part 2 -- enhanced state mitigation plans

The Enhanced State Mitigation Plan designation recognizes the State as a
proactive leader in implementing a comprehensive statewide hazard
mitigation program. The enhanced status acknowledges the extra effort a
State has made to reduce losses, protect its resources, and create safer
communities. For mitigation plans to receive this designation, the State
must obtain a "Satisfactory" score on all of the Standard State Plan
requirements as described in Part 1 of this manual. In addition, it must
receive a "Satisfactory" score on each of the Enhanced State
requirements.

The sections covered in Part 2 -- Enhanced State Mitigation Plans
include:

-   Prerequisite

-   Comprehensive State Hazard Mitigation Planning Program

Prerequisite

The State submitting a mitigation plan for designation as an Enhanced
State Mitigation Plan **must** meet the following prerequisite before
FEMA can approve the plan.

compliance with Standard State Plan requirements

+--------------+-------------------------------------------------------+
| Requirement  | Enhanced State Mitigation Plans must include all      |
| §201.5(b):   | elements of the Standard State Mitigation Plan        |
|              | identified in §201.4 ... .                            |
+--------------+-------------------------------------------------------+
| Explanation: | In order to be considered for Enhanced Plan status,   |
|              | the plan **must** contain all the elements of the     |
|              | Standard Plan (per §201.4), in addition to meeting    |
|              | all the requirements listed in §201.5. All the        |
|              | elements required for the Standard Plan must receive  |
|              | a score of "Satisfactory" before the plan is reviewed |
|              | for compliance with the Enhanced State requirements.  |
+--------------+-------------------------------------------------------+
| Resource:    | For more information on preparing and implementing a  |
|              | mitigation plan, see:                                 |
|              |                                                       |
|              | -   *Developing the Mitigation Plan* (FEMA 386-3),    |
|              |     Step 3.                                           |
|              |                                                       |
|              | -   *Bringing the Plan to Life* (FEMA 386-4), Step 2. |
+--------------+-------------------------------------------------------+
| Scoring:     | -   Not Met. Not all of the Standard State Plan       |
|              |     elements have received a "Satisfactory" rating.   |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   Met. All elements of the Standard State Plan      |
|              |     contained in the Enhanced Plan received a         |
|              |     "Satisfactory" rating.                            |
+--------------+-------------------------------------------------------+

Comprehensive State Hazard Mitigation Planning Program

§201.5 addresses Enhanced State Mitigation Plans. This is FEMA's effort
to recognize those States that go above and beyond the minimum
mitigation requirements by making them eligible to receive an increased
amount of mitigation grant funding. Strong State and local mitigation
planning processes and comprehensive mitigation program management at
the State level are important elements in reducing vulnerability to
future disaster losses. It is hoped that the Enhanced Plan option will
encourage more States to take their planning to a higher level. For the
Enhanced State Plan, States must meet all of the requirements of the
Standard Plan, plus be able to demonstrate that the State already has a
comprehensive mitigation program, that they effectively use available
mitigation funding, and that they are capable of managing the increased
funding.

This section includes the following six subsections:

-   Integration with Other Planning Initiatives

-   Project Implementation Capability

-   Program Management Capability

-   Assessment of Mitigation Actions

-   Effective Use of Available Mitigation Funding

-   Commitment to a Comprehensive Mitigation Program

Integration with Other Planning Initiatives

+--------------+-------------------------------------------------------+
| Requirement  | \[An Enhanced Plan must demonstrate\] that the plan   |
| §            | is integrated to the extent practicable with other    |
| 201.5(b)(1): | State and/or regional planning initiatives            |
|              | (comprehensive, growth management, economic           |
|              | development, capital improvement, land development,   |
|              | and/or emergency management plans) and FEMA           |
|              | mitigation programs and initiatives that provide      |
|              | guidance to State and regional agencies.              |
+--------------+-------------------------------------------------------+
| Explanation: | This requirement is similar to §201.4(b) for the      |
|              | Standard Plan, which is discussed previously in       |
|              | *Program Integration* (page 1--11), except that it    |
|              | requires the State to detail how the Enhanced Plan is |
|              | specifically integrated into other State, regional,   |
|              | and FEMA initiatives that provide primary guidance    |
|              | for hazard mitigation-related activities.             |
|              |                                                       |
|              | States might demonstrate that they have integrated    |
|              | the plan with planning initiatives that provide       |
|              | guidance by such activities as coordinating with      |
|              | developers of State plans (e.g., statewide economic   |
|              | development, capital improvement, or public works     |
|              | plans) to incorporate hazard mitigation priorities;   |
|              | passing State laws or regulations that mandate        |
|              | integration of mitigation considerations with other   |
|              | planning initiatives at the State level; and/or       |
|              | working with Regional Planning Authorities or         |
|              | Councils of Government.                               |
|              |                                                       |
|              | When applying this requirement, reviewers should keep |
|              | in mind the differences in planning conditions among  |
|              | States. For example, in States with extensive         |
|              | planning resources, integration with other plans may  |
|              | be more comprehensive. However, States with limited   |
|              | resources and little tradition of collaboration       |
|              | across agencies should receive credit for             |
|              | demonstrating measurable progress towards integration |
|              | of efforts.                                           |
+--------------+-------------------------------------------------------+
| Resource:    | For more information on integrating hazard mitigation |
|              | activities in other initiatives, see:                 |
|              |                                                       |
|              | -   *Getting Started* (FEMA 386-1), Step 1.           |
|              |                                                       |
|              | -   *Bringing the Plan to Life* (FEMA 386-4), Step 2. |
+--------------+-------------------------------------------------------+

Examples:

+--------------+-------------------------------------------------------+
| ![           | **Original Submittal:**                               |
| ](media/imag |                                                       |
| e1.png){widt | **[Integration with Other Planning                    |
| h="0.4861111 | Initiatives]{.underline}**                            |
| 111111111in" |                                                       |
| height       | In furthering the concept and practice of hazard      |
| ="0.49305555 | mitigation across the State, the Hazard Mitigation    |
| 55555556in"} | Committee (HMC) created a subcommittee to explore the |
|              | feasibility of integrating State hazard mitigation    |
|              | planning with other statewide planning initiatives    |
|              | such as the State Smart Growth initiative and the     |
|              | State economic development plan.                      |
+--------------+-------------------------------------------------------+

  --------------- -------------------------------------------------------
                  REVIEWER'S COMMENTS

  --------------- -------------------------------------------------------

+--------------+------------+------------------------------------------+
| **RULE       | **LOCATION | **REVIEWER'S COMMENTS**                  |
| SECTION**    | IN THE     |                                          |
|              | PLAN**     |                                          |
+--------------+------------+------------------------------------------+
| §201.5(b)(1) |            | -   While it is encouraging that the HMC |
|              |            |     created a subcommittee to explore    |
|              |            |     integration with other planning      |
|              |            |     initiatives, a strategy to promote   |
|              |            |     integration has not yet been         |
|              |            |     developed.                           |
+--------------+------------+------------------------------------------+

+--------------+-------------------------------------------------------+
|              | **Required Revisions:**                               |
|              |                                                       |
|              | The submittal must explain the steps that the         |
|              | planning committee has taken or intends to take to    |
|              | integrate hazard mitigation.                          |
+--------------+-------------------------------------------------------+

+--------------+-------------------------------------------------------+
| ![           | **Revised Submittal:**                                |
| ](media/imag |                                                       |
| e2.png){widt | **[Integration with Other Planning                    |
| h="0.5923611 | Initiatives]{.underline}**                            |
| 111111111in" |                                                       |
| height       | In furthering the concept and practice of hazard      |
| ="0.45833333 | mitigation across the State, the Hazard Mitigation    |
| 33333333in"} | Committee (HMC) created a subcommittee to explore the |
|              | feasibility of integrating State hazard mitigation    |
|              | planning with other statewide planning initiatives    |
|              | such as the State Smart Growth initiative and the     |
|              | State economic development plan. **The subcommittee   |
|              | developed the following strategy to further this      |
|              | work:**                                               |
|              |                                                       |
|              | -   **The State Hazard Mitigation Officer met with    |
|              |     the Director and Assistant Director of the State  |
|              |     Economic Development Agency to discuss            |
|              |     integration of hazard mitigation concepts into    |
|              |     economic development initiatives. The meeting     |
|              |     produced a commitment from the Director to invite |
|              |     HMC representatives to participate in upcoming    |
|              |     strategic planning sessions. The strategic plan   |
|              |     is to be completed before the next budget         |
|              |     cycle.**                                          |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   **The Governor's Authorized Representative, who   |
|              |     co-chairs the HMC, has agreed to have the         |
|              |     Governor's office develop an executive order      |
|              |     directing State agencies to work with the HMC to  |
|              |     integrate hazard mitigation concepts into State   |
|              |     operations where feasible.**                      |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   **The HMC is developing a presentation and        |
|              |     training program to educate State workers about   |
|              |     the need for hazard mitigation and the ways that  |
|              |     mitigation can be integrated into everyday        |
|              |     operations.**                                     |
|              |                                                       |
|              | -   **The State Smart Growth Office, a strong         |
|              |     supporter of hazard mitigation, and with          |
|              |     representation on the HMC, has developed a new    |
|              |     position, Hazard Reduction Policy Coordinator.    |
|              |     The Coordinator is the first paid hazard          |
|              |     mitigation employee hired by the State who is     |
|              |     outside the State Office of Emergency             |
|              |     Preparedness.**                                   |
|              |                                                       |
|              | **These new initiatives will create a comprehensive   |
|              | approach to reducing losses in the State. The State's |
|              | CRS and FMA programs have been in place since these   |
|              | programs were created. Additionally, the State        |
|              | received PDM funding for all planning and project     |
|              | grant applications it submitted in fiscal year        |
|              | 2004.**                                               |
|              |                                                       |
|              | []{.mark}                                             |
+--------------+-------------------------------------------------------+

Project Implementation Capability

+--------------+-------------------------------------------------------+
| Requirement  | \[The Enhanced Plan must document\] the State's       |
| §20          | project implementation capability, identifying and    |
| 1.5(b)(2)(i) | demonstrating the ability to implement the plan,      |
| and (ii):    | including:                                            |
|              |                                                       |
|              | -   Established eligibility criteria for multi-hazard |
|              |     mitigation measures.                              |
|              |                                                       |
|              | -   A system to determine the cost effectiveness of   |
|              |     mitigation measures, consistent with OMB Circular |
|              |     A-94, Guidelines and Discount Rates for           |
|              |     Benefit-Cost Analysis of Federal Programs, and to |
|              |     rank the measures according to the State's        |
|              |     eligibility criteria.                             |
+--------------+-------------------------------------------------------+
| Explanation: | These requirements build on §201.4(c)(3)(ii), which   |
|              | is discussed in the sections on State and local       |
|              | capability assessment on pages 1-37 through 1-42.     |
|              | However, while §201.4(c)(3)(ii) requires that the     |
|              | State demonstrate its capabilities to implement       |
|              | policies and programs to mitigate hazards,            |
|              | §201.5(b)(2)(i) requires that States identify their   |
|              | eligibility criteria for mitigation actions.          |
|              |                                                       |
|              | Development of such criteria was formerly undertaken  |
|              | during the *HMGP application process*. However, DMA   |
|              | 2000 now requires each State to consider these        |
|              | criteria as part of its *planning process* (See       |
|              | §206.435 of the Rule). States with HMGP experience    |
|              | might list existing criteria or use the planning      |
|              | effort as an opportunity to revisit and update these  |
|              | criteria. These eligibility criteria should be        |
|              | integral to developing a State's mitigation strategy  |
|              | where, ideally, mitigation actions would be           |
|              | categorized by short, medium, and long-term           |
|              | timeframes and then further prioritized as high,      |
|              | medium, or low.                                       |
|              |                                                       |
|              | Per §201.5(b)(2)(ii), States **must** also describe   |
|              | their approach to evaluating the cost-effectiveness   |
|              | of identified actions and explain or demonstrate how  |
|              | this approach is consistent with OMB Circular A-94.   |
|              | The description should include the agency and staff   |
|              | responsible for conducting benefit-cost analyses,     |
|              | reviews, or any other assessment method used. The     |
|              | selected actions **must** then be ranked according to |
|              | the eligibility criteria.                             |
+--------------+-------------------------------------------------------+
| Resource:    | For information on prioritizing actions and           |
|              | determining eligibility, and for a discussion about   |
|              | methods to determine cost effectiveness, see          |
|              | respectively:                                         |
|              |                                                       |
|              | -   *Developing the Mitigation Plan* (FEMA 386-3),    |
|              |     Step 2.                                           |
|              |                                                       |
|              | -   *Mitigation Benefit Cost Analysis (BCA) Toolkit   |
|              |     Compact Disc (CD).*                               |
+--------------+-------------------------------------------------------+

Examples:

+--------------+------------------------------------------------------+---+
| ![           | **Original Submittal:**                              |   |
| ](media/imag |                                                      |   |
| e1.png){widt | During the formation of its Mitigation Strategy, the |   |
| h="0.4861111 | State developed eligibility criteria for determining |   |
| 111111111in" | how hazard mitigation projects will be addressed.    |   |
| height       | These criteria were initially developed for the HMGP |   |
| ="0.49305555 | application and have been revised.                   |   |
| 55555556in"} |                                                      |   |
|              | Each County within the State provided a prioritized  |   |
|              | list of mitigation projects for their                |   |
|              | municipalities. These projects included such things  |   |
|              | as buyouts for repetitive flood loss properties, the |   |
|              | building of tornado shelters, the application of     |   |
|              | certain communities to the CRS program, and the      |   |
|              | development of new routes for the transportation of  |   |
|              | hazardous materials. The State then categorized      |   |
|              | these projects by their priority to the County,      |   |
|              | their cost, and the timeframe for implementation.    |   |
+--------------+------------------------------------------------------+---+
|              | REVIEWER'S COMMENTS                                  |   |
+--------------+------------------------------------------------------+---+

+--------------+------------+-----------------------------------------+
| **RULE       | **LOCATION | **REVIEWER'S COMMENTS**                 |
| SECTION**    | IN THE     |                                         |
|              | PLAN**     |                                         |
+--------------+------------+-----------------------------------------+
| §201.5(b)(2) |            | -   The plan does not list the          |
| (i) and (ii) |            |     eligibility criteria, the method    |
|              |            |     used to determine cost              |
|              |            |     effectiveness, or the system for    |
|              |            |     ranking actions.                    |
+--------------+------------+-----------------------------------------+

+--------------+-------------------------------------------------------+
|              | **Required Revisions:**                               |
|              |                                                       |
|              | The plan must list its eligibility criteria and       |
|              | address how cost-benefit analysis, review, or other   |
|              | methods were used to determine cost effectiveness of  |
|              | actions. It must also describe the system for ranking |
|              | eligible actions.                                     |
+--------------+-------------------------------------------------------+

+--------------+-------------------------------------------------------+
| ![           | **Revised Submittal:**                                |
| ](media/imag |                                                       |
| e2.png){widt | During the formation of its Mitigation Strategy, the  |
| h="0.5923611 | State developed eligibility criteria for determining  |
| 111111111in" | how hazard mitigation projects will be addressed.     |
| height       | These criteria were initially developed for the HMGP  |
| ="0.45833333 | application and have been revised. **This was done    |
| 33333333in"} | through the State Hazard Mitigation Planning          |
|              | Committee in regular meetings with the Counties. The  |
|              | eligibility criteria requires projects to:**          |
|              |                                                       |
|              | -   **Be cost effective.**                            |
|              |                                                       |
|              | -   **Address repetitive loss properties.**           |
|              |                                                       |
|              | -   **Be located in the most vulnerable areas         |
|              |     identified in the State Hazard Mitigation Plan.** |
|              |                                                       |
|              | -   **Have local matching funds (including in-kind    |
|              |     contributions).**                                 |
|              |                                                       |
|              | Each County within the State provided a prioritized   |
|              | list of mitigation projects for their municipalities. |
|              | These projects included such things as buyouts for    |
|              | repetitive flood loss properties, the building of     |
|              | tornado shelters, the application of certain          |
|              | communities to the CRS program, and the development   |
|              | of new routes for the transportation of hazardous     |
|              | materials. The State then categorized these projects  |
|              | by their priority to the County, their cost, and the  |
|              | time frame for implementation.                        |
|              |                                                       |
|              | **The State helped the Counties apply a cost-benefit  |
|              | analysis to their proposed mitigation projects. The   |
|              | Counties used this analysis to prioritize their       |
|              | projects. Projects were prioritized by such items as  |
|              | frequency of the disaster being mitigated, financial  |
|              | impact to the community, human losses, and timeframe  |
|              | for completion. For example, flooding is the biggest  |
|              | concern in certain areas of the State, whereas in the |
|              | "flats" tornadoes are the major concern. Each County  |
|              | has a different prioritization for hazard mitigation  |
|              | projects within its jurisdiction (see Appendix XX for |
|              | a list of criteria provided by County).**             |
|              |                                                       |
|              | **The State is then responsible for prioritizing each |
|              | of the County's projects with respect to how much and |
|              | when State help will be available. The State takes    |
|              | the number one priority for each County and then      |
|              | ranks these projects by giving a certain number of    |
|              | points to as follows:**                               |
|              |                                                       |
|              | -   **Cost effectiveness (i.e., those projects that   |
|              |     demonstrate that they are the most cost           |
|              |     effective) (20 to 35 points).**                   |
|              |                                                       |
|              | -   **Listing on the Repetitive Loss Property List    |
|              |     (40 points).**                                    |
|              |                                                       |
|              | -   **Location within the most vulnerable areas in    |
|              |     the State (10 to 25 points).**                    |
|              |                                                       |
|              | **In addition to funding, the State provides support  |
|              | to the Counties in several ways, including actual     |
|              | project implementation, seeking additional funding,   |
|              | project support, public involvement activities, and   |
|              | the provision of additional information (see Appendix |
|              | XX for a list of ranked projects).**                  |
|              |                                                       |
|              | **The State Hazard Mitigation Committee (HMC) tracks  |
|              | when and how projects are being implemented, as well  |
|              | as how their funding is being used (see Section XX of |
|              | the plan for more details). If there is a problem or  |
|              | conflict with a project, the State acts as a mediator |
|              | to resolve the problem as quickly and efficiently as  |
|              | possible. The State also conducts "lessons learned"   |
|              | meetings with Counties as necessary. As projects are  |
|              | completed, the State makes note of this in each       |
|              | County's file and maintains records on every          |
|              | project.**                                            |
+--------------+-------------------------------------------------------+

Program Management Capability

+--------------+-------------------------------------------------------+
| Requirement  | \[The Enhanced Plan must demonstrate\] that the State |
| §201         | has the capability to effectively manage the HMGP as  |
| .5(b)(2)(iii | well as other mitigation grant programs, \[and        |
| A-D):        | provide\] a record of the following:                  |
|              |                                                       |
|              | -   Meeting HMGP and other mitigation grant           |
|              |     application timeframes and submitting complete,   |
|              |     technically feasible, and eligible project        |
|              |     applications with appropriate supporting          |
|              |     documentation;                                    |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   Preparing and submitting accurate environmental   |
|              |     reviews and benefit-cost analyses;                |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   Submitting complete and accurate quarterly        |
|              |     progress and financial reports on time; and       |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   Completing HMGP and other mitigation grant        |
|              |     projects within established performance periods,  |
|              |     including financial reconciliation.               |
+--------------+-------------------------------------------------------+
| Explanation: | Because approval of an Enhanced Plan results in       |
|              | increased mitigation grant funding, this section      |
|              | requires States to demonstrate their capabilities to  |
|              | effectively manage the HMGP and other mitigation      |
|              | grant funds they have previously received. FEMA       |
|              | Regional Offices will certify that the State has the  |
|              | capacity to effectively manage the HMGP, FMA, and PDM |
|              | programs. The State is not required to document this  |
|              | in their plan.                                        |
+--------------+-------------------------------------------------------+
|              |                                                       |
+--------------+-------------------------------------------------------+

Assessment of mitigation actions

+--------------+-------------------------------------------------------+
| Requirement  | \[The Enhanced Plan must document the\] system and    |
| §201.        | strategy by which the State will conduct an           |
| 5(b)(2)(iv): | assessment of the completed mitigation actions and    |
|              | include a record of the effectiveness (actual cost    |
|              | avoidance) of each mitigation action.                 |
+--------------+-------------------------------------------------------+
| Explanation: | §201.5(b)(2)(iv) builds on §201.4(c)(5)(ii) and       |
|              | (iii), which were discussed previously in *Monitoring |
|              | Progress of Mitigation Activities* (page 1-59).       |
|              | States **must** describe how they would assess the    |
|              | effectiveness of each completed mitigation action,    |
|              | what agency or agencies will be involved in the       |
|              | assessment, and indicate the timeframe for carrying   |
|              | out this assessment. The results of this assessment   |
|              | will be necessary during the next plan update to      |
|              | verify achievement of the plan's goals and            |
|              | objectives, and to fine-tune or revise the mitigation |
|              | strategy.                                             |
|              |                                                       |
|              | The State **must** describe how it will track         |
|              | potential losses avoided for each action taken (e.g., |
|              | by developing a database or GIS system) since, in     |
|              | many cases, losses avoided cannot be accurately       |
|              | determined until a disaster occurs and damages are    |
|              | assessed.                                             |
+--------------+-------------------------------------------------------+
| Resource:    | For information on how to evaluate the effectiveness  |
|              | of mitigation actions see:                            |
|              |                                                       |
|              | -   *Bringing the Plan to Life* (FEMA 386-4), Step 3. |
+--------------+-------------------------------------------------------+

Examples:

+--------------+-------------------------------------------------------+
| ![           | Original Submittal:                                   |
| ](media/imag |                                                       |
| e1.png){widt | The State has established a method to determine the   |
| h="0.4861111 | effectiveness of mitigation actions being undertaken  |
| 111111111in" | in the State. During the preparation of the State     |
| height       | Hazard Mitigation Plan, the State partnered with the  |
| ="0.49305555 | State University to develop several economic analysis |
| 55555556in"} | models to determine the economic feasibility of       |
|              | various past mitigation actions. One of these models  |
|              | considered reductions in physical damages and         |
|              | financial losses that helped determine the            |
|              | effectiveness of mitigation actions by showing the    |
|              | resulting reduction in damages and losses. Other      |
|              | models showed various cost-benefit analyses to help   |
|              | communities decide which mitigation activities to     |
|              | implement.                                            |
|              |                                                       |
|              | Several of the State's communities currently have     |
|              | hazard mitigation plans in place. The economic models |
|              | can be applied to those existing plans as well as     |
|              | help communities who are in the process of developing |
|              | hazard mitigation plans. The State will provide help  |
|              | to the local communities in running and analyzing the |
|              | economic models.                                      |
+--------------+-------------------------------------------------------+

  --------------- -------------------------------------------------------
                  REVIEWER'S COMMENTS

  --------------- -------------------------------------------------------

+--------------+-------------+-----------------------------------------+
| **RULE       | **LOCATION  | **REVIEWER'S COMMENTS**                 |
| SECTION**    | IN THE      |                                         |
|              | PLAN**      |                                         |
+--------------+-------------+-----------------------------------------+
| §201.5(b)(2) |             | -   The State is active in trying to    |
| (iv)         |             |     assess the effectiveness of its     |
|              |             |     mitigation actions; however, no     |
|              |             |     specifics are given.                |
|              |             |                                         |
|              |             | ```{=html}                              |
|              |             | <!-- -->                                |
|              |             | ```                                     |
|              |             | -   It is not clear what agency or      |
|              |             |     agencies will be responsible for    |
|              |             |     developing and implementing the     |
|              |             |     economic modeling analyses or how   |
|              |             |     the local communities will benefit. |
+--------------+-------------+-----------------------------------------+

+--------------+-------------------------------------------------------+
|              | **Required Revisions:**                               |
|              |                                                       |
|              | The plan must provide specific information about how  |
|              | the effectiveness of mitigation actions will be       |
|              | assessed. Specific agency or agencies must be         |
|              | mentioned and a timeframe for conducting these        |
|              | assessments must be developed.                        |
+--------------+-------------------------------------------------------+

+--------------+-------------------------------------------------------+
| ![           | **Revised Submittal:**                                |
| ](media/imag |                                                       |
| e2.png){widt | The State has established a method to determine the   |
| h="0.5923611 | effectiveness of mitigation actions being undertaken  |
| 111111111in" | in the State. During the preparation of the State     |
| height       | Hazard Mitigation Plan, the State partnered with the  |
| ="0.45833333 | State University to develop several economic analysis |
| 33333333in"} | models to determine the economic feasibility of       |
|              | various past mitigation actions. One of these models  |
|              | considered reductions in physical damages and         |
|              | financial losses that helped determine the            |
|              | effectiveness of mitigation actions by showing the    |
|              | resulting reduction in damages and losses. Other      |
|              | models showed various cost-benefit analyses to help   |
|              | communities decide which mitigation activities to     |
|              | implement.                                            |
|              |                                                       |
|              | **As part of the State Hazard Mitigation Plan, the    |
|              | State Office of Economic Development partnered with   |
|              | the State University to develop several economic      |
|              | models to assess the losses avoided by various        |
|              | mitigation actions. These models used hazard data     |
|              | from recent events to determine the likely damages to |
|              | structures *had mitigation actions not taken place*.  |
|              | The models then used the probability of the event to  |
|              | calculate the avoided damages based on the net        |
|              | present value of the benefits.**                      |
|              |                                                       |
|              | Several of the State's communities currently have     |
|              | hazard mitigation plans in place. The economic models |
|              | can be applied to those existing plans as well as     |
|              | help communities who are in the process of developing |
|              | hazard mitigation plans. The State will provide help  |
|              | to the local communities in running and analyzing the |
|              | economic models.                                      |
|              |                                                       |
|              | **The Office of Economic Development is working with  |
|              | local communities to help them apply these analyses.  |
|              | A majority of the State's communities already have    |
|              | implemented some mitigation actions, and these models |
|              | can be applied to quantify the benefits of mitigation |
|              | activities identified in previous mitigation plans.   |
|              | The State Office of Planning is working with the      |
|              | remainder of the communities to develop hazard        |
|              | mitigation plans, whereupon economic feasibility      |
|              | analyses can be applied to specific mitigation        |
|              | strategies.**                                         |
|              |                                                       |
|              | **Following hazard events in the areas receiving      |
|              | mitigation action, communities will be required to    |
|              | show what damages and losses have been avoided (e.g., |
|              | structural damages prevented, business inventory      |
|              | damages prevented, rental income losses avoided,      |
|              | personal property losses prevented) by implementing   |
|              | their mitigation strategies. The communities are      |
|              | allowed discretion in determining how they will track |
|              | losses avoided (e.g., utilizing GIS or database       |
|              | technology).**                                        |
|              |                                                       |
|              | **The Office will review these analyses and provide   |
|              | feedback to the communities. The Office of Economic   |
|              | Development will conduct yearly checks on the         |
|              | communities to ensure that they are using these       |
|              | analyses effectively. It is recognized that           |
|              | non-economic factors are a major consideration and    |
|              | are difficult to incorporate into economic            |
|              | modeling.**                                           |
+--------------+-------------------------------------------------------+

effective use of available mitigation funding

+--------------+-------------------------------------------------------+
| Requirement  | \[The Enhanced Plan must demonstrate\] that the State |
| §            | effectively uses existing mitigation programs to      |
| 201.5(b)(3): | achieve its mitigation goals.                         |
+--------------+-------------------------------------------------------+
| Explanation: | In order for FEMA to increase the amount of HMGP      |
|              | funding available to a State in subsequent disasters, |
|              | it is important that the State document that it has   |
|              | fully and effectively made use of FEMA and other      |
|              | funding already at its disposal. §201.5(b)(3)         |
|              | requires States to demonstrate how they have taken    |
|              | advantage of FEMA programs, such as the Flood         |
|              | Mitigation Assistance Program (FMA), the Hazard       |
|              | Mitigation Grant Program (HMGP), and the Pre-Disaster |
|              | Mitigation Program (PDM) to fund mitigation actions.  |
|              | If States have used other FEMA and non-FEMA funding   |
|              | to support mitigation, they *should* include this     |
|              | documentation as well.                                |
|              |                                                       |
|              | In addition to describing projects that have been     |
|              | implemented, the plan *should* link the projects to   |
|              | specific State goals and objectives and assess the    |
|              | effectiveness of the projects in achieving the goals. |
|              |                                                       |
|              | The plan *should* also describe the State's strategy  |
|              | for ensuring continued effective use of resources     |
|              | (e.g., forming partnerships to leverage funding).     |
+--------------+-------------------------------------------------------+
| Resource:    | For information on how to evaluate the effectiveness  |
|              | of mitigation actions in achieving the plan's goals,  |
|              | see:                                                  |
|              |                                                       |
|              | -   *Bringing the Plan to Life* (FEMA 386-4), Step 3. |
+--------------+-------------------------------------------------------+

Examples:

+--------------+-------------------------------------------------------+
| ![           | **Original Submittal:**                               |
| ](media/imag |                                                       |
| e1.png){widt | The State uses a variety of funds and programs to     |
| h="0.4861111 | achieve its mitigation goals, including the Flood     |
| 111111111in" | Mitigation Assistance Program (FMA), the Hazard       |
| height       | Mitigation Grant Program (HMGP), and the State Hazard |
| ="0.49305555 | Mitigation Assistance Initiative (HMAI).              |
| 55555556in"} |                                                       |
+--------------+-------------------------------------------------------+
|              | REVIEWER'S COMMENTS                                   |
+--------------+-------------------------------------------------------+

+-------------+------------+------------------------------------------+
| **RULE      | **LOCATION | **REVIEWER'S COMMENTS**                  |
| SECTION**   | IN THE     |                                          |
|             | PLAN**     |                                          |
+-------------+------------+------------------------------------------+
| §           |            | -   The plan needs to explain *how* the  |
| 201.5(b)(3) |            |     State has taken advantage of all of  |
|             |            |     the hazard mitigation opportunities  |
|             |            |     currently available to them.         |
+-------------+------------+------------------------------------------+

+--------------+-------------------------------------------------------+
|              | **Required Revisions:**                               |
|              |                                                       |
|              | The revised plan must explain how the State uses      |
|              | Federal and State hazard mitigation funds and         |
|              | programs to achieve its goals, including the possible |
|              | combination of two or more funding programs.          |
+--------------+-------------------------------------------------------+

+--------------+-------------------------------------------------------+
| ![           | **Revised Submittal:**                                |
| ](media/imag |                                                       |
| e2.png){widt | The State uses a variety of funds and programs to     |
| h="0.5923611 | achieve its mitigation goals, including the Flood     |
| 111111111in" | Mitigation Assistance Program (FMA), the Hazard       |
| height       | Mitigation Grant Program (HMGP), and the State Hazard |
| ="0.45833333 | Mitigation Assistance Initiative (HMAI). **These are  |
| 33333333in"} | described below:**                                    |
|              |                                                       |
|              | **Flood Mitigation Assistance Program (FMA): The      |
|              | State has facilitated the use of FMA funds by local   |
|              | governments for the development of local hazard       |
|              | mitigation plans and projects. The State Hazard       |
|              | Mitigation Grant Coordinator visits each County       |
|              | yearly to develop local project applications and      |
|              | provides project management oversight for the grant.  |
|              | The State's goal is to have one-quarter of its        |
|              | communities using FMA project, planning, or technical |
|              | assistance funds each year to help fund planning      |
|              | initiatives, projects, or flood hazard studies.**     |
|              |                                                       |
|              | **Hazard Mitigation Grant Program (HMGP): The State   |
|              | has facilitated the use of HMGP funds for             |
|              | post-disaster hazard mitigation projects. Because     |
|              | HMGP funds are post-disaster funds and their          |
|              | availability from year to year is uncertain and       |
|              | limited, the State only allows funding for local      |
|              | projects that are captured in existing local hazard   |
|              | mitigation strategies. Also, the State uses its 5%    |
|              | HMGP set-aside to help fund State technical           |
|              | assistance to local governments.**                    |
|              |                                                       |
|              | **State Hazard Mitigation Assistance Initiative       |
|              | (HMAI): The State can provide up to 12.5% matching    |
|              | funds through the HMAI to help fund local hazard      |
|              | mitigation projects implemented through HMGP or FMA.  |
|              | These funds are provided to localities based first on |
|              | need (i.e., there are few local resources to meet the |
|              | 25% match requirement for Federal grants), and then   |
|              | on a competitive basis that compares benefit-cost     |
|              | analyses, environmental compatibility and justice,    |
|              | and political viability across jurisdictions**.       |
+--------------+-------------------------------------------------------+

Commitment to a Comprehensive Mitigation Program

+--------------+-------------------------------------------------------+
| Requirement  | \[The Enhanced Plan must demonstrate\] that the State |
| §201.5(      | is committed to a comprehensive state mitigation      |
| b)(4)(i-vi): | program, which might include any of the following:    |
|              |                                                       |
|              | -   A commitment to support local mitigation planning |
|              |     by providing workshops and training, State        |
|              |     planning grants, or coordinated capability        |
|              |     development of local officials, including         |
|              |     Emergency Management and Floodplain Management    |
|              |     certifications.                                   |
|              |                                                       |
|              | -   A Statewide program of hazard mitigation through  |
|              |     the development of legislative initiatives,       |
|              |     mitigation councils, formation of public/private  |
|              |     partnerships, and /or other executive actions     |
|              |     that promote hazard mitigation.                   |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   The State provides a portion of the non-Federal   |
|              |     match for HMGP and/or other mitigation projects.  |
|              |                                                       |
|              | -   To the extent allowed by State Law, the State     |
|              |     requires or encourages local governments to use a |
|              |     current version of a nationally applicable model  |
|              |     building code or standard that addresses natural  |
|              |     hazards as a basis for design and construction of |
|              |     State sponsored mitigation projects.              |
|              |                                                       |
|              | -   A comprehensive, multi-year plan to mitigate the  |
|              |     risks posed to the existing buildings that have   |
|              |     been identified as necessary for post-disaster    |
|              |     response and recovery operations.                 |
|              |                                                       |
|              | -   A comprehensive description of how the State      |
|              |     integrates mitigation into its post-disaster      |
|              |     recovery operations.                              |
+--------------+-------------------------------------------------------+
| Explanation: | The intent of this requirement is to allow States to  |
|              | describe mitigation-related activities that do not    |
|              | necessarily have a basis in a program or regulation.  |
|              | These activities truly show State commitment to       |
|              | reducing losses from hazards. States may demonstrate  |
|              | this commitment by describing how they have           |
|              | successfully implemented programs or projects that    |
|              | have reduced their exposure to hazards and how they   |
|              | will build on these past successes. Each State's      |
|              | mitigation strategy may include, but is not limited   |
|              | to, any of those elements mentioned above. Other      |
|              | actions that go "above and beyond" the requirements   |
|              | of the Standard Plan will be considered. If a State   |
|              | has no previous experience with mitigation            |
|              | initiatives, then the plan may only contain the       |
|              | various elements that the State proposes to           |
|              | implement. In either case, States *should* provide a  |
|              | timeframe for implementing these initiatives.         |
|              |                                                       |
|              | If the documentation to satisfy this plan requirement |
|              | is not included in its own section of the plan, the   |
|              | plan review crosswalk accompanying the plan *should*  |
|              | identify where in the plan these various commitments  |
|              | are described.                                        |
+--------------+-------------------------------------------------------+

+--------------+-------------------------------------------------------+
| Special      | Although the Rule requirements do not specifically    |
| Con          | mention the development of a statewide risk           |
| siderations: | assessment as a means to facilitate better            |
|              | coordination and detail in local mitigation planning, |
|              | carrying out such an activity is a good way to meet   |
|              | this particular requirement.                          |
+--------------+-------------------------------------------------------+
| Resource:    | For information on implementing a hazard mitigation   |
|              | program, see:                                         |
|              |                                                       |
|              | -   *Bringing the Plan to Life* (FEMA 386-4), Step 2. |
|              |                                                       |
|              | For ideas and examples of mitigation programs,        |
|              | policies, and projects, see:                          |
|              |                                                       |
|              | -   *Developing the Mitigation Plan* (FEMA 386-3),    |
|              |     Steps 1 and 2.                                    |
+--------------+-------------------------------------------------------+

Examples:

+--------------+-------------------------------------------------------+
| ![           | **Original Submittal:**                               |
| ](media/imag |                                                       |
| e1.png){widt | The State has developed a program by which it         |
| h="0.4861111 | provides hazard mitigation training workshops for     |
| 111111111in" | local governments. The State advertises the           |
| height       | availability of the program through a brochure        |
| ="0.49305555 | mailing that details the procedures for requesting    |
| 55555556in"} | the workshop.                                         |
+--------------+-------------------------------------------------------+
|              | REVIEWER'S COMMENTS                                   |
+--------------+-------------------------------------------------------+

+-------------+------------+-------------------------------------------+
| **RULE      | **LOCATION | **REVIEWER'S COMMENTS**                   |
| SECTION**   | IN THE     |                                           |
|             | PLAN**     |                                           |
+-------------+------------+-------------------------------------------+
| §201.5(     |            | -   The description of providing          |
| b)(4)(i-vi) |            |     assistance is very brief; it does not |
|             |            |     include such details as the duration  |
|             |            |     of the workshops, the staff or        |
|             |            |     agencies providing training, or       |
|             |            |     sources of funding.                   |
+-------------+------------+-------------------------------------------+

+--------------+-------------------------------------------------------+
|              | **Required Revisions:**                               |
|              |                                                       |
|              | The plan must document in detail the process by which |
|              | the State implements its hazard mitigation programs   |
|              | and initiatives. If the program has been in place for |
|              | some time, the plan should provide details about the  |
|              | results or performance of the program.                |
+--------------+-------------------------------------------------------+

+--------------+-------------------------------------------------------+
| ![           | **Revised Submittal:**                                |
| ](media/imag |                                                       |
| e2.png){widt | The State has developed a program by which it         |
| h="0.5923611 | provides hazard mitigation training workshops for     |
| 111111111in" | local governments. The State advertises the           |
| height       | availability of the program through a brochure        |
| ="0.45833333 | mailing that details the procedures for requesting    |
| 33333333in"} | the workshop. **After a local government requests the |
|              | training workshop, the State coordinates the          |
|              | logistical details with the local government for      |
|              | holding the workshop.**                               |
|              |                                                       |
|              | **The following State HMC representatives have been   |
|              | trained and authorized to conduct training for local  |
|              | governments on hazard mitigation planning:**          |
|              |                                                       |
|              | -   **The State Hazard Mitigation Officer, State      |
|              |     Office of Emergency Preparedness**                |
|              |                                                       |
|              | -   **The Hazard Reduction Policy Coordinator, State  |
|              |     Smart Growth Office**                             |
|              |                                                       |
|              | -   **The Environmental Stewardship Officer, State    |
|              |     Division of Environmental Protection**            |
|              |                                                       |
|              | **Funding for the two-day workshop is provided        |
|              | through the State Hazard Mitigation Assistance        |
|              | Initiative (HMAI) and local funds. Each County        |
|              | government receives up to \$1,500 to arrange the      |
|              | location, audio/visual equipment, invitations to      |
|              | interested staff and other local interested parties,  |
|              | and food. Any shortfall is made up through local      |
|              | funds. Since the training workshop program's          |
|              | initiation in 1999, five workshops have been          |
|              | conducted, and each of these localities has submitted |
|              | a compliant hazard mitigation plan within one year of |
|              | the workshop, as required.**                          |
+--------------+-------------------------------------------------------+