Frequently Asked Questions
Mitigation Planning
Q: What is Mitigation Planning?
Q: What is the State of South Carolina Hazard Mitigation Plan (SHMP)?
Q: How can I receive a copy of the current State of South Carolina Hazard Mitigation Plan?
Q: Are local jurisdictions required to have a Local Hazard mitigation Plan (LHMP) in order to receive mitigation project grants?
Q: Do the details of specific mitigation projects have to be included in a Local Hazard Mitigation Plan (LHMP) in order to meet the grant requirement projects be in compliance with a jurisdiction's approved LHMP?
Q: If a jurisdiction identifies flooding as a hazard in its mitigation plan, but does not participate in the NFIP, can FEMA still approve the plan?
Q: For planning purposes, what should be considered a critical facility?
Hazard Mitigation Grant Program (HMGP)
Q: Must private nonprofit organizations (PNPs) have a FEMA-approved multi-hazard mitigation plan in order to receive HMGP project funds?
Q: Must school districts (or independent school districts, or other special districts defined as local governments at 44 CFR 201.2) have a FEMA-approved plan in order to receive HMGP project funds? (Note: Independent school districts are independent of the local government where they are located.)
Q: Are jurisdictions that are not participating in the NFIP eligible to receive HMGP Planning grants?
Pre-Disaster Mitigation Program (PDM)
Q: Is every State guaranteed to receive PDM funds?
Q: How will the State sub-applications be ranked for the threshold?
Q: What if my State submits sub-applications totaling more than the threshold?
Q: What if my State submits sub-applications totaling less than the threshold?
Q: Is there a limit on the number of sub-applications that each State can submit?
Q: Is participation in the National Flood Insurance Program (NFIP) a requirement to qualify for the PDM program? Are there any exceptions?
Q: Is a storm water drainage study eligible as a project under PDM?
Q: Is a hydrologic and hydraulic study eligible as a project under PDM?
Q: Can a paper application be submitted in place of the FEMA eGrants system?
Q: What is a Benefit Cost Analysis (BCA)? Do all PDM Applications require a BCA?
Q: What information is needed to perform a Benefit Cost Analysis (BCA)?
Mitigation Planning
Q: What is Mitigation Planning?
A: A process for States and communities to identify policies, activities and tools to implement mitigation actions. Mitigation is any sustained action taken to reduce or eliminate long-term risk to life and property from a hazard event. This process has four steps:
- organizing resources;
- assessing risks;
- developing a mitigation plan; and
- implementing the plan and monitoring progress.
Q: What is the State of South Carolina Hazard Mitigation Plan (SHMP)?
A: The State of South Carolina Hazard Mitigation Plan (SHMP) is the official statement of the State's hazard identification, vulnerability analysis, and hazard mitigation strategy. The SHMP is the result of a collaborative multi-agency planning process with multiple opportunities for public participation. The goal of the SHMP is to guide implementation activities to achieve the greatest reduction of vulnerability, which results in saved lives, reduced injuries, reduced property damages, and protection for the environment.
The SHMP is also a federal requirement under the Disaster Mitigation Act of 2000 (DMA 2000) for the State of South Carolina to receive federal funds for the following disaster assistance grant programs: Public Assistance (PA)--Category C through G, Fire Management Assistance Grant Program (FMAGP), and Hazard Mitigation Grant Program (HMGP).
In order for South Carolina to continue to be eligible for federal disaster assistance funding, South Carolina is required to update the SHMP every three years. The next SHMP update must be approved by the Federal Emergency Management Agency (FEMA) by October 18, 2007.
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Q: How can I receive a copy of the current State of South Carolina Hazard Mitigation Plan?
A: A digital copy can be viewed from this Web Portal.
Q: Are local jurisdictions required to have a Local Hazard mitigation Plan (LHMP) in order to receive mitigation project grants?
A: Local jurisdictions are required by Federal law to have a FEMA-approved hazard mitigation plan in order to qualify for the following hazard mitigation funding: Hazard Mitigation Grant Program (HMGP), Flood Mitigation Assistance (FMA) and Pre-Disaster Mitigation.
Q: Do the details of specific mitigation projects have to be included in a Local Hazard Mitigation Plan (LHMP) in order to meet the grant requirement projects be in compliance with a jurisdiction's approved LHMP?
A: No. For instance, a list of potential properties or areas that are being "considered" for mitigation strategies, such as acquisition, should be included as part of the mitigation strategy section of the LHMP, but the specifics regarding property addresses should remain at the project level, and need not be in the plan in advance.
Q: If a jurisdiction identifies flooding as a hazard in its mitigation plan, but does not participate in the NFIP, can FEMA still approve the plan?
A: Yes. NFIP participation is not currently a requirement for approval of multi-hazard mitigation plans. Therefore, FEMA cannot disapprove a plan solely because the local government is not participating in the NFIP. However, local plan regulations at 44 CFR 201.6(c)(3)(ii) require the mitigation strategy to identify and analyze "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." If a plan identifies flooding as a significant hazard and the plan's mitigation strategy does not adequately address this hazard (particularly with respect to new and existing structures and infrastructure), FEMA may disapprove the plan for failure to satisfy this requirement.
Q: For planning purposes, what should be considered a critical facility?
A: Every jurisdiction is unique. The list of assets that are most important to protect, as well as the criticality of any given facility, can vary widely from community to community. Thus, there is no universal definition of a critical facility, nor is one associated with the DMA 2000 planning requirements as promulgated in the Interim Final Rule. For planning purposes, a jurisdiction should determine criticality based on the relative importance of its various assets for the delivery of vital services, the protection of special populations, and other important functions.
A good place to start is Step Three of FEMA's Mitigation Planning How-To Guide, Understanding Your Risks: Identifying Hazards and Estimating Losses (FEMA 386-2). Based on a hazard-by-hazard identification of facilities that may be at risk, the Guide's emphasis on determining priorities for inventory data collection will help planners identify assets that are most critical to the jurisdiction. The companion publication Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7) builds on the guidance in Understanding Your Risks, detailing how the asset inventory can be tailored to focus on high-risk facilities such as critical infrastructures and key assets (see definitions below). A third potential point of departure is the inventory information available with FEMA's HAZUS-MH loss estimation software. HAZUS-MH databases include information on essential facilities such as hospitals, police and fire stations, emergency operations centers, shelters, and schools; transportation systems; utility lifelines; high potential loss facilities such as potable water, wastewater, oil, natural gas, electric power, and communication systems; and hazardous material facilities.
Numerous other sources provide additional guidance on identifying facilities that may be critical. First, FEMA's Public Assistance Guide (PDF) (FEMA 322) states that "A critical facility is a structure that, if flooded, would present an immediate threat to life, public health, and safety. Critical facilities include hospitals, facilities that produce toxic materials, and emergency operations centers." The related regulation at 44 CFR @#167; 206.226, Restoration of damaged facilities (text / PDF), states that "Eligible private nonprofit facilities may receive funding under the following conditions, The facility provides critical services, which include power, water (including water provided by an irrigation organization or facility in accordance with @#167; 206.221(e)(3)), sewer services, wastewater treatment, communications, emergency medical care, fire department services, emergency rescue, and nursing homes"
The definition can be construed more or less broadly as appropriate to the jurisdiction's planning approach. FEMA's State and Local Guide (SLG) 101: Guide for All-Hazard Emergency Operations Planning does not define critical facilities but provides the following examples:
- Emergency service facilities and equipment (fire stations; police stations; custodial facilities, such as jails and juvenile detention centers, hospitals, and other health care facilities; rescue squads; public works facilities, etc.).
- Communications networks (telephones, emergency service radio systems, repeater sites and base stations, television and radio stations, etc.).
- Water supply system/facilities, to include waste water treatment.
- Utilities (power plants, substations, power lines, etc.)
- Transportation networks (roads, bridges, airports, rail terminals, maritime ports).
- Homes, businesses, public facilities, etc.
Hazard Mitigation Grant Program (HMGP)
Q: Must private nonprofit organizations (PNPs) have a FEMA-approved multi-hazard mitigation plan in order to receive HMGP project funds?
A: No. PNP applicants for HMGP project grants do not need to have an approved multi-hazard mitigation plan in order to receive HMGP project funds. However, in order for a PNP project application to be approved, the following conditions must be met:
1. The jurisdiction in which the project is located must have an approved plan, and
2. The project must be consistent with the plan's goals and objectives.
(Note that, for FEMA's PDM program, PNPs are not eligible sub-applicants, but an eligible local government could apply for a grant on their behalf.)
Q: Must school districts (or independent school districts, or other special districts defined as local governments at 44 CFR 201.2) have a FEMA-approved plan in order to receive HMGP project funds? (Note: Independent school districts are independent of the local government where they are located.)
A: Yes. These districts, because they are defined as local governments, are required to have an approved plan - or demonstrate their participation as a separate government entity in another local government's approved mitigation plan - in order to receive project grants under HMGP or PDM. They would have to meet all FEMA local plan requirements. School districts do not fall under the definition of private nonprofit organizations [44 CFR 206.2(a)(19)].
Q: Are jurisdictions that are not participating in the NFIP eligible to receive HMGP Planning grants?
A: Yes. Non-participating jurisdictions are eligible for planning grants under the HMGP. Because of the post-disaster aspect of HMGP, FEMA wants to provide an opportunity to encourage sound mitigation planning, which may in turn serve to motivate non-participating jurisdictions to participate in the NFIP. Up to 7% of the total disaster HMGP funds may be used for State and local planning activities. For example, if a state receives $1 Million in HMGP, up to $70,000 could be used for planning grants to sub-applicants.
Pre-Disaster Mitigation Program (PDM)
Q: Is every State guaranteed to receive PDM funds?
A: As a new initiative for 2007, each State (including Territories) will receive no less than $500,000 provided the State submits sub-applications for at least that amount and the application(s) meets all program eligibility and completeness requirements. The maximum PDM award for any one state shall not exceed $15 million. There is a $1 million cap on Federal share for plans and a single Federal share cap of $3 million for projects.
Q: How will the State sub-applications be ranked for the threshold?
A: Selections will be based on eligible and complete sub-applications ranked by highest score after the Application Review, National Ranking, National Evaluation, and National Technical Review.
Q: What if my State submits sub-applications totaling more than the?
A: The ranking order of the sub-applications based on the results of the Application Review, National Ranking, National Evaluation, and National Technical Review will decide which sub-applications will receive the State threshold, and compete for the remaining PDM funds.
For example, if a State submits four eligible and complete sub-applications:
- Sub-application A $34,000
- Sub-application B $466,000
- Sub-application C $2,000,000
- Sub-application D $700,000
Scenario A
Based on the National Evaluation Score, all sub-applicants are ranked nationally. Sub-applicant A and B are ranked highest within the State. Both sub-applicants are selected for further review, and the $500,000 threshold has been met. Sub-applications C and D will compete for the remaining PDM funds after all State and Territory thresholds have been met.
Scenario B
If based upon the National Evaluation Score, either sub-application C or D is ranked highest within the State, either the $2,000,000 or $700,000 will more than satisfy the $500,000 threshold. The remaining three sub-applications will compete for the balance of PDM funds after all State and Territory thresholds have been met.
Scenario C
If the National Evaluation Score determines that sub-application A is ranked the highest within the State, and sub-application C is ranked second highest within the State, they both will be selected for further review to meet the $500,000 threshold. The remaining two sub-applications will compete for the balance of PDM funds after all State and Territory thresholds have been met.
Q: What if my State submits sub-applications totaling less than the threshold?
A: States and Territories will only receive up to the threshold for eligible sub-applications that meet the eligibility and completeness requirements through National Ranking, National Evaluation, and National Technical Review. FEMA will select for further review the entire amount of the sub-application Federal share request if it is less than the threshold, but, will not make up the difference.
Q: Is there a limit on the number of sub-applications that each State can submit?
A: No, there no limit to the number of sub-applications that States can submit during the 90-day application period. States are still limited to a single management cost application to cover Applicant management costs.
Q: Is participation in the National Flood Insurance Program (NFIP) a requirement to qualify for the PDM program? Are there any exceptions?
A: Active NFIP participation is required for Applicants and sub-applicants that have been identified through the NFIP as having a Special Flood Hazard Area (SFHA); a Flood Hazard Boundary Map (FHBM); or, a Flood Insurance Rate Map (FIRM) issued for their specific jurisdiction. These Applicants and Sub-applicants must be in good standing (i.e., not on probation, suspended, or withdrawn from the NFIP). Applicants and Sub-applicants that are not mapped or have not been issued a map are eligible for the PDM program.
The only exception to this requirement is for Federally-recognized Indian tribal governments, who are eligible to receive PDM planning grants even if they are not participating in the NFIP and have been issued a FHBM or FIRM. However, Tribal governments will not be eligible for PDM project grants until they participate in the NFIP.
Q: Is a storm water drainage study eligible as a project under PDM?
A: Yes, storm water drainage studies are eligible as a project under PDM. In Section 4.1 of the FY 2007 PDM guidance (page34), storm water management plans, or drainage studies can be an eligible activity as part of a larger proposed project for the purposes of project design and feasibility determination. In other words, a storm water drainage study is eligible for reimbursement if it is used to determine the technical feasibility of a larger project (i.e. a culvert enlargement project).
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Q: Is a hydrologic and hydraulic study eligible as a project under PDM?
A: Yes, hydrologic and hydraulic studies are eligible as a as a project under PDM. In Section 4.2 of the PDM guidance, hydrologic and hydraulic studies that are not integral or necessary for project design or feasibility determinations are ineligible for funding under PDM. Conversely, a hydrologic and hydraulic study used to determine the technical feasibility of a larger proposed project (i.e. a drainage ditch enlargement project) would be eligible under PDM as part of the overall project costs.
Q: Can a paper application be submitted in place of the FEMA eGrants system?
A: FEMA has developed a web-based, electronic grants (eGrants) management system to allow States, Federally-recognized Indian Tribal governments, territories, and local governments to apply for and manage their mitigation grant application processes electronically. The e-Grants system is an intuitive, user-friendly system that follows the current paper application requirements. These initiatives streamlines grant application processes and provide the means to electronically create, review, and submit a grant application via the Internet. As a part of the eGovernment initiative, FEMA's Mitigation eGrants system reduces the time and paperwork involved in the application process and at full development will manage the grant process through the entire grant life cycle from submission of an application to grant close out.
Q: What is a Benefit Cost Analysis (BCA)? Do all PDM Applications require a BCA?
A: A Benefit Cost Analysis (BCA) is the method by which the future benefits of a mitigation project are determined and compared to its cost. The end result is a Benefit-Cost Ratio (BCR), which is derived from a project's total net benefits divided by its total cost. The BCR is a numerical expression of the cost-effectiveness of a project. Composite BCRs of 1.0 or greater have more benefits than costs, and are therefore cost-effective. FEMA requires a BCA to be performed on all PDM project applications; a BCA is waived for all planning applications submitted to FEMA. To assist Applicants and Sub-applicants, FEMA has prepared the FEMA Mitigation BCA Toolkit CD. Please contact Thomas Queen at tqueen@emd.state.sc.us with your full mailing address and a disk will be mailed to you.
Q: What information is needed to perform a Benefit Cost Analysis (BCA)?
A: Supporting documentation that gives a history of damages to the project or county. These are things like road closures – times of closure, how long, detour times and traffic counts, Emergency payroll or total cost to the city or county for protection of the citizens due to the disaster. Other items would be loss of economic impacts such as businesses closure, loss of time for buildings. This information has to be documented and submitted with application to prove the loss and impact to the city or county.
