## [Multi-Jurisdictional Approaches to Mitigation Planning]{.mark}

(Excerpts from May 2005 Draft Multi-Jurisdictional Approaches to
Mitigation Planning FEMA 386-8)

## [Why Conduct Multi-Jurisdictional Natural Hazard Mitigation Planning?]{.mark} 

Multi-jurisdictional mitigation planning is a critical aspect of DMA
2000. A multi-jurisdictional plan ideally makes sense because it:

-   [offers an opportunity to cooperate on mutual concerns;]{.mark}

-   [allows economies of scale]{.mark} by:

    -   leveraging individual capabilities;

    -   sharing costs and resources;

-   avoids duplication of efforts; and

-   imposes an external discipline on the process.

Multi-jurisdictional plans may prove disadvantageous because there is:

-   a likelihood that some jurisdictions will not become fully involved;

-   less individual control over the process;

-   a need for strong leadership and organizational skills;

-   a possibility that there will be conflict among participants; and

-   a need for equal participation by all jurisdictions.

It is important to note that the authority and responsibility to adopt
the mitigation plan will lie ultimately at the jurisdiction level. Each
jurisdiction is responsible for adoption of the plan individually, even
if it has been prepared collectively. As this guide explains, each
jurisdiction has to meet certain requirements wherever the plan is
expected to meet a requirement spelled out by the Rule. If a
jurisdiction decides to participate in a plan but does not meet the
requirements, it will be denied funding approval by FEMA, while other
jurisdictions that participated in the same multi-jurisdictional plan
can receive approval if they have met all the criteria. Therefore,
multi-jurisdictional plans should in no way be used as a short-cut
approach to avoid preparing a local hazard mitigation plan.

## Multi-Jurisdictional Planning Participation

**TIP - Participation by multiple jurisdictions**

The first order of business is to create a structure for communication
and decision-making. It is [recommended that one person be the manager
for the overall plan development and that each participating
jurisdiction have a designated point of contact.]{.mark} Whatever
organization or methodology is used, it is essential that some structure
for accountability be [developed at the onset]{.mark} of the process.
The organizational models below have:

-   a ["Plan Author"]{.mark} who does much of the work in preparing the
    plan. This may be a consultant, a County agency, or some
    organization with the staff and capability to do research, prepare
    maps, develop text, and orchestrate the actual production of the
    plan document. Sometimes this Author is a combination of in-house
    capability and leadership of a public agency with technical support
    of outside consultants.

-   [a "Planning Team"]{.mark} when the group leading the planning
    effort comprises individuals other than the Plan Author. For
    details, refer to Chapter 2 of FEMA 386-1: *Getting Started:
    Building Support for Mitigation Planning.*

[There is no single organizational model that will work best for all
jurisdictions.]{.mark} This guide describes three organizational models.
Select the one that most closely fits with your capabilities. Whichever
you choose, the bottom line is that all participating jurisdictions
agree on the structure, follow an agreed-upon schedule, and meet some
minimum criteria for satisfactory participation.

## [Direct Representation Model]{.mark} 

The first model for the multi-jurisdictional plan organization allows
each participating jurisdiction to have direct representation on the
Planning Team (see Figure 2). The representatives are empowered to act
on the jurisdiction's behalf and bear the responsibility to be a conduit
between the Author and the jurisdiction. Because of the direct
representation, the individual jurisdictions are expected to be fully
engaged in the development of all aspects of the Plan.

This model works best where the [number of participants is relatively
small]{.mark} and representatives are actively engaged in the process.
Because of the direct involvement, the plan should be highly reflective
of the unique needs and interests of the individual jurisdictions.

[Figure 2. Direct Representation Model]{.mark}

## [Proxy Model]{.mark} 

In the second model, individual jurisdictions may authorize the Plan
Author to prepare the plan on their behalf. In essence, [the Plan Author
acts as a [proxy]{.underline} for the jurisdictions in developing the
plan]{.mark} (see Figure 3). The jurisdictions must formally authorize
the Plan Author to act on their behalf in developing the plan and must
each formally adopt the resulting plan to clearly satisfy the
participation requirements.

This model is most applicable where the subordinate participants have
little to no capability for active participation in the process. An
[example might be where a County agency prepares a plan that includes
several small towns or incorporated places that have no staff
experienced in preparing plans]{.mark}.

The benefit of this model is that it has few coordination issues. (A
sample resolution granting the Plan Author the authority to act on
behalf of the jurisdiction is found as Exhibit 2.) This model has
limited benefit, in that it lacks the direct involvement of the
jurisdictions and may not be fully reflective of the jurisdiction's
concerns, interests, and goals.

[Figure 3. Proxy Model]{.mark}

At the conclusion of the plan preparation, each jurisdiction must
formally adopt the plan as its own.

The Proxy model does not relieve the participating jurisdiction from
meeting other requirements of the Rule. The responsibility of the plan
containing all the pertinent pieces always remains with the
participating jurisdiction; however a jurisdiction can authorize the
Plan Author to act on its behalf.

**Sample Exhibit 2: [Authorization Resolution]{.mark}**

Resolution for Authorizing the Plan Author to act on behalf of Local
Jurisdiction

(Name of Jurisdiction) [Town A]{.underline}

(Governing Body) [Town Council]{.underline}

(Address) [100 Main Street, Town A]{.underline}

**RESOLUTION**

WHEREAS, [Town A]{.underline} has limited capability to undertake
extensive participation in the preparation of a hazard mitigation plan;
and

WHEREAS, [Consultant X]{.underline} is able to act on behalf of [Town
A]{.underline} in the analysis and development of a hazard mitigation
plan; and

WHEREAS, [Consultant X]{.underline} shall prepare a hazard mitigation
plan in accordance with the Disaster Mitigation Act of 2000;

NOW THEREFORE, [Town Council]{.underline}, authorizes [Consultant
X]{.underline} to prepare the [County ABC Plan]{.underline} on behalf of
[Town A]{.underline} which shall be reviewed and considered for adoption
by [Town Council]{.underline} upon completion.

ADOPTED this [20th day of September, 2005]{.underline} at the meeting of
the Town Council*.*

*\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*

(Mayor)

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(Clerk)

## [Indirect Representation Model]{.mark} 

[For relatively large groups of jurisdictions]{.mark}, an indirect model
may be appropriate. Led by a Plan Author, the jurisdictions may, due to
large numbers, be divided into several sub-groups, perhaps by geographic
proximity or some other common element or interest. Each of the
sub-groups may authorize a Representative to act on their behalf,
similar to the Proxy model described earlier. The sub-group of
Representatives then constitutes the core working group for development
of the plan which is directed, coordinated, or managed by the Plan
Author (see Figure 4). In order to fully meet the participation
criteria, each jurisdiction must authorize the Representative to act as
proxy in the development of the Plan and then formally adopt the plan.

[This model may be appropriate in situations where the level of planning
capability is limited at the individual jurisdictional level, similar to
the Proxy situation. What is different from the Proxy situation is that
there are so many participants that the Plan Author cannot adequately
represent all.]{.mark}

The sub-group of representatives may be one of the local jurisdictions
or a Council of Governments (COG) or some other appropriate agency or
individual who is tasked with communicating between the Plan Author and
the individual jurisdictions.

[Figure 4. Indirect Representation]{.mark}

## 

## [Variants]{.mark} 

Some plans have been prepared with a combination of Direct
Representation and Indirect Representation, as in the situation where a
large county relies upon COGs to represent the smaller jurisdictions,
and the larger Cities have direct representation. Any reasonable way to
organize the participants will be acceptable if the jurisdiction had
some kind of direct or representative participation and formally adopts
the final plan.

Make sure the plan clearly demonstrates jurisdictional representation or
formally authorized proxy in the process.

**TIP - Define satisfactory participation**

One of the first activities of the planning team should be to define
what constitutes satisfactory participation. In the Proxy model, the
measure of satisfactory participation could be that the participating
jurisdictions formally authorize the Plan Author to develop the plan and
then each jurisdiction formally adopts the plan. With direct or indirect
representation, satisfactory participation should reflect the amount of
interaction deemed appropriate to make the plan reflective of
participant needs and interests. Some measures that could be used
include:

-   Attendance at a specified number of meetings or work sessions

-   Submission of requested data

-   Submission of completed questionnaires

-   Response to interviews

-   Review and comment on draft materials

-   Hosting opportunities for public involvement

-   Linking local internet presence to a plan Web site

How to document the planning process is explained in Step 4 of FEMA
386-3: *Developing the Mitigation Plan: Identifying Mitigation Actions
and Implementation Strategies*.