Estimate B. Methodology
t val
heck
ue
ed.”

N

S

N

S

B. Does the new or updated 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 new or updated plan estimate potential dollar losses to vulnerable structures?
B. Does the new or updated plan describe the methodology used to prepare the estimate?

A - 14

LOCAL MITIGATION PLAN REVIEW CROSSWALK
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
Dam Failure
Drought
Earthquake
Expansive Soils
Levee Failure
Flood
Hailstorm
Hurricane
Land Subsidence
Landslide
Severe Winter Storm
Tornado
Tsunami
Volcano
Wildfire
Windstorm
Other
Other
Other

To c
he
click ck boxe
s
o
cha
nge n the b , double
ox a
the
de
nd
to “
chec fault va
lue
ked.
”

Legend:
§201.6(c)(3)(ii) Identification and Analysis of Mitigation Actions
A. Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for
each hazard?

J U L Y

1 ,

2 0 0 8

A - 15