Stantec Consulting Services Issues Public Comment on FEMA Notice

WASHINGTON, May 16 -- Caroline Cunningham, principal and hazard mitigation services lead, and Mike Anderson, vice president, at Stantec Consulting Services Inc., Raleigh, North Carolina, have issued a public comment on the Federal Emergency Management Agency's notice entitled "Hazard Mitigation Assistance: Building Resilient Infrastructure and Communities". The comment was written on May 11, 2020, and posted on May 13, 2020:

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Thank you for the opportunity to submit comments regarding FEMA's Building Resilient Infrastructure and Communities (BRIC) program as initiated under Section 1234 of the Disaster Recovery and Reform Act.

Stantec has worked with FEMA for over 40 years to advance mitigation through support of the National Flood Insurance Program, Risk MAP, and dozens of disasters. We have also assisted state, territory, tribal, and local governments to identify and implement mitigation projects.

We have helped applicants and subapplicants secure and administer over $1 billion in non-disaster and post-disaster funding through various mitigation programs including FEMA Hazard Mitigation Assistance (HMA) programs, FEMA Public Assistance 406 Mitigation, and the U.S. Department of Housing and Urban Development (HUD) Community Development Block Grant (CDBG)-Mitigation (MIT) program. We have reviewed the BRIC policy with our insights into these programs, applicant needs, and FEMA's mission and strategic plan in mind.

Stantec is pleased that BRIC policy aims to continue, and ideally expand, the opportunity for communities to reduce their long-term risk to natural hazards. Further, Stantec believes the policy is meeting its purpose to provide a framework from which the BRIC program can be administered. We also commend the guiding principles including capacity and capability building, innovation, partnerships, and higher standards. Below are specific comments for consideration as FEMA moves to finalize the BRIC policy and the initial Notice of Funding Opportunity (NOFO):

Requirement A2 (lines 64-68) & Requirement A3 (lines 69-78)

Inconsistent annual funding and inconsistent annual allocation determinations could introduce uncertainty with respect to applicant project planning, prioritization and expectations. We suggest FEMA establishes a date as early as possible, and prior to each year's NOFO, to inform the public of pending changes. In addition, please consider including a minimum annual allocations for BRIC program areas (Requirement A3). Such revisions will reduce the complexity of BRIC and encourage increased use.

Requirements A2 (lines 64-68)

In the event that the entire portion of the 6 percent set aside is not utilized, it is unclear what the remaining funds would be used for. Consider adding language to clarify this item.

Requirement B1 (lines 99-101)

Consider removing the eligibility requirement to have received a major disaster declaration in the seven years prior to the annual application period. If receipt of a recent disaster declaration is a priority for the BRIC program, consider including appropriate weightings to address this in the NOFO's selection criteria.

As written, the existing requirement may exclude those with high vulnerability and need. In addition, BRIC offers technical assistance and capability/capacity assistance (Requirements C1 and C2). Communities who have not been impacted by a disaster in recent years may be most in need of this support to enhance their programs. Disaster impacts, while devastating to communities, typically result in availability of multiple funding options not otherwise available to those in non-impacted areas. While the program is funded with disaster set aside monies, as a non-disaster program aimed at increasing national resilience, this funding should be accessible to applicants and subapplicants throughout the entire country to reduce their future losses, regardless of the timeframe of previous impacts.

Thank you for your review and consideration of our comments. Should you have any questions, we can be reached through the contact information presented below.

Sincerely,

Stantec Consulting Services Inc.

Caroline Cunningham, AICP, CFM, Principal, Hazard Mitigation Services Lead, Phone: (919) 475-9171

Mike Anderson, PMP, GISP, Vice President, FEMA Account Manager, Phone: (202) 955-7138

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The notice can be viewed at: https://www.regulations.gov/document?D=FEMA-2019-0018-0001

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