State Mitigation Plan

Review Guide

Released March 2015 

Effective March 2016 

FP 302-094-2 
This page is intentionally blank. 
State Mitigation Plan Review Guide 2015

Page | i

Table of Contents

List of Acronyms and Abbreviations ............................................................................. iii

SECTION 1: INTRODUCTION ..................................................................................... 1

1.1 Purpose ................................................................................................................. 1 

1.2 Guiding Principles ................................................................................................ 2 

1.3 Organization ......................................................................................................... 3 

SECTION 2: MITIGATION PLANNING RESPONSIBILITIES............................... 5

2.1 FEMA Responsibilities ........................................................................................ 5 

2.1.1 Communicating Mitigation Plan Status ............................................................. 5 

2.1.2 Mitigation Program Consultation ................................................................... 6 

2.2 State Responsibilities ........................................................................................... 8 

SECTION 3: STANDARD STATE PLAN REQUIREMENTS ................................. 11

3.1 Planning Process ................................................................................................ 11 

3.2 Hazard Identification and Risk Assessment....................................................... 13 

3.3 Mitigation Strategy............................................................................................. 17 

3.4 State Mitigation Capabilities .............................................................................. 19 

3.5 Local Coordination and Mitigation Capabilities ................................................ 20 

3.6 Plan Review, Evaluation, and Implementation .................................................. 22 

3.7 Adoption and Assurances................................................................................... 23 

3.8 Repetitive Loss Strategy..................................................................................... 25 

SECTION 4: ENHANCED STATE PLAN REQUIREMENTS ................................ 27

4.1 Meet Required Standard Plan Elements............................................................. 28 

4.2 Integrated Planning ............................................................................................ 28 

4.3 State Mitigation Capabilities .............................................................................. 29 

4.4 HMA Grants Management Performance............................................................ 32 

APPENDIX A: SUBMISSION AND REVIEW PROCEDURES............................... 35

A.1 Communication .................................................................................................. 35 

A.2 Plan Submittal .................................................................................................... 35 

A.3 Plan Adoption..................................................................................................... 35 

A.4 Plan Review Status............................................................................................. 36 

A.4.1 Requires Revisions ........................................................................................ 36 

A.4.2 Approvable Pending Adoption ...................................................................... 36 

A.4.3 Approved ....................................................................................................... 36 

A.5 Enhanced State Mitigation Plan Review ............................................................ 36 

A.5.1 Status Categories ........................................................................................... 37 

A.5.2 Hazard Mitigation Assistance Grants Management Performance Review ... 38 

A.5.3 FEMA Regional Review ............................................................................... 38 

A.5.4 National Review Panel .................................................................................. 38 

A.5.5 Enhanced Plan Review Procedure Summary ................................................ 39 

A.6 Review of Mitigation Commitments.................................................................. 40 

APPENDIX B: STATE MITIGATION PLAN REVIEW TOOL .............................. 43

B.1 Plan Review Tool Summary .............................................................................. 44 
State Mitigation Plan Review Guide 2015

Page | ii

B.2 Standard State Mitigation Plan Regulation Checklist ........................................ 45

B.3 Enhanced State Mitigation Plan Regulation Checklist ...................................... 47 

B.4 Strengths and Opportunities for Improvement ................................................... 48

APPENDIX C: APPROVAL LETTER TEMPLATE ................................................. 49

APPENDIX D: CONSULTATION SUMMARY TEMPLATE ................................. 51

Tables

Table A-1. Summary of Enhanced Plan Status, Review Panel Types, and Review Panel 

Composition. ..................................................................................................................... 37 

Table A-2. Summary of Enhanced Plan Review Procedures. .......................................... 39 
State Mitigation Plan Review Guide 2015

Page | 3 

List of Acronyms and Abbreviations

APA Approvable Pending Adoption 

BW-12 Biggert-Waters Flood Insurance Reform Act of 2012 

CFR Code of Federal Regulations 

CRS Community Rating System 

FEMA Federal Emergency Management Agency 

FFR Federal Financial Report 

FMA Flood Mitigation Assistance 

FMAG Fire Management Assistance Grants 

HMA Hazard Mitigation Assistance 

HMGP Hazard Mitigation Grant Program 

NFIP National Flood Insurance Program 

PA C-G Public Assistance Categories C-G 

PDM Pre-Disaster Mitigation Program 

PPD Presidential Policy Directive 

Risk MAP Risk Mapping, Assessment, and Planning Program 

RL Repetitive Loss 

SF Standard Form 

SRL Severe Repetitive Loss 

U.S.C. United States Code 
State Mitigation Plan Review Guide 2015

Page | 4 

This page is intentionally blank. 
State Mitigation Plan Review Guide 2015

Page | 1

SECTION 1: INTRODUCTION

1.1 Purpose

Hazard mitigation is sustained action to reduce or eliminate the long‐term risk to human 

life and property from hazards. Natural hazard mitigation planning is a process used by

state, tribal, and local governments to engage stakeholders, identify hazards and 

vulnerabilities, develop a long-term strategy to reduce risk and future losses, and 

implement the plan, taking advantage of a wide range of resources. A state mitigation 

plan demonstrates commitment to reduce risks from natural hazards and serves as a guide 

for decision makers for reducing the effects of natural hazards as resources are

committed. 

FEMA supports hazard mitigation planning as a means to:







Foster partnerships for natural hazard mitigation; 

Promote more resilient and sustainable states and communities; and

Reduce the costs associated with disaster response and recovery.

This State1Mitigation Plan Review Guide (Guide) is FEMA’s official policy on and 

interpretation of the natural hazard mitigation planning requirements.2 The intended use 

of the Guide is to facilitate consistent evaluation and approval of state mitigation plans, 

as well as to facilitate state compliance with the mitigation planning requirements when 

updating plans. Separate local and tribal mitigation planning guidance is available from 

the FEMA Mitigation Planning website.

This Guide incorporates principles from the following documents:





Presidential Policy Directive (PPD)

o

o

PPD 8 National Preparedness (March 2011) 

PPD 21 Critical Infrastructure Security and Resilience (February 2013)

National Preparedness Goal3(September 2011)

1

For mitigation planning, the term “state” is inclusive of the District of Columbia, American Samoa, Commonwealth 

of Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands [44 Code of Federal Regulations (CFR)

§201.2 Definitions]. Indian tribal governments follow the Tribal Multi-Hazard Mitigation Planning Guidance. If

interested in being eligible for the 20 percent Hazard Mitigation Grant Program funding, the tribal mitigation plan must 

meet the enhanced state mitigation plan criteria presented in this Guide [44 CFR §201.3(e)(3)]. 

2 The mitigation planning requirements are authorized under the Robert T. Stafford Disaster Relief and Emergency 

Assistance Act (Stafford Act) (Public Law 93-288; 42 United States Code [U.S.C.] 5121 et seq.), as amended by the 

Disaster Mitigation Act of 2000; National Flood Insurance Act of 1968, as amended [42 U.S.C. 4001 et seq.]; 44 CFR 

Part 201 Mitigation Planning; and 44 CFR Part 206, Subpart N Hazard Mitigation Grant Program, §206.434 Eligibility. 

3 “A secure and resilient nation with the capabilities required across the whole community to prevent, protect against, 

mitigate, respond to, and recover from the threats and hazards that pose the greatest risk.”
State Mitigation Plan Review Guide 2015

Page | 2







National Mitigation Framework (May 2013) 

FEMA’s Climate Change Adaptation Policy (January 2012)

Executive Order 13653: Preparing the United States for the Impacts of Climate

Change (November 2013)

This Guide supersedes the following policies:













“Multi-Hazard Mitigation Planning Guidance under the Disaster Mitigation Act 

of 2000” (January 2008) 

“Guidance to FEMA Regions and States for Updating Standard State MultiHazard Mitigation Plans” (Mitigation Planning Memorandum #5, November 6, 

2006) 

“Blue Book Guidance to FEMA Regions and States for New and Updated 

Enhanced State Multi-Hazard Mitigation Plans” (Mitigation Planning 

Memorandum #7, July 10, 2007) 

“Implementation of State Mitigation Plan 

Requirement for Severe Repetitive Loss 

Strategy” (Mitigation Planning 

Memorandum #9, January 11, 2008) 

“Enhanced Mitigation Plan Review 

Procedure” (Mitigation Planning 

Memorandum #14, December 6, 2010) 

“Restrictions on Grant Obligations to 

State, Tribal and Local Governments 

without a FEMA-Approved Mitigation 

Plan” (FP 306-112-1, August 19, 2013) 

FEMA supports hazard 

mitigation planning as a 

means to:

• Foster partnerships for 

natural hazard mitigation;

• Promote more resilient 

and sustainable states 

and communities; and

• Reduce the costs 

associated with disaster 

response and recovery.

1.2 Guiding Principles

1. Foster Cooperative Relationships.

FEMA will focus on maintaining a close

and constructive working relationship 

with the state. FEMA, as a partner with 

the state, will conduct plan review and approval, and will work with the states 

where possible, to help the states achieve mitigation goals through the 

implementation of activities and programs proposed in the plans. Plan review and 

approval should not be the sole focal point of communication concerning 

mitigation planning and programs. FEMA will facilitate technical assistance both 

during the approval period and during the plan update process to strengthen this 

relationship. 

2. Emphasis on the Planning Processes. FEMA encourages states to focus on a 

comprehensive and inclusive planning process to support mitigation throughout 

state government and at the community level. While the plan provides 

documentation of state mitigation planning processes, continuous coordination 

among state agencies and communities is the key to achieving mitigation goals 

and long-term resilience. 
State Mitigation Plan Review Guide 2015

Page | 3

3. Focus on Reducing Risks. Resilience4, in terms of mitigation planning, means 

the ability to adapt to changing conditions and prepare for, withstand, and

rapidly recover from disruptions caused by a hazard. State risk assessments must 

be current, relevant, and include new hazard data, such as recent events, current 

probability data, loss estimation models, or new flood studies as well as 

information from local and tribal mitigation plans, as applicable, and 

consideration of changing environmental or climate conditions that may affect 

and influence the long-term vulnerability from hazards in the state. FEMA 

recognizes there exists inherent uncertainty about future conditions and will work 

with states to identify tools and approaches that enable decision-making to reduce 

risks and increase resilience from a changing climate. An understanding of 

vulnerabilities will assist with prioritizing mitigation actions and policies that 

reduce risk from future events. 

4. Improve Mitigation Capabilities. FEMA seeks opportunities for engagement to 

support and advance hazard mitigation. The National Mitigation Framework

focuses on core capabilities, including community resilience and the connections 

between economy, housing, health and social services, infrastructure, as well as 

natural and cultural resources. State governments contribute to hazard mitigation 

through the integration of planning processes, policies, and programs. FEMA will 

work with the states to provide technical assistance beyond plan review and 

approval so that coordination and mitigation capabilities are strengthened. 

1.3 Organization

This Guide is organized as follows: 

1. Introduction 

2. Mitigation Planning Responsibilities 

3. Standard State Plan Requirements 

4. Enhanced State Plan Requirements 

Appendices 

A: Submission and Review Procedures 

B: State Mitigation Plan Review Tool 

C: Approval Letter Template 

D: Consultation Summary Template

Section 2 clarifies the state and FEMA responsibilities set forth in the mitigation planning 

regulations at 44 CFR Part 201, and explains the mitigation program consultation process 

for supporting state mitigation activities and programs. The sections on standard state

plan requirements and enhanced state plan requirements (Sections 3 and 4) describe the

Guiding Principles:

1. Foster Cooperative

Relationships.

2. Emphasis on the Planning

Processes.

3. Focus on Reducing Risks.

4. Improve Mitigation

Capabilities.

4 According to PPD 8 National Preparedness, the term "resilience" “refers to the ability to adapt to changing conditions 

and withstand and rapidly recover from disruption due to emergencies.”
State Mitigation Plan Review Guide 2015

Page | 4

requirements for each element reviewed by FEMA in order to approve the plan. Excerpts 

from the mitigation planning regulations are included for reference. 

Appendix A, Submission and Review Procedures, sets forth the standard operating 

procedures for the submission and review of both Standard and Enhanced state mitigation 

plans and includes information on: 

1. Communication

2. Plan Submittal

3. Plan Adoption

4. Plan Review Status 

5. Enhanced State Mitigation Plan Review 

6. Review of Mitigation Commitments 

Appendix B, State Mitigation Plan Review Tool, is for use by FEMA plan reviewers to 

determine if the plan meets the standard or enhanced state mitigation plan requirements, 

to provide more comprehensive feedback to the state to acknowledge where the plan 

exceeds minimum standard or enhanced state mitigation plan requirements, and to 

provide suggestions for improvements. State staff may use the Tool as a checklist to 

ensure all requirements have been addressed. 

Appendix C, Approval Letter Template, is for use by FEMA Mitigation Planning staff in 

communicating the plan approval status to the state. 

Appendix D, Consultation Summary Template, is for use by FEMA Mitigation staff to 

provide a written summary of the mitigation program consultation to the state. 
State Mitigation Plan Review Guide 2015

Page | 5

SECTION 2: MITIGATION PLANNING 

RESPONSIBILITIES

This section outlines the responsibilities for both FEMA and the state regarding the 

update, review, and approval of the state mitigation plan, including implementation, plan 

maintenance, and support of local and tribal, as applicable, mitigation planning, and 

review of the state’s mitigation planning program and commitments. 

This section is organized as follows: 

2.1 FEMA Responsibilities under 44 CFR Part 201

2.1.1 Communicating Mitigation Plan Status

2.1.2 Mitigation Program Consultation

2.2 State Responsibilities under 44 CFR Part 201 

2.1 FEMA Responsibilities

44 CFR REGULATORY TEXT

§201.3(b) The key responsibilities of the Regional Administrator are to:

(1) Oversee all FEMA related pre- and post-disaster hazard mitigation 

programs and activities;

(2) Provide technical assistance and training to State, local, and Indian tribal

governments regarding the mitigation planning process;

(3) Review and approve all Standard and Enhanced State Mitigation plans; 

(4) Review and approve all local mitigation plans, unless that authority has

been delegated to the State in accordance with §201.6(d);

(5) Conduct reviews, at least once every five years, of State mitigation 

activities, plans, and programs to ensure that mitigation commitments are

fulfilled, and when necessary, take action, including recovery of funds or 

denial of future funds, if mitigation commitments are not fulfilled.

§201.4(d) and

§201.6(d)(2)

The Regional review will be completed within 45 days after receipt from the

State, whenever possible.

§201.7(d)(2) The Regional review will be completed within 45 days after receipt from the

Indian tribal government, whenever possible.

2.1.1 Communicating Mitigation Plan Status 

At a minimum of 12 months prior to each state mitigation plan expiration date, FEMA 

will provide the state with written information, including but not limited to: 





State mitigation plan expiration date; 

Consequences of not having a FEMA-approved mitigation plan with respect to 

eligibility for the following FEMA programs: 

o

o

o

o

o

Public Assistance Categories C-G (PA C-G)

Fire Management Assistance Grants (FMAG)

Hazard Mitigation Grant Program (HMGP)

Pre-Disaster Mitigation (PDM)

Flood Mitigation Assistance (FMA)
State Mitigation Plan Review Guide 2015

Page | 6

 Availability of mitigation planning technical assistance. 

At a minimum of every 6 months, FEMA will provide the state with written information, 

including but not limited to: 







Local and tribal, as applicable, mitigation plan expiration dates; 

Consequences of not having a FEMA-approved mitigation plan with respect to 

eligibility for FEMA mitigation grants, such as HMGP, PDM, and FMA; and

Availability of mitigation planning training and technical assistance.

For more information on the mitigation plan requirement relative to eligibility for FEMA 

mitigation grants, refer to the Hazard Mitigation Assistance (HMA) Guidance.

2.1.2 Mitigation Program Consultation

FEMA is responsible for providing technical assistance and reviewing state activities, 

plans, and programs to ensure mitigation commitments are fulfilled. Many states and the 

corresponding FEMA Regional Mitigation staff already coordinate regularly on the status 

of the state’s mitigation program, in particular, the status of HMA grants or other FEMA 

assistance. 

FEMA will provide the opportunity for technical assistance through review and 

consultation on the state’s mitigation program, to be completed at least annually. The 

benefits of an annual mitigation program consultation to the state include but are not 

limited to: 









Promoting dialogue between FEMA and the state on the means to achieve, 

support, and maintain effective state mitigation programs; 

Identifying the status of the state’s mitigation program, including strengths and 

challenges, as well as specific needs and opportunities; 

Ensuring feedback to the state on maintaining continuous HMA grants 

management performance, particularly for states interested in developing an 

enhanced plan; and 

For states that currently have an approved enhanced plan, demonstrating 

continued mitigation capabilities, including HMA grants management 

performance, in advance of a plan update and not at the review of a five-year 

mitigation plan update. 

During the consultation, topics of discussion will include, but are not limited to, status of 

and specific needs for:













Advancing implementation of the state mitigation strategy; 

Ensuring the state mitigation plan remains relevant over the approval period;

Facilitating the plan update and approval process;

Building mitigation capabilities through training, technical assistance, and 

partnerships with FEMA and other Federal agencies;

Advancing local and tribal, as applicable, mitigation planning, including 

submitting approvable mitigation plans to FEMA; 

Maintaining and/or improving mitigation capabilities, with particular attention to 

human resources and funding; and 
State Mitigation Plan Review Guide 2015

Page | 7

 Maintaining and/or improving HMA grants management performance, including 

effectively using all available funding from FEMA mitigation programs. 

FEMA and the state may consider preparing a written agreement to establish expectations 

upfront. FEMA may include the agreement as an attachment to the plan approval letter,

as appropriate, or the state may include the agreement with the official adoption 

documentation of the plan to increase awareness and support. The benefits of a written 

agreement include: 











Clearly describes the topics to be discussed and outcomes targeted with the 

consultation process;

Identifies the appropriate FEMA and state staff that will be included in the 

consultation; 

Explains the responsibilities of key personnel from both FEMA and the state, as 

well as specific roles in the consultation; 

Clearly explains the process for coordinating with and collecting input into 

FEMA’s review, with particular emphasis on minimizing the level of effort by 

state participants; and 

Establishes:

o

o

o

o

Timeframe or dates for when consultation will occur; 

Location (such as state or FEMA office);

Method of contact (such as in person, phone, or video conference); and

Frequency (at least annually, but more frequently if requested).

For example, the consultation may be scheduled to align with an in-person 

meeting, such as the state’s Hazard Mitigation Planning Committee, a FEMA 

workshop, or a FEMA meeting; or the meeting may be held remotely, such as by 

phone or video conferencing. 

After each consultation, FEMA will provide the state with a summary of the discussion. 

Appendix D, Consultation Summary Template, is for use by FEMA Mitigation staff in 

preparing a summary of the discussion. FEMA will document recommendations for 

improvements to the State Mitigation Program and any items that should be corrected or 

modified before the next state mitigation plan update. FEMA will not require a state 

mitigation plan update as a result of the consultation. 
State Mitigation Plan Review Guide 2015

Page | 8

2.2 State Responsibilities

44 CFR REGULATORY TEXT

§201.3(c) The key responsibilities of the State are to coordinate all State and local

activities relating to hazard evaluation and mitigation and to:

(1) Prepare and submit to FEMA a Standard State Mitigation Plan following 

the criteria established in §201.4 as a condition of receiving nonemergency Stafford Act assistance and FEMA mitigation grants. In 

addition, a State may choose to address severe repetitive loss properties in

their plan as identified in §201.4(c)(3)(v) to receive the reduced cost share 

for the Flood Mitigation Assistance (FMA)

5

and Severe Repetitive Loss 

(SRL) programs,

6

pursuant to §79.4(c)(2) of this chapter.

(2) In order to be considered for the 20 percent HMGP funding, prepare and 

submit an Enhanced State Mitigation Plan in accordance with §201.5,

which must be reviewed and updated, if necessary, every 5 years from the 

date of the approval of the previous plan.

(3) At a minimum, review and update the Standard State Mitigation Plan every

5 years from the date of the approval of the previous plan in order to 

continue program eligibility.

(4) Make available the use of up to the 7 percent of HMGP funding for 

planning in accordance with §206.434.

(5) Provide technical assistance and training to local governments to assist 

them in applying for HMGP planning grants, and in developing local 

mitigation plans.

(6) For Managing States that have been approved under the criteria 

established by FEMA pursuant to 42 U.S.C. 5170c(c), review and approve

local mitigation plans in accordance with §201.6(d).

§201.4(a) Plan requirement. States must have an approved Standard State Mitigation

Plans meeting the requirements of this section as a condition of receiving nonemergency Stafford Act assistance and FEMA mitigation grants. Emergency 

assistance provided under 42 U.S.C. 5170a, 5170b, 5173, 5174, 5177, 5179,

5180, 5182, 5183, 5184, 5192 will not be affected. Mitigation planning grants 

provided through the Pre-disaster Mitigation (PDM) program, authorized

under section 203 of the Stafford Act, 42 U.S.C. 5133, will also continue to be 

available. The mitigation plan is the demonstration of the State's commitment

to reduce risks from natural hazards and serves as a guide for State decision 

makers as they commit resources to reducing the effects of natural hazards.

§201.4(c)(7) Assurances. The plan must include assurances that the State will comply with

all applicable Federal statutes and regulations in effect with respect to the

periods for which it receives grant funding, including 2 CFR parts 200 and

3002.

5

Under FMA, the Federal cost share is 90 percent for repetitive loss properties and 100 percent for severe repetitive 

loss properties [42 U.S.C. 4104c(d)(1),(2)]. 

6 The Biggert-Waters Flood Insurance Reform Act of 2012 (BW-12) (Public Law 112-131) consolidated the SRL

program into the FMA program.
State Mitigation Plan Review Guide 2015

Page | 9

44 CFR REGULATORY TEXT

§201.4(d) Review and updates. Plan must be reviewed and revised to reflect changes in

development, progress in statewide mitigation efforts, and changes in 

priorities and resubmitted for approval to the appropriate Regional 

Administrator every 5 years.

§201.6(d)(1) The State is responsible for the initial review and coordination of Local

Mitigation Plans prior to sending the plan to the appropriate FEMA 

Regional Office for formal review and approval.

§201.7(d)(1) Indian tribal governments interested in the option of being a subgrantee

under the State must submit the Tribal Mitigation Plan to the State Hazard

Mitigation Officer for review and coordination. The State is responsible for 

the initial review and coordination prior to sending the plan to the 

appropriate FEMA Regional Office for formal review and approval.

The state is responsible for providing supplemental data to FEMA, as requested. For 

example, FEMA may request data on HMA mitigation grants to verify performance. 

Further, the state is responsible for reviewing and submitting approvable state, local, and 

tribal, as applicable, mitigation plans to FEMA. If the state is not submitting approvable 

mitigation plans, FEMA will provide feedback as well as technical assistance or training, 

as needed. The objective is to decrease the required plan revisions by ensuring that plan 

developers understand the requirements as early as possible in the planning process. 

The state is responsible for communicating with local and tribal officials, as applicable, 

interested in applying through the state for FEMA assistance. FEMA encourages states to 

communicate with the appropriate officials regarding: 







Mitigation plan expiration dates; 

Consequences of not having a FEMA-approved mitigation plan with respect to 

eligibility for FEMA mitigation grants, such as HMGP, PDM, and FMA; and

Availability of funding and state-sponsored training and technical assistance

For more information on the mitigation plan requirement relative to eligibility for FEMA 

mitigation grants, refer to the HMA Guidance. 
State Mitigation Plan Review Guide 2015

Page | 10

This page is intentionally blank. 
State Mitigation Plan Review Guide 2015

Page | 11

SECTION 3: STANDARD STATE PLAN REQUIREMENTS 

This section provides detailed guidance on how FEMA interprets the various 

requirements of the regulations for all standard state mitigation plan reviews. The 

guidance is limited only to the minimum requirements of what must be in a standard state 

mitigation plan, and does not provide guidance on how the state may develop a plan. 

Each “element” links to a specific regulation, and citations are provided for reference. 

FEMA will not grant conditional approvals of standard state mitigation plans; all 

requirements must be met at time of approval.

This section is organized as follows: 

3.1 Planning Process

3.2 Hazard Identification and Risk Assessment 

3.3 Mitigation Strategy 

3.4 State Mitigation Capabilities 

3.5 Local Coordination and Mitigation Capabilities 

3.6 Plan Review, Evaluation, and Implementation 

3.7 Adoption and Assurances 

3.8 Repetitive Loss Strategy 

For additional information on standard state mitigation plan approvals, refer to Appendix 

A: Submission and Review Procedures.

3.1 Planning Process

The planning process is as important as the plan itself. Any successful planning activity, 

such as developing a comprehensive plan or local land use plan, involves a cross‐section

of stakeholders to reach consensus on desired outcomes or to resolve a problem. The

result is a common set of values and widespread support for directing financial, technical, 

and human resources to an agreed-upon course of action, usually identified in a plan. The 

same is true for mitigation planning. 

The National Mitigation Framework emphasizes the valuable role of collaboration among 

various sectors to ensure mitigation capabilities continually develop and that 

comprehensive mitigation includes strategies for all community systems. Examples of 

sectors with mitigation capabilities are those agencies and stakeholders with

responsibility for:



















Hazard data; 

Climate projections and data; 

Emergency management;

Economic development;

Land use and development;

Housing;

Health and social services;

Infrastructure; and 

Natural and cultural resources.

“An effective planning 

process is essential in 

developing and 

maintaining a good plan.”

44 CFR §201.4(b)
State Mitigation Plan Review Guide 2015

Page | 12

ELEMENT REQUIREMENTS

S1. Does the plan 

describe the process 

used to develop the 

plan? [44 CFR

7 §§201.4(b) and

8 (c)(1) ] 

Intent: To 

demonstrate a 

deliberative approach 

to plan development.

The plan must describe the current process used to update the plan, 

including how the plan was prepared, the schedule or timeframe, specific 

milestones and activities, the agencies and stakeholders who were 

involved in the process, and if the mitigation planning process was 

integrated to the extent possible with other state planning efforts. 

Agencies and stakeholders means state, local, and tribal agencies, 

colleges and universities, private entities, or private non-profit 

organizations, such as multi-jurisdictional utilities, that perform a critical 

function. 

Special Consideration: The plan must describe the planning process, but 

supporting documentation, such as meeting sign-in sheets and notes, 

does not need to be included in the plan itself. States are encouraged to 

retain supporting documentation as a permanent record of how decisions 

were made and who was involved. 

S2. Does the plan 

describe how the state 

coordinated with 

other agencies and 

stakeholders? [44

CFR §§201.4(b) and 

(c)(1)] 

Intent: To actively 

involve stakeholders 

with the data and 

expertise to develop 

the plan, but also with 

the responsibility or 

authority to

implement mitigation 

actions and reduce

risk state-wide.

The plan must describe how other state and Federal agencies and other 

stakeholders were involved in the process. At a minimum, the plan must 

describe how the state coordinated with other agencies and stakeholders 

responsible for the following sectors:

a. Emergency management; 

b. Economic development; 

c. Land use and development; 

d. Housing; 

e. Health and social services; 

f. Infrastructure; and 

g. Natural and cultural resources. 

Where coordination with agencies and stakeholders representing these 

sectors is not practicable, the plan must describe the limitations.

Involved in the process means engaged as participants and given the 

chance to provide input to affect the plan’s content. 

Special Consideration: While coordination with other agencies and 

stakeholders is foundational to the success of the plan update as well as 

implementation, FEMA acknowledges the inherent differences in state 

governance and capabilities. In evaluating coordination, FEMA will 

credit the state’s efforts to engage other agencies and stakeholders.

7

44 CFR §201.4(b): “Planning process. An effective planning process is essential in developing and maintaining a 

good plan. The mitigation planning process should include coordination with other state agencies, appropriate Federal 

agencies, interested groups, and be integrated to the extent possible with other ongoing state planning efforts as well as 

other FEMA mitigation programs and initiatives.”

8

44 CFR §201.4(c)(1): “Description of the planning process used to develop the plan, including how it was prepared, 

who was involved in the process, and how other agencies participated.”
State Mitigation Plan Review Guide 2015

Page | 13

3.2 Hazard Identification and Risk Assessment

The risk assessment provides the factual basis for activities proposed in the mitigation 

strategy that will reduce losses from identified hazards. The risk assessment makes a 

clear connection between the vulnerability and the proposed hazard mitigation actions. 

The risk assessment process focuses attention on areas most at risk by evaluating where 

populations, infrastructure, and critical facilities are vulnerable to hazards, and to what 

extent injuries or damage may occur. 

Hazard mitigation planning includes a process to assess vulnerability, identify a strategy 

to guide decisions and investments, and implement actions that will reduce risk, including 

impacts from a changing climate. Changes in the probability of future hazard events may 

include changes in location, increases or decreases to the impacts, and/or extent of known 

natural hazards, such as floods or droughts. Changes in temperature, intensity, hazard 

distribution, and/or frequency of weather events may increase vulnerability to these 

hazards in the future. 

FEMA’s Climate Change Adaptation Policy (2011-OPPA-01) directs FEMA programs 

and policies to integrate considerations of climate change adaptation9. The mitigation 

planning regulation (44 CFR Part 201) requires consideration of the probability of future 

hazard events as part of the risk assessment in order to reduce risks and potential damage. 

Past occurrences are important to a factual basis of hazard risk; however, the challenges 

posed by climate change10

, such as more intense storms, frequent heavy precipitation,

heat waves, drought, extreme flooding, and higher sea levels, could significantly alter the 

types and magnitudes of hazards impacting states in the future. Due to the inherent 

uncertainties with projections of future hazard

events, states are expected to look across the

whole community of partners (for example, 

public, private, academic, non-governmental, 

etc.) to identify the most relevant data and select 

the most appropriate methodologies to assess 

risks and vulnerability. 

State risk assessments characterize the impacts 

of natural hazard on both state assets as well as 

the jurisdictions throughout the state. This 

overview allows the state to compare potential 

Risk assessment evaluates 

where populations, 

infrastructure, and critical 

facilities are vulnerable to 

hazards, and to what extent 

injuries or damage may occur

9

Authorities: The Homeland Security Act of 2002, as amended (6 U.S.C. 101 et seq.); the Stafford Act; the President’s 

Executive Order 13514 “Federal Leadership in Environmental, Energy, and Economic Performance” (October 2009); 

the 2010 Climate Change Adaptation Report drafted by the Interagency Climate Change Adaptation Task Force; and 

the Instructions for Implementing Climate Change Adaptation Planning issued by the Council on Environmental 

Quality. 

10 According to the Intergovernmental Panel on Climate Change report, Fourth Assessment Report: Climate Change

2007, climate change refers to “a statistically significant variation in either the mean state of the climate or in its 

variability, persisting for an extended period (typically decades or longer). Climate change may be due to natural 

internal processes or external forcings, or to persistent anthropogenic changes in the composition of the atmosphere or 

in land use.”
State Mitigation Plan Review Guide 2015

Page | 14

losses and determine priorities for mitigation measures for its own infrastructure and 

critical facilities, but also to prioritize jurisdictions for receiving technical and financial 

support in not only developing more detailed community risk assessments but in 

implementing mitigation actions. 

FEMA encourages states to include summaries, evaluations, and overviews resulting 

from the analysis of risk assessment data, rather than the data itself, and to only include 

raw data, as needed, in support of summaries or conclusions. 

ELEMENT REQUIREMENTS

S3. Does the risk

assessment include 

an overview of the

type and location of 

all natural hazards

that can affect the 

state? [44 CFR

§201.4(c)(2)(i)11]

Intent: To 

understand natural 

hazards across the 

state in order to 

identify which 

hazard risks have 

been or may be the 

most significant and 

the locations that

have been or may be 

the most adversely

affected.

a. The plan must include a current summary of the natural hazards that

can affect the state. The summary must include information on 

location, extent, and previous occurrences for each natural hazard,

using maps where appropriate.

b. If any commonly recognized natural hazards are omitted, the plan 

must provide an explanation.

Manmade or human-caused hazards may be included in the risk 

assessment but are not required. FEMA will neither review these hazards 

nor require the removal of this extra information prior to plan approval.

Natural hazards are a source of harm or difficulty created by a 

meteorological, environmental, or geological phenomenon or 

combination of phenomena.

12

Risk for the purpose of hazard mitigation planning is the potential for 

damage or loss created by the interaction of natural hazards with assets, 

such as buildings, infrastructure, or natural and cultural resources.

Extent means the strength or magnitude of the hazard. Extent is not the 

same as impacts.

Impacts are the consequences or effect of the hazard on the state, 

including assets and jurisdictions. The type and severity of the impact 

depend on the vulnerability of the asset, as well as the capabilities in 

place to mitigate, prepare for, respond to, and recover from events.

The exposure of people and assets to natural hazards can result in 

disasters, depending on the impacts.

11 44 CFR §201.4(c)(2)(i): “An overview of the type and location of all natural hazards that can affect the state, 

including information on previous occurrences of hazard events, as well as the probability of future hazard events, 

using maps where appropriate;”

12 U.S. Department of Homeland Security Risk Lexicon, 2010 Edition. 
State Mitigation Plan Review Guide 2015

Page | 15

ELEMENT REQUIREMENTS

S4. Does the risk

assessment provide 

an overview of the 

probabilities of 

future hazard 

events? [44 CFR

§201.4(c)(2)(i)]

Intent: To 

understand the 

probability of hazard 

events in the future

as the basis for 

anticipated impacts 

of hazard risks 

statewide.

a. The risk assessment must provide a summary of the probability of

future hazard events that includes projected changes in occurrences 

for each natural hazard in terms of location, extent, intensity, 

frequency, and/or duration.

b. Probability must include considerations of changing future 

conditions, including the effects of long-term changes in weather

patterns and climate on the identified hazards.

Probability means the likelihood of the hazard occurring and may be 

defined in terms of general descriptors (for example, unlikely, likely, 

highly likely), historical frequencies, statistical probabilities (for 

example: 1% chance of occurrence in any given year), and/or hazard 

probability maps. If using general descriptors, then the plan must 

provide a definition. For example, “highly likely” could be defined as

equals near 100% chance of occurrence next year or happens every year.

S5. Does the risk

assessment address 

the vulnerability of

state assets located

in hazard areas and 

estimate the

potential dollar

losses to these 

assets? [44 CFR

§§201.4(c)(2)(ii)

13

and

201.4(c)(2)(iii)14]

Intent: To 

understand 

vulnerability of 

assets critical for 

state resilience as a 

basis for identifying 

and prioritizing 

mitigation actions.

a. The risk assessment must include an analysis of the potential

impacts of hazard events to state assets and a summary of the assets 

most vulnerable to the identified hazards. These assets may be

located in the identified hazard areas or affected by the probability

of future hazard events.

b. The risk assessment must estimate potential dollar losses to state 

assets located in identified hazard areas.

Vulnerability and potential losses are not a list or inventory of state 

facilities but the summary of the potential impacts to those assets from 

the identified hazards. Factors affecting vulnerability may include asset 

use and function as well as construction type, age, or intended use.

State assets may include state-owned or operated buildings, 

infrastructure, and critical facilities.

Critical facilities

15 means structures that the state determines must 

continue to operate before, during, and after an emergency and/or hazard 

event and/or are vital to health and safety. Examples of critical facilities 

may include, but are not limited to:

 Emergency operations centers, police and fire stations, and storage 

facilities (including data storage).

 Structures that house occupants with restricted mobility or access 

and/or functional needs, such as hospitals, institutions, and shelters.

 Utility generating, transmission, and storage facilities and related 

infrastructure, such as power and/or water treatment plants.

 Transportation facilities, such as ports, airports, roads, railroads, 

bridges, and/or tunnels.

13 44 CFR §201.4(c)(2)(ii): “An overview and analysis of the State's vulnerability to the hazards described in this 

paragraph (c)(2), based on estimates provided in local risk assessments as well as the State risk assessment. The State 

shall describe vulnerability in terms of the jurisdictions most threatened by the identified hazards, and most vulnerable
State Mitigation Plan Review Guide 2015

Page | 16

ELEMENT REQUIREMENTS

S6. Does the risk 

assessment include 

an overview and 

analysis of the 

vulnerability of 

jurisdictions to the 

identified hazards 

and the potential 

losses to vulnerable 

structures? [44 CFR

§§201.4(c)(2)(ii) and 

201.4(c)(2)(iii)] 

Intent: To 

understand potential 

impacts of future 

hazard events on

jurisdictions

a. The risk assessment must provide a current summary of the most 

vulnerable jurisdictions based on the state, local, and tribal, as 

applicable, risk assessments. Vulnerability must be analyzed in terms 

of: 

1. Jurisdictions most threatened by the identified hazards (based on 

hazard location, extent, and probability). 

2. Jurisdictions most susceptible to damage and loss from hazard 

events related to populations and assets (such as, structures, 

infrastructure, critical facilities, and systems). These populations 

and assets may be located in the identified hazard areas or 

affected by the probability of future hazard events.

b. The risk assessment must include a summary of the potential losses 

to the identified vulnerable structures based on estimates in the local 

risk assessments as well as the state risk assessment. 

c. If the state is interested in an increased Federal cost share under the

FMA program, the risk assessment must address repetitive loss (RL)

16

throughout the state 

as the basis for

and SRL properties.

Strategy.)

(See RL1 in Section 3.8 Repetitive Loss

identifying and 

prioritizing

mitigation actions.

Special Consideration: An overview or summary provides the results of 

the analysis and does not need to include the details from each local 

plan. An example is a list of key issues or problem statements that 

clearly describes the greatest vulnerabilities and compares losses across 

the state, allowing the state to determine mitigation priorities.

to damage and loss associated with hazard events. State owned or operated critical facilities located in the identified 

hazard areas shall also be addressed.”

14 44 CFR §201.4(c)(2)(iii): “An overview and analysis of potential losses to the identified vulnerable structures, based 

on estimates provided in local risk assessments as well as the State risk assessment. The State shall estimate the 

potential dollar losses to State owned or operated buildings, infrastructure, and critical facilities located in the identified 

hazard areas.”

15 Adapted from 44 CFR §9.4 Definitions (critical action) and National Flood Insurance Program Community Rating 

System Coordinator’s Manual (2013); definition and examples do not supersede any regulatory definitions.

16 For the current RL and SRL property definitions consistent with the changes in the BW-12, refer to the HMA 

Guidance (Part VIII. Additional Program Guidance: C. Flood Mitigation Assistance Program).
State Mitigation Plan Review Guide 2015

Page | 17

ELEMENT REQUIREMENTS

S7. Was the risk 

assessment revised 

to reflect changes in 

development? [44 

CFR §201.4(d)17] 

Intent: To ensure 

that the mitigation 

strategy addresses 

the risk and 

vulnerabilities to 

existing and 

potential 

development, and 

takes into 

consideration 

possible future 

conditions that can 

impact statewide 

vulnerability.

The plan must provide a summary of the changes in development that 

have occurred or are projected to occur in hazard prone areas based on 

the state, local, and tribal, as applicable, risk assessments, specifically: 

a. Changes in land use and the built environment; 

b. Changes in population demographics that may affect vulnerability 

to hazard events; and 

c. Changes to the vulnerability of state-owned or operated buildings,

infrastructure, and critical facilities. 

Changes in development means recent development, potential and 

projected land use and development, or conditions that may affect risk 

and vulnerability to the state and jurisdictions within the state, such as 

changes in population demographics. 

3.3 Mitigation Strategy

The mitigation strategy serves as the long‐term blueprint for reducing the potential losses

identified in the risk assessment, or in other words the mitigation strategy represents riskbased decisions. Included in the strategy are goals, or the long‐term policy statements and

global visions that support the mitigation strategy. The Stafford Act directs state

mitigation plans to identify hazard mitigation goals and actions and establish a strategy to 

implement those actions. 

A critical component of updating the state’s mitigation strategy is the consideration of 

and inclusion of the local and tribal, as applicable, mitigation plan strategies. By 

reviewing, prioritizing, and incorporating the types or categories of actions identified by 

communities, the state can better understand how it can support investments in local and 

tribal, as applicable, mitigation efforts. The state is thus pre-positioned to provide the 

appropriate resources for this support when available, such as post-disaster when 

recovery and mitigation assistance are authorized. 

17 44 CFR §201.4(d): “Review and updates. Plan must be reviewed and revised to reflect changes in development, 

progress in statewide mitigation efforts, and changes in priorities and resubmitted for approval to the appropriate 

Regional Administrator every 5 years.”
State Mitigation Plan Review Guide 2015

Page | 18

ELEMENT REQUIREMENTS

S8. Does the mitigation strategy

include goals to reduce long-term 

vulnerabilities from the identified

hazards? [44 CFR

§201.4(c)(3)(i)18]

Intent: To guide development and 

implementation of hazard 

mitigation actions. Goals are 

statements of the vision for the 

future.

a. The plan must identify hazard mitigation goals

representing what the state seeks to accomplish through 

mitigation plan implementation.

b. The goals must be consistent with the hazards and 

vulnerabilities identified in the risk assessment.

c. The goals must address reducing the vulnerability of 

jurisdictions within the state as well as the vulnerability 

of state-owned or operated buildings, infrastructure, and

critical facilities.

d. If the state is interested in an increased Federal cost 

share under the FMA program, the plan must include

goals to address RL and SRL properties. (See RL2 in

Section 3.8 Repetitive Loss Strategy.)

Goals are broad, long-term policy and vision statements that 

explain what is to be achieved by implementing the 

mitigation strategy.

S9. Does the plan prioritize

mitigation actions to reduce 

vulnerabilities identified in the 

risk assessment? [44 CFR

§§201.4(c)(3)(iii)19 and (iv)

20]

Intent: To establish specific 

hazard mitigation actions that

will be implemented to reduce the

vulnerabilities identified in the 

risk assessment. This is the heart 

of the mitigation plan, and is

essential to leading statewide 

mitigation programs to reduce 

risk.

a. The plan must identify actions based on the current risk

assessment to reduce the vulnerability of jurisdictions 

within the state as well as the vulnerability of stateowned or operated buildings, infrastructure, and critical 

facilities.

b. The plan must describe the process used by the state to 

evaluate and prioritize actions that are cost effective, 

environmentally sound, and technically feasible.

c. The plan must describe how each action contributes to 

the hazard mitigation goals.

d. The plan must describe how the local and tribal, as 

applicable, mitigation strategies are linked with the state 

mitigation strategy.

e. If the state is interested in an increased Federal cost 

share under the FMA program, the plan must address

RL and SRL properties in the risk assessment. (See RL3 

in Section 3.8 Repetitive Loss Strategy.)

18 44 CFR §201.4(c)(3)(i): “A description of State goals to guide the selection of activities to mitigate and reduce 

potential losses.”

19 44 CFR §201.4(c)(3)(iii): “An identification, evaluation, and prioritization of cost-effective, environmentally sound, 

and technically feasible mitigation actions and activities the State is considering and an explanation of how each 

activity contributes to the overall mitigation strategy. This section should be linked to local plans, where specific local 

actions and projects are identified.”

20 44 CFR §201.4(c)(3)(iv): “Identification of current and potential sources of Federal, State, local, or private funding 

to implement mitigation activities.”
State Mitigation Plan Review Guide 2015

Page | 19

ELEMENT REQUIREMENTS

S10. Does the plan identify

current and potential sources of 

funding to implement mitigation

actions and activities? [44 CFR

§201.4(c)(3)(iv)]

Intent: For the responsible entity 

to take action to complete 

activities and projects as funding 

opportunities to implement them 

arise.

a. Each mitigation action or project must include the

identification of current and/or potential sources of

Federal, state, local, tribal, as applicable, or private 

funding for implementation.

b. At a minimum, the plan must identify FEMA mitigation

funding sources, including, if applicable, but not limited 

to HMGP, PDM, FMA, and PA C-G.

21

c. If the state is interested in an increased Federal cost

share under the FMA program, the plan must address 

identify current and potential sources of funding with 

respect to RL and SRL properties. (See RL4 in Section

3.8 Repetitive Loss Strategy.)

S11. Was the plan updated to

reflect progress in statewide 

mitigation efforts and changes in

priorities? [44 CFR §201.4(d)]

Intent: To evaluate progress in 

implementing the mitigation 

strategy and to ensure the plan 

reflects current conditions, 

including financial, legal, and 

political realities and postdisaster conditions.

a. The plan must describe the status of hazard mitigation

actions in the previous plan by identifying those that 

have been completed or not completed. For those

actions not completed, the plan must provide a narrative

describing the status (for example, is the action relevant 

or will it be included in the plan update).

b. The prioritization of mitigation actions and activities

must be updated based on the updated analysis of risks, 

capabilities, and progress.

3.4 State Mitigation Capabilities

Capabilities provide the means to accomplish a desired outcome. In the context of 

mitigation planning, the state capability assessment should not only address the ways the 

state’s existing capabilities can aid the mitigation effort, but also address areas in which 

the state needs to strengthen its capabilities. This is not simply a list or report of existing 

programs, but an assessment based on existing capabilities that demonstrates the state’s 

commitment to mitigation, identifies a wide range of resources from which to implement 

mitigation activities, and reveals areas to target improvements. Without an assessment of 

the state’s capability, implementation of the plan could stall from inadequate resources.

21 Stafford Act, §406(e) Repair, Restoration, and Replacement of Damaged Facilities and 44 CFR §206.226 

Restoration of damaged facilities. FEMA Recovery Policy 9526.1 “Hazard Mitigation Funding Under Section 406 

(Stafford Act)”, dated March 30, 2010. 
State Mitigation Plan Review Guide 2015

Page | 20

ELEMENT REQUIREMENTS

S12. Does the plan discuss the

evaluation of the state’s hazard

management policies, programs, 

capabilities, and funding sources

to mitigate the hazards identified

in the risk assessment? [44 CFR

§201.4(c)(3)(ii)

22]

Intent: To identify and build the 

state’s capabilities to reduce risk 

and increase resilience.

The plan must describe existing state pre- and post-disaster

hazard management policies, programs, and capabilities to 

mitigate the hazards in the state, including:

a. An evaluation of state laws, regulations, policies, and 

programs related to hazard mitigation, as well as to 

development in hazard-prone areas, to include the 

state’s administration of the:

1. National Flood Insurance Program (NFIP) and

Community Rating System (CRS); and

2. Risk Mapping, Assessment, and Planning (Risk

MAP) program.

b. A discussion of state funding capabilities for hazard 

mitigation projects, including:

1. A general description of how the state has used its 

own funds for hazard mitigation projects; and

2. A general discussion of how the state has used

FEMA mitigation programs and funding sources, 

including but not limited to:

a. HMGP, PDM, and FMA; and

b. PA C-G.

c. A general summary of:

1. Obstacles and challenges; and

2. Changes since the previous plan approval.

3.5 Local Coordination and Mitigation Capabilities

Just as all disasters are local, all mitigation is local. The state bears the responsibility of 

supporting local and tribal, as applicable, governments with mitigation planning through 

training, technical assistance, and where available, funding. This ensures that the 

community is aware of hazard data, planning resources, and state priorities for mitigation. 

Likewise, consideration of local and tribal, as applicable, mitigation strategies and 

capabilities informs and influences the state’s risk assessment and mitigation priorities. 

22 44 CFR §201.4(c)(3)(ii): “A discussion of the State’s pre and post-disaster hazard management policies, programs, 

and capabilities to mitigate the hazards in the area, including: an evaluation of State laws, regulations, policies, and 

programs related to hazard mitigation as well as to development in hazard-prone areas; a discussion of State funding 

capabilities for hazard mitigation projects; a general description and analysis of the effectiveness of local mitigation 

policies, programs, and capabilities.”
State Mitigation Plan Review Guide 2015

Page | 21

ELEMENT REQUIREMENTS

S13. Does the plan generally

describe and analyze the 

effectiveness of local and tribal,

as applicable, mitigation policies, 

programs, and capabilities? [44

CFR §201.4(c)(3)(ii)]

Intent: To ensure the state 

understands the local and tribal, 

as applicable, jurisdictions’ 

capabilities to accomplish 

hazard mitigation, particularly 

as capability varies across 

jurisdictions.

a. The plan must provide a general summary of current

local and tribal, as applicable, policies, programs, and 

capabilities of jurisdictions to accomplish hazard

mitigation.

b. The plan must describe the effectiveness of local and 

tribal, as applicable, mitigation policies, programs, and

capabilities, including:

1. Challenges to implementing local and tribal, as 

applicable, mitigation policies, programs, and 

capabilities.

2. Opportunities for implementing mitigation actions 

through local and tribal, as applicable, capabilities.

c. If the state is interested in an increased Federal share 

under the FMA program, the plan must include RL and 

SRL properties in the analysis of effectiveness. (See

RL5 in Section 3.8 Repetitive Loss Strategy.)

S14. Does the plan describe the

process to support the 

development of approvable local

and tribal, as applicable,

mitigation plans? [44 CFR

§§201.3(c)(5)

23 and

201.4(c)(4)(i)24]

Intent: To direct state resources 

toward effective local and tribal, 

as applicable, mitigation 

planning.

a. The plan must describe how the state supports

developing or updating FEMA-approvable local and 

tribal, as applicable, mitigation plans, including the

process used to provide:

1. Training;

2. Technical assistance; and

3. Funding [NOTE: criteria for prioritizing funding 

for planning and project awards are addressed in

S15].

b. The plan must provide a summary of the:

1. FEMA-approved local and tribal, as applicable, 

mitigation plan coverage;

2. Barriers to developing or updating, adopting, and 

implementing FEMA-approved local and tribal, as

applicable, mitigation plans; and

3. Approach to remove barriers in order to advance 

local and tribal, as applicable, mitigation planning.

23 44 CFR §201.3(c)(5): “Provide technical assistance and training to local governments to assist them in applying for 

HMGP planning grants, and in developing local mitigation plans.”

24 44 CFR §201.4(c)(4)(i): “A description of the State process to support, through funding and technical assistance, the 

development of local mitigation plans.”
State Mitigation Plan Review Guide 2015

Page | 22

ELEMENT REQUIREMENTS

S15. Does the plan describe the

criteria for prioritizing funding? 

[44 CFR §201.4(c)(4)(iii)

25]

Intent: To guide investment 

decisions and communicate state 

priorities for mitigation actions.

a. The plan must describe criteria for prioritizing

jurisdictions to receive planning and project grants under 

available Federal and non-Federal programs. A principal

criterion for prioritizing grants shall be the extent to 

which benefits are maximized.

b. If the state is interested in an increased Federal share 

under the FMA program, the plan must address RL and 

SRL properties when prioritizing funding. (See RL6 in

Section 3.8 Repetitive Loss Strategy.)

S16. Does the plan describe the

process and timeframe to review, 

coordinate, and link local and

tribal, as applicable, mitigation 

plans with the state mitigation 

plan? [44 CFR §§201.3(c)(6),

26

201.4(c)(2)(ii), 201.4(c)(3)(iii), 

and 201.4(c)(4)(ii)27]

Intent: To streamline the review 

and approval of local and tribal, 

as applicable, mitigation plans, 

create a common understanding 

of risk, and align mitigation 

strategies between state, local, 

and tribal, as applicable, plans.

a. The plan must describe the process and timeframe used

by the state to review and submit approvable local and 

tribal, as applicable, mitigation plans to FEMA.

b. The plan must describe the process and timeframe used 

by the state to coordinate and link risk assessments and

mitigation strategy information from local and tribal, as 

applicable, mitigation plans into the state mitigation 

plan.

3.6 Plan Review, Evaluation, and Implementation

In order to continue to be an effective representation of the state’s overall strategy for 

reducing risks from natural hazards, the mitigation plan must reflect current conditions, 

including trends or anticipated growth and development statewide. Impacts of future 

hazard events on current and projected land use and development should be the driving 

influence of decisions on mitigation priorities for the next five years, but should also look 

outward to the long-term 10- or 20-year planning period. 

The plan update is an opportunity for the state to assess previous goals and action plan, 

evaluate progress in implementing hazard mitigation actions, and adjust actions to 

25 44 CFR §201.4(c)(4)(iii): “Criteria for prioritizing communities and local jurisdictions that would receive planning 

and project grants under available funding programs, which should include consideration for communities with the 

highest risks, repetitive loss properties, and most intense development pressures. Further, that for non-planning grants, 

a principal criterion for prioritizing grants shall be the extent to which benefits are maximized according to a cost 

benefit review of proposed projects and their associated costs.”

26 44 CFR §201.3(c)(6): “For Managing States that have been approved under the criteria established by FEMA 

pursuant to 42 U.S.C. 5170c(c), review and approve local mitigation plans in accordance with §201.6(d).”

27 44 CFR §201.4(c)(4)(ii): “A description of the State process and timeframe by which the local plans will be 

reviewed, coordinated, and linked to the State Mitigation Plan.”
State Mitigation Plan Review Guide 2015

Page | 23

address the current and projected realities. Where conditions of growth or revisions in 

priorities may have changed very little, much of the text in the updated plan may be 

unchanged. This is acceptable as long as the plan still fits the priorities of the state and 

reflects current conditions. 

ELEMENT REQUIREMENTS

S17. Is there a 

description of the 

method and schedule for

keeping the plan current? 

[44 CFR

28 §§201.4(c)(5)(i) and

29 201.4(d) ] 

Intent: To ensure the 

implementation of the 

plan over time, but also 

to ensure the plan 

remains current and 

reflects changes to the 

statewide mitigation 

program.

The plan must describe the process to monitor, evaluate, and update 

the plan, specifically the: 

a. Agency/office responsible for monitoring, evaluating, and 

updating; and 

b. Schedule for monitoring, evaluating, and updating. 

Monitoring means tracking the relevance and implementation of the 

plan over time and includes all elements of the plan. 

Evaluating means assessing the effectiveness of the plan at achieving 

the goals and objectives. 

Special Consideration: Various methods are possible for keeping the 

plan current. For example, one method may be to amend the plan, as 

appropriate, using annexes to document changes during the plan 

approval period that can be more fully integrated during the next plan 

update cycle.

S18. Does the plan 

describe the systems for 

monitoring 

implementation and 

reviewing progress? [44 

30 CFR §§201.4(c)(5)(ii)

31 and 201.4(c)(5)(iii) ] 

Intent: To establish a 

process for collecting 

and evaluating feedback 

on the state’s progress 

toward long-term goals 

for resiliency.

a.

b. 

c.

The plan must describe the system for tracking the 

implementation of the mitigation activities and projects 

identified in the mitigation strategy. This includes all mitigation 

activities, not just those funded by FEMA. 

The system must include the following: 

1. A schedule; 

2. Agency/office responsible for coordination; and 

3. Role of the agencies/offices identified in the mitigation 

strategy as responsible for implementation of actions. 

The plan must describe a system for reviewing progress on 

achieving the goals of the mitigation strategy that includes the 

criteria and process for evaluating progress.

3.7 Adoption and Assurances

Plan adoption by the state’s highest elected official or designee demonstrates 

commitment to the mitigation strategy and may serve as a means to communicate

28 44 CFR §201.4(c)(5)(i): “An established method and schedule for monitoring, evaluating, and updating the plan.”

29 44 CFR §201.4(d): “Plan must be reviewed and revised to reflect changes in development, progress in statewide 

mitigation efforts, and changes in priorities and resubmitted for approval to the appropriate Regional Administrator 

every five years.”

30 44 CFR §201.4(c)(5)(ii): “A system for monitoring implementation of mitigation measures and project closeouts.”

31 44 CFR §201.4(c)(5)(iii): “A system for reviewing progress on achieving goals as well as activities and projects

identified in the Mitigation Strategy.”
State Mitigation Plan Review Guide 2015

Page | 24

priorities to entities within the state agencies regarding vulnerability and mitigation 

measures. Plan adoption by the state’s highest elected official or designee may increase 

awareness of and support from the state agencies with mitigation capabilities and 

responsibilities, not just the state agency responsible for the mitigation planning program.

The assurances convey that the state is aware of and understands the obligations to 

comply with applicable Federal statutes and regulations. 

ELEMENT REQUIREMENTS

S19. Did the state provide

documentation that the plan

has been formally adopted?

[44 CFR §201.4(c)(6)

32]

Intent: Adoption 

demonstrates commitment to 

the goals and actions 

identified in the plan.

Ideally, adoption by the 

highest elected official or 

designee provides statewide 

recognition and 

demonstrates risk reduction 

as a statewide priority.

The state must provide documentation of formal adoption by the 

highest elected official or designee prior to the final review and 

approval by FEMA. Documentation of formal adoption may be a

resolution or other mechanism.

Highest elected official or designee means a senior state official

with authority to commit the various state agencies responsible 

for implementing the mitigation actions identified in the plan.

Special Consideration: After all other plan requirements have 

been met and FEMA has received the formal adoption 

documentation, FEMA will provide a letter indicating the plan is 

approved. See Appendix A: Submission and Review Procedures.

S20. Did the state provide 

assurances? [44 CFR

§201.4(c)(7)]

Intent: To confirm the 

state’s intent to comply with 

all applicable Federal

statutes and regulations.

a. The plan must include assurances that the state will manage 

and administer FEMA funding in accordance with applicable 

Federal statutes and regulations. For information on FEMA

mitigation grants programs award administration 

requirements, refer to the HMA Guidance (Part VI. Award 

Administration Information). For example, reporting

requirements include, but are not limited to, submitting 

quarterly financial and performance reports on time. 

b. The plan must include assurances that the state will amend its 

plan whenever necessary to reflect changes in state or Federal

laws and statutes.

Special Consideration: For information regarding consequences 

of failure to comply with applicable Federal statutes and 

regulations, see Appendix A: Submission and Review 

Procedures.

32 44 CFR §201.4(c)(6): “A Plan Adoption Process. The plan must be formally adopted by the State prior to submittal 

to us for final review and approval.”
State Mitigation Plan Review Guide 2015

Page | 25

3.8 Repetitive Loss Strategy

44 CFR REGULATORY TEXT

§201.2 Severe Repetitive Loss properties

33

are defined as single or multifamily 

residential properties that are covered under an NFIP flood insurance policy

and:

(1) That have incurred flood-related damage for which 4 or more 

separate claims payments have been made, with the amount of each

claim (including building and contents payments) exceeding $5,000,

and with the cumulative amount of such claims payments exceeding

$20,000; or

(2) For which at least 2 separate claims payments (building payments 

only) have been made under such coverage, with cumulative amount of

such claims exceeding the market value of the property.

(3) In both instances, at least 2 of the claims must be within 10 years of 

each other, and claims made within 10 days of each other will be 

counted as 1 claim.

§201.3(c)(1) [Note: text repeated from Section 2.2 State Responsibilities]

Prepare and submit to FEMA a Standard State Mitigation Plan following the 

criteria established in §201.4 as a condition of receiving non-emergency

Stafford Act assistance and FEMA mitigation grants. In addition, a State

may choose to address severe repetitive loss properties in their plan as 

identified in §201.4(c)(3)(v) to receive the reduced cost share for the Flood 

Mitigation Assistance (FMA)

34 and Severe Repetitive Loss (SRL) programs,35 

pursuant to §79.4(c)(2) of this chapter.

§201.4(c)(3)(v) A State may request the reduced cost share authorized under §79.4(c)(2) of

this chapter for the FMA and SRL

36

programs, if it has an approved State 

Mitigation Plan meeting the requirements of this section that also identifies

specific actions the State has taken to reduce the number of repetitive loss 

properties (which must include severe repetitive loss properties), and 

specifies how the State intends to reduce the number of such repetitive loss

properties. In addition, the plan must describe the strategy the State has to 

ensure that local jurisdictions with severe repetitive loss properties take 

actions to reduce the number of these properties, including the development 

of local mitigation plans.

The Repetitive Loss Strategy identifies actions to reduce damage to RL and SRL

properties throughout the state. For information on defining RL properties and areas and

33 For the current severe repetitive loss property definition consistent with the changes in the BW-12, refer to the HMA 

Guidance (Part VIII. Additional Program Guidance: C. Flood Mitigation Assistance Program).

34 Under FMA, the Federal cost share is 90 percent for repetitive loss properties and 100 percent for severe repetitive 

loss properties [42 U.S.C. §4104c(d)(1),(2)]. 

35 BW-12 consolidated the SRL program into the FMA program.

36 BW-12 consolidated the SRL program into the FMA program. 
State Mitigation Plan Review Guide 2015

Page | 26

identifying flood mitigation activities, as well as to access the “Repetitive Loss Update

Worksheet” (AW-501), refer to the NFIP CRS Coordinator’s Manual.

Under the FMA program, states have the option to develop a Repetitive Loss Strategy for 

RL and SRL properties to be eligible to request an increased Federal cost share. For FMA 

program requirements, including eligible property requirements and definitions for RL 

and SRL properties consistent with the changes in BW-12, refer to the HMA Guidance

(Part VIII. Additional Program Guidance: C. Flood Mitigation Assistance Program). 

To be eligible for the increased Federal cost share under FMA, the Repetitive Loss 

Strategy must address the following requirements: 

ELEMENT REQUIREMENTS

RL. Did the state 

develop a Repetitive 

Loss Strategy? [44 CFR

§201.4(c)(3)(v)] 

Intent: Describe how 

the state intends to 

reduce the number of 

repetitive loss 

properties (which must 

include severe 

repetitive loss 

properties).

1. RL1. Did Element S6 (risk assessment) address RL and SRL 

properties? [44 CFR §§201.4(c)(2)(ii), 201.4(c)(2)(iii), and 

201.4(c)(3)(v)] 

2. RL2. Did Element S8 (mitigation goals) address RL and SRL 

properties? [44 CFR §§201.4(c)(3)(i) and 201.4(c)(3)(v)] 

3. RL3. Did Element S9 (mitigation actions) address RL and SRL 

properties? [44 CFR §§201.4(c)(3)(iii) and 201.4(c)(3)(v)] 

4. RL4. Did Element S10 (funding sources) address RL and SRL 

properties? [44 CFR §§201.4(c)(3)(iv) and 201.4(c)(3)(v)] 

5. RL5. Did Element S13 (local and tribal [as applicable] 

capabilities) address RL and SRL properties? [44 CFR

§§201.4(c)(3)(ii) and 201.4(c)(3)(v)] 

6. RL6. Did Element S15 (prioritizing funding) address RL and SRL 

properties? [44 CFR §§201.4(c)(4)(iii) and 201.4(c)(3)(v)]

Special Consideration: Descriptions of the various programs and 

initiatives to meet this requirement do not need to be repeated in a 

separate section. However, if the documentation to meet this 

requirement is not a separate section, the Plan Review Tool (refer to 

Appendix B: State Mitigation Plan Review Tool) should identify 

where in the plan the descriptions are found. 
State Mitigation Plan Review Guide 2015

SECTION 4: ENHANCED STATE PLAN REQUIREMENTS 

A FEMA-approved enhanced state mitigation plan documents sustained, proven 

commitment to hazard mitigation. This designation recognizes current or ongoing 

proactive efforts in implementing a comprehensive program. The enhanced status 

acknowledges the coordinated effort a state37 currently is taking to reduce losses, protect 

life and property, and create safer communities. Approval of an enhanced state mitigation 

plan results in eligibility for increased HMGP funding. 

44 CFR REGULATORY TEXT

§201.5(a) A State with a FEMA-approved Enhanced State Mitigation Plan at the time of a

disaster declaration is eligible to receive increased funds under the HMGP, based 

on twenty percent of the total estimated eligible Stafford Act disaster assistance.

The Enhanced State Mitigation Plan must demonstrate that a State has developed

a comprehensive mitigation program, that the State effectively uses available 

mitigation funding, and that it is capable of managing the increased funding. In 

order for the State to be eligible for the 20 percent HMGP funding, FEMA must 

have approved the plan within 5 years prior to the disaster declaration.

The capabilities listed in 44 CFR §201.5(a) demonstrate increased capabilities that build 

on, and exceed, the standard mitigation plan requirements. States seeking Enhanced 

status must “demonstrate” through a narrative and examples that the state is already 

clearly engaged in processes, activities or initiatives that further risk reduction. FEMA 

expects that information on the state processes, activities, or initiatives are already 

incorporated into the plan or can be independently validated. 

FEMA will not grant conditional approvals of Enhanced state mitigation plans; all 

requirements must be met at time of approval.

This section provides detailed guidance on how FEMA interprets the various 

requirements of the regulation for all enhanced state mitigation plan reviews. The 

guidance is limited only to the minimum requirements of what must be in an enhanced 

state mitigation plan, and does not provide guidance on how the state may develop a plan. 

Each element links to a specific regulation, and citations are provided for reference. 

This section is organized as follows: 

4.1 Meet Required Standard Plan Elements 

4.2 Integrated Planning 

4.3 State Mitigation Capabilities 

4.4 HMA Grants Management Performance 

For additional information on enhanced state mitigation plan approvals, please see 

Appendix A: Submission and Review Procedures.

37 44 CFR §201.3(e)(3): “In order to be considered for the increased HMGP funding, the Tribal Mitigation Plan must 

meet the Enhanced State Mitigation Plan criteria identified in §201.5.”

Page | 27
State Mitigation Plan Review Guide 2015

Page | 28

4.1 Meet Required Standard Plan Elements

In order to be considered for Enhanced status, the plan must contain all of the required 

elements of the standard state mitigation plan. 

ELEMENT REQUIREMENTS

E1. Does the enhanced plan include all 

elements of the standard state mitigation 

plan? [44 CFR §201.5(b)

38]

Intent: To meet the minimum 

requirements for a state mitigation plan 

under 44 CFR §201.4.

The enhanced plan must meet all the required 

elements of the standard state mitigation plan.

4.2 Integrated Planning

States that are “enhanced” can demonstrate a history of integration with agencies and 

stakeholders with mitigation capabilities or shared objectives to reduce risks from natural 

hazards. The National Mitigation Framework describes integration in terms of 

“Coordinating Structures,” which include the organizations, agencies, groups, 

committees, and teams that carry out activities in support of building resiliency. It also 

includes other programs, procedures, or initiatives carried out by a cross-section of state 

partners that work together to identify and implement effective, long-term mitigation 

solutions. For example, the Silver Jackets program developed through the U.S. Army 

Corps of Engineers facilitates the integration of agencies in various states.39

In terms of enhanced state mitigation planning, integrated planning means embedding 

mitigation in other state planning, decision making, and development, as well as enabling 

other agency planning initiatives to inform the state’s mitigation strategy. No single 

agency can be solely responsible for mitigation across all community sectors, but 

collaboration among stakeholders with the authority, interest, and expertise to implement 

mitigation measures enables the leveraging of resources to reduce risk and increase 

resilience. 

38 44 CFR §201.5(b): “Enhanced State Mitigation Plans must include all elements of the Standard State Mitigation plan 

identified in §201.4.”

39 National Mitigation Framework, FEMA, May 2013. 
State Mitigation Plan Review Guide 2015

Page | 29

ELEMENTS REQUIREMENTS

E2. Does the plan 

demonstrate integration to 

the extent practicable with 

other state and/or regional 

planning initiatives and 

FEMA mitigation 

programs and initiatives? 

40 [44 CFR §201.5(b)(1) ] 

Intent: To demonstrate 

realized integration with 

other planning initiatives 

and mitigation programs 

into ongoing state 

activities that achieve risk 

reduction and resilience.

a. The Enhanced plan must demonstrate integration with other 

state and/or regional planning initiatives, including, at a 

minimum, the following sectors: 

1. Emergency management; 

2. Economic development; 

3. Land use development; 

4. Housing; 

5. Health and social services;

6. Infrastructure; and 

7. Natural and cultural resources. 

Where integration with other state and/or regional planning 

initiatives representing these sectors is not practicable, the plan 

must describe the limitations.

b. The Enhanced plan must demonstrate integration of FEMA 

mitigation programs and initiatives, including, if applicable, 

but not limited to: HMGP, PDM, FMA, NFIP, CRS, Risk 

MAP, and the National Dam Safety Program, as well as 

FEMA programs that advance mitigation, such as Threat 

Hazard Identification and Risk Assessment, Emergency 

Management Performance Grant Program, and PA C-G. 

Where integration with FEMA mitigation programs and 

initiatives is not practicable, the plan must describe the 

limitations. 

Special Consideration: In evaluating integration, consideration 

will be given to the inherent differences in governance and 

capabilities among states, crediting measurable progress towards 

integration of efforts. 

4.3 State Mitigation Capabilities

States with enhanced state mitigation plans are able to demonstrate successfully 

implemented programs or projects that reduce exposure to hazards or other mechanisms 

that show the state has exceeded the requirements of the standard plan. Where the state 

standard mitigation plan requires the evaluation of capabilities (see Element S12), 

enhanced states can demonstrate a comprehensive approach to reducing losses of life and 

property by lessening the impact of disasters through development, implementation, and 

coordination of a variety of capabilities. 

40 44 CFR §201.5(b)(1): “Demonstration that the plan is integrated to the extent practicable with other State and/or 

regional planning initiatives (comprehensive, growth management, economic development, capital improvement, land 

development, and/or emergency management plans) and FEMA mitigation programs and initiatives that provide 

guidance to State and regional agencies.”
State Mitigation Plan Review Guide 2015

Page | 30

ELEMENT REQUIREMENTS

E3. Does the state 

demonstrate commitment 

to a comprehensive 

mitigation program? [44 

41 CFR §201.5(b)(4) ] 

Intent: Demonstrate 

commitment to advancing 

risk reduction and 

resilience using a wide 

range of resources.

The plan must describe an existing comprehensive state mitigation 

program that might include, but is not limited to, examples listed in 

the mitigation planning regulation at 44 CFR §201.5(b)(4). 

Comprehensive state mitigation program means a broad range of 

state-supported initiatives and activities that: 

1. Targets risk reduction for each of the identified hazards in the 

state; 

2. Is inclusive of various state agencies and sectors with 

mitigation capabilities and resources; and 

3. Is coordinated to increase statewide resilience from the adverse 

impacts of future hazard events.

Initiatives and activities that demonstrate commitment include, but 

are not limited to, a combination of current training, partnerships, 

leadership initiatives, funding, technical assistance, codes and 

ordinances, or other activities that reduce risks.

Special Consideration: Descriptions of the various programs and 

initiatives to meet this requirement do not need to be repeated in a 

separate section. However, if the documentation to meet this 

requirement is not a separate section, the Plan Review Tool (refer

to Appendix B: State Mitigation Plan Review Tool) should identify 

where in the plan the descriptions are found. 

41 44 CFR §201.5(b)(4): “Demonstration that the State is committed to a comprehensive state mitigation program, 

which might include any of the following: 

(i) A commitment to support local mitigation planning by providing workshops and training, State planning grants, 

or coordinated capability development of local officials, including Emergency Management and Floodplain 

Management certifications.

(ii) A statewide program of hazard mitigation through the development of legislative initiatives, mitigation councils, 

formation of public/private partnerships, and/or other executive actions that promote hazard mitigation. 

(iii) The State provides a portion of the non-Federal match for HMGP and/or other mitigation projects. 

(iv) To the extent allowed by State law, the State requires or encourages local governments to use a current version of 

a nationally applicable model building code or Standard that addresses natural hazards as a basis for design and 

construction of State sponsored mitigation projects. 

(v) A comprehensive, multi-year plan to mitigate the risks posed to existing buildings that have been identified as 

necessary for post-disaster response and recovery operations.

(vi) A comprehensive description of how the State integrates mitigation into its post-disaster recovery operations.”
State Mitigation Plan Review Guide 2015

Page | 31

ELEMENT REQUIREMENTS

E4. Does the Enhanced 

plan document capability 

to implement mitigation 

actions? [44 CFR

42 §§201.5(b)(2)(i),

43 201.5(b)(2)(ii), and

44 201.5(b)(2)(iv) ] 

Intent: To exhibit 

successful application of 

a statewide mitigation 

program to advance risk 

reduction and resilience 

toward mitigation goals.

a.

b. 

The Enhanced plan must describe the system to rank the 

mitigation measures according to established eligibility criteria, 

including a process to prioritize between funding programs, 

jurisdictions, and proposals that address different or multiple 

hazards. 

 The Enhanced plan must describe how the state will assess the 

effectiveness of mitigation actions, including the agencies that 

are involved as well as the timeline, and use the results to 

inform the mitigation strategy. Effectiveness may be based on 

cost factors but may also include other beneficial functions. 

E5. Is the state effectively 

using existing mitigation 

programs to achieve 

mitigation goals? [44 

CFR §§201.5(a) and

45 201.5(b)(3) ] 

Intent: To exhibit 

successful application of 

a statewide mitigation 

program to advance risk 

reduction and resilience 

toward mitigation goals. 

Also to demonstrate the 

effective use of the 

additional HMGP funds 

for which the Enhanced 

state is eligible.

a. The enhanced plan must document how the state has fully made 

use of the funding available through the FEMA assistance 

programs (for example, PA C-G, HMGP, PDM, and FMA). If 

the state has not made full use of available funding, the 

enhanced plan must document the reasons why funding was not 

used and explain the process to improve this capability. 

b. The enhanced plan must document how the state effectively 

uses existing state programs to achieve its mitigation goals.

Special Consideration: Citing limited staff resources is not 

considered an acceptable reason for not making full use of funding. 

Further, citing limited staff resources would document the inability 

to meet the requirement at §201.5(b)(2)(iii), that requires the state 

to demonstrate HMA grants management capability. 

42 44 CFR §201.5(b)(2)(i): “Documentation of the State’s project implementation capability, identifying and 

demonstrating the ability to implement the plan, including: Established eligibility criteria for multi-hazard mitigation 

measures.”

43 44 CFR §201.5(b)(2)(ii): A system “to rank the measures according to the State’s eligibility criteria. A system to 

determine the cost effectiveness of mitigation measures, consistent with OMB Circular–94, Guidelines and Discount 

Rates for Benefit-Cost Analysis of Federal Programs.”

44 44 CFR §201.5(b)(2)(iv): “A system and strategy by which the State will conduct an assessment of the completed 

mitigation actions and include a record of the effectiveness (actual cost avoidance) of each mitigation action.”

45 44 CFR §201.5(b)(3): “Demonstration that the State effectively uses existing mitigation programs to achieve its 

mitigation goals.”
State Mitigation Plan Review Guide 2015

Page | 32

4.4 HMA Grants Management Performance

Approval of an enhanced state mitigation plan results in eligibility for increased HMGP 

funding. Therefore, the mitigation planning regulation requires states to demonstrate 

existing capabilities to effectively manage the HMGP as well as other mitigation grant 

programs (44 CFR §§201.5(a), 201.5(b)(3), and 201.5(b)(2)(iii)).

At the time of plan submission and review, and annually during the approval period, 

FEMA will review the state’s last four quarters of past grants management performance 

data for all FEMA HMA programs. For reviews of new Enhanced state mitigation plans, 

FEMA may extend the timeframe when sufficient data is not available for the last four 

quarters. FEMA will supplement the review with any additional necessary grants 

management data or may request additional data from the state, if necessary.

For additional information on the requirements to: 





Make use of the funding available through the FEMA assistance programs, refer 

to Element E5 in Section 4.3 State Mitigation Capabilities.

Maintain HMA grants management performance capabilities over the plan 

approval period, refer to Appendix A: Submission and Review Procedures.

ELEMENT REQUIREMENTS

E6. With regard to

HMA, is the state 

maintaining the 

capability to meet 

application timeframes 

and submitting 

complete project 

applications? [44 CFR

§201.5(b)(2)(iii)(A)46]

a. All applications and amendments are submitted by the end of

each program’s respective application period.

b. All applications are entered into FEMA’s electronic data systems

(such as, NEMIS and/or eGrants).

c. Eligibility and Completeness Checklist is prepared for all 

applications.

d. All applications are determined to be complete by FEMA within

90 days of submittal or selection for further review. Required 

environmental and historic preservation reviews and

consultations will not be included in the 90-day review timeframe

calculation.

46 44 CFR §201.5(b)(2)(iii)(A): “Demonstration that the State has the capability to effectively manage the HMGP as 

well as other mitigation grant programs, including a record of the following: (A) Meeting HMGP and other mitigation 

grant application timeframes and submitting complete, technically feasible, and eligible project applications with 

appropriate supporting documentation;”
State Mitigation Plan Review Guide 2015

Page | 33

ELEMENT REQUIREMENTS

E7. With regard to

HMA, is the state 

maintaining the 

capability to prepare 

and submit accurate 

environmental reviews 

and benefit-cost 

analyses? [44 CFR

§201.5(b)(2)(iii)(B)47]

All applications and amendments are determined to be complete by

FEMA within 90 days of submittal or selection for further review, 

including all data requested by FEMA to support Cost Effectiveness 

determinations and environmental/historic preservation compliance 

reviews. Required environmental and historic preservation reviews 

and consultations will not be included in the 90-day review timeframe 

calculation.

E8. With regard to

HMA, is the state 

maintaining the

capability to submit

complete and accurate 

quarterly progress and

financial reports on

time? [44 CFR

§201.5(b)(2)(iii)(C)48]

a. All progress reports must be complete and submitted on time.

Information in reports must accurately describe grant activities, 

including data related to the completion of individual property

acquisitions. Incomplete progress reports that do not provide

information on all open grants and subgrants or include all 

information required by the HMA Guidance are not considered

on time.

b. All Federal financial reports (FFR), Standard Form (SF) SF-425 

are submitted on time. Information in reports must accurately 

describe grant activities, as described in the HMA Guidance.

c. State consistently complies with the Financial Management

Standard requirements described in 2 CFR §§200.300 to 200.309.

47 44 CFR §201.5(b)(2)(iii)(B): “Demonstration that the State has the capability to effectively manage the HMGP as 

well as other mitigation grant programs, including a record of the following: (B) Preparing and submitting accurate 

environmental reviews and benefit-cost analyses;”

48 44 CFR §201.5(b)(2)(iii)(C): “Demonstration that the State has the capability to effectively manage the HMGP as 

well as other mitigation grant programs, including a record of the following: (C) Submitting complete and accurate 

quarterly progress and financial reports on time;”
State Mitigation Plan Review Guide 2015

Page | 34

ELEMENT REQUIREMENTS

E9. With regard to

HMA, is the state 

maintaining the 

capability to complete 

HMA projects within 

established 

performance periods, 

including financial

reconciliation? [44 CFR

§201.5(b)(2)(iii)(D)49]

a. All work as part of HMA subawards must be completed by the

end of Period of Performance as described in the HMA Guidance. 

b. No major findings on last single audit obtained by the state

related to HMA programs. For states without HMA grants, 

FEMA will review other Federal grants prepared by the 

responsible agency (such as state Emergency Management

Agency).

c. All grant close-out activities, including financial reconciliation, 

are completed within 90 days from the end of the performance

period including:

1. Final FFR SF-425 and Performance Reports were submitted 

within 90 days from the end of the performance period unless 

an extension is granted by FEMA.

2. Statement submitted that approved Scope of Work and all 

environmental and historic preservation requirements have 

been satisfied.

3. SF-270 Request for Advance or Reimbursement or request to 

de-obligate funds is completed, if applicable due to cost

underruns.

4. Other documentation as required in the HMA Guidance.

5. No late drawdowns are requested or performed after the 

liquidation period has ended.

d. Actual expenditures have been documented and are consistent 

with SF-424A or SF-424C.

49 44 CFR §201.5(b)(2)(iii)(D): “Demonstration that the State has the capability to effectively manage the HMGP as 

well as other mitigation grant programs, including a record of the following: (D) Completing HMGP and other 

mitigation grant projects within established performance periods, including financial reconciliation.”
State Mitigation Plan Review Guide 2015

Page | 35

APPENDIX A: SUBMISSION AND REVIEW PROCEDURES 

The “Submission and Review Procedures” Appendix is to set forth the standard operating 

procedures for the submission and review of both Standard and Enhanced state mitigation 

plans and includes information on: 

A.1 Communication 

A.2 Plan Submittal 

A.3 Plan Adoption 

A.4 Plan Review Status 

A.5 Enhanced State Mitigation Plan Review 

A.6 Review of Mitigation Commitments 

A.1 Communication

FEMA will work with each state to determine mutually agreeable communication 

methods. These methods include a schedule, notification milestones, points of contact,

and contact information, not limited to phone number, email, and mailing address. FEMA 

and state staffs are encouraged to coordinate with each other regarding clarifications or 

questions. FEMA may contact the state to discuss required revisions and offer an 

opportunity for minor changes prior to issuing a formal letter. Official communications 

will be documented using formal letters to the state. 

A.2 Plan Submittal

FEMA requires that the plans be submitted electronically. In some cases, FEMA may 

request that the state submit paper copies. FEMA will work with the state on a mutually 

agreeable method and format for the plan submittal. If mailing materials to the FEMA 

Regional Office, the state will confirm with FEMA that delivery instructions are current 

and appropriate for the submission. Upon receipt of materials, FEMA will provide 

confirmation to the state. 

A.3 Plan Adoption

The state is encouraged to share drafts, in whole or part, with FEMA in advance of 

deadlines to ensure plan is approvable upon first review by FEMA. The state is 

encouraged to submit a final draft to FEMA for review before seeking formal adoption of 

the plan to ensure that the plan meets all requirements. Once the plan receives an 

“Approvable Pending Adoption (APA)” status from FEMA, the state must provide 

documentation of formal adoption by the state’s highest elected official or designee 

within a reasonable timeframe. 

This process allows the state to proceed with the formal adoption process, knowing the 

adopted plan will be approved by FEMA. If deficiencies are found in the plan, the state 

will be able to make the required revisions before engaging in the formal adoption 

process.
State Mitigation Plan Review Guide 2015

Page | 36

A.4 Plan Review Status

All state mitigation plans will be reviewed by FEMA using the State Mitigation Plan

Review Guide within 45 days after receipt from the state, whenever possible (44 CFR 

§201.4(d)). Upon completion of a plan review, FEMA will provide notification to the 

state of the plan review outcome, using the following status designations: 







“Requires Revisions”

“Approvable Pending Adoption (APA)”

“Approved”

FEMA will include a copy of the Plan Review Tool when providing notification of plan 

review status to the state. 

A.4.1 Requires Revisions 

State mitigation plans not meeting all of the requirements are returned with a “Requires 

Revisions.” The required revisions are documented in writing, using the Plan Review 

Tool or other method, for discussions with the state. When a plan requires revisions to 

meet 44 CFR Part 201, FEMA will complete subsequent plan reviews as necessary. The 

review of a revised state mitigation plan will focus on those elements where revisions 

were required but may also include review of any changes from the previous version. 

A.4.2 Approvable Pending Adoption 

APA is a recommended and potentially time‐saving process by which states submit the

final draft state mitigation plan for a review prior to formal adoption by the appropriate

officials, agencies, or organizations. If FEMA determines the plan is not approvable, the 

state will be able to address deficiencies before adopting the plan. 

If all Elements are met except adoption, FEMA determines that the state mitigation plan 

is APA. Once the state receives a letter from FEMA noting the plan status is APA, the 

state can then proceed with the adoption process, assured that the adopted plan will 

receive FEMA’s final approval. 

A.4.3 Approved 

Once all Elements are “Met” and the adoption resolution is received by the FEMA 

Regional office, FEMA will send an “Approved” letter to the state signed by the FEMA 

Regional Administrator or designee. The designee for the FEMA Regional Administrator 

may be the Regional Mitigation Division Director, Risk Analysis Branch Chief, or other 

designated official. Correspondence for “Approved” plans will identify, at a minimum, 

the name of the approved plan, date(s) of plan adoption, date of plan approval, and the 

expiration date of FEMA’s approval of the plan (e.g., February 1 through January 31). 

A.5 Enhanced State Mitigation Plan Review

The plan submittal procedures are the same as standard state plans. If, upon completion of 

the FEMA review, required revisions are identified, the FEMA Regional Mitigation 

Planning staff coordinates with the state regarding the expected revisions to the Enhanced 
State Mitigation Plan Review Guide 2015

Page | 37

plan. Upon satisfactory completion of all Enhanced plan requirements, the FEMA 

Regional Administrator or designee will send a notice of approval or APA to the state.

As stated in Section 4, Enhanced State Plan Requirements, FEMA will not grant 

conditional approvals of enhanced state plans. All requirements must be met at time of 

review for the plan to be approved.

A.5.1 Status Categories 

The status of an enhanced plan submittal will be either New or Update. An Update of an 

enhanced plan will be “continuous” or “expired” as shown in Table A-1 and discussed 

below.

Table A-1. Summary of Enhanced Plan Status, Review Panel Types, and Review

Panel Composition.

ENHANCED PLAN STATUS

REVIEW PANEL TYPE REVIEW PANEL

R COMPOSITION*egional National

(A) New Enhanced Plan   2S - 2R - 2HQ

(or at a minimum, 1S -

1R - 1HQ)

(B) Enhanced

Plan Update

(i) Continuous  (Upon Established by Region

Request)

(ii) Expired  (Upon Established by Region

Request)

(A) Never received FEMA approval for an enhanced state mitigation plan

(B) (i) Complete enhanced plan submitted prior to expiration of current enhanced plan

(ii) Complete enhanced plan submitted no more than 12 months after expiration of the 

previous enhanced plan

*S = State, R = Region, HQ = Headquarters 

A “New Enhanced Plan” is a plan submitted by a state that has never had an approved 

enhanced plan. If a state submitted an enhanced state mitigation plan for review, but it 

was never approved by FEMA, the next enhanced state mitigation plan submittal will fall 

under this category as well. “New Enhanced Plans” will be reviewed by a National 

Review Panel composed of two state, two FEMA Region, and two FEMA Headquarters 

representatives. 

A “Continuous Enhanced Plan Update” is a plan submitted by a state that has a current, 

approved enhanced plan that has not expired and has been submitted to FEMA at least 45 

day before the plan expires. “Continuous Enhanced Plan Updates” will be reviewed by 

the respective Regional office. 

An “Expired Enhanced Plan Update” is a plan submitted by a state that has an enhanced 

plan that expired less than 12 months before submission or will expire within the next 45 

days. “Expired Enhanced Plans Updates” will be reviewed by the FEMA Regional office. 

Prior to expiration, the state may have submitted and received approval of the standard 

plan, but not an enhanced plan. Plan approval for an “Expired Enhanced Plan Update” as 
State Mitigation Plan Review Guide 2015

Page | 38

defined within this section will be for the remaining balance of the approval period to 

coincide with approval of the standard state mitigation plan. 

A.5.2 Hazard Mitigation Assistance Grants Management Performance Review 

The FEMA Regional Mitigation staff will complete the grant program management 

review per 44 CFR §201.5(b)(2)(iii) within 30 days of receipt of the state mitigation plan 

and before the National Review Panel convenes. FEMA will evaluate the HMA grants 

management performance using the criteria provided in Section 4.4, HMA Grants 

Management Performance. 

FEMA will notify the state of the results of the HMA grants management review and 

provide specific reasons if the state performance is not satisfactory to pass the review. 

The state may not request a National Panel Review to reconsider the FEMA HMA grants 

management performance review. 

A.5.3 FEMA Regional Review 

The FEMA Region notifies the state and FEMA Headquarters of the review status 

milestones. The FEMA Region will complete its review of the Enhanced plan within 45 

days after receipt from the state, whenever possible (44 CFR §201.4(d)). Additional 

reviews may be necessary if required revisions are identified.

The FEMA Regional Mitigation Planning staff will complete the internal Regional 

review process and then send a copy to FEMA Headquarters Mitigation Planning staff for 

a parallel consistency review. FEMA Headquarters Mitigation Planning staff will review 

the plan within the same 45-day review period. The Regional Mitigation Planning staff 

will coordinate with and incorporate Headquarters comments into the Regional review. 

The parallel review by FEMA Headquarters will not delay the Regional review.

If the finding from the Regional review is not satisfactory, a review by the National 

Review Panel may be requested. This secondary review process will follow the same 

panel composition and process as a “New Enhanced Plan.” If a review by the National 

Review Panel is requested, the review will be completed within 30 days of the request. 

A.5.4 National Review Panel 

The FEMA Regional Mitigation Planning staff completes the internal Regional review 

process, including grant program management, and notifies the state and FEMA 

Headquarters Mitigation Planning staff of the review status. If, upon completion of the 

FEMA Regional review, required revisions are identified, the FEMA Region sends the 

completed plan review to the state, and coordinates with the state to adjust the schedule 

based on the expected revisions to the enhanced plan. Upon satisfaction that all elements 

of the Regional review process have been met, the FEMA Regional Mitigation Planning 

staff submits the enhanced state mitigation plan to FEMA Headquarters Mitigation 

Planning staff for a review by the National Review Panel.

Upon notification from the FEMA Region, FEMA Headquarters Mitigation Planning 

staff will assemble the National Review Panel. Once convened, the National Review 

Panel will complete its review and provide timely feedback through the FEMA Regional 

Mitigation Planning staff to the submitting state.
State Mitigation Plan Review Guide 2015

Page | 39

Upon receipt of the Plan from the FEMA Region, FEMA Headquarters Mitigation 

Planning staff and FEMA Regional Mitigation staff participate in an initial coordinat

conference call with the National Review Panelists to coordinate schedules and ensur

materials have been provided to Panelists to complete reviews.









Each National Review Panelist completes an independent review of the plan a

submits a completed Plan Review Tool to the FEMA Headquarters Mitigation

Planning staff.

FEMA Headquarters Mitigation Planning staff consolidates comments into a 

single Plan Review Tool and distributes to Panelists. 

FEMA Headquarters Mitigation Planning staff facilitates National Review Pa

discussion (generally held via conference call) to discuss the plan reviews and

reach Panel consensus on recommendations for plan approval or required 

revisions. 

The FEMA Headquarters Mitigation Planning staff notifies the Regional 

Mitigation Planning staff of the Panel outcome. 

If, upon completion of the National Review Panel review, required revisions are 

identified, the FEMA Regional Mitigation Planning staff sends the National Review 

Panel Plan Review Tool to the state. Upon receipt of the revisions, FEMA Regional a

Headquarters Mitigation Planning staff confirms whether all required revisions have 

met. Additional communication may be required if all requirements still have not bee

met.

A.5.5 Enhanced Plan Review Procedure Summary 

A summary of the enhanced plan procedures is provided in Table A-2. 

ion 

e all 

nd 

nel 

nd

been 

n 

Table A-2. Summary of Enhanced Plan Review Procedures.

ENHANCED PLAN

CATEGORY

PROCESS SUMMARY TIMELINE

A. New Enhanced Plan

submitted by state and:

1. State never had an 

approved enhanced 

plan before; or

2. State had enhanced 

plan that expired 

more than 12 months 

prior to submittal.

Region will review the plan

within 45 days of submittal

During 45 day Regional 

review:

 HQ assembles National

Review Panel

 Revisions may be 

required

After Regional review, 

National Review Panel 

convenes

National Panel review of plan 

will not exceed 45 days, 

whenever possible.

Day 1: Submittal to Region;

HQ assembles review panel 

with HQ, state, and Regional 

reviewers while Region is 

conducting the review

Day 30: Region completes its 

review

Day 45: National Review 

Panel provides feedback to 

the state

Additional review time may 

be necessary for either the 

Regional or National Review 

Panel reviews if required 

revisions are identified.
State Mitigation Plan Review Guide 2015

Page | 40

ENHANCED PLAN 

CATEGORY

PROCESS SUMMARY TIMELINE

B. Updated Enhanced Plan

(Continuous) must be 

submitted to the FEMA

Region at least 45 days prior

to plan expiration, or up to 12 

months after Enhanced Plan 

expiration date.

Initial Review:

Region/HQ will do joint 

review within 45 days. Plan

will either be approved or

returned for revisions in this 

timeframe.

Optional Secondary

Review: If the state is not 

satisfied with outcome of the 

Regional review, a National 

Review Panel review can be 

requested and will be 

completed within 30 days.

Initial Review:

Day 1: Submitted to Region

Day 45: Region and HQ

make determination

Optional Secondary

Review: (State not satisfied 

with outcome of Regional 

review):

Day 1: HQ begins to 

assemble National Review 

Panel

Day 30: Region shares 

outcome of National Review 

Panel review with state

Additional review time may 

be necessary either from the 

Regional or National Review 

Panel reviews if required 

revisions are identified.

A.6 Review of Mitigation Commitments

If at any time over the plan approval period FEMA determines that the state is not 

complying with all applicable Federal statutes and regulations in effect with respect to the 

periods for which it receives funding or is unable to fulfill mitigation commitments, 

FEMA may take action to correct the noncompliance (44 CFR §§201.3(b)(5) and 

201.4(c)(7)). If the state does not comply with HMA award administration requirements, 

FEMA may consider taking actions as detailed in the HMA Guidance (Part VI. Award 

Administration Information, D.8 Remedies for Noncompliance). Before taking action, 

FEMA Regional Mitigation staff must coordinate with the respective FEMA 

Headquarters program offices.

A FEMA-approved enhanced state mitigation plan documents sustained, proven 

commitment to hazard mitigation and results in eligibility for increased HMGP funding. 

Annually, FEMA staff will validate that “Enhanced” states are maintaining a 

comprehensive mitigation program, effectively using available mitigation funding, and 

remain capable of managing the increased HMGP funding (44 CFR §201.5(a)). 

Following the validation, FEMA will provide the state with a written summary of 

findings. The benefit of this annual validation to the state is to show that the state is on 

track and continues to meet grants management performance requirements over the 5- 

year approval period, rather than discovering retroactively at the review of the mitigation 

plan update that the state does not meet the requirements. FEMA will not require a state 

mitigation plan update as a result of the annual validation. 
State Mitigation Plan Review Guide 2015

Page | 41

If FEMA determines that the state’s mitigation capabilities have not improved or have 

declined, FEMA will work with the state to identify appropriate activities to improve the 

mitigation capabilities and determine a reasonable timeframe for completing these 

actions. The state will have 30 days after receipt of the summary of findings to submit to 

FEMA the proposed actions and timeframes that the state will take to make the 

improvements. 

If the state mitigation capabilities do not improve, FEMA may consider withholding 

funds or denying future funding by suspending the state’s “Enhanced” plan status prior to 

the 5-year update. If the “Enhanced” plan status is suspended by FEMA, the state 

mitigation plan would revert to “Standard” plan status and the state would no longer be 

eligible to receive the increased portion of HMGP funding for future disaster 

declarations. If the state is subsequently able to demonstrate the capability to manage the 

increased HMGP funding to FEMA’s satisfaction consistent with the criteria in the 

applicable regulations and this Guide, FEMA would restore the “Enhanced” plan status 

making the state eligible to receive increased HMGP funding for future disaster 

declarations. 
Page | 42

State Mitigation Plan Review Guide 2015

This page is intentionally blank. 
Page | 43

State Mitigation Plan Review Guide 2015

APPENDIX B: STATE MITIGATION PLAN REVIEW TOOL

This section is organized as follows: 

B.1 Plan Review Tool Summary 

B.2 Standard State Mitigation Plan Regulation Checklist 

B.3 Enhanced State Mitigation Plan Regulation Checklist 

B.4 Strengths and Opportunities for Improvement 

FEMA uses the State Mitigation Plan Review Tool (“Plan Review Tool”) to document how the 

state mitigation plan meets the regulation. If plan requirements are not met, FEMA informs the 

state of the changes it needs to make in each of the Required Revisions sections.

The “Strengths and Opportunities for Improvement” summary offers FEMA an opportunity 

to provide more comprehensive feedback to the state. 

INSTRUCTIONS: The Regulation Checklist must be completed by FEMA. The FEMA Plan 

Approver must reference the State Mitigation Plan Review Guide when completing the Plan 

Review Tool. The purpose of the Checklist is to identify the location of relevant or applicable 

content in the Plan by Element/sub-element and to determine if each requirement has been ‘Met’ 

or ‘Not Met.’

The “Required Revisions” summary at the bottom of each Element must be completed by 

FEMA to provide a clear explanation of the revisions that are required for plan approval. 

Required revisions must be explained for each plan sub-element that is ‘Not Met.’ Sub-elements 

should be referenced in each summary by using the appropriate number, where applicable. 

Requirements for each Element and sub-element are described in detail in the State Mitigation 

Plan Review Guide. 

FEMA will provide a narrative summary of the review findings that includes a discussion of 

“Strengths and Opportunities for Improvement” as a means to offer more comprehensive 

feedback to the state to acknowledge where the plan exceeds minimum requirements as well as 

provide suggestions for improvements. FEMA will describe the strengths that are demonstrated 

and highlight examples of best practices.

FEMA may provide suggestions for improvement as part of the Plan Review Tool or in a 

separate document. FEMA’s suggestions for improvement are not required to be made for plan 

approval.

Required revisions from the Regulation Checklist are not documented in the “Strengths and

Opportunities for Improvement” section. 
Page | 44

State Mitigation Plan Review Guide 2015

B.1 Plan Review Tool Summary

State: Title and Date of Plan: Date of Submission:

State Point of Contact (Name / Title): Address:

Agency:

Phone Number: E-Mail:

Date Received in FEMA Region:

FEMA Reviewer (Planning – Name / Title): Date:

FEMA Reviewer (HMA – Name / Title): Date:

FEMA Reviewer (Name / Title): Date:

FEMA Reviewer (Name / Title): Date:

FEMA Approver (Name / Title): Date:

Plan Status (Not Approved, Approvable Pending Adoption, Approved): Date:

SUMMARY YES NO

STANDARD STATE MITIGATION PLAN

Does the plan meet the standard state mitigation plan requirements?

REPETITIVE LOSS STRATEGY

Does the plan include a Repetitive Loss Strategy? [see S6 / RL1; S8 / RL2; S9 / 

RL3; S10 / RL4; S13 / RL5; and S15 / RL6]

ENHANCED STATE MITIGATION PLAN

Does the plan meet the enhanced state mitigation plan requirements?
Page | 45

State Mitigation Plan Review Guide 2015

B.2 Standard State Mitigation Plan Regulation Checklist

REGULATION CHECKLIST – STANDARD PLAN

*M=Met; NM=Not Met

Location

in Plan

M / NM*

STANDARD (S) STATE MITIGATION PLAN

Planning Process

S1. Does the plan describe the planning process used to develop the plan? [44

CFR §§201.4(b) and (c)(1)]

S2. Does the plan describe how the state coordinated with other agencies and

stakeholders? [44 CFR §§201.4(b) and (c)(1)]

Required Revisions:

Hazard Identification and Risk Assessment

S3. Does the risk assessment include an overview of the type and location of

all natural hazards that can affect the state? [44 CFR §201.4(c)(2)(i)]

S4. Does the risk assessment provide an overview of the probabilities of

future hazard events? [44 CFR §201.4(c)(2)(i)]

S5. Does the risk assessment address the vulnerability of state assets located

in hazard areas and estimate the potential dollar losses to these assets? [44

CFR §§201.4(c)(2)(ii) and 201.4(c)(2)(iii)]

S6. Does the risk assessment include an overview and analysis of the

vulnerability of jurisdictions to the identified hazards and the potential losses 

to vulnerable structures? [44 CFR §§201.4(c)(2)(ii) and 201.4(c)(2)(iii)]

S7. Was the risk assessment revised to reflect changes in development? [44

CFR §201.4(d)]

Required Revisions:

Mitigation Strategy and Priorities

S8. Does the mitigation strategy include goals to reduce / avoid long-term

vulnerabilities from the identified hazards? [44 CFR §201.4(c)(3)(i)]

S9. Does the plan prioritize mitigation actions to reduce vulnerabilities

identified in the risk assessment? [44 CFR §§201.4(c)(3)(iii) and (iv)]

S10. Does the plan identify current and potential sources of funding to

implement mitigation actions and activities? [44 CFR §201.4(c)(3)(iv)]

S11. Was the plan updated to reflect changes in development, progress in

statewide mitigation efforts, and changes in priorities? [44 CFR §201.4(d)]

Required Revisions:

State Mitigation Capabilities

S12. Does the plan discuss the evaluation of the state’s hazard management

policies, programs, capabilities, and funding sources to mitigate the hazards 

identified in the risk assessment? [44 CFR §201.4(c)(3)(ii)]

Required Revisions:
Page | 46

State Mitigation Plan Review Guide 2015

REGULATION CHECKLIST – STANDARD PLAN

*M=Met; NM=Not Met

Location 

in Plan

M / NM*

Local Coordination and Mitigation Capabilities

S13. Does the plan generally describe and analyze the effectiveness of local

and tribal, as applicable, mitigation policies, programs, and capabilities? [44

CFR §201.4(c)(3)(ii)]

S14. Does the plan describe the process to support the development of

approvable local and tribal, as applicable, mitigation plans? [44 CFR

§§201.3(c)(5) and 201.4(c)(4)(i)]

S15. Does the plan describe the criteria for prioritizing funding? [44 CFR

§201.4(c)(4)(iii)]

S16. Does the plan describe the process and timeframe to review, coordinate

and link local and tribal, as applicable, mitigation plans with the state 

mitigation plan? [44 CFR §§201.3(c)(6), 201.4(c)(2)(ii), 201.4(c)(3)(iii), and

201.4(c)(4)(ii)]

Required Revisions:

Plan Review, Evaluation, and Implementation

S17. Is there a description of the method and schedule for keeping the plan

current? [44 CFR §§201.4(c)(5)(i) and 201.4(d)]

S18. Does the plan describe the systems for monitoring implementation and

reviewing progress? [44 CFR §§201.4(c)(5)(ii) and 201.4(c)(5)(iii)]

Required Revisions:

Adoption and Assurances

S19. Did the state provide documentation that the plan has been formally

adopted? [44 CFR §201.4(c)(6)]

S20. Did the state provide assurances? [44 CFR §201.4(c)(7)]

Required Revisions:

Repetitive Loss (RL) Strategy

RL1. Did Element S6 (risk assessment) address RL and SRL properties? [44

CFR §§201.4(c)(2)(ii), 201.4(c)(2)(iii), and 201.4(c)(3)(v)]

RL2. Did Element S8 (mitigation goals) address RL and SRL properties? [44

CFR §§201.4(c)(3)(i) and 201.4(c)(3)(v)]

RL3. Did Element S9 (mitigation actions) address RL and SRL properties?

[44 CFR §§201.4(c)(3)(iii) and 201.4(c)(3)(v)]

RL4. Did Element S10 (funding sources) address RL and SRL properties? [44

CFR §§201.4(c)(3)(iv) and 201.4(c)(3)(v)]

RL5. Did Element S13 (local and tribal, as applicable, capabilities) address

RL and SRL properties? [44 CFR §§201.4(c)(3)(ii) and 201.4(c)(3)(v)]

RL6. Did Element S15 (prioritizing funding) address RL and SRL properties?

[44 CFR §§201.4(c)(4)(iii) and 201.4(c)(3)(v)]

Required Revisions:
Page | 47

State Mitigation Plan Review Guide 2015

B.3 Enhanced State Mitigation Plan Regulation Checklist

REGULATION CHECKLIST – ENHANCED PLAN

*M=Met; NM=Not Met

Location

in Plan

M / NM*

ENHANCED (E) STATE MITIGATION PLAN

Meet Standard State Mitigation Plan Elements

E1. Does the Enhanced plan include all elements of the standard state

mitigation plan? [44 CFR §201.5(b)]

Required Revisions:

Integrated Planning

E2. Does the plan demonstrate integration to the extent practicable with other

state and/or regional planning initiatives and FEMA mitigation programs and 

initiatives? [44 CFR §201.5(b)(1)]

Required Revisions:

State Mitigation Capabilities

E3. Does the state demonstrate commitment to a comprehensive mitigation

program? [44 CFR §201.5(b)(4)]

E4. Does the enhanced plan document capability to implement mitigation

actions? [44 CFR §§201.5(b)(2)(i), 201.5(b)(2)(ii), and 201.5(b)(2)(iv)]

E5. Is the state effectively using existing mitigation programs to achieve

mitigation goals? [44 CFR §201.5(b)(3)]

Required Revisions:

HMA Grants Management Performance

E6. With regard to HMA, is the state maintaining the capability to meet

application timeframes and submitting complete project applications? [44

CFR §201.5(b)(2)(iii)(A)]

E7. With regard to HMA, is the state maintaining the capability to prepare and

submit accurate environmental reviews and benefit-cost analyses? [44 CFR

§201.5(b)(2)(iii)(B)]

E8. With regard to HMA, is the state maintaining the capability to submit

complete and accurate quarterly progress and financial reports on time? [44

CFR §201.5(b)(2)(iii)(C)]

E9. With regard to HMA, is the state maintaining the capability to complete

HMA projects within established performance periods, including financial 

reconciliation? [44 CFR §201.5(b)(2)(iii)(D)]

Required Revisions:
Page | 48

State Mitigation Plan Review Guide 2015

B.4 Strengths and Opportunities for Improvement

STRENGTHS AND OPPORTUNITIES FOR IMPROVEMENT

INSTRUCTIONS: The purpose of the “Strengths and Opportunities for Improvement” section is

for FEMA to provide more comprehensive feedback on the state mitigation plan to help the state 

advance mitigation planning. The intended audience is the state staff responsible for the mitigation plan 

update. FEMA will address the following topics:

1. Plan strengths, including specific sections in the plan that are above and beyond the minimum 

requirements; and

2. Suggestions for future improvements.

FEMA will provide feedback and include examples of best practices, when possible, as part of the Plan 

Review Tool, or, if necessary, as a separate document. The state mitigation plan elements are included 

below in italics for reference but should be deleted as the narrative summary is completed. FEMA is not 

required to provide feedback for each element.

Required revisions from the Regulation Checklist are not documented in the Strengths and

Opportunities for Improvement section.

Results from the Strengths and Opportunities for Improvement section are not required for Plan

Approval, but may inform discussions during the Program Consultation.

Describe the mitigation plan strengths, including areas that may exceed minimum requirements.

 Planning process

 Hazard identification and risk assessment

 Mitigation strategy

 State mitigation capabilities

 Local and tribal, as applicable, coordination and mitigation capabilities

 Plan review, evaluation, and implementation

 Adoption and assurances

 Repetitive loss strategy, if applicable

 Integrated planning process, if applicable

 Commitment to a comprehensive mitigation program, if applicable

 HMA grants management performance, if applicable

Describe areas for future improvements to the mitigation plan.

 Planning process

 Hazard identification and risk assessment

 Mitigation strategy

 State mitigation capabilities

 Local and tribal, as applicable, coordination and mitigation capabilities

 Plan review, evaluation, and implementation

 Adoption and assurances

 Repetitive loss strategy, if applicable

 Integrated planning process, if applicable

 Commitment to a comprehensive mitigation program, if applicable

 HMA grants management performance, if applicable
Page | 49

State Mitigation Plan Review Guide 2015

APPENDIX C: APPROVAL LETTER TEMPLATE

[insert date]

[insert name, title]

[insert State agency name]

[insert State agency address line 1] 

[insert State agency address line 2] 

Reference: Approval of the [insert name] State Mitigation Plan

Dear [insert name]: 

The U.S. Department of Homeland Security, Federal Emergency Management Agency 

(FEMA) Region [insert number] Mitigation Division, Risk Analysis Branch has approved the 

updated [insert name] state mitigation plan effective [insert date] through [insert date] in 

accordance with the planning requirements of the Robert T. Stafford Disaster Relief and 

Emergency Assistance Act (Stafford Act), as amended, the National Flood Insurance Act of 

1968, as amended, and Title 44 Code of Federal Regulations (CFR) Part 201. 

A FEMA-approved state mitigation plan is a condition of receiving certain non-emergency 

Stafford Act assistance and FEMA mitigation grants from the following programs: 











Public Assistance Categories C-G (PA C-G)

Fire Management Assistance Grants (FMAG)

Hazard Mitigation Grant Program (HMGP)

Pre-Disaster Mitigation (PDM)

Flood Mitigation Assistance (FMA)

State mitigation plans must be updated and resubmitted to FEMA Region [insert number] 

Mitigation Division, Risk Analysis Branch for approval. If the plan is not updated by the date 

indicated on this FEMA approval letter, the plan is considered lapsed and FEMA will not 

obligate funds until the mitigation plan is approved by FEMA. 

If at any time over the plan approval period, FEMA determines that the state is not complying 

with all applicable Federal statutes and regulations in effect with respect to the periods for whi

it receives funding or is unable to fulfill mitigation commitments, FEMA may take action to 

correct the noncompliance (44 CFR §§201.3(b)(5) and 201.4(c)(7)).

If the included Repetitive Loss Strategy is approved, insert: 

FEMA determined the state mitigation plan includes a Repetitive Loss Strategy that meets the 

requirements set forth in 44 CFR §201.4(c)(3)(v) and qualifies the state to request an increased

Federal share for repetitive loss properties under the FMA program.

If the approved plan is Enhanced, insert: 

FEMA recognizes the state for the additional effort and commitment to mitigation, authorizing

the state to receive additional HMGP funds of up to 20 percent of the total estimated eligible 

Stafford Act disaster assistance. The “Enhanced” designation is recognition for states that are 

ch 
Page | 50

State Mitigation Plan Review Guide 2015

leaders in implementing a comprehensive statewide hazard mitigation program that results in 

safer, more sustainable communities. 

The state is responsible for communicating with local and tribal officials, as applicable, 

interested in applying through the state for FEMA assistance. FEMA encourages states to 

communicate with the appropriate officials regarding mitigation plan status and eligibility 

requirements. At a minimum of every 6 months, FEMA will provide to the state written 

information on mitigation plans, including but not limited to: 









Local and tribal, as applicable, mitigation plan expiration dates; 

Consequences of not having a FEMA-approved local or tribal, as applicable, mitigation 

plan with respect to eligibility for HMA programs; and 

Availability of mitigation planning training and technical assistance.

Upcoming funding opportunities.

The state is responsible for reviewing and submitting approvable mitigation plans to FEMA. If 

the state is not submitting approvable mitigation plans, FEMA will provide feedback as well as 

technical assistance or training, as needed. 

In addition, FEMA will provide a reminder to the state, at a minimum, 12 months prior to the 

plan expiration date, of the consequences of not having a FEMA-approved mitigation plan with 

respect to eligibility for the FEMA assistance programs that require FEMA-approved mitigation 

plan as a condition of eligibility. To maintain eligibility for PA C-G, FMAG, HMGP, PDM, and 

FMA, the state must submit a draft of the next plan update prior to the end of the approval 

period, and allow sufficient time for the review and approval process, including any revisions, if 

needed, and for formal adoption by the state following determination by FEMA that the plan has 

achieved a status of “Approvable Pending Adoption.”

Finally, we look forward to working with you to discuss the status of the state mitigation 

program each year over the approval period. The written consultation agreement is attached to 

clarify expectations regarding the consultation process, including details such as purpose and 

outcomes; points of contact; roles and responsibilities; and logistics. 

If we can be of assistance, please contact [insert name], at [insert phone # and email address].

Sincerely,

[insert name] 

[insert title] 

Attachments:

1. State Mitigation Plan Review Tool 

2. Mitigation Program Consultation Agreement
Page | 51

State Mitigation Plan Review Guide 2015

APPENDIX D: CONSULTATION SUMMARY TEMPLATE

MITIGATION PROGRAM CONSULTATION SUMMARY

INSTRUCTIONS: The purpose of the Mitigation Program Consultation Summary is for use by

FEMA Mitigation staff to provide a written summary of the highlights of the consultation on the state

Mitigation Program to help the state advance mitigation. The intended audience is the state staff 

responsible for the mitigation program. At a minimum, FEMA will address the following topics:

1. Mitigation program strengths.

2. Specific challenges to advancing mitigation.

3. Suggestions for opportunities to improve mitigation capabilities.

The topics included in each section below in italics are for reference and should be deleted as the 

narrative summary is completed.

Describe mitigation program strengths.

 State mitigation plan strategy implementation

 State mitigation plan maintenance

 Plan update and approval process

 Training, technical assistance, and partnerships

 Local and tribal, as applicable, mitigation planning

 Mitigation capabilities, including funding

 HMA grants management performance

Describe specific challenges to advancing mitigation.

 State mitigation plan strategy implementation

 State mitigation plan maintenance

 Plan update and approval process

 Training, technical assistance, and partnerships

 Local and tribal, as applicable, mitigation planning

 Mitigation capabilities, including funding

 HMA grants management performance

Describe suggestions for opportunities to improve mitigation capabilities.

 State mitigation plan strategy implementation

 State mitigation plan maintenance

 Plan update and approval process

 Training, technical assistance, and partnerships

 Local and tribal, as applicable, mitigation planning

 Mitigation capabilities, including funding

 HMA grants management performance

Attachments