(@katherine1)

Infrastructure Mitigation Projects

Advanced Energy Management Alliance

Regarding the Building Resilient Hazard Mitigation Grant Program (BRIC), Advanced Energy Management Alliance recommends that communities and third party Distributed Energy Resource (DER) solutions providers be enabled to partner under this program. AEMA has weighed in on numerous government proceedings regarding resilience, including at the Federal Energy Regulatory Commission, Puerto Rico's microgrid proceeding, and ...more »

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(@katherine1)

Infrastructure Mitigation Projects

Scale Microgrid Solutions

Regarding the Building Resilient Hazard Mitigation Grant Program (BRIC), Scale Microgrid Solutions recommends that clean distributed technologies such as microgrids be actively considered as resilient solutions and included in the grant program. As an example, because of the life-threatening risk of wildfires in California, utilities are having to pro-actively cut power to entire communities to prevent fires from starting ...more »

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(@jaleesa.tate)

Lifelines

Include Mitigation Stakeholders In Outreach

During the hazard mitigation planning process cross sector collaboration is encouraged and stressed in order to ensure stakeholders from all community lifelines are integrated into the plan to reduce risk. Currently, the focus on community lifelines has been within the operations phases of emergency management. FEMA must begin to incorporate community lifelines education to mitigation stakeholders. At a minimum FEMA ...more »

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(@robert.coates)

Grant Project Evaluation

States Should be Polled for Evaluation Criteria

Project proposals can be evaluated in many ways, but the current evaluation system that FEMA has offers a lot of subjectivity and in many cases isn't clear as to how two projects may stack up against each other. It may be beneficial to poll states on how the prioritize their HMGP and PDM/FMA funding cycles for ideas. The states really understand the evaluation process, being that they sometimes do it 2-3 times a year. ...more »

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(@jaleesa.tate)

Capacity & Capability Building

Gaps Must Be Identified and Filled

Overarching we advocates for rules, regulations, and implementation of the mitigation grant programs which allows for flexibility, introduces simplicity, and builds capacity. It's essential to build applicant and subapplicant mitigation implementation capacity through technical assistance. Expansion of the allowable and desirable projects under HMA requires additional capacity to navigate projects within the Federal ...more »

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(@jaleesa.tate)

Grant Project Evaluation

Grant Management Fundamentals Specific to HMA Programs

Grant project evaluation requires proper and best grant management practices. This capability varies widely from applicant to applicant. Grant management practice improvements require transparency in FEMA's data collection with corresponding feedback to applicants on areas requiring improvement. Notification of improvement can be translated into actionable outcomes with increased FEMA assistance around financial and grant ...more »

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(@robert.coates)

Benefit-Cost Analysis (BCA)

BCA Should Be a High Scoring Criteria

The benefit cost analysis is the only true criteria that assesses the risk in the project. The higher the BCR, the more the project will potentially reduce future risk. For PDM/FMA this really is not on the forefront, but states use it as an important evaluation tool.

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(@jaleesa.tate)

Funding & Resource Management

Permit PAS for Non-Disaster Grant Programs

FEMA should allow applicants greater oversight of funding activities. The current oversight regime is overly restrictive through the numerous stipulations requiring applicants to serve as the "middle man" to convey information and arrange reviews between subapplicants and FEMA. Per the FEMA Strategic Plan, the most effective strategies for emergency management are those that are Federally supported, state managed, and ...more »

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(@jaleesa.tate)

Hazard Mitigation Planning

Expand Support for Planning

Ensuring applicants/subapplicants have adequate resources and funding to develop robust, comprehensive hazard mitigation plans is the cornerstone to improving mitigation and building resilient communities. The HMA grant funding should permit conceptual designs to be incorporated into the plan development process in order to jump-start application development that will lead to implementation. FEMA should maintain the current ...more »

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(@jaleesa.tate)

Risk Informed Funding

All Data Is Not Created Equally

Many factors are taken into consideration when prioritizing mitigation activities. From a risk data perspective this includes evaluating hazards and vulnerabilities; analyzing historic occurrences and Presidential Major Disaster Declarations; determining social vulnerability; and evaluating the geographical extent of a hazard. At a State level it can often times prove challenging to utilize data as a driving factor in ...more »

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(@jaleesa.tate)

Benefit-Cost Analysis (BCA)

Increase Opportunities for All Hazards

The ability of applicants/subapplicants to accurately demonstrate the cost-effectiveness of proposed projects is hampered by weaknesses within the underlying assumptions and implementation of the benefit-cost analysis methods. The current FEMA resources intended to aid applicants/subapplicants are generalized in a manner that allows for use with many project types. However, effective use of the resources is limited when ...more »

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(@jaleesa.tate)

Building Codes & Enforcement

Stringent Enforcement and Increased Education

States and local communities are often faced with several challenges in terms of adopting stringent regulations, including building codes. Obstacles can range from opposition from developers and community members to the lack of resources for enforcement. Improved outreach and education is at the forefront of overcoming these challenges. Staff and local government officials must be properly trained and educated to ensure ...more »

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(@jaleesa.tate)

The Hazard Mitigation Assistance Application Process

Reduce Complexity and Provide Activity Specific Guidance

The complexity of the current HMA submission process is an impediment to encouraging subapplicants to pursue mitigation. Improving the user experience of the eGrants system is key to improving the HMA application process. FEMA can begin improving and streamlining the submission process by developing activity specific guidance for applicants/subapplicants to include activity specific information and documentation requirements ...more »

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(@jim.poppen)

The Hazard Mitigation Assistance Application Process

Change to Eligibility of Subapplicants

When 2 CFR 200 went effective December 26, 2014, several our County governments became apprehensive to be a pass-through entity for local private non-profit rural electric cooperatives due to the additional requirements in 2 CFR § 200.331 - Requirements for Pass-Through Entities and §200.328 Monitoring and Reporting Program Performance. These additional requirements have made the county governments reluctant in being ...more »

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