Repetitive Flood Claims 
(RFC) Program Guidance 

 

 

 


 

 

REPETITIVE FLOOD CLAIMS (RFC) 
PROGRAM GUIDANCE 

 

OVERVIEW....................................................................................................................IV 
SECTION 1 GRANT APPLICATION GUIDANCE.........................................................1 
1.1 PURPOSE.................................................................................................1 
1.1.1 APPLICATION CONSIDERATION UNDER OTHER MITIGATION 
GRANT PROGRAMS...........................................................................1 
1.2 AUTHORIZATION AND APPROPRIATION...............................................1 
1.2.1 AUTHORIZATION................................................................................1 
1.2.2 APPROPRIATION................................................................................2 
1.3 GRANT PROGRAM ELIGIBILITY..............................................................2 
1.3.1 ELIGIBLE PROPERTIES.....................................................................2 
1.3.2 ELIGIBLE APPLICANTS......................................................................2 
1.3.3 ELIGIBLE SUBAPPLICANTS...............................................................2 
1.3.4 PROGRAM REQUIREMENTS.............................................................3 
1.3.4.1 PLANNING REQUIREMENTS........................................................3 
1.3.4.2 NATIONAL FLOOD INSURANCE PROGRAM (NFIP)....................3 
1.3.4.3 PRIVACY OF REPETITIVE LOSS DATA.......................................3 
1.3.4.4 REDUCED CAPACITY REQUIREMENT........................................4 
1.3.4.5 NON-DISCRIMINATION.................................................................7 
1.3.4.6 COST-EFFECTIVENESS...............................................................7 
1.3.4.7 GEOCODING MITIGATION PROJECTS........................................7 
1.3.5 PROGRAM RESTRICTIONS...............................................................7 
1.3.5.1 DUPLICATION OF PROGRAMS....................................................7 
1.3.5.2 DUPLICATION OF BENEFITS........................................................7 
1.3.5.3 CONFLICT OF INTEREST.............................................................8 
1.3.5.4 COST OVERRUNS AND COST UNDER-RUNS............................8 
1.3.5.5 PRE-AWARD COSTS.....................................................................8 
1.4 ELIGIBLE ACTIVITIES AND ASSOCIATED COSTS................................8 
1.5 INELIGIBLE ACTIVITIES...........................................................................9 
1.6 APPLICANT MANAGEMENT COSTS.......................................................9 
1.6.1 PRE-AWARD MANAGEMENT COSTS................................................9 
1.6.2 SELECTION AND AWARD..................................................................9 
1.7 APPLICATION PROCESS.......................................................................10 
1.7.1 APPLICATION PERIOD.....................................................................10 
1.7.2 FEMAS ELECTRONIC GRANTS SYSTEM......................................10 
1.7.3 APPLICANT REVIEW OF SUBAPPLICATIONS................................11 
1.7.4 GRANT APPLICATION CHECKLIST.................................................11 
1.8 COST SHARE REQUIREMENTS............................................................12 
1.9 FEMA REVIEW AND AWARDS..............................................................12 
1.9.1 FEMA REVIEW..................................................................................12 
1.9.2 TECHNICAL REVIEW........................................................................12 
1.9.3 NATIONAL RANKING & SELECTION................................................12 
1.9.4 FEMA PRE-AWARD ACTIVITIES......................................................12 
1.9.5 AWARDS............................................................................................13 
1.9.6 NOTIFICATION OF STATUS OF SUBAPPLICATIONS.....................13 
1.9.7 RECONSIDERATION.........................................................................13 
1.10 PERFORMANCE PERIOD......................................................................14 
1.11 EXTENSIONS..........................................................................................14 
1.12 REPORTING REQUIREMENTS..............................................................15 
1.12.1 FEDERAL CASH TRANSACTION REPORTS...................................15 
1.12.2 FINANCIAL STATUS REPORTS.......................................................15 
1.12.3 PERFORMANCE REPORTS.............................................................16 
1.12.4 FINAL REPORTS...............................................................................16 
1.13 CLOSEOUT.............................................................................................16 
1.14 REGIONAL CONTACT INFORMATION..................................................16 
SECTION 2 MITIGATION PROJECT SUBAPPLICATION GUIDANCE......................18 
2.1 ELIGIBLE PROJECT ACTIVITIES...........................................................18 
2.2 INELIGIBLE PROJECT ACTIVITIES AND COSTS.................................19 
2.3 MITIGATION PROJECT REQUIREMENTS............................................19 
2.3.1 FEASIBILITY AND EFFECTIVENESS REQUIREMENT....................19 
2.3.2 ELIGIBILITY CRITERIA......................................................................20 
2.3.3 PROPERTY ACQUISITION AND RELOCATION REQUIREMENTS.21 
2.3.3.1 ELIGIBILITY FOR PROPERTY ACQUISITION PROJECTS........21 
2.3.3.2 REQUIREMENT TO APPLY DEED RESTRICTIONS...................22 
2.3.3.3 SUBAPPLICATIONS FOR PROPERTY ACQUISITION...............22 
2.3.3.4 PRE-AWARD REQUIREMENTS..................................................25 
2.3.3.5 POST-AWARD REQUIREMENTS................................................25 
2.3.4 SPECIAL FLOOD HAZARD AREA REQUIREMENTS.......................26 
2.3.5 FLOOD ELEVATION DATA...............................................................27 
2.3.6 FEDERAL INCOME TAX AND MITIGATION PROJECT FUNDS......28 
2.3.7 GEOCODING REQUIREMENTS.......................................................28 
2.3.8 PROJECT MAINTENANCE................................................................28 
2.4 SCOPE OF WORK..................................................................................28 
2.4.1 SCOPE OF WORK DOCUMENTATION............................................29 
2.4.2 SCOPE OF WORK CHANGES..........................................................29 
2.5 COST ESTIMATE....................................................................................29 
2.5.1 COST ESTIMATE DOCUMENTATION..............................................30 
2.5.2 COST ESTIMATE CHANGES............................................................30 
2.5.3 SUBAPPLICANT MANAGEMENT COSTS........................................31 
2.6 COST EFFECTIVENESS........................................................................31 
2.6.1 METHODOLOGY...............................................................................32 
2.6.2 COST-EFFECTIVENESS DOCUMENTATION..................................33 
2.7 ENVIRONMENTAL/HISTORIC PRESERVATION REVIEW....................34 
2.7.1 ENVIRONMENTAL/HISTORIC PRESERVATION REVIEW 
DOCUMENTATION............................................................................35 
2.7.2 CONDITIONS FOR THE AWARD OF FUNDS...................................36 
2.8 PROJECT SUBAPPLICATION CHECKLIST...........................................37 
2.9 FEMA REVIEW & RANKING...................................................................38 
2.9.1 ELIGIBILITY & COMPLETENESS REVIEW......................................38 
2.9.2 BENEFIT-COST TECHNICAL REVIEW.............................................39 
2.9.3 NATIONAL RANKING........................................................................40 
2.10 FEMA PRE-AWARD ACTIVITIES...........................................................40 
2.10.1 PROPERTY ACQUISITION AND RELOCATION REQUIREMENTS.40 
2.10.2 GEOCODING REQUIREMENTS.......................................................41 
2.10.3 ENVIRONMENTAL/HISTORIC PRESERVATION COMPLIANCE 
REQUIREMENTS...............................................................................41 
2.11 UPDATING REPETITIVE LOSS DATABASE FOR MITIGATED 
PROPERTIES..........................................................................................41 
SECTION 3 TECHNICAL ASSISTANCE RESOURCES.............................................42 
3.1 EGRANTS HELPDESK...........................................................................42 
3.2 PROJECT TECHNICAL ASSISTANCE...................................................42 
3.3 ENGINEERING FEASIBILITY TECHNICAL ASSISTANCE.....................42 
3.4 BENEFIT-COST ANALYSIS TECHNICAL ASSISTANCE.......................43 
3.5 ENVIRONMENTAL/HISTORIC PRESERVATION TECHNICAL 
ASSISTANCE..........................................................................................43 
3.6 PROJECT TECHNICAL ASSISTANCE HELPLINES...............................44 

REPETITIVE FLOOD CLAIMS (RFC) PROGRAM 
OVERVIEW 

OVERVIEW 
OVERVIEW 

RFC PROGRAM 

The Repetitive Flood Claims (RFC) grant program provides 
funding to reduce or eliminate the long-term risk of flood 
damage to structures insured under the National Flood Insurance 
Program (NFIP) that have had one or more claim payments for 
flood damages. The long-term goal of RFC is to reduce or 
eliminate claims under the NFIP through mitigation activities 
that are in the best interest of the National Flood Insurance Fund 
(NFIF). 

RFC funds may only mitigate structures that are located within a 
State or community that can not meet the cost share or 
management capacity requirements of the Flood Mitigation 
Assistance (FMA) program. 

Applications will be accepted for any insured property that has 
one or more claim payments for flood damages and is located 
within a State or community that can not meet the requirements 
of the FMA program for either cost share or capacity to manage 
the activities stipulations. RFC awards will prioritize projects 
that create the greatest savings to the NFIF based on a Benefit-
Cost Analysis (BCA). 

APPLICATION CONSIDERATION IN OTHER MITIGATION GRANT 
PROGRAMS: 

FEMA may determine that subapplications submitted under a 
specific grant program and not funded under the requested grant 
program may be considered by another mitigation grant program(s) 
when the following requirement is met: 

.. Applicants must include a statement in their grant 
application under the Comments for FEMA field 
indicating their interest to have its subapplications considered 
for another mitigation grant program (specify the additional 
mitigation grant program(s) and corresponding CFDA 
number(s)). 

FEMA may request additional information from the Applicant. The 
Applicant must provide all requested information within the 
specified timeframe. 

 

RFC GUIDANCE: 

RFC guidance document is available from any FEMA 
Regional Office or on the FEMA web page: 

http://www.fema.gov/government/grant/rfc/index.shtm

AVAILABILITY OF FUNDS 

The RFC program is subject to the availability of appropriation 
funding, as well as any directive or restriction made with 
respect to such funds. 

 

FUNDS: 

RFC grants are awarded nationally without reference to State 
allocations, quotas, or other formula-based allocation(s) of funds. 
The RFC program is subject to the availability of appropriation 
funding. 

 

ELIGIBLE ACTIVITIES: 

RFC funds are available for mitigation projects that: 
.. Acquire insured properties that have one or more claim 
payments for flood damages and demolish or relocate 

INELIGIBLE PROJECT ACTIVITIES: 
.. Mitigation plan development, update or amendment; 
.. Major flood control projects; 
.. Dry floodproofing of residential structures; 
.. Mitigation reconstruction; 
.. Applications involving any activities for which 
implementation has already been initiated or 
completed are not eligible for funding, and will not 
be considered; 
.. Phased or partial projects; 
.. Studies that do not result in a completed mitigation 
project; 
.. Flood studies or flood mapping; 
.. Projects that solely address maintenance or repairs 

KEY POINTS 

 

KEY POINTS 


structures, with conversion of property to deed-restricted open-
space use; 
.. Elevations; 

.. Dry Floodproofing of non-residential structures; 

.. Minor Localized Flood Control Projects (funding limited to 
$1M per project). 

 

COST-SHARE: 

All RFC grants are eligible for up to 100% Federal assistance. 

of existing structures, facilities, or infrastructure; 
.. Generators, and related equipment; 
.. Warning and alert notification systems; 
.. Response and communication equipment; 
.. Properties that are subject to pending litigation; 

.. Legal procedures related to litigation for an 
approved application or subapplication; 

.. Landscaping for ornamentation; and 

ELIGIBILITY REQUIREMENTS 

APPLICANT ELIGIBILITY: 

Only the following entities are eligible to apply to FEMA as 
Applicants: State emergency management agencies or a similar 
office of the State (i.e., the office that has primary emergency 
management or floodplain management responsibility); the District 
of Columbia; the US Virgin Islands; the Commonwealth of Puerto 
Rico; American Samoa; the Commonwealth of the Northern 
Mariana Islands; Guam; and Federally-recognized Indian Tribal 
governments. Each State, Territory, or Indian Tribal government 
shall designate one agency to serve as the Applicant for the RFC 
program. 

 

SUBAPPLICANT ELIGIBILITY: 

State-level agencies; Federally-recognized Indian Tribal 
governments; and local communities (to include State-recognized 
Indian tribes, authorized Indian Tribal organizations, and Alaska 
Native villages) are eligible to apply to the Applicant for assistance. 
Private individuals and Private Non-Profit (PNP) organizations are 
not eligible subapplicants; however, a relevant State agency or local 
community may apply to the Applicant for assistance to mitigate 
private or PNP structures. 

 

REDUCED CAPACITY REQUIREMENT: 

RFC funds may only be awarded if the Applicant has certified, 
either: 

.. The State and the community are not able to meet the 25% non-
Federal match that would otherwise make the activity eligible 
under the Flood Mitigation Assistance (FMA) program; or 

.. The State or community does not have the capacity to manage 
the activities under the FMA program. 

 

NFIP PARTICIPATION: 

All Applicants and subapplicants must be participating in 
the National Flood Insurance Program (NFIP), and must 
not be suspended or withdrawn from the NFIP. RFC 
funds shall not be awarded for activities in non-
participating communities. Properties in all RFC projects 
must be NFIP insured at the time of project application 
and maintained at least through completion of the 
mitigation activity.

 

MITIGATION PLAN REQUIREMENT: 

APPLICATION PROCESS 

APPLICATION PROCESS: 

Applicants must use the electronic grants (eGrants) management 
system: https://portal.fema.gov to submit a RFC grant application to 
include project and management cost subapplications. Only RFC 
grant applications submitted through the eGrants system will be 
accepted. If a subapplicant does not use the eGrants system, the 
Applicant must enter the subapplicants paper subapplication(s) into 
the eGrants system on their behalf using the Paper subapplication 
Intake function. Paper and project subapplications that follow the 
eGrants format are available in the eGrants system for subapplicants 
to use. Applicants must provide an original and two copies of any 
paper supporting documentation that cannot be electronically 
attached to the eGrants application (e.g., engineering drawings, 
photos, maps) to the appropriate Regional Office. However the 
entire application, including all paper documentation, must be 
received by the appropriate FEMA Regional office by the 
application deadline. Paper duplicates of attachments submitted 
with subapplications in eGrants are not necessary. 

APPLICATION PERIOD: 

Applicants must submit an FY 2008 RFC grant 
application to the appropriate FEMA Regional Office by 
January 31, 2008 at 11:59:59 p.m. Eastern Standard 
Time. 

 

eGRANTS TECHNICAL ASSISTANCE: 

FEMA will provide technical assistance regarding the 
eGrants system through the eGrants Helpdesk: 1-866-
476-0544 or mtegrants@dhs.gov. 

 

TECHNICAL ASSISTANCE HELPLINES: 

Technical assistance for Engineering Feasibility, Benefit-
Cost Analysis, and Environmental/Historic Preservation 
compliance is available through the Technical Assistance 
Helplines: 

Phone: 

(866) 222-3580 (toll free) 

E-mail: 

.. Site remediation of hazardous contaminants. 

KEY POINTS 

To be eligible for RFC grants, an eligible Applicant must 
have a FEMA-approved State Mitigation Plan (Standard 
or Enhanced) in compliance with 44 CFR PART 201. A 
local mitigation plan is not required to receive RFC 
funds.

KEY POINTS 


 

BENEFIT-COST ANALYSIS: 

A Benefit-Cost Analysis (BCA) is required for each project 
subapplication. Only FEMA-approved BCA methodologies may be 
used to meet this requirement. 

 

TECHNICAL ASSISTANCE: 

FEMA will provide technical assistance by answering questions 
about the RFC program, as well as providing general technical 
assistance related to project Engineering Feasibility, Benefit-Cost 
Analysis, and Environmental/Historic Preservation compliance. 

 

enghelpline@dhs.com

bchelpline@dhs.com

APPLICATION REVIEW & SELECTION 

APPLICATION REVIEW: 

FEMA will review each project subapplication to ensure the 
following: 

 
.. Eligibility of the Applicant/subapplicant 
.. Eligibility of proposed activities, properties and costs 
.. Completeness of the Scope of Work 
.. Completeness of the Cost Estimate and consistency with the 
Scope of Work 
.. Consistency of the proposed activity with the goals and 
objectives of the Applicants State/Indian Tribal hazard 
mitigation plan 
.. Feasibility and effectiveness of mitigation projects, including 
supporting documentation 
.. Benefit-cost ratio of 1.0 or greater for each project 
subapplication 

.. Technical accuracy, complete supporting documentation and 
source credibility of benefit-cost analysis for each project 
subapplication 

.. Supporting documentation and appropriate mitigation measures 
for environmental/historic preservation compliance 

.. Demonstrated reduced capacity or lack of non-federal cost 
share under FMA program for State or community 

 

Subapplications that do not satisfy the eligibility and completeness 
requirements will be removed from consideration. 

TECHNICAL REVIEW: 

Eligible and complete project subapplications will be 
forwarded to FEMA HQ where a technical review of 
BCA's will be conducted to verify cost-effectiveness for 
each project subapplication. 

 

APPLICATION RANKING: 

Eligible mitigation project subapplications will be ranked 
in the order of the greatest savings to the NFIF as 
demonstrated by the verified BCA. FEMA may also 
select individual properties from within a larger project, 
where appropriate to achieve the greatest savings to the 
NFIF. 

 

ENVIRONMENTAL/HISTORIC PRESERVATION REVIEW: 

FEMA will complete the environmental/historic 
preservation compliance review for selected projects for 
further review as part of pre-award activities. Funds 
may not be awarded and the project cannot be 
initiated until FEMA has completed the 
environmental/historic preservation review. 

 

AWARD PROCESS 

SELECTION/AWARD: 

FEMA will notify Applicants of project subapplications selected for 
award. FEMA Headquarters will grant awards for project 
subapplications based on the national ranking of projects and 
program priorities up to the amount of funds available. FEMA may 
select individual properties from within a project application for 
award, where appropriate to achieve the greatest savings to the 
NFIF. 

 

UNSUCCESSFUL APPLICATIONS: 

FEMA will notify Applicants of project subapplications that are not 
selected for award by the Approving Federal Official. 

PRE-AWARD: 

ehhelpline@dhs.com

KEY POINTS 

FEMA strongly encourages Applicants/subapplicants to 
coordinate with relevant State or Federal agencies as 
soon as possible in order to identify any environmental or 
historic preservation compliance issues associated with 
proposed projects. 

KEY POINTS 

Applicants with project subapplications selected for 
award will be notified of the date by which all pre-award 
activities must be completed. 

 

List of Acronym


SECTION 1 GRANT APPLICATION GUIDANCE 

 

1.1 PURPOSE 

The Repetitive Flood Claims (RFC) grant program provides funding to reduce or eliminate the 
long-term risk of flood damage to structures insured under the National Flood Insurance Program 
(NFIP) that have had one or more claim payments for flood damages. RFC funds may only 
mitigate structures that are located within a State or community that can not meet the 
requirements of the Flood Mitigation Assistance (FMA) program for either cost share or capacity 
to manage the activities. The long-term goal of the RFC program is to reduce or eliminate flood 
claims under the NFIP through mitigation activities that are in the best interest of the National 
Flood Insurance Fund (NFIF). 

 

1.1.1 APPLICATION CONSIDERATION UNDER OTHER MITIGATION 
GRANT PROGRAMS 

FEMA may determine that subapplications submitted but not funded under a specific grant 
program may be considered by another mitigation grant program(s) when the following 
requirement is met: 

.. Applicants must include a statement in their grant application under the 
Comments for FEMA field indicating their interest to have its subapplications 
considered for another mitigation grant program (specify the additional mitigation grant 
program(s) and corresponding CFDA number(s)). 

FEMA may request additional information from the Applicant. The Applicant must provide 
all requested information within the specified timeframe. Examples of other mitigations 
grant programs include the Pre-Disaster Mitigation Grant Program (PDM), and the Flood 
Mitigation Grant Program (FMA). This option is not available under the Severe 
Repetitive Loss (SRL) Program. 

 

1.2 AUTHORIZATION AND APPROPRIATION 

 

The RFC program is subject to the availability of appropriation funding, as well as any 
directive or restriction made with respect to such funds. 

 

1.2.1 AUTHORIZATION 

The RFC grant program was created pursuant to Section 1323 of the National Flood 
Insurance Act of 1968 (NFIA, or the Act), 42 U.S.C. 4030, as amended by the Bunning-
Bereuter-Blumenauer Flood Insurance Reform Act of 2004, Public Law 108-264, with the 
goal of reducing flood damages to individual properties for which one or more claim 
payments for losses have been made under flood insurance coverage and that will result in 
the greatest savings to the NFIF in the shortest period of time. The Catalog of Federal 
Domestic Assistance (CFDA) number is 97.092. 

 

 

 


1.2.2 APPROPRIATION 

The RFC program is subject to the availability of appropriation funding. RFC grants will be 
awarded on a national basis without reference to State allocations, quotas or other formula-
based allocation(s) of funds. The funding source for the RFC grant program is the NFIF. 

 

1.3 GRANT PROGRAM ELIGIBILITY 

 

1.3.1 ELIGIBLE PROPERTIES 

All currently NFIP-insured residential or non-residential (commercial) properties with one or 
more claims to the NFIP are eligible to apply for RFC funds. 

 

1.3.2 ELIGIBLE APPLICANTS 

Only the following entities are eligible to apply to FEMA for RFC grants: State emergency 
management agencies or a similar office of the State (i.e., the office that has primary 
emergency management or floodplain management responsibility); the District of Columbia; 
the US Virgin Islands; the Commonwealth of Puerto Rico; American Samoa; the 
Commonwealth of the Northern Mariana Islands; Guam; and Federally-recognized Indian 
Tribal governments. Each State, Territory, or Indian Tribal government shall designate one 
agency to serve as the Applicant for the RFC program. If an agency is not designated for any 
of these entities, a local community may apply directly to FEMA for assistance under 44 
CFR Part 78.14 Alternative Procedures. 

 

Consistent with FEMA policy and 44 CFR Government-to-Government Relations with 
American Indian and Alaska Native Indian Tribal Governments, published in the January 12, 
1999, issue of the Federal Register, Federally-recognized Indian Tribal governments may 
choose to apply for RFC grants either through the State as a subapplicant or directly to 
FEMA as an Applicant. This choice is independent of a designation under other FEMA 
grants and programs. Some State regulations prohibit the State from acting as an Applicant 
for an Indian tribe. In such cases, or if the Indian tribe chooses, the Indian Tribal government 
may act as an Applicant. If awarded, the Indian Tribal government therefore assumes the full 
responsibilities of a Grantee for the purposes of administering the grant. FEMA has 
determined that the unique status of Indian Tribal governments justifies providing this option 
to apply directly to FEMA. However, when legally permitted, Indian Tribal governments are 
encouraged to continue existing relationships with the State. 

 

1.3.3 ELIGIBLE SUBAPPLICANTS 

Only the following entities are eligible to apply through the Applicant for assistance: 
.. State-level agencies; 
.. Federally-recognized Indian Tribal governments including State-recognized Indian tribes, 
authorized Indian Tribal organizations, and Alaska Native villages; and 

.. Local communities. 

Certain non-participating political subdivisions (e.g., Councils of Governments, Regional 
Planning Commissions, or County governments) may apply and act as subgrantee on behalf 
of the NFIP-participating community in areas where the political subdivision provides zoning 
and building code enforcement, or planning and community development professional 


services for that community. Only those NFIP-participating communities or Federally-
recognized Indian tribal governments that are not suspended or withdrawn from the NFIP are 
eligible to receive RFC grant funds. Private non-profit (PNP) organizations and individuals 
are not eligible subapplicants; however, a relevant State agency or local community may 
apply to the Applicant for assistance to mitigate privately-owned or PNP-owned properties. 

 

1.3.4 PROGRAM REQUIREMENTS 

 

1.3.4.1 PLANNING REQUIREMENTS 

All Applicants must have a FEMA-approved State/tribal Standard or Enhanced hazard 
mitigation plan by the application deadline, to be eligible to apply for project grant 
funding under the RFC program in accordance with 44 CFR Part 201. 

 

A State, Indian tribal government or territory hazard mitigation plan that expires prior to 
the award of a grant or subgrant must provide a FEMA-approved hazard mitigation plan 
in accordance with 44 CFR Part 201 in order to receive grant funding. 

 

All activities submitted for consideration must be consistent with the Applicants 
State/tribal Standard or Enhanced Hazard Mitigation Plan. 

 

1.3.4.2 NATIONAL FLOOD INSURANCE PROGRAM (NFIP) 

All subapplicants must be participating in the NFIP, and must not be suspended or 
withdrawn from the NFIP, to be eligible to apply for RFC funds and to act as subgrantee. 
Certain non-participating political subdivisions (e.g., Councils of Governments, Regional 
Planning Commissions, or County governments, etc.) may apply and act as subgrantee on 
behalf of the NFIP-participating community in areas where the political subdivision 
provides zoning and building code enforcement, or planning and community 
development professional services for that community. RFC funds shall not be used to 
support project activities in communities that are not participating in the NFIP. 

 

Properties in all RFC projects must be NFIP insured at the time of project application and 
maintained at least through completion of the mitigation activity or, for acquisition 
projects, until the transfer of ownership. For structures that remain in the SFHA, flood 
insurance must be maintained for the life of the structure, regardless of ownership of such 
property. Minor physical flood mitigation projects that reduce localized flooding 
problems must reduce or eliminate the risk of flood damage to buildings, manufactured 
homes, and other structures insured under the NFIP. 

 

1.3.4.3 PRIVACY OF REPETITIVE LOSS DATA 

State NFIP Coordinators may access a version of BureauNet called Data Exchange. In 
addition, the State Hazard Mitigation Officer and other approved State staff, may access 
an internet portal called Simple Quick Access (SQANet) developed as part of the FEMA 
NextGen project. Both of these data systems allow the State to access and download 
current claims, policy and repetitive loss data. This will allow eligible RFC Applicants to 
identify properties eligible for mitigation under the RFC grant program. 

 


Communities cannot access either of these systems and it is the responsibility of State or 
FEMA Regional staff to provide claims, policy and repetitive loss property information 
to the communities. States may access this sensitive data and may provide it directly to 
community governments on the basis of their status as an approved category of users. 
Use of the data by this approved category of users is limited to engaging in flood plain 
management, improved real property acquisitions, and relocation projects that are 
consistent with the National Flood Insurance Program, and to further flood plain 
management and hazard mitigation goals of FEMA. These uses are authorized pursuant 
to notices published in the Federal Register, most recently on January 23, 2002 
(DHS/FEMA-008). State staff wishing to gain access to sensitive NFIP data may request 
a login ID and Password for SQANet by visiting http://www.nfipnextgen.com and then 
clicking on the SQANet Pilot link and then selecting the click here to sign up option. 

 

When BureauNet and SQANet records are accessed by States, they are advised of the 
sensitive nature of the information and the need to protect the release of the data to 
unauthorized users. When the data is released to a community by either the State or the 
FEMA Regions, the recipient must be notified in writing that the records relating to 
individuals and individual properties are being made available through the FEMA routine 
use policy for the specific purposes of mitigation planning, research, analysis and 
feasibility studies consistent with the NFIP and for uses that further the floodplain 
management and hazard mitigation goals of the States and FEMA. The records are 
protected pursuant to the Privacy Act of 1974 (5 USC 552a) and must not be publicly 
disclosed. FEMA shares this information at its discretion and may choose not to provide 
this information in the future to States or communities if it finds unauthorized uses of this 
information have been made. 

 

1.3.4.4 REDUCED CAPACITY REQUIREMENT 

All RFC grant applications must demonstrate that the proposed activities cannot be 
funded under the Flood Mitigation Assistance (FMA) program due to lack of State or 
local capacity, which includes either inability to manage the subgrant or lack of 25% 
match. Applicants are encouraged to conduct outreach to potential subapplicants that 
may have previously been unable to apply for FMA or other mitigation programs due to 
their inability to provide a match or their insufficient capacity to manage a grant. FEMA 
may contribute up to 100% of the total amount approved under the RFC grant award to 
implement approved activities, if the Applicant has demonstrated either of the following: 
.. The State and the community are not able to meet the 25% non-Federal match that 
would otherwise make the activity eligible under the FMA program. The Applicant 
and the subapplicant must provide certification (i.e., signed letter or other document 
from an authorized government official) that they can not meet this requirement, and 
the activity could therefore not be funded under the FMA program through the annual 
State FMA allocations. If a project has been previously submitted (within one year) 
for funding under FMA and was not funded, the State or community must explain and 
certify why the 25% non-Federal match is no longer available for this project; or 
.. The State or community does not have the capacity to manage the activities under the 
FMA program. The Applicant or subapplicant must provide certification (i.e., signed 
letter or other document from an authorized government official) that the State or 


community does not have the capacity to manage the proposed activities. If a project 
has been previously submitted (within one year) for funding under FMA and was not 
funded, the State or community must explain and certify why it no longer has the 
capacity to manage this project. Lack of capacity may be shown to be: 
1) Lack of adequate resources (staff or funding) to successfully administer and 
manage the grant activity; or 

2) Meeting the definition of small, impoverished community. 

If claiming reduced capacity as a small, impoverished community, the subapplicant 
MUST meet ALL of the following criteria: 
.. Must be a community of 3,000 or fewer individuals that is identified by the State as a 
rural community, and is not a remote area within the corporate boundaries of a larger 
city; 
.. Must be economically disadvantaged, with residents having an average per capita 
annual income not exceeding 80% of the national per capita income, based on best 
available data. (The Department of Commerce Bureau of Economic Analysis (BEA) 
website states that the per capita personal income for the United States in 2006 was 
$31,794.) More up-to-date information may be used. Please see the BEA web site at: 
http://www.bea.gov; 
.. Must have a local unemployment rate that exceeds by one percentage point or more 
the most recently reported, average yearly national unemployment rate. (According 
to the US Bureau of Labor Statistics (USBL), the current average unemployment rate 
for 2006 is 4.6%. For up-to-date information, please see the USBL web site located 
at: http://stats.bls.gov; and, 

.. Must meet any other factors as determined by the State/Indian Tribal 
government/Territory in which the community is located. 

See Table 1.3.4.4, RFC Reduced Capacity Requirement, for further clarification. 


Table 1.3.4.4, RFC REDUCED CAPACITY REQUIREMENT 
LOCALSTATENotEligible for RFC 
fundsEligible forRFC fundsEligible forRFC fundsState is able to 
provide a 25% matchLocal is able to 
provide the remainder 
of the matchLocal is not able to 
provide the remainder 
of the matchLocal is / is not ableto provide matchState is able to 
provide less than full 
25% match 
(e.g., State has policy 
of providing 12.5%)
State is not able to 
provide a 25% matchLocal is not able to 
provide the full matchLocal is able to 
provide the full matchState does not have 
the capability to 
manage grant on 
behalf ofSub-applicantState has the 
capability to manage 
grant on behalf of 
Sub-applicantOR Sub-applicant 
does not have 
capability to manage 
grantAND Sub-applicant 
has capability to 
manage grantNotEligible for RFC 
funds


 

1.3.4.5 NON-DISCRIMINATION 

Like other FEMA mitigation programs, the RFC program must be administered in an 
equitable and impartial manner, without discrimination on the grounds of race, color, 
religion, nationality, sex, age, or economic status. The RFC program complies with 
Section 308 of the Stafford Act and Title VI of the 1964 Civil Rights Act. All 
Applicants/Grantees must comply with Title VI, including State and local governments 
distributing Federal assistance. 

 

In implementing the RFC program, Grantees and subgrantees will ensure that no 
discrimination is practiced. Applicants must consider fairness, equity, and equal access 
when prioritizing and selecting project subapplications to submit with their RFC 
application. Subgrantees must ensure fairness and equal access to homeowners and 
individuals that benefit from grant activities. 

 

1.3.4.6 COST-EFFECTIVENESS 

Project subapplications must demonstrate cost-effectiveness through a BCR of 1.0 or 
greater (See Section 2.6, Cost Effectiveness). 

 

1.3.4.7 GEOCODING MITIGATION PROJECTS 

The location of all approved mitigation projects funded by the RFC program must be 
geocoded using standard datum prior to award (See Section 2.10, FEMA Pre-award 
Activities). The guidance for Geocoding Mitigation Data is available online from the 
FEMA Information Resources Library: 
http://www.fema.gov/library/viewRecord.do?id=1849 and from the FEMA Regional 
Office. 

 

1.3.5 PROGRAM RESTRICTIONS 

 

1.3.5.1 DUPLICATION OF PROGRAMS 

FEMA will not provide assistance under the RFC program for activities that it determines 
another Federal program has a more specific or primary authority to provide. FEMA also 
will not provide assistance for the Applicant or subapplicants legal obligations. FEMA 
may disallow or recoup amounts that duplicate other authorities. 

 

1.3.5.2 DUPLICATION OF BENEFITS 

FEMA will not provide assistance under the RFC program for activities that duplicate 
benefits received by or available to Applicants, subapplicants and other project 
participants from insurance, other assistance programs, legal awards, or any other source 
to address the same purpose. This includes projects previously submitted under other 
FEMA Hazard Mitigation Grant Programs. Such individual or entity must notify the 
Grantee and FEMA of all benefits that it receives or anticipates from other sources for the 
same purpose, and must seek all such benefits available to them. FEMA will reduce the 
RFC grant by the amounts available for the same purpose from another source. If FEMA 
provides assistance under this program when other benefits are available, the Grantee will 
be liable to FEMA for any duplicative amounts that are received from other sources, and 
must reimburse FEMA for such amounts. 


 

FEMA also will not provide assistance for the Applicant or subapplicants legal 
obligations, such as those imposed by a legal settlement, court order or State law. 

 

1.3.5.3 CONFLICT OF INTEREST 

Applicants and subapplicants must avoid conflicts of interest. Subapplicants must 
comply with the procurement guidelines at 44 CFR Part 13.36. Among other 
requirements, 44 CFR Part 13.36 urges subapplicants to avoid situations where local 
officials with oversight authority might benefit financially from the grant disbursement. 
In addition, Part 13.36 requires the subgrantee to also ensure that their procurements are 
subject to full and open competition and undergo a cost or price analysis before award. 
Applicants must comply with guidelines for awarding and administering subgrants at 44 
CFR Part 13.37. 

 

1.3.5.4 COST OVERRUNS AND COST UNDER-RUNS 

In the RFC program the Federal award amounts are final. There will be no additional 
FEMA funding beyond the initial award. FEMA will not cover the cost of overruns 
associated with grant activities. All costs for which funding is requested must be 
included in the original grant applications budget section. 

 

Cost under-runs (i.e., unexpended funds) remaining after the expiration of the 
performance period must be reported to FEMA for de-obligation. Cost under-runs from 
one subapplication can not be used to meet another subapplications cost overrun. 

 

1.3.5.5 PRE-AWARD COSTS 

Eligible costs incurred prior to the date of the grant award, but after the RFC application 
period has opened, are identified as pre-award costs. FEMA may allow pre-award costs 
at its discretion and as funds are available. Applicants and subapplicants may be 
reimbursed for pre-award costs incurred after the publication of the RFC guidance for 
activities directly related to the development of the project proposal. Activities may 
include, but are not limited to, development of the BCA, environmental/historic 
preservation data and documentation, and engineering design. Pre-award costs must be 
identified as separate line items in the Cost Estimate for the project subapplication or they 
will not be considered. Pre-award costs associated with the implementation of the project 
started prior to award will not be eligible. 

 

1.4 ELIGIBLE ACTIVITIES AND ASSOCIATED COSTS 

Mitigation projects must be long-term, feasible, and meet all requirements referenced in the RFC 
Guidance. Projects also must demonstrate cost-effectiveness. 

 

The following are eligible activities for the RFC program: 
.. Mitigation project activities (See Section 2, Mitigation Project Subapplication Guidance); 
and 

.. Applicant management costs (See Section 1.6, Applicant Management Costs). 

 


1.5 INELIGIBLE ACTIVITIES 

Mitigation project subapplications must meet all requirements referenced in the RFC Guidance. 
Ineligible project activities are listed in Section 2.2, Ineligible Project Activities and Costs. 

 

1.6 APPLICANT MANAGEMENT COSTS 

Applicants may request a maximum of up to 10% of the total funds requested in their RFC grant 
application budget for management costs to support the project subapplications. Applicants 
requesting management costs MUST itemize these costs separately from the project 
subapplications through a Management Costs subapplication, or the funds requested will 
not be considered. Eligible management costs may include: 
.. Solicitation, review, and processing of RFC project subapplications and subgrant awards; 
.. Technical assistance to subapplicants regarding Benefit-Cost Analysis and 
Environmental/Historic Preservation documentation; 
.. Geocoding mitigation projects selected for further review (See Section 2.3.7, Geocoding 
Requirements); 
.. Managing grants (e.g., quarterly reporting and close-out); 
.. Technical monitoring (e.g., site visits, technical meetings); and 

.. Staff salary costs directly related to performing the activities listed above. 

Management costs must be consistent with Office of Management and Budget Circular A-87, 
Cost Principles for State and Local Governments. Indirect costs, if requested, must be included 
as part of the Applicant management costs, not to exceed 10% of the total amount awarded for 
project subgrants. There will be no exception to permit the increase in Applicant management 
costs. Indirect costs must be supported with a current Indirect Cost Rate approved by a Federal 
Cognizant Agency and submitted with the application. 

 

1.6.1 PRE-AWARD MANAGEMENT COSTS 

Eligible management costs incurred prior to the date of the grant award, but after the RFC 
application period has opened, are identified as pre-award management costs. FEMA may 
allow pre-award management costs at its discretion and as funds are available. Applicants 
and subapplicants may be reimbursed for pre-award management costs incurred after the 
publication of the RFC guidance for activities directly related to the development of the 
project proposal. Pre-award management costs must be identified as separate line items in 
the Cost Estimate for the project subapplication or they will not be considered. Pre-award 
management costs associated with the implementation of the project started prior to award 
will not be eligible. 

 

1.6.2 SELECTION AND AWARD 

Applicant management costs may be approved for up to 10% of the total amount awarded for 
the Applicants project subgrants, or the amount of management costs requested by the 
Applicant, whichever is less. There are no exceptions. If the Applicant is also the 
subapplicant, the Applicant may not request subgrantee management costs in their own 
project subapplication under any circumstance (See Section 2.5.3, Subapplicant Management 
Costs). Applicants who are not awarded RFC funds will not receive reimbursement for 
management costs. 


 

1.7 APPLICATION PROCESS 

 

1.7.1 APPLICATION PERIOD 

The opening of the RFC application period will be posted on FEMAs website: 
http://www.fema.gov/government/grant/rfc/index.shtm. RFC grant applications must be 
submitted to FEMA by the application deadline. Applications, including all supporting 
documentation, will not be accepted after January 31, 2008, at 11:59:59 p.m. Eastern Standard 
Time. 

 

Subapplicants must consult the official designated point of contact for their Applicant State/ 
Tribe/Territory for more information regarding the application process. Applicants are 
strongly encouraged to establish an earlier deadline for subapplicants to submit 
subapplications in order to allow time to review and prioritize subapplications as well as 
enter any paper subapplications into FEMAs Electronic Grants (eGrants) System. 

 

1.7.2 FEMAS ELECTRONIC GRANTS SYSTEM 

 

Applicants must use the electronic grants (eGrants) management system: 
https://portal.fema.gov to submit a RFC grant application to include project, and management 
cost subapplications. Only grant applications submitted through the eGrants system will be 
accepted. If a subapplicant does not use the eGrants system, the Applicant must enter the 
subapplicants paper subapplication(s) into the eGrants system on their behalf using the 
Paper subapplication Intake function or the subapplication will not be eligible for further 
consideration. Paper project subapplications that follow the eGrants format are available in 
the eGrants system for subapplicants to use. Applicants must provide an original and two 
copies of any paper supporting documentation that cannot be electronically attached to the 
eGrants application (e.g., engineering drawings, photos, maps) to the appropriate Regional 
Office. However, the entire application, including all paper documentation, must be received 
by the appropriate FEMA Regional office by the application deadline. Paper duplicates of 
attachments submitted with subapplications in eGrants are not necessary. 

 

FEMA requires Applicants to use eGrants for the RFC program as it facilitates the 
competitive process and simplifies the selection and award process. FEMA has developed 
the eGrants system to meet the intent of the eGovernment initiative authorized by Public Law 
106107, passed on November 20, 1999. This initiative requires that all government 
agencies both streamline the grant application processes and provide the means to 
electronically create, review, and submit a grant application via the Internet. 

 

FEMAs eGrants system incorporates all elements of the RFC application in a user-friendly 
format for both Applicant and subapplicant use. The electronic process replaces the paper-
based process in that subapplicants project subapplications may be electronically submitted 
to the Applicant for review and approval in eGrants. Then, the Applicant must attach the 
subapplicants subapplications to a grant application along with the Applicants own project 
and management cost subapplications, if any, for submission to FEMA. FEMA uses the 
eGrants system to monitor ongoing performance, manage the flow of Federal funds, and 
close out the grant award when all work is completed. 


 

In addition to the online help available within the eGrants system and the Grantee and 
subgrantee Quick Reference Guides available at https://portal.fema.gov, FEMA has 
established an eGrants Helpdesk to provide technical assistance to Applicants and 
subapplicants completing subapplications and grant applications in the eGrants system. The 
eGrants Helpdesk can be reached via telephone: 1 (866) 476-0544 or e-mail: 
mtegrants@dhs.gov. Standard hours of operation are 9 a.m. to 5 p.m. Eastern Time. Hours 
may be extended during the application period. 

 

1.7.3 APPLICANT REVIEW OF SUBAPPLICATIONS 

Applicants should review all project sub-applications for eligibility, completeness, and 
consistency with the Applicants State Standard/Enhanced hazard mitigation plan (See 
Section 2.3, Mitigation Project Requirements) prior to inclusion in the grant application. 

 

1.7.4 GRANT APPLICATION CHECKLIST 

Applicants must provide the following in their RFC grant application in order to be eligible 
for consideration: 
.. Applicant Information: Provide name, Grant type, and State of the Applicant, State and 
Federal tax numbers, Federal Employer Identification Number, DUNS number. Indicate 
whether the Applicant has a Smartlink account, whether the application is subject to 
review by the Executive Order 12372 process (select Program is not covered by E.O. 
12372 in eGrants), and whether the Applicant is delinquent on any Federal debt; 
.. Contact Information: Provide the name, agency, and address for the point of contact for 
the grant application; 
.. Subgrant applications: Include the total number of subapplications for eligible project 
activities that the Applicant has reviewed and approved. A separate management cost 
subapplication must be submitted for Applicant management costs; 
.. Schedule: Provide the title of the grant application and the overall projected performance 
period for the grant, and ensure that the work schedule for each subapplication included 
with the grant application is appropriate (See Section 2.4, Scope of Work); 
.. Budget: Ensure that the requested Cost Estimate for each subapplication is acceptable 
and provide the grant budget class for each item. Provide an Approved Indirect Cost 
Agreement, if applicable; 
.. Properties: Ensure that all of the properties in each project subapplication are included 
and eligible for funding, if applicable; and 
.. Assurance and Certifications: If applicable in your Applicant State/Tribe/Territory, 
complete the Summary Sheet for Assurances and Certification, FEMA Form 20-16; 
Assurances-Non-Construction Programs, FEMA Form 20-16A; Assurances-Construction 
Programs, FEMA Form 20-16B; Certification Regarding Lobbying; Debarment, 
Suspension and Other Responsible Matters; Drug-Free Workplace Requirements, FEMA 
Form 20-16C; and Disclosure of Lobbying Activities, Standard Form LLL. 

.. Match Sources: In the Match Sources comment section of the Management Costs Sub-
application Form, the Applicant must certify that properties included in the 


subapplication for the current RFC application period are not included or approved in any 
other FEMA Mitigation Grant application or award. 

1.8 COST SHARE REQUIREMENTS 

Approved RFC activities are eligible for up to 100% Federal funding for the amount approved 
under the grant award, with no non-Federal match required. Like other FEMA mitigation grant 
funds, RFC funds retain their Federal identity and cannot be used as cost share for another 
federally funded activity. 

 

If non-Federal funds are provided to match part of the total project cost, the Applicant shall 
follow the requirements for Matching or Cost Sharing under 44 CFR Part 13.24, Uniform 
Administrative Requirements for Grants and Administrative Agreements for State and Local 
Governments. 

 

1.9 FEMA REVIEW AND AWARDS

 

1.9.1 FEMA REVIEW 

FEMA will review all project subapplications to ensure eligibility and completeness (See 
Section 2, Mitigation Project Subapplication Guidance). Project subapplications that do not 
satisfy either the eligibility or completeness requirements will be removed from 
consideration. 

 

1.9.2 TECHNICAL REVIEW 

Eligible and complete project subapplications will be forwarded to FEMA HQ where a 
technical review of BCAs will be conducted to verify cost-effectiveness for each property. 
Project subapplications that do not meet cost-effectiveness requirements will be removed 
from consideration and will not be selected. 

 

Projects involving relocation of structures from acquired property will be evaluated for 
engineering feasibility. 

 

 

1.9.3 NATIONAL RANKING & SELECTION 

FEMA will rank all eligible mitigation project subapplications on the basis of the greatest 
savings to the NFIF as demonstrated by the verified project aggregate BCA. All projects will 
be ranked from highest verified BCA to lowest verified BCA. The Approving Federal 
Official at FEMA Headquarters will consider the National Ranking and program priorities in 
determining which projects are selected for award up to the amount of funds available for the 
RFC program. 

 

Eligible project subapplications not selected for RFC grant awards during the current cycle 
will be placed on a waiting list and may be considered for RFC grant awards during the next 
RFC program funding cycle. 

 

1.9.4 FEMA PRE-AWARD ACTIVITIES 

FEMA will work with Applicants who have approved project subapplications to implement 
required pre-award activities prior to grant award, such as verifying Applicant and 


subapplicant commitments and understanding of grant terms. In addition, FEMA will ensure 
that the Applicant has met all reporting requirements for FEMA-State grant awards currently 
in progress. FEMA may, at its discretion, request information or documentation from 
Applicants to support certain project subapplications as part of pre-award activities (See 
Section 2.10, FEMA Pre-award Activities). Applicants must respond to requests for 
information from the FEMA Regional Offices regarding their project subapplications within 
the specified timeframe. Applicants with project subapplications selected for award will be 
notified of the date by which all pre-award activities must be completed. Please note that 
pre-award activities are not considered notification of an award. 

 

FEMA will complete the environmental/historic preservation compliance review for projects 
as part of pre-award activities. Subgrantees shall not initiate grant activities until FEMA has 
completed the environmental/historic preservation review. FEMA may, at its discretion, 
request information or documentation from Applicants to resolve outstanding administrative 
or procedural requirements as part of its pre-award activities. Additional compliance 
information for the environmental/historic preservation review is available at 
http://www.fema.gov/government/grant/resources/index.shtm. 

 

1.9.5 AWARDS 

FEMA will provide an award package to Applicants for approved subapplications once pre-
award activities are completed. The award package must be signed by the Applicant and 
returned to FEMA before funds can be awarded. The Applicant must agree to abide by the 
grant award terms and conditions as set forth in this Guidance and in the RFC Agreement 
Articles (Attachment I) available on FEMAs web page: 
http://www.fema.gov/government/grant/rfc/index.shtm or from the FEMA Regional Offices. 

 

1.9.6 NOTIFICATION OF STATUS OF SUBAPPLICATIONS 

FEMA will notify Applicants of project subapplications that do not satisfy completeness and 
eligibility requirements; project subapplications that do not meet cost-effectiveness or 
feasibility; and project subapplications that are not selected for award by the Approving 
Federal Official. 

 

FEMA will notify Applicants of project subapplications that were eligible, but not selected 
for RFC grant awards due to RFC program funding limitations. These subapplications will 
be placed on a waiting list and may be considered for RFC grant awards during the next RFC 
program funding cycle. 

 

1.9.7 RECONSIDERATION 

At its discretion, FEMA may review a decision regarding a project subapplication that does 
not meet RFC requirements only where there is an indication of material, technical, or 
procedural error that may have influenced FEMAs decision. As RFC grants are awarded on 
a competitive basis, FEMA will not consider new information provided in the request for 
reconsideration. FEMA encourages Applicants to incorporate any new information into 
applications for future grant cycles. There will be no reconsideration regarding the amount 
of Applicant management costs. In addition, Applicants who are not awarded any RFC funds 
may not receive reimbursement for management costs. 

 


Applicants must send requests for reconsideration based upon material, technical, or 
procedural error to the FEMA Regional Administrator within 60 calendar days from the date 
of the FEMA notification letter to the Applicant. The Regional Administrator will analyze 
the reconsideration request and make a recommendation to the Assistant Administrator of the 
Mitigation Directorate or his designee. FEMAs decision to uphold or overturn a decision 
regarding a subapplication that does not meet RFC requirements is final. 

 

A small percentage of funds will be set aside to fund additional project subapplications after 
reconsideration requests have been analyzed. FEMA may convene a panel to determine the 
National Evaluation Score, if necessary, for any subapplications that FEMA overturns a 
decision. Overturned subapplications and the remaining eligible project subapplications will 
be sorted by National Evaluation Score, and the highest scored subapplications will be 
selected for further review up to the amount of funds available. Remaining funds may be 
used to fund additional eligible subapplications on the waiting list or returned to the National 
RFC Fund for use in the next grant cycle. 

 

1.10 PERFORMANCE PERIOD 

The performance period is the period of time during which the Grantee is expected to complete 
the grant activities and to incur and expend funds approved for the RFC grant. The performance 
period for the grant shall begin on the date that the grant is awarded and end on the last day of 
the performance period of the longest subgrant awarded to the Grantee. The performance period 
is specified in the RFC Agreement Articles (Attachment I), available on FEMAs web page: 
http://www.fema.gov/government/grant/rfc/index.shtm or from the FEMA Regional Offices. 

 

The performance period for the grant shall begin on the date that the grant is awarded and end on 
the last day of the performance period of the longest subgrant awarded to the Applicant. Project 
subgrants may not be awarded with a performance period exceeding three years. Project 
subapplications that propose a work schedule in excess of three years will not be accepted. 

 

The Grantee has up to 90 days following the expiration of the performance period to liquidate 
valid expenditures incurred during the performance period. Cost under-runs remaining after the 
performance period expiration date must be reported to FEMA for de-obligation. 

1.11 EXTENSIONS 

Requests for extensions to the performance period will be considered but will not be approved 
automatically. In accordance with FEMAs Financial and Acquisition Management Division 
Extension Policy, the Regional Office may extend the performance period up to one year. 
Requests for a period of performance extension must be submitted in writing to the Regional 
Administrator and must be supported by adequate justification in order to be processed. This 
justification is a written explanation of the reason or reasons for an extension and must 
demonstrate that work is in progress and will be completed within the extended period of 
performance. The justification must address the following areas to enable the review of 
extension request: 
.. Submission Date: The request must be submitted at least 60 calendar days prior to the 
expiration date of the performance period; 
.. Reason for Delay: Identify the status of the activity, including the original approved period 
of performance, and give a brief description for the delay (i.e., weather conditions); 


.. Budget: Identify the remaining funds, both FEMA share and cost share match, available for 
the extended period and outline how the funds will be used. Identify sources of additional 
funding if remaining FEMA funds and cost share will not support the extension request; 
.. Plan for Completion: Identify the objectives necessary to complete the activity, completion 
date for each objective, and list the position/person responsible for oversight of completion of 
the activity; 
.. Completion Date: Identify the projected completion date (new period of performance end 
date) for the activity; and, 

.. No change of scope: Provide a certification that the activity will be completed within the 
extended period without any modification to the original Scope of Work approved by FEMA. 

If a second performance period extension becomes necessary, then the Grantee must submit an 
additional formal written request to the FEMA Regional Administrator. As with the first request, 
the second extension request must be made at least 60 calendar days prior to the expiration of the 
period of performance and must include a justification for the extension that addresses the items 
noted above. The Regional Office will make a recommendation and submit the second request 
to the Chief Procurement Official at FEMA Headquarters, who will review the request in 
coordination with the Headquarters Mitigation Directorate. 

 

Should any subgrant performance period be extended past the grant performance period, the 
grant performance period would be extended as well. This grant extension would be established 
so that all completed subgrants are closed out within their individual performance periods. 

 

1.12 REPORTING REQUIREMENTS 

The following reports are required from Grantees: 

 

1.12.1 FEDERAL CASH TRANSACTION REPORTS 

If the Grantee uses the Department of Health and Human Services (DHHS), Division of 
Payment Management, Payment Management System-SMARTLINK, the Grantee shall 
submit to FEMA a copy of the SF 272, Federal Cash Transaction Report submitted to the 
Department of Health and Human Services (DHHS). 

 

1.12.2 FINANCIAL STATUS REPORTS 

The Grantee shall submit Financial Status Reports, FF 20-10, to the FEMA Regional Office 
within 30 days from the end of the first Federal quarter following the initial grant award. The 
Regional Administrator may waive the initial report. The Grantee shall submit quarterly 
financial status reports thereafter until the grant ends. Reports are due on January 30, April 
30, July 30, and October 30. 

 

Financial Quarterly Reports will be available for completion in the eGrants system. 
Financial reports must include the activity name or other identification, expenditures, and 
payment-to-date information (reference 44 CFR Part 13.40, Monitoring and Reporting for 
additional information). 

 

Note: The Regional Administrator may suspend drawdowns from the HHS/Payment 
Management System-SMARTLINK if quarterly financial reports are not submitted on time. 


 

1.12.3 PERFORMANCE REPORTS 

The Grantee shall submit performance reports for each grant award to the FEMA Regional 
Office within 30 days from the end of the first Federal quarter following the initial grant 
award. The Regional Administrator may waive the initial report. The Grantee shall submit 
quarterly performance reports thereafter until the grant ends. Reports are due on January 30, 
April 30, July 30, and October 30. 

 

Quarterly Performance Reports will be available for completion in the eGrants system. 
Performance/progress reports must include the activity name or other identification as well 
as: 
.. Describe significant activities and developments that have occurred that show 
performance during the quarter, including a comparison of actual accomplishments to the 
objectives established in the subapplication; 
.. Indicate whether completion of work is anticipated within the performance period. If not, 
describe any problems, delays, or adverse conditions that will impair the ability to meet 
the stated objectives in the subapplication; and 

.. Indicate whether cost under-run/cost overrun, change of scope request, or request for 
extension of performance period is anticipated. 

1.12.4 FINAL REPORTS 

The Grantee shall submit a Final Financial Status Report and Performance Report within 90 
days from Grant Award Performance Period expiration date, per 44 CFR Part 13.50. 

 

1.13 CLOSEOUT 

The Grantee has up to 90 days following the expiration of the grant performance period to 
liquidate valid expenditures incurred during the performance period. Cost underruns remaining 
after the performance period expiration date must be reported to FEMA for de-obligation. 

 

1.14 REGIONAL CONTACT INFORMATION 

Contact information for FEMA Regional Offices is provided on the FEMA website: 
http://www.fema.gov/about/contact/regions.shtm and also is listed here for your information. 

 

FEMA Region I - Serving Connecticut, Maine, Massachusetts, New Hampshire, Rhode 
Island, and Vermont: 99 High Street, 6th Floor, Boston, MA 02110-2356. (617) 956-7506 

 

FEMA Region II - Serving New York, New Jersey, Puerto Rico, and the US Virgin Islands: 
26 Federal Plaza, Suite 1337, New York, NY 10278-0001. (212) 680-3600 

 

FEMA Region III - Serving the District of Columbia, Delaware, Maryland, Pennsylvania, 
Virginia, and West Virginia: 615 Chestnut Street, One Independence Mall, Sixth Floor, 
Philadelphia, PA 19106-4404. (215) 931-5608 

 

FEMA Region IV - Serving Alabama, Florida, Georgia, Kentucky, Mississippi, North 
Carolina, South Carolina, and Tennessee: 3003 Chamblee Tucker Road, Atlanta, GA 30341-
4112. (770) 220-5200 


 

FEMA Region V - Serving Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin: 
536 South Clark Street, 6th Floor, Chicago, IL 60605-1523. (312) 408-5500 

 

FEMA Region VI - Serving Arkansas, Louisiana, New Mexico, Oklahoma, and Texas: 800 
North Loop 288, Denton, TX 76209-3698. (940) 898-5399 

 

FEMA Region VII - Serving Iowa, Kansas, Missouri, and Nebraska: 9221 Ward Parkway, 
Suite 300, Kansas City, MO 64114-3372. (816) 283-7002 

 

FEMA Region VIII - Serving Colorado, Montana, North Dakota, South Dakota, Utah, and 
Wyoming: Denver Federal Center, Building 710, Box 25267, Denver, CO 80255-0267. 
(303) 235-4800 

 

FEMA Region IX - Serving Arizona, California, Hawaii, Nevada, the Territory of American 
Samoa, the Territory of Guam, and the Commonwealth of the Northern Mariana Islands: 
1111 Broadway Street, Suite 1200, Oakland, CA 94607-4052. (510) 627-7100 

 

FEMA Region X - Serving Alaska, Idaho, Oregon, and Washington: Federal Regional 
Center, 130 228th Street, SW, Bothell, WA 98021-9796. (425) 487-4600 

 


SECTION 2 MITIGATION PROJECT SUBAPPLICATION GUIDANCE 

 

The purpose of the RFC program is to fund mitigation activities that reduce flood damages and, 
consequently, flood claim payments in the order that will result in the greatest savings to the 
NFIF in the shortest period of time. Other benefits of RFC mitigation projects include saving 
lives and reducing disaster housing and emergency response expenses. Most importantly, 
communities and their residents will be safer from flood hazards. 

 

RFC grant applications must provide sufficient information for FEMA to determine the 
eligibility of each proposed activity for RFC funds, and to prioritize projects in the order that will 
result in the greatest savings to the NFIF in the shortest period of time. The Mitigation Project 
Subapplication Guidance identifies how proposed activities will be reviewed to ensure that all 
grants awarded under the RFC meet the intent of the authorizing legislation of the NFIA. Any 
proposed activity submitted without enough information for FEMA to determine eligibility and 
priority for funding will not be considered for funding. 

 

2.1 ELIGIBLE PROJECT ACTIVITIES 

Eligible RFC activities are limited to the mitigation of residential or non-residential 
(commercial) NFIP-insured properties that have had one or more claims for flood damages. 

 
Eligible activities include: 
.. Acquisitions/Relocations: The acquisition of the structure and underlying real property for 
the purpose of creating open space, demolition or relocation of the structure, and conversion 
of the property to deed restricted open space uses in perpetuity. The relocation of existing 
residential structures must be to areas outside of the SFHA or local regulatory floodplain, 
outside of any regulatory erosion zones, and in conformance with any other applicable State 
or local land-use regulations; 
.. Elevations: The elevation of existing structures and elevation to at least the BFE or an ABFE 
or higher if required by any State or local ordinance, and in accordance with criteria 
established in this Guidance. The techniques used for elevating structures in accordance with 
FEMA requirements can be found at: 
http://www.fema.gov/government/grant/mitmeasures/elevate.shtm; 
.. Dry Floodproofing: Floodproofing of existing non-residential structures in accordance with 
the requirements of the NFIP or higher standards if required by FEMA or if required by any 
State or local ordinance, and in accordance with criteria established by the Administrator. 

.. Minor Localized Flood Control Projects: These projects may include the installation or 
modification of culverts and floodgates; the creation of small retention and detention basins; 
and upgrade of culverts to bridges. Minor localized flood control projects must not duplicate 
the flood prevention activities of other Federal agencies. 

At least 50% of the structures directly benefiting from the mitigation activity must be 
properties that are both NFIP insured and have one or more claims to the NFIP. 


Documentation must be provided in the subapplication that identifies all properties that will 
benefit from this activity and specifically identifies the RFC properties. 

Funding is restricted to a maximum of $1 Million for minor localized flood control projects. 

2.2 INELIGIBLE PROJECT ACTIVITIES AND COSTS 
Certain project activities and their associated costs are not eligible. The following project 
activities are not eligible for the RFC grant program: 
.. Mitigation plan development, update or amendment; 
.. Major flood control projects such as the construction, demolition, or repair of dams, dikes, 
levees, floodwalls, seawalls, groins, jetties, breakwaters, waterway channelization, and 
erosion projects related to beach nourishment or renourishment; 
.. Dry floodproofing of any residential structures; 
.. Phased or partial project that is dependent on another phase or part to be effective and/or 
feasible; 
.. Mitigation reconstruction - any mitigation activities involving demolition of an existing 
structure (i.e., commercial or residential building, publicly or privately owned) and building a 
new structure (formerly known as demolition/rebuild); 
.. Applications involving any activities for which implementation has already been initiated or 
completed are not eligible for funding, and will not be considered; 
.. Studies that do not result in a completed mitigation project (e.g., engineering designs, 
feasibility studies, or drainage studies that are not integral to the proposed project); 
.. Flood studies or flood mapping (i.e., general hydrologic and hydraulic studies/analyses not 
integral or necessary for project design or feasibility determination); 
.. Projects that solely address operation, maintenance, or repairs of existing structures, facilities 
or infrastructure (e.g., dredging, debris removal, bridges and dam repair/rehabilitation); 
.. Generators, and related equipment, such as generator hook-ups, for non-critical facilities or 
as a stand-alone activity; 
.. Warning and alert notification systems (e.g., NOAA weather radios); 
.. Response and communication equipment; 
.. Landscaping for ornamentation (trees, shrubs, etc.); 
.. Site remediation of hazardous contaminants; 

.. Properties that are subject to pending litigation; and 

.. Legal procedures related to litigation for an approved application or subapplication. 

2.3 MITIGATION PROJECT REQUIREMENTS 

 

2.3.1 FEASIBILITY AND EFFECTIVENESS REQUIREMENT 

Mitigation projects funded by the RFC program must be both feasible and effective at 
mitigating the hazard(s) for which the project was designed. To determine both feasibility 


and effectiveness, FEMA will use the information provided in the project subapplication, 
including the SOW and Cost Estimate sections, as well as any supporting documentation to 
review the engineering feasibility of the proposed project. If applicable, proposed schematic 
or detailed engineering drawings, or engineering designs for projects that demonstrate the 
design parameters and how the project will achieve the stated objectives must be included to 
allow FEMA to assess the effectiveness and feasibility of the proposed project. 

 

Project subapplications must address the level of protection provided by the proposed project 
as well as any residual risk to the structure after project implementation. Upon request, 
FEMA will provide technical assistance regarding engineering documentation and cost 
estimation, Section 3.2, Engineering Feasibility Technical Assistance. Project 
subapplications that do not include appropriate documentation to support the determination 
of feasibility and effectiveness may be removed from consideration. 

 

2.3.2 ELIGIBILITY CRITERIA 
Projects approved for RFC grant awards must meet all of the following eligibility criteria: 
.. Cost-effectiveness, not costing more than the anticipated value of the reduction in both 
direct damages and reducing the risk of future damage, hardship, loss, or suffering 
resulting if future floods were to occur. A Benefit-Cost Analysis (BCA) using a FEMA-
approved methodology must be submitted for each project to demonstrate this 
requirement; Conformance with 44 CFR Part 9, Floodplain Management and Protection 
of Wetlands, and 44 CFR Part 10, and any applicable environmental laws and regulations; 
.. Technical feasibility and ability to be implemented. The project Cost Estimate must 
reflect the engineering design, if applicable, and all anticipated costs (See Section 3.2, 
Engineering Feasibility Technical Assistance). The subapplicant should determine prior 
to application submission the technical feasibility of any proposed structure relocation; 
.. Properties in all RFC projects must be NFIP insured at the time of project application and 
maintained at least through completion of the mitigation activity, or, for acquisition 
projects, until the transfer of ownership. For structures that remain in the SFHA, flood 
insurance must be maintained for the life of the structure, regardless of ownership of such 
property; 
.. Any improvements on the property shall be in accordance with the standards of the NFIP 
Floodplain Management Regulations. Structures on the property shall be floodproofed or 
elevated to at least the BFE or an ABFE or higher if required by any State or local 
ordinance, and in accordance with criteria established in this Guidance; 
.. Physical location in a community that is participating in the NFIP where the community 
is not suspended or withdrawn (deleted on probation) from the NFIP; 
.. Solving of a problem independently or constituting a functional portion of a solution 
where there is assurance that the project as a whole will be completed; 

.. Consistency with the goals and objectives identified in the current FEMA-approved 
State/Indian Tribal hazard mitigation plan and, if available, the FEMA-approved Flood 
Mitigation Plan pursuant to 44 CFR Part 78 or flood hazard component of the 44 CFR 


Part 201 compliant multi-hazard mitigation plan for the community in which the project 
is located; and 

.. Meeting the requirements of applicable Federal, State, Indian Tribal, and local laws, 
implementing regulations, and executive orders. 

2.3.3 PROPERTY ACQUISITION AND RELOCATION REQUIREMENTS 

For property acquisition and relocation projects, Applicants and subapplicants must comply 
with the following requirements, 44 CFR Part 206.434(e) and related program guidance. A 
project may not be framed in a manner that has the effect of circumventing these 
requirements. 

 

2.3.3.1 ELIGIBILITY FOR PROPERTY ACQUISITION PROJECTS 

Eligible Properties 
Properties eligible for acquisition include those where: 
.. The property will be acquired from a willing, voluntary seller; 
.. The property contains a structure that may or may not have been damaged or 
destroyed due to an event; 
.. All incompatible easements or encumbrances can be extinguished; 
.. The property cannot be contaminated with hazardous materials at the time of 
acquisition, other than incidental demolition or household waste; 
.. Any relocated structure must be placed on a site located outside of the SFHA, outside 
of any regulatory erosion zones, and in conformance with any other applicable State 
or local land use regulations; 

.. The property cannot be part of an intended, planned, or designated project area for 
which the land is to be acquired by a certain date, and/or where there is an intention to 
use the property for any public or private future use inconsistent with the open space 
deed restrictions and FEMA acquisition requirements (examples include roads and 
flood control levees); and 

.. The property will not be subdivided prior to acquisition, except for portions outside 
the identified hazard area, such as the SFHA or any risk zone identified by FEMA. 

Hazardous Materials 

Subapplicants considering the purchase of property (or land adjacent to property) with 
past or present commercial or industrial use must ensure that the owner provides 
information identifying what, if any, hazardous materials are on the property. To be 
considered an eligible property, before purchasing commercial or industrial properties, 
the subapplicant must require the owner to remove hazardous materials and containers. 
The owner must provide a clean-site certification from the appropriate State agency 
before the subapplicant can purchase any interest in the property, including easements for 
development rights. Clean-up costs associated with hazardous materials are not 
eligible project costs. 

 


The presence of non-leaking underground storage tanks, septic systems, home heating oil 
tanks, and normal quantities of lead, asbestos, and hazardous material associated with 
residential/household use does not preclude the use of mitigation funds for acquisition. 
However, local permitting ordinances, State laws, as well as Federal laws, regulations 
and Executive Orders, must be followed. The costs of removing these typical 
residential/household items must be addressed in the project Cost Estimate. 

 
Eligible costs 
.. Value of the land to be acquired, and either value of structure and demolition cost of 
that structure or relocation of the structure; 

.. Cost of appraisals, cost of title insurance and any additional escrow costs, such as 
recordation of the deed and deed restrictions, and other costs necessary for the real 
estate transaction; and 

.. Other necessary and appropriate costs for implementation of the project. 
Ineligible costs 
.. Compensation for land that is already held by an eligible entity is not an allowable 
cost, but compensation for development rights (open space easement) may be 
allowable; 
.. Cleanup or remediation of contaminated properties, except for permitted disposal of 
incidental demolition and household hazardous wastes; 

.. Pre-award costs may not be reimbursed for pre-award activities associated with 
implementation of the project; and 

.. FEMA acquisition funds are not available when an Applicant, subapplicant, other 
project participant or third partys negligence or intentional actions contributed to the 
conditions needing mitigation. 

2.3.3.2 REQUIREMENT TO APPLY DEED RESTRICTIONS 

Subapplicants requesting assistance for a real property acquisition or building relocation 
must apply specific deed restriction language to all acquired properties. See the Model 
Deed Restriction language on FEMAs mitigation website at 
http://www.fema.gov/government/grant/resources/index.shtm or from the Regional 
Office (See Section 1.14, Regional Contact Information). Any modifications to the 
model deed restriction can only be made with prior approval from FEMAs Office of 
Chief Counsel. 

 

2.3.3.3 SUBAPPLICATIONS FOR PROPERTY ACQUISITION 

Subapplicants for property acquisition and relocation projects must include the following 
in their application: 

1) Statement of Assurances; 

As part of the project application, subapplicants must attach a Statement of 
Assurances, signed by the subapplicants authorized agent, acknowledging the 
requirements as identified below that will apply to the acquisition of the property. 


See FEMAs website for this Statement of Assurances that must be submitted with 
the project application http://www.fema.gov/government/grant/resources/index.shtm. 
Open-space acquisition projects without these formal assurances will not be funded 
by FEMA. 

 
The following conditions apply to the grant and must be included in the Statement of 
Assurances: 
.. Participation by property owners is voluntary. The prospective participants were 
informed in writing that participation in the program is voluntary, that the 
subapplicant will not use its eminent domain authority to acquire their property 
for the project purposes should negotiations fail; 
.. Each property owner will be informed, in writing, of what the subapplicant 
considers to be the market value of the property. The subapplicant will use the 
model Statement of Voluntary Participation to document this and will provide a 
copy for each property after award. This model is available on FEMAs web 
page: http://www.fema.gov/government/grant/resources/index.shtm or from the 
Regional Office (See Section 1.14, Regional Contact Information); 
.. The subapplicant accepts all of the requirements of the FEMA grant and the deed 
restriction governing the use of the land, as restricted in perpetuity to open-space 
uses. The subapplicant must apply and record a deed restriction on each property 
in accordance with the language in the FEMA model deed. The community will 
seek FEMA approval for any changes in language differing from the model deed. 
.. The subapplicant understands that the land will be unavailable for the 
construction of flood damage reduction levees and other incompatible purposes, 
and is not part of an intended, planned, or designated project area for which the 
land is to be acquired by a certain date; 
.. The subapplicant will demonstrate that it has consulted with the US Army Corps 
of Engineers regarding the subject lands potential future use for the construction 
of a levee system, and will reject future consideration of such use if it accepts 
FEMA assistance to convert the property to permanent open-space; 
.. The subapplicant will demonstrate that it has coordinated with its State 
Department of Transportation to ensure that no future, planned improvements or 
enhancements to the Federal aid systems are under consideration that will affect 
the subject property; 
.. Existing buildings will be removed within 90 days of settlement; 
.. Post grant award, the subgrantee may convey a property interest only with the 
prior approval of the FEMA Regional Administrator and only to another public 
entity or to a qualified conservation organization pursuant to 26 CFR 1.170A-14; 

.. Every three years, the subgrantee must submit to the Grantee, who will submit to 
FEMA Regional Administrator a report certifying that it has inspected the subject 
property within the month preceding the report, and that the property continues to 
be maintained consistent with the provisions of the grant. If the subject property 
is not maintained according to the terms of the grant, the Grantee and FEMA, its 


representatives, designated authorities, and assigns are responsible for taking 
measures to bring the property back into compliance; and 

.. After settlement, no disaster assistance for any purpose from any Federal entity 
may be sought or provided with respect to the property, and FEMA will not 
distribute flood insurance benefits for that property for claims related to damage 
occurring after the date of the property settlement. 
2) Property Information for each property in the SOW; and 
.. Notice of Voluntary Interest Documentation in a specific format chosen by the 
subapplicant (such as a letter of interest, intent to participate form, project signup 
sheet or similar format) the subapplicant must record the name and signature of 
interested property owners associated with each property and must also clearly 
show each property owner acknowledging the following language: The property 
owner has been informed that this project for open-space acquisition is voluntary 
and that neither the [Applicant] or the [subapplicant] will use its eminent domain 
authority to acquire the property for open-space purposes should negotiations 
fail. This documentation of voluntary interest for each property owner must be 
submitted with the project application. It is the communitys discretion how this 
documentation is integrated into the project development process; however it 
should be accomplished as early in the project development process as is feasible. 
An example is available on FEMAs mitigation web page: 
http://www.fema.gov/government/grant/resources/index.shtm; 
.. Market value documentation for each parcel and include it in the cost estimate. 
The market value must be derived using a reasonable methodology that has been 
consistently applied throughout the community, such as independent appraisals, 
opinions of value, or a formula based on tax assessments; 
.. Net present value of the project benefits for each property to be acquired; 
.. The Uniform Relocation Assistance and Real Property Acquisition Act of 1970 
(URA) mandates that displaced tenants receive relocation assistance in 
accordance with 49 CFR Part 24. The project application should document 
properties occupied by tenants. This must be included in the cost estimate. See 
the FEMA Hazard Mitigation Grant Program Desk Reference for additional 
guidance; 

.. A photograph that represents the appearance of each property at the time of 
application; and 

.. For acquisition projects, changes to the properties in an approved mitigation 
project will be considered by FEMA but not approved automatically. The 
Applicant and subapplicant must have initially identified the alternate properties 
in the project application and must include a BCA for each alternate property in 
order to be considered. However, the alternate properties must not be included in 
the Cost Estimate or the overall project BCA. Eligible properties may be 
substituted as alternatives in the application as long as the substitution does not 
change the overall nature of the project or increase the amount of the Federal 
share and were included as alternatives in the subapplication. 


3) Other information as determined by the Administrator. 

 

2.3.3.4 PRE-AWARD REQUIREMENTS 
After application, but prior to award, the Applicant must provide FEMA with the 
following (See Section 1.9.4, FEMA Pre-award Activities): 

.. Documentation that the subapplicant has consulted the U.S Army Corps of Engineers 
and the State Department of Transportation regarding potential future land use 
conflicts of levee systems and Federal aid systems with open-space acquisition and 
has reject future consideration of such use if it accepts FEMA assistance to convert 
the property to permanent open-space (See the subapplication assurances for more 
detail). FEMA encourages subapplicants to conduct this consultation as early as 
possible so that incompatible properties can be removed earlier in the process. 
FEMA will not award funds for any property without this documentation; and 

.. A copy of the deed restriction, incorporating the specific language from FEMAs 
model deed restriction, which the local government will record with acquired 
properties. 

2.3.3.5 POST-AWARD REQUIREMENTS 
Following award of the grant, the subgrantee must adhere to the following requirements: 
.. A property owner who did not own the property at the time of the relevant event, or 
who is not a National of the United States or qualified alien, is not eligible for a 
purchase offer based on pre-event market value of the property, but may receive 
current market value; 
.. Subgrantees shall ask each property owner participating to certify that they are either 
a National of the United States or qualified alien before offering pre-event market 
value for the property. This information should be retained in the project file; 
.. The amount of purchase offer is based on the current market value of the property or 
on the market value of the property immediately before the relevant event affecting 
the property (pre-event): The relevant event for the Flood Mitigation Assistance 
program and the Repetitive Flood Claims Program is the most recent event resulting 
in a National Flood Insurance Program claim of at least $5000; 
.. The Grantee should coordinate with the subgrantee in determination of whether the 
valuation should be based on pre-event or current market value. Generally the same 
method to determine market value should be used for all participants in the project; 
.. A title insurance policy demonstrating clear title must be obtained for each approved 
property that will be acquired; 
.. All incompatible easements or other encumbrances must be extinguished before 
acquisition; 
.. The property must transfer by a warrantee deed; 
.. See Section 2.3.3.3 Subapplications for Property Acquisition regarding limitations on 
substitution of alternate properties; 
.. For acquisition projects, changes to the properties in an approved mitigation project 


will be considered by FEMA but not approved automatically. The Applicant and 
subapplicant must have initially identified the alternate properties in the project 
application and must include a BCA for each alternate property in order to be 
considered. However, the alternate properties must not be included in the Cost 
Estimate or the overall project BCA. Eligible properties may be substituted as 
alternatives in the application as long as the substitution does not change the overall 
nature of the project or increase the amount of the Federal share and were included as 
alternatives in the subapplication; 
.. Incompatible facilities must be removed from acquired property within 90 days of 
settlement; and 

.. Property Reporting Requirements from the subgrantee, through the Grantee, to 
FEMA: 

1) A photo of the property site after project implementation 

2) Latitude and longitude coordinates of the property 

3) Signed Statements of Voluntary Participation from the owner of each property 
identified in the SOW. This statement documents more formally the voluntary 
participation notice provided earlier, as well as documenting required property 
valuation notices. A Model Statement of Voluntary Participation is available on 
FEMAs web page: http://www.fema.gov/government/grant/resources/index.shtm 
or from the Regional Office (See Section 1.14, Regional Contact Information); 

4) A copy of the recorded deed and the attached deed restrictions for each acquired 
property must be submitted. 

5) For any property identified on FEMAs Repetitive Loss list, complete and submit 
FEMA form AW-501, documenting the completion of mitigation to those 
properties that are identified by FEMA as Repetitive Loss Properties. 

6) Every three years following acquisition, submit a report certifying that the 
subgrantee has inspected the property within the month preceding the report, and 
that the property continues to be maintained consistent with the provisions of the 
deed restriction. 

2.3.4 SPECIAL FLOOD HAZARD AREA REQUIREMENTS 

For projects related to improved structures sited in SFHAs, FEMA will verify that 
participating property owners had flood insurance on the property at the time of the 
application and require assurance that flood insurance is maintained for the life of the 
structure. Signed notices of the conditions for receiving FEMA grant funds for projects in a 
SFHA must be provided to FEMA prior to award. Properties that do not meet these 
requirements will not be eligible to receive assistance under the RFC program (See Section 
1.3.4, Program Requirements). 

 
The following requirements apply to any project to alter existing structures that are sited 
within a Special Flood Hazard Area (SFHA): 
.. When the project is implemented, all structures that will not be demolished or relocated 
out of the SFHA must be covered by flood insurance to an amount at least equal to the 


project cost or to the maximum limit of coverage made available with respect to the 
particular property, whichever is less; and 

.. The subapplicant (or property owner) will legally record with the county or appropriate 
jurisdictions land records a notice that includes the name of the current property owner 
(including book/page reference to record of current title, if readily available), a legal 
description of the property, and the following notice of flood insurance requirements: 

This property has received Federal hazard mitigation assistance. 
Federal law requires that insurance coverage on this property must be 
maintained during the life of the property regardless of transfer of 
ownership of such property. Pursuant to 42 U.S.C. Part 5154a, failure to 
maintain flood insurance on this property may prohibit the owner from 
receiving Federal disaster assistance with respect to this property in the 
event of a flood disaster. The property owner is also required to maintain 
this property in accordance with the flood plain management criteria of 
Title 44 of the Code of Federal Regulations Part 60.3 and City/County 
Ordinance. 

 

Applicants receiving assistance for projects sited in a SFHA will ensure that these 
requirements are met by requesting the participating property owner(s) to sign an 
Acknowledgement of Conditions for Mitigation of Property in a SFHA with FEMA Grant 
Funds form and providing the form to FEMA prior to award. This form is available on the 
RFC web page: http://www.fema.gov/government/grant/resources/pre-award.shtm or from 
FEMA Regional Offices (See Section 1.14, Regional Contact Information). Properties that 
do not meet these requirements will not be eligible to receive assistance under the RFC 
program. 

 

2.3.5 FLOOD ELEVATION DATA 
In the wake of a major flood event, FEMA may issue Advisory Base Flood Elevations 
(ABFE) that more closely reflects post-storm conditions. In areas where ABFEs have not 
been established, existing and effective flood boundaries and elevations must be utilized 
during project development. ABFEs developed following Hurricanes Katrina and Rita are 
currently available for several areas eligible for RFC activities. Applicants should check the 
status of this information during project scoping. 

.. ABFE information is available for the coastal counties in Mississippi from the FEMA 
website at: 
http://www.fema.gov/hazard/flood/recoverydata/katrina/katrina_ms_index.shtm 

.. For the parishes in Louisiana from the FEMA website at: 
http://www.fema.gov/hazard/flood/recoverydata/katrina/katrina_la_index.shtm. 

In addition to the issuance of ABFE data, FEMA periodically updates the flood hazard data 
for a community by issuing a new FIS and FIRM. It is conceivable that while a community 
is implementing an approved mitigation project, a new FIRM with flood elevations different 
from the previous map is adopted for use in administering the NFIP. Under this scenario, the 
mitigation project must be permitted in accordance with the effective FIRM. 


During the grant application development process, Applicants are encouraged to contact the 
office of the State NFIP coordinator to assess the potential for FIRM updates in potential 
project areas. 

 

2.3.6 FEDERAL INCOME TAX AND MITIGATION PROJECT FUNDS 

FEMA mitigation payments that benefit property owners through the mitigation of their 
structures are not subject to Federal income taxation. FEMA mitigation payments to acquire 
a property will be treated as an involuntary conversion for tax purposes. For more 
information, property owners should consult their IRS office or a tax advisor. 

 

2.3.7 GEOCODING REQUIREMENTS 

The location of all approved mitigation projects funded by the RFC program must be 
geocoded using standard datum. Geospatial coordinates, in the form of latitude and 
longitude with an accuracy of +/- 20 meters (64 feet), must be provided for all individual 
properties contained in the mitigation project. The specific Guidance for Geocoding 
Mitigation Data was provided to the FEMA Regional Offices in August, 2004, and provides 
guidance for collecting and formatting location information. This is available on FEMAs 
web page: http://www.fema.gov/government/grant/rfc/index.shtm or from the Regional 
Offices (See Section 1.14, Regional Contact Information). FEMA will work with Applicants 
to ensure this information is provided prior to award (See Section 1.9.4, FEMA Pre-award 
Activities). 

 

2.3.8 PROJECT MAINTENANCE 

FEMA is not responsible for project maintenance. FEMA will not pay for any future 
maintenance, such as dredging or debris removal, mowing open space, or ensuring hurricane 
shutters are operable. Subapplicants must provide a maintenance plan that identifies the 
maintenance tasks and budget and the entity that will perform long-term maintenance and 
include a description of maintenance agreements to be in place for long-term upkeep of the 
proposed project prior to award. Maintenance costs must not be included in the Cost 
Estimate; however, anticipated future maintenance costs must be included in the BCA. 

 

2.4 SCOPE OF WORK 
The Scope of Work (SOW) describes the objectives, methodology, feasibility, outcomes, 
timeline, milestones, resources, deliverables, and benefits of as well as reasons for the proposed 
project(s). The SOW must establish the who, what, where, when, and how of the proposal and 
timeline. The SOW should include the following as well as applicable references and supporting 
documentation: 
.. Purpose of the project; 
.. Clear, concise description of the proposed project and the means to implement and construct 
it (i.e., how will the project be implemented and by whom?); 
.. Outcomes (i.e., what are the expected accomplishments?); 
.. Identification of the flooding hazards to be addressed; 
.. Location within the community and/or geographical extent of the project (natural, built and 
socioeconomic environments); 


.. Feasibility and effectiveness provided by the proposed project, specifically for relocation 
projects, include engineering design parameters and copies of or references to: 

1) Proposed schematic or detailed plans, engineering drawings, or engineering design, 
particularly information to address potential feasibility concerns such as structural 
stability/suitability and movement/transportation of the structure; 
2) Applicable building code/edition or engineering standard used; 
.. Description of the alternatives considered prior to deciding upon the project; 
.. Description of the maintenance agreements to be in place for long-term upkeep of the 
proposed project; and 

.. Work schedule for all project tasks (e.g., survey, appraisal, permitting, inspection 
requirements, site preparation), and significant milestones throughout the entire performance 
period (See Section 1.10, Performance Period). 

2.4.1 SCOPE OF WORK DOCUMENTATION 

Documentation provided will be used by FEMA to evaluate the SOW to determine eligibility 
of the proposed subapplication. Examples of documentation, where applicable to the project, 
include proposed schematic or detailed engineering drawings, or engineering design; 
photographs, maps, sketches, and/or drawings (e.g., appropriate sections of Flood Insurance 
Studies and Flood Insurance Rate Maps) to document elements of the project and project 
parameters; or data sources, references, citations, and/or notations. 

 

2.4.2 SCOPE OF WORK CHANGES 

FEMA may not consider changes to the scope of work (SOW) between the close of the 
application period and the completion of the selection and award process, and no changes 
will be approved for cost overruns after award. Requests for changes to the SOW after 
award are permissible as long as they do not change the nature of the activity, the feasibility 
and effectiveness of the project, or render the project ineligible. Requests must be supported 
by adequate justification from the Applicant in order to be processed. The justification is a 
description of the proposed change, a written explanation of the reason or reasons for the 
change; an outline of remaining funds available to support the change; and a description of 
the work necessary to complete the activity. All approvals will be at FEMAs discretion, and 
there is no guarantee that SOW changes will be approved. 

 

2.5 COST ESTIMATE 

The Cost Estimate describes all anticipated and potential costs associated with the proposed 
activity, and represents the subapplicants best estimate of the total value of the proposed 
activity. Sufficient detail must be provided regarding various cost item categories such as labor, 
materials, equipment, subcontract costs, etc. Applicants/subapplicants shall submit detailed 
budgets and shall avoid lump sum items and provide references for all sources of the Cost 
Estimate (e.g., RS Means, Marshall and Swift, etc.). 

 
The Cost Estimate for all projects MUST include: 
.. All anticipated project costs, such as: 


o Anticipated environmental resource remediation or historic property treatment 
measures; 
o Engineering designs/specifications to include Hydrologic and Hydraulic; 
o Studies/analyses required as an integral part of the project design; 

o Other related construction/demolition/relocation costs, such as survey, permitting, site 
preparation, material disposal; and 
o Other related acquisition costs, such as appraisals, legal recordation, displacement 
costs for renters. 
.. Pre-award Costs: Indicate all costs that may be incurred prior to grant award but subsequent 
to the RFC application period opening. These should be identified as separate line items (See 
Section 1.3.5.5, Pre-award Costs); 
.. Subapplicant management costs: These should be identified as a separate line item to ensure 
cost threshold for this activity is not exceeded. Subapplicants may include a maximum of 
five percent of the total funds requested in their subapplication for management costs (See 44 
CFR Part 78.8, Grant funding limitations); 
.. Indicate any item for which a cost has been over-estimated which could result in a cost 
under-run. (For example, if the cost estimate received from a contractor will increase if the 
subapplication is not awarded for up to one year after the date of the receipt of initial 
quotation, this cost must be over-estimated and noted as such); and 

.. Maintenance costs are not eligible and should not be included in Cost Estimate, but MUST 
be included in the Benefit-Cost Analysis. 

2.5.1 COST ESTIMATE DOCUMENTATION 

Documentation provided will be used by FEMA to evaluate the Cost Estimate in order to 
determine eligibility. Applicants/subapplicants shall submit detailed budgets and shall avoid 
lump sum items and provide references for all sources of the Cost Estimate (i.e., RS 
Means). Identify sources of cost items (e.g., documented local cost, bids from qualified 
professionals, published national or local cost estimating guides) and provide documentation 
supporting each source, as appropriate (e.g., salary and fringe benefit rates for personnel 
involved in the project, bids from qualified professionals, published nationally or local cost 
estimating guides). If another project is used as the source of the Cost Estimate, detailed 
documentation showing the related project scope items must be provided. 

 

The project must be identified with enough details so that material, labor and other costs 
associated with the project can be identified. The cost estimating tools used must be 
identified and a detailed Cost Estimate must be provided. Examples of cost estimating tools 
may include: national cost estimating guides; an Applicants own cost estimating guides; an 
estimate based on bids; or an estimate based on awarded contracts for similar work 

 

2.5.2 COST ESTIMATE CHANGES 

FEMA will not consider changes to the Cost Estimate between the close of the application 
period and the completion of the selection process. FEMA will not approve changes for cost 
overruns (See Section 1.3.5.4, Cost Overruns and Cost Under-runs). 


 

Revisions to the approved budget may be considered after the selection as long as the 
approved deliverable is not adversely impacted. In accordance with 44 CFR Part 13, 
adjustments may be made among cost line items in the approved budget up to a cumulative 
threshold of 10% of the total budget without seeking formal approval from FEMA. 
Adjustments exceeding this threshold must be approved in advance by FEMA. As with 
SOW changes, requests for a budget revision must be supported by adequate justification 
from the Applicant in order to be processed. 

 

2.5.3 SUBAPPLICANT MANAGEMENT COSTS 

Subapplicants may include a maximum of 5% of the total funds requested for their project 
subapplication for management costs to support the project. Subgrantee management cost 
activities must be consistent with the Office of Management and Budget Circular A-87, Cost 
Principles for State and Local Governments. Subapplicants requesting management costs 
should provide supporting documentation and include these costs as separate line items in the 
Cost Estimate for the project subapplication in order to be considered. Management costs 
also MUST be included in the projects Benefit-Cost Analysis. If the Applicant is also the 
subgrantee, the Applicant may not request subgrantee management costs in their own project 
subapplication under any circumstance. Indirect costs, if requested, must be included as part 
of the subgrantee management costs, not to exceed 5% of the total cost of the project 
subapplication. There will be no exception to permit the increase in subgrantee management 
costs. Indirect costs should be supported with a current Indirect Cost Rate that is approved 
by a Federal Cognizant Agency. 

 

2.6 COST EFFECTIVENESS 

The RFC program must fund cost-effective mitigation activities. To ensure this objective is met, 
a FEMA-approved Benefit-Cost Analysis (BCA) will be required for all mitigation projects. 
BCA is a well-established method for quantitatively comparing the benefits and costs of 
mitigation projects. The end result is a Benefit-Cost Ratio (BCR), which is derived from a 
projects total net present value of benefits (i.e., the value of benefits today versus the value of 
future benefits after taking inflation and return into account) divided by the total project cost to 
include all documented project and maintenance costs. 

 

The Applicant or subapplicant is required to perform a BCA for each property, including 
repetitive flood loss properties and substantially damaged properties. For projects that address 
multiple structures (e.g., acquisition or elevation), the BCR must be calculated by totaling the 
anticipated or net present value of benefits for each structure to obtain the projects total net 
present value of benefits and dividing the total project benefits by the total project Cost Estimate. 
Applicants/subapplicants are encouraged to ensure that the BCA includes all benefits associated 
with the proposed mitigation project. Project subapplications with a BCR less than 1.0 will be 
removed from consideration. 

 

FEMA will convene a Benefit-Cost Technical Review panel of subject matter experts to conduct 
a detailed and comprehensive review of the BCAs for mitigation projects. 

 


The conduct of FEMAs BCAs are governed by the Office of Management and Budget (OMB) 
Circular A-94, Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs. 
Accordingly, the benefits of mitigation projects are avoided damages, disruptions, losses, and 
casualties. Examples of common benefits include avoided or reduced: 
.. Damages to buildings, contents or infrastructure; 
.. Economic impacts of loss of function of buildings; 
.. Displacement costs for temporary quarters; 
.. Loss of public services; 
.. Loss of net business income; 
.. Economic impacts of loss of function of infrastructure; 

.. Road or bridge closures; and 

.. Loss of utility services; 

The OMB circular excludes indirect benefits or "multiplier" effects, for example long-term 
changes in regional economic activity, future employment and tourism, which are not directly 
linked to the project. For further details of categories of benefits that may or may not be counted 
see "What is a Benefit? - Guidance on Benefit-Cost Analysis of Hazard Mitigation Projects" 
located on the Mitigation BCA Toolkit CD (See Section 3, Technical Assistance Resources). 
This document provides standardized benefit categories, approaches, and data inputs for many 
common mitigation projects. 

 

The cost of performing the BCA and providing supporting documentation may be included by 
the subapplicant as part of the project Cost Estimate or by the Applicant as part of the Grantee 
management costs (See Section 1.6, Applicant Management Costs). 

 

2.6.1 METHODOLOGY 

Applicants and subapplicants MUST use a FEMA-approved methodology to determine the 
BCA. Applicants and subapplicants are strongly encouraged to use FEMA's BCA software 
for their analyses, which may be obtained from FEMA by contacting the BCA helpline via 
phone: 1-866-222-3580, via e-mail: bchelpline@dhs.gov (See Section 3, Technical 
Assistance Resources), or from the applicable FEMA Regional Office (See Section 1.14, 
Regional Contact Information). Applicants and subapplicants should submit the completed 
BCA module with their applications. Using FEMA-approved software will ensure that all 
calculations are prepared in accordance with OMB and FEMA's standardized methodologies 
and approaches and will facilitate FEMA's review process. The Flood Very Limited Data 
Module may NOT be used to demonstrate cost-effectiveness for RFC project 
subapplications, only to screen projects for cost-effectiveness. Projects that use the 
Flood Very Limited Data Module will be removed from consideration. 

 

The OMB-mandated discount rate for the program is seven percent. This discount rate is 
incorporated into all FEMA software programs as a default and must not be modified. 

 

Alternative BCA methodologies will be considered only if the FEMA Regional Office and 
FEMA Headquarters approve the software prior to the Applicants submission of the RFC 


grant application to FEMA. The Applicant must provide verification that FEMA has 
approved the alternative BCA software or methodologies. An e-mail or letter signed and 
dated by FEMA is considered appropriate verification. Applications using BCAs conducted 
with software not approved in advance by FEMA will not be considered for the RFC 
program. 

 

FEMA has developed a simplified, alternative methodology to conduct the BCA, which may 
be used in lieu of a traditional BCA for certain properties insured under the NFIP and 
included in the NFIP Repetitive Loss Properties List. The list of properties and the guidance 
for using this alternative approach was provided to the FEMA Regional Offices under 
separate cover (information on the alternative approach is available on the FEMA website: 
http://www.fema.gov/government/grant/resources/bcarlalt.shtm). The NFIP Repetitive Loss 
properties may be combined in a project with other repetitive flood loss properties and/or 
non-repetitive flood loss properties; however, the alternative cost-effectiveness approach may 
only be used for the NFIP Repetitive Loss properties. 

 

2.6.2 COST-EFFECTIVENESS DOCUMENTATION 

For each BCA, the Applicant/subapplicant MUST provide a copy of each page of the actual 
analysis used, whether the BCA was performed using FEMA software or a pre-approved 
alternative methodology. An electronic version of the BCA MUST be provided in Microsoft 
Excel as well. BCA cover pages or summary reports will NOT constitute submission of a 
complete BCA. Project subapplications without legible or complete BCA information for 
each property may be removed from consideration. 

 
Project subapplications that do not include appropriate documentation to support the 
submitted BCA may be removed from consideration. Therefore, it is imperative that all 
supporting documentation be included in the application. The documentation must support 
figures, assumptions, data derivation and calculation methods used in the BCA. 
Subapplications MUST include full and credible documentation, which: 
.. Clearly explains the data used in the analysis, including the source; 
.. Explains reasons and sources of information for the use of non-default values in the 
BCA; 

.. Is well organized; and 

.. Provides references to the appropriate parts of the analysis. 

Project subapplications should include surveys, copies of elevation certificates, copies of 
appropriate sections of Flood Insurance Studies (FIS) and FIRM, copies of relevant 
supporting information from Engineering reports and other documentation to support figures 
used in their BCAs. A good rule of thumb to observe is that a subject matter expert should 
be able to calculate the BCA based upon the information provided in the subapplication 
without any additional explanation. FEMA has prepared Benefit-Cost Analysis Data 
Documentation Templates (DDT) to assist subapplicants in organizing and addressing all 
required documentation in support of the BCA. It is suggested that a DDT be prepared and 
attached with the supporting documentation for each project BCA. The DDT templates are 


found in the FEMA on-line library or can be reached through: 
http://www.fema.gov/government/grant/resources/index.shtm. 

 

The credibility of data sources also is extremely important. FEMA recommends obtaining 
information from published technical sources, in particular engineering studies such as FIS's 
and technical web sites such as those operated by the USGS, NOAA, and a range of 
academic organizations and State agencies and including this information with the project 
subapplication. Professional licensure is strongly preferred in all cases. In addition, data 
from FEMA software and default values from FEMA BCA guidance located on the 
Mitigation BCA Toolkit CD (See Section 3, Technical Assistance Resources) will be 
accepted as completely credible, when software is used correctly and documentation is 
provided. 

 
2.7 ENVIRONMENTAL/HISTORIC PRESERVATION REVIEW 
.. Pre-Award Requirement: Applicants and subapplicants are required to provide information 
to support FEMAs environmental/historic preservation compliance process. Funds will 
NOT be awarded and the Applicant/subapplicant may NOT initiate the project until 
FEMA has completed its review; 
.. Authorities: As part of this review process, FEMA will assess compliance with applicable 
requirements including the National Environmental Policy Act (NEPA), the National 
Historic Preservation Act (NHPA), the Endangered Species Act (ESA), and the Executive 
Orders on Wetlands, Floodplains, and Environmental Justice. The application of these laws 
and orders is threefold: 
1) Helps a subapplicant understand the compliance requirements for the proposed project 
and how in meeting some of those requirements, the overall design and cost of the project 
may be affected; 

2) Helps FEMA determine how well the Applicant/subapplicant understands these issues 
and has addressed them in the project design. In the case of historically significant 
structures, the owner has the option to use dry floodproofing when elevation and 
acquisition would adversely affect the historic characteristics of the property or area; and 
3) Helps to expedite the actual environmental/historic preservation compliance process that 
FEMA must complete before final approval and of the project. Technical Assistance: 
Applicants and subapplicants are strongly encouraged to request assistance from FEMA 
with their environmental/historic preservation questions by contacting the FEMA 
helpline via phone: (866) 222-3580, via e-mail: ehhelpline@dhs.gov, Section 3.4, 
Environmental/Historic Preservation Technical Assistance, or from the applicable FEMA 
Regional Office, Section 1.14, Regional Contact Information. 

.. Coordination with State and Federal Agencies: It is recommended that 
Applicants/subapplicants initiate coordination with relevant State or Federal agencies as soon 
as possible in order to identify any environmental or historic preservation compliance issues 
associated with proposed projects. Applicants with project subapplications selected for 
further review will be notified of the date by which all pre-award activities (including 
environmental and historic preservation activities) must be completed that are considered a 


FEMA responsibility. The Applicants and subapplicants cooperation in the EHP process 
will ensure timely completion of this review. 
2.7.1 ENVIRONMENTAL/HISTORIC PRESERVATION REVIEW 
DOCUMENTATION 
.. Scope of Work: An accurate and thorough SOW provides crucial information to FEMA 
when undertaking Environmental/Historic Preservation review. In addition to the 
information provided in the SOW, Applicants/subapplicants must answer a series of 
Environmental/Historic Preservation review questions in the project subapplication to 
provide information about potential environmental resources and/or historic properties in 
the project area and potential impacts to those resources. If the potential resources are 
identified, the Applicant/subapplicant must provide the following information in order for 
the project subapplication to be considered complete including the source and date for all 
information provided: 
1) The property address and original date of construction for any buildings or structures 
that are 50-years or more in age; 
2) Any identified Federally listed threatened or endangered species and its designated 
critical habitat in the project area; 
3) Vegetation, including amount (area), type, and extent to be removed or affected; 

4) Identification of all surface waters in the project area regardless of drainage area, size, 
or perceived hazard level. Information about surface waters should include 
dimensions, proximity of the project activity to the water , and the expected and 
possible impacts of the project upon surface waters, if any; and 
5) Description of any adverse effects on low or minority populations in the project area; 
.. Eligibility and Completeness Review: During Eligibility and Completeness Review, 
FEMA will review the completeness of the responses to the questions in the 
Environmental/Historic Preservation review section of the project subapplication and 
supporting documentation. Project subapplications and individual properties that do 
NOT include the required information may result in a delay in identifying outstanding 
environmental or historic preservation compliance measures and may prohibit FEMA 
from awarding RFC grants by deadline; and 
.. Review and Compliance Process: FEMA will use the information provided in the SOW, 
Cost Estimate, and Environmental/Historic Preservation sections of the project 
subapplication to perform the Environmental/Historic Preservation Review of the 
proposed projects. To facilitate the required compliance process, FEMA strongly 
encourages the Applicant/subapplicant to: 
1) Work with Federal and State resource agencies to begin collecting information about 
potential environmental or historic preservation impacts from the proposed project 
and provide any documentation from the resource agency. The 
Applicant/subapplicant should also determine if the mitigation projects will impact 
historically significant properties; 


2) Evaluate how identified environmental or historic preservation impacts could affect 
the overall project feasibility or if project alternatives or changes to the design, scope 
or location of the project may be required to minimize potential adverse impacts; 
3) Determine if potential environmental impact mitigation measures and historic 
preservation measures, or changes to the project to minimize adverse effects to 
environmental resources or historic properties, may affect the overall project costs. 
For example, certain structures may be floodproofed if acquisition, mitigation 
reconstruction, or elevation would diminish the historic value of the property; 

4) Provide supporting documentation at the time of the subapplication submission to 
include clearly labeled maps, diagrams, photographs, letters, or other documentation 
from resource agencies; and 
5) Utilize the eLearning Tool for FEMA Grant available online at: 
http://www.fema.gov/plan/ehp/elearning/index.shtm. The project subapplication 
provides the necessary information for FEMA to determine the eligibility of proposed 
projects under the RFC program, including a thorough evaluation of Environmental/ 
Historic Preservation impacts. 
2.7.2 CONDITIONS FOR THE AWARD OF FUNDS 

.. FEMA Environmental/Historic Preservation Review: For mitigation project 
subapplications selected for further review, FEMA will complete the Environmental/ 
Historic Preservation review and compliance process in consultation with appropriate 
Federal and State resource agencies. This review will be conducted with the assistance of 
both the Applicant and the subapplicant as part of the Pre-award Activities. The outcome 
of this review may be the identification of required environmental impact mitigation or 
historic preservation treatment measures necessary to avoid, minimize or compensate for 
adverse effects caused by the project. Depending on the type of property or resource 
affected and the scope of the project, the measures may be minimal or extensive. These 
required environmental impact mitigation or historic preservation treatment measures 
will be required conditions placed on the award of the grant; and 
.. Cost Estimate for Impact Mitigation and Treatment Measures: The 
Applicant/subapplicant should ensure, to the best of their ability, that costs of any 
treatment measures necessary to address potential adverse impacts are realistically 
reflected in the Cost Estimate. Clean-up costs associated with hazardous materials are 
not eligible project costs. The Applicant/subapplicant is encouraged to provide an 
explanation of how the Cost Estimate was developed to include costs associated with 
anticipated impact mitigation and treatment measures. All such costs identified through 
the review and consultation process may be eligible if included as part of the project 
subapplication Cost Estimate. 

The amount of the Federal share may NOT be increased to cover any additional costs 
identified after the application deadline. If the estimated additional costs of these measures 
exceed the Cost Estimate submitted, the Applicant/subapplicant may accept the subgrant 
award and pay the additional costs or decide not to accept the subgrant award. 

 


FEMA may recoup subgrant funds if any conditions of the award are not implemented as 
agreed upon or if the Applicant/subapplicant initiates the project prior to FEMAs completion 
of the Environmental/Historic Preservation review. Within 4 months of selection, the 
Applicant must provide all additional required documentation so that the Environmental/ 
Historic Preservation review can be completed or subapplication may not be approved for 
award. One year extensions of the obligations deadline will be permitted on a limited basis. 

 

2.8 PROJECT SUBAPPLICATION CHECKLIST 
Subapplications provide the scope of work and other necessary information for each proposed 
project that allows FEMA to review projects for eligibility and completeness and to select 
projects for award. Subapplicants MUST submit a separate project subapplication for each 
project for which RFC funding is requested. The project subapplication provides all of the 
necessary information for FEMA to determine the eligibility of proposed projects under the RFC 
program. The project subapplication must include the following information: 
.. Applicant Information  Provide name, type of subapplicant (e.g., State Agency, Local, 
Indian tribe), address, State and Federal Tax numbers, and Employer Identification Number. 
.. Contact Information  Provide name, agency, and address for the point(s) of contact for the 
subapplication. 
.. Community Information  Provide name of community and brief description of the 
community to include population, location, any geographic areas of interest, a synopsis and 
history of hazards affecting the community, and other applicable information that will clarify 
the need for the mitigation project. 
.. Reduced Capacity Certification  Provide certification that the proposed activities can not 
be funded under the FMA program, and an explanation why the State or community can not 
meet the non-Federal match, or lacks the capacity to manage the activities under the FMA 
program. 
.. Mitigation Plan Information: Indicate whether the State/Indian tribe/territory is covered by 
a FEMA-approved State/Indian Tribal Standard or Enhanced hazard mitigation plan; if 
applicable, indicate whether the local entity in which the project is located is covered by a 
FEMA-approved Indian Tribal/local hazard mitigation plan; and describe how the proposed 
project is consistent with the goals, objectives, and priorities identified in any existing hazard 
mitigation plans. Provide reference to planning documents (i.e., section and page number). 
.. Scope of Work Describe the objectives, methodology, feasibility, outcomes, resources, 
deliverables, and benefits of the proposed project, including the hazard(s) to be mitigated, 
and location of project (e.g., appropriate sections of FIRM), and engineering design, 
feasibility and effectiveness for relocation projects. 
.. Activity Information  Identify the type of activity proposed (e.g., acquisition and 
demolition or acquisition and relocation). 
.. Properties  Provide a list of properties to be mitigated. For each property, provide the 
address, latitude and longitude, NFIP repetitive loss number, Market Value, and BCA. In 
addition, provide a letter of interest or from the owner of each property identified. 


.. Schedule  Provide timeframes to complete each project task (e.g., survey, appraisal, 
permitting, inspection requirements, site preparation), and significant milestones throughout 
the entire performance period (See Section 1.10, Performance Period); 
.. Cost Estimate Provide all anticipated and potential costs for each proposed project activity. 
Provide an Approved Indirect Cost Agreement, if applicable. Include URA, if applicable. 
.. Cost-Effectiveness Information Provide complete BCA and documentation for each 
property, including damage history, methodology used for the event frequency 
determination, and all BCAs to support property Benefit-Cost Ratios. 
.. Environmental/Historic Preservation Review -- Provide a description of Environmental/ 
Historic Preservation impacts and the alternatives considered prior to deciding upon the 
project. 
.. Maintenance Schedule and Costs  Provide a maintenance schedule, including cost 
information, and identify the entity that will perform long-term maintenance. 

.. Assurances and Certifications: If applicable in your Applicant State/Tribe/Territory, 
complete the Summary Sheet for Assurances and Certification, FEMA Form 20-16; 
Assurances-Non-Construction Programs, FEMA Form 20-16A; Assurances-Construction 
Programs, FEMA Form 20-16B; Certification Regarding Lobbying; Debarment, Suspension 
and Other Responsible Matters; Drug-Free Workplace Requirements, FEMA Form 20-16C; 
and Disclosure of Lobbying Activities, Standard Form LLL. 

.. Property Acquisition Statement of Assurances  Provide signed statement of agreement 
with certain assurances required for projects involving property acquisition (See FEMAs 
RFC website for a model statement of assurances: 
http://www.fema.gov/government/grant/rfc/index.shtm). 

2.9 FEMA REVIEW & RANKING 

 

2.9.1 ELIGIBILITY & COMPLETENESS REVIEW 
FEMA will review all project subapplications to ensure the following: 
.. Eligibility of the Applicants/subapplicants (See Section 1.3, Grant Program Eligibility); 
.. Eligibility of proposed activities, properties and costs (See Section 1.4, Eligible Activities 
and Associated Costs); 
.. Completeness of Scope of Work; 
.. Completeness of the Cost Estimate and consistency with the Scope of Work; 
.. Demonstrated Reduced Capacity of State or community (See Section 1.3.4.4, Reduced 
Capacity Requirement); 
.. State/Indian Tribal planning requirements are met, and consistency of mitigation projects 
with the Applicants State/Indian Tribal hazard mitigation plan; 
.. Feasibility and effectiveness of mitigation projects, including complete supporting 
documentation; 
.. Benefit-cost ratio of 1.0 or greater for the proposed mitigation project; 


.. Technical accuracy, complete supporting documentation, and source credibility of the 
BCA information for each property; and 

.. Supporting documentation and inclusion of appropriate environmental mitigation 
measure and historic property treatment measures in the Cost Estimate. 

Project subapplications that do not satisfy the eligibility and completeness requirements 
will be removed from consideration. 

 

2.9.2 BENEFIT-COST TECHNICAL REVIEW 

FEMA will conduct a Benefit-Cost Technical Review for a detailed and comprehensive 
review of the BCAs for mitigation projects. The Benefit-Cost Technical Review will be 
based on the documentation provided in the project subapplication. Project subapplications 
MUST demonstrate cost-effectiveness through a Benefit-Cost Ratio of 1.0 or greater. 

 

During both the Eligibility and Completeness and Benefit-Cost Technical Reviews, FEMA 
may contact Applicants or subapplicants to request additional information or clarification on 
BCA documentation submitted in the subapplication. However, Applicants/subapplicants 
must provide any information requested from FEMA to support the BCA within a specific 
timeframe identified in the request. At no time after the application deadline may the 
Applicant / subapplicant submit information that is not requested by FEMA. 

 
FEMA has developed a review methodology based on a series of key data points related to 
FEMAs BCA software that have a significant influence on the outcome of the analysis. The 
technical review process will focus on the data that have the greatest impact on the BCR. 
FEMA will determine the reasonableness, credibility, and accuracy of all BCAs by reviewing 
each data point of the BCA in three key areas: 
1) Technical Accuracy: FEMA has established a series of review criteria for each 
combination of hazard and analysis type (engineering data or frequency-damage). The 
key data points of greatest influence differ depending upon the hazard being addressed 
and the chosen methodology. The BCA review methodology associates higher weight to 
data points of greater importance; 

2) Supporting Documentation: Every data point in the BCA should be clearly documented 
and included in the project application. Deviations from standard procedures, guidance, 
techniques, or FEMA default values should be thoroughly explained and documented. 
The BCA review methodology associates higher scores to better documentation of data 
derivation methods and assumptions in the project application. Projects not adequately 
documented may be removed from consideration; and 

3) Source Credibility: The more technical the data and the more it influences the outcome of 
the BCA, the more emphasis the Benefit-Cost Technical Review panel will place on the 
credibility of its source. Data used in the BCA should be from a reliable source (i.e., 
licensed engineer, architect, or appropriate local official). 
BCAs that are technically correct and thoroughly documented will be validated. However, 
when insufficient or conflicting information is provided in the project subapplication, FEMA 
may contact the Applicant to verify any correctable information. Applicants must provide 
any information requested from FEMA to support the BCA within a specific timeframe 


identified in the request. The Benefit-Cost Technical Review panel may prepare a new, 
technically correct and defensible BCA(s) to calculate a BCR for the project. The panel will 
prepare new BCA(s) as follows: 
.. Resolve conflicting information between the application, support data, and BCA(s); 
.. Correct user input errors in the BCA(s); 
.. Use FEMA default values in the BCA(s) instead of User-defined values not 
substantiated in the subapplication; 
.. Include all documented project and maintenance costs in the BCA(s); 

.. Use data in the subapplication that was not included in the subapplicants BCA(s) to 
improve the accuracy of the BCAs; and 

.. Remove unsubstantiated benefits from the BCA(s). 

Projects where BCRs are inadequately documented or where critical data or sources appear 
unreasonable may be removed from consideration. 

 

2.9.3 NATIONAL RANKING 

FEMA will rank all eligible mitigation project subapplications on the basis of the greatest 
savings to the NFIF as demonstrated by the verified BCA. All projects will be ranked from 
highest verified BCA to lowest verified BCA. The Approving Federal Official at FEMA 
Headquarters will consider the National Ranking and other program priorities in determining 
which projects are selected for award up to the amount of funds available for the RFC 
program. 

 

Eligible project subapplications not selected for RFC grant awards during the current cycle 
will be placed on a waiting list and may be considered for RFC grant awards during the next 
RFC program funding cycle. 

 

2.10 FEMA PRE-AWARD ACTIVITIES 

FEMA will work with Applicants who have approved project subapplications to implement 
required pre-award activities prior to grant award. FEMA may, at its discretion, request 
information or documentation from Applicants to support certain project subapplications as part 
of pre-award activities. Applicants must respond to requests for information from the FEMA 
Regional Offices regarding their project subapplications within the specified timeframe. 
Applicants with project subapplications selected for award will be notified of the date by which 
all pre-award activities must be completed. 

 

2.10.1 PROPERTY ACQUISITION AND RELOCATION REQUIREMENTS 

The subapplicant must submit documentation that the subapplicant has consulted the US 
Army Corps of Engineers and the State Department of Transportation regarding potential 
future land use conflicts with open-space acquisition. Additionally, the subapplicant must 
submit a copy of the deed restriction, incorporating the specific language from FEMAs 
model deed restriction, which the local government will record with acquired properties. 

 

 


2.10.2 GEOCODING REQUIREMENTS 

FEMA will work with Applicants to ensure that geocoding information is provided prior to 
award, including individual property information on properties mitigated. 

 

2.10.3 ENVIRONMENTAL/HISTORIC PRESERVATION COMPLIANCE 
REQUIREMENTS 

FEMA will complete the environmental/historic preservation compliance review for projects 
approved for award as part of pre-award activities. Certain projects are of a nature that 
environmental/historic review can be accomplished with the information provided in the 
subapplication. Other projects may require some additional review, or extensive review. 
FEMA will often request that the Applicant and subapplicant work with FEMA in the review 
process. FEMA will complete the environmental/historic preservation compliance review for 
projects as part of pre-award activities. Subgrantees shall not initiate grant activities until 
FEMA has completed the environmental/historic preservation review. FEMA may, at its 
discretion, request information or documentation from Applicants to resolve outstanding 
administrative or procedural requirements as part of its pre-award activities. 

 

2.11 UPDATING REPETITIVE LOSS DATABASE FOR MITIGATED 
PROPERTIES 

In order to maintain accurate, up-to-date records of all repetitive loss properties mitigated as a 
result of FEMA mitigation grants, FEMA requires the submission of Form AW-501, NFIP 
Repetitive Loss Update Worksheet (OMB #1660-0022). Typically, this form is completed by the 
State or community, but may be completed by a Region with appropriate documentation that 
shows any changes in the status of a property (e.g., elevation certificate). This form, along with 
the transmittal sheet or other document signed by an authorized community official, must be 
submitted for each property mitigated with RFC funds prior to closeout. Form AW-501 and 
instructions for completing and submitting the Form are available on FEMAs web page, 
http://www.fema.gov/government/grant/rfc/index.shtm or from the Regional Offices (See 
Section 1.14, Regional Contact Information). 

 


SECTION 3 TECHNICAL ASSISTANCE RESOURCES 

 

FEMA will provide technical assistance to both Applicants and subapplicants by answering 
general questions about the RFC program as well as providing general technical assistance 
related to project subapplications. FEMA will also provide technical assistance regarding the 
application process. FEMA encourages Applicants and subapplicants to seek technical 
assistance early in the application period by contacting their FEMA Regional Office (See Section 
1.14, Regional Contact Information). 

 

3.1 eGRANTS HELPDESK 

FEMA provides technical assistance to Applicants and subapplicants specific to the eGrants 
through the eGrants Helpdesk, which can be reached via phone: 1-866-476-0544 or e-mail: 
mtegrants@dhs.gov. Standard hours of operation are 9 a.m. to 5 p.m. Eastern Time. Hours may 
be extended during the application period. 

 

3.2 PROJECT TECHNICAL ASSISTANCE 

FEMA will provide technical assistance to both Applicants and subapplicants by answering 
general questions about the RFC program at all times, and by providing technical assistance 
related to specific project subapplications after the application period opens. FEMA will also 
provide technical assistance regarding the application process. FEMA will provide general 
technical assistance to both Applicants and subapplicants related to project Engineering 
Feasibility, BCA, and Environmental/Historic Preservation compliance during the application 
period. FEMA encourages Applicants and subapplicants to seek technical assistance early in the 
application period by contacting their FEMA Regional Office (See Section 1.14, Regional 
Contact Information). 

 

3.3 ENGINEERING FEASIBILITY TECHNICAL ASSISTANCE 

FEMA may provide technical assistance to Applicants and subapplicants regarding the level of 
documentation and the types of information that FEMA will need to adequately review the 
feasibility and effectiveness of proposed projects. In addition, FEMA may provide technical 
assistance to Applicants and subapplicants regarding the completeness and accuracy of project 
cost estimates. Project subapplications must address the level of protection provided by the 
proposed project as well as any residual risk to the structure after project implementation. 
Certain retrofitting measures may increase risk to the structure from multiple natural hazards. 
For example, elevation to decrease adverse effects from flooding may increase exposure to wind 
and seismic hazards. Therefore, vulnerabilities to all hazards should be considered. 
To assist Applicants and subapplicants with developing project proposals, the following 
guidance documents are available on FEMAs web site at 
http://www.fema.gov/government/grant/rfc/index.shtm, or from the Regional Offices (See 
Section 1.14, Regional Contact Information): 

.. For the documentation of their proposed projects, a Sample Engineering Case Study for 
acquisition projects. The case study provides examples of the information needed for 


proposed mitigation projects and highlights the importance of the Scope of Work and Cost 
Estimate sections of the project subapplication as they relate to documentation for the 
engineering and feasibility review. The case study is not a sample application and should 
only be used as guidance. 

.. To assist Applicants applying for funding under FEMA's mitigation grant programs 
Procedures for Developing Scopes of Work for five common flood project types. The 
purpose of these documents is to provide guidance to Applicants and subapplicants regarding 
collection of the administrative and technical data that FEMA requires. 

.. Property Acquisition Handbook for Local Communities (FEMA 317) provides a "how to" 
guide to help communities work through property acquisition (also referred to as "buyout"). 

3.4 BENEFIT-COST ANALYSIS TECHNICAL ASSISTANCE 

FEMA has prepared a Mitigation BCA Toolkit CD. This CD includes all of the FEMA BCA 
software, technical manuals, BCA training courses, and other supporting documentation. 
Applicants and subapplicants may obtain the FEMA Mitigation BCA Toolkit CD free from 
FEMA by contacting the Technical Assistance Helpline or the applicable FEMA Regional Office 
(See Section 1.14, Regional Contact Information). 
FEMA will provide technical assistance on the BCA data needs and documentation requirements 
during the application period. The BCA technical assistance provided to potential Applicants 
and subapplicants may cover: 
.. Use of the FEMA Mitigation BCA Toolkit CD; 

.. Use of the BCA Data Documentation Templates found on the Toolkit CD; 

.. Proper use of the BCA modules, procedures, and methodologies; and 

.. How to prepare detailed Cost Estimates. 

During both the Eligibility and Completeness and Benefit-Cost Reviews, FEMA may contact 
Applicants or subapplicants to request additional information or clarification on BCA 
documentation in the subapplication. 

 

3.5 ENVIRONMENTAL/HISTORIC PRESERVATION TECHNICAL 
ASSISTANCE 

The Applicant and subapplicant may find specific guidance on completing the Environmental/ 
Historic Preservation questions in the Environmental/Historic Preservation Information section 
of the project subapplication linked on FEMA's website at: 
http://www.fema.gov/plan/ehp/index.shtm. 

 

In addition, an eLearning Tool is available to assist Applicants and subapplicants with answering 
the Environmental/Historic Preservation questions and provides interactive and dynamic, 
context-sensitive help, instructions, and resources for each of the parts of the Environmental/ 
Historic Preservation Information section of the project subapplication. Although developed for 
the Pre-Disaster Mitigation (PDM) grant program, the eLearning Tool may be utilized for all of 
FEMAs mitigation grant programs. The eLearning Tool also highlights Environmental/Historic 
Preservation considerations that may need to be addressed in other parts of the project 
subapplication, such as the Scope of Work and Cost Estimate. 


The Help Module is linked directly to the Environmental/Historic Preservation Information 
section of the project subapplication in the eGrants system as well as to the FEMA web page: 
http://www.fema.gov/plan/ehp/elearning/index.shtm. 

 

FEMA also offers training related to Environmental/Historic Preservation online through the 
National Emergency Training Center Virtual Campus. This interactive, computer-based, 
independent study course is designed to provide the user with the basic background and practical 
knowledge needed to participate in FEMA's Environmental/Historic Preservation Review 
process; help the user understand how the Environmental/Historic Preservation Review process 
applies to various projects proposed under FEMA's programs; and, provide the resources 
necessary for the user to accomplish Environmental/Historic Preservation responsibilities. The 
Independent Study course, IS 253, includes interactive knowledge checks, case studies, and 
resource materials. Please visit the FEMA website at: 
http://training.fema.gov/EMIWeb/IS/is253.asp for more information about the online course or 
contact your FEMA Regional Office (See Section 1.14, Regional Contact Information). 

 

3.6 PROJECT TECHNICAL ASSISTANCE HELPLINES 

FEMA established Technical Assistance Helplines to provide assistance to Applicants and 
subapplicants with engineering feasibility and effectiveness; BCA, including BCA software, 
technical manuals, and other BCA references; and Environmental/Historic Preservation 
compliance for project subapplications. The Helplines can be reached via phone: 1-866-222-
3580 or e-mail: enghelpline@dhs.gov; bchelpline@dhs.gov; and ehhelpline@dhs.gov, 
respectively, and a representative will respond within two (2) business days.