Department of Homeland Security
 

Survey of Hazard Mitigation Planning
 

OIG-12-109 August 2012
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 Iwww.oig.dhs.gov 

MEMORANDUM FOR: David l. Miller 

Associate Administrator, Federal Insurance and Mitigation 

Administration 

Federal Emerge ¥_Manag;e ~~ Agency 

FROM: D. Michael Beard

"---I/· ,If/ ~-/'/L--

Assistant Inspe r General 

Office of Emergency Management Oversight 

SUBJECT: Survey of Hazard Mitigation Planning 

Attached for your action is our final report, Survey of Hazard Mitigation Planning. We 

incorporated the formal comments from the Federal Emergency Management Agency in 

the final report. 

The report contains two recommendations aimed at improving the Hazard Mitigation 

Planning program. Your office concurred with both of the recommendations. As 

prescribed by the Department of Homeland Security Directive 077~1, Follow~Up and 

Resolutions for the Office of Inspector General Report Recommendations, within 

90 days of the date of this memorandum" please provide our office with a written 

" response that includes your (1) agreement or disagreement, (2) corrective action plan, 

and (3) target completion date for each recommendation. Also, please include 

responsible parties and any other supporting documentation necessary to inform us 

about the current status of the recommendation. Until your response is received and 

evaluated, the recommendations will be considered open and unresolved. 

Consistent with our responsibility under the Inspector General Act, we are providing 

copies of our report to appropriate congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will post 

the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact John Kelly, Acting Deputy 

Assistant Inspector General, Office of Emergency Management Oversight, at 

(202) 254-4100. 

Attachment 

August 9, 2012
 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Executive Summary............................................................................................................. 1 


Background ........................................................................................................................ 2 


Results of Review................................................................................................................ 6 


Plan Participation .................................................................................................... 6 


Plan Review Process ................................................................................................ 6 


Project Implementation ......................................................................................... 7 


Conclusion .............................................................................................................. 9 


Recommendations ............................................................................................... 10 


Management Comments and OIG Analysis ......................................................... 10 


Appendixes 

Appendix A: Objectives, Scope, and Methodology ............................................ 11 


Appendix B: Management Comments to the Draft Report ............................... 12 


Appendix C: Major Contributors to This Report ................................................ 14 


Appendix D: Report Distribution ........................................................................ 15 


Abbreviations 

DHS Department of Homeland Security 

CFR Code of Federal Regulations 

FEMA Federal Emergency Management Agency 

FMA Flood Mitigation Assistance 

HMGP Hazard Mitigation Grant Program 

OIG Office of Inspector General 

PDM Pre-disaster Mitigation 

www.oig.dhs.gov OIG-12-109 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary 

The Federal Emergency Management Agency (FEMA) has made progress in the hazard 

mitigation planning program since the passage of the Disaster Mitigation Act of 2000, as 

amended. The program is designed to encourage State, tribal, and local jurisdictions to 

(1) identify the natural hazards that affect them and (2) implement projects that will reduce 

losses from disasters, including development of land use and building code regulations. A State 

mitigation plan is required as a condition for receiving certain types of nonemergency disaster 

assistance, including funding for mitigation projects. 

The program is voluntary, but all 50 States plus the District of Columbia and several territories 

have participated since its inception, and more than 26,000 jurisdictions have developed 

mitigation plans. Communities that participate account for about 70 percent of the Nation’s 

population. Despite the program’s relative success, some communities have been reluctant to 

participate, particularly those in less populated areas that have not experienced recent 

disasters. FEMA is developing a system to monitor State, tribal, and local participation and to 

track planned or implemented mitigation projects. 

FEMA receives high marks from mitigation grantees who rely on the agency for program 

guidance, technical assistance, and training that is made available to State, tribal, and local 

communities, as well as their contractors. A common concern among State grantees was the 

“too-frequent” plan renewal process. 

We conducted this survey to evaluate the program’s efficiency and effectiveness, and to 

determine whether a more comprehensive audit was needed. Although we determined that 

further audit work on FEMA’s hazard mitigation planning program is not warranted at this time, 

FEMA needs to implement a better system to track participants’ progress, and continue 

ongoing efforts to address States’ concerns regarding plan reporting requirements. We are 

making two recommendations to assist FEMA in its management and oversight function. In the 

future, we will follow up on FEMA’s progress as the program continues to develop. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

Hazard mitigation is defined as any sustained action taken to reduce or eliminate the 

long-term risk to human life and property from hazards. It is intended to break the cycle 

of disaster damage, reconstruction, and repeated damage. Mitigation activities may be 

implemented before, during, or after an incident. However, it has been demonstrated 

that hazard mitigation is most effective when based on an inclusive, long-term plan that 

is developed before a disaster occurs. Two recent cost-benefit analyses found that 

every $1 spent on mitigation saved society $3 to $4.1 

Mitigation planning is a voluntary process through which communities assess risks and 

identify actions to reduce vulnerability through hazard mitigation. The jurisdictional 

plans prepared by State, tribal, and local governments demonstrate their commitment 

and serve as a guide for decision makers as they commit resources for mitigation 

projects that reduce or eliminate long-term risk to people and property from hazards. 

In keeping with the intent of Congress, the mitigation planning program is designed to 

encourage jurisdictions to (1) identify the natural hazards that affect them and 

(2) implement projects in order to reduce losses from disasters, including development 

of land use and building code regulations. States must have an approved mitigation 

plan as a condition of receiving certain nonemergency assistance and mitigation grants. 

FEMA promotes planning, provides assistance and guidance, and reviews and approves 

plans. 

Section 322 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act 

(42 U.S.C. 5121 et seq.), as amended by the Disaster Mitigation Act of 2000 (P.L. 106-390), 

provides for States, tribes, and local governments to undertake a risk-based approach to 

reducing the exposure to loss by natural hazards through mitigation planning. 

Implementing rules were codified in Title 44, Part 201 of the Code of Federal 

Regulations (CFR). 

Following the issuance of the CFR regulations, the first round of State and local 

mitigation plans were approved in 2004. Since the program began, FEMA has reviewed, 

critiqued, and approved more than 5,000 mitigation plans, and overseen more than 

$5.2 billion in hazard mitigation grants. 

1

 Congress of the United States, Congressional Budget Office, Potential Cost Savings from the Pre-Disaster 

Mitigation Program (Washington, DC, 2007); and National Institute of Building Sciences, The Multihazard 

Mitigation Council, Natural Hazard Mitigation Saves: An Independent Study to Assess the Future Savings 

from Mitigation Activities (Washington, DC, 2005). 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

This survey concentrated on the following three hazard mitigation grant programs that 

include a planning function. 

Mitigation Planning Grants 

•	 Hazard Mitigation Grant Program (HMGP): Provides grants to State, tribal, and local 

governments, and certain nonprofits, to implement mitigation measures after a 

major disaster declaration. The Disaster Mitigation Act of 2000, as amended, 

authorizes up to 7 percent of available HMGP funds for planning purposes. Of the 

more than $1.3 billion awarded under HMGP from 2007 through 2011, $48.9 million 

was awarded for mitigation planning. These funds accounted for the largest 

segment of mitigation planning grants out of all of the hazard mitigation assistance 

programs. 

•	 Pre-disaster Mitigation (PDM) Grant: Provides funding to States, territories, tribal 

governments, communities, and universities for hazard mitigation planning and the 

implementation of mitigation projects prior to a disaster event. PDM grants 

exceeded $270 million over the past 5 years, of which $52.2 million was for 

mitigation plans. 

•	 Flood Mitigation Assistance (FMA): Provides funds to help States and communities 

implement measures that reduce or eliminate the long-term risk of flood damage to 

buildings, manufactured homes, and other structures insured under the National 

Flood Insurance Program. FMA provides annual grant funds for flood mitigation 

planning, and exceeded $120 million over the past 5 years, of which $2.75 million 

was for mitigation plans. 

FEMA provides grants to States, which in turn provide subgrants to local governments 

and communities. The State selects and prioritizes subgrant applications and submits 

them to FEMA for funding consideration. Figure 1 shows the total amounts spent for 

the grant programs from 2007 through 2011. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1. Mitigation Funding by Grant 


HMGP 

77% 

PDM 

16% 

FMA 

7% 

Hazard Mitigation Grants 2007-2011 

$1,345,209,907 

$272,583,194 

$128,672,145 

Source: Department of Homeland Security (DHS) Office of Inspector General (OIG), based on FEMA data. 

Plan Elements 

CFR Part 201, Title 44 is specific on the elements that must be included in plans 

submitted by States, tribes, and local jurisdictions. Elements for a standard State 

mitigation plan include a risk assessment that identifies hazards and risks, including 

information on previous occurrences, and the probability of future hazard events in the 

jurisdictional area. Plans contain a mitigation strategy that provides a blueprint for 

reducing losses and includes (1) a description of proposed projects to reduce future 

losses and (2) a benefit-cost analysis to demonstrate the cost-effectiveness of the 

projects; and an evaluation of pertinent laws and regulations, as well as development in 

hazard-prone areas. Plans also include a description of the planning process and a 

schedule for monitoring, evaluating, and updating the plan. 

A State may submit an enhanced mitigation plan that, in addition to the above-cited 

elements, demonstrates integration with other State and/or regional planning 

initiatives, such as economic and land development and emergency management. 

States with an enhanced plan are eligible for increased mitigation funds, but must 

demonstrate the capability to implement and assess mitigation projects and achieve 

mitigation goals. Furthermore, States with an enhanced plan must display a 

commitment to supporting local jurisdictions by providing workshops and training. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Mitigation Projects

A mitigation project is a specific undertaking by a community to reduce or eliminate 

long-term risk to people and property from hazards. Eligible projects must provide a 

long-term solution to a problem—for example, elevating a home to reduce the risk of 

flood damages as opposed to buying sandbags and pumps to fight the flood. In 

addition, a project’s potential savings must be more than the cost of implementing the 

project. Funds may be used to protect either public or private property or to purchase 

property that has been subjected to, or is in danger of, repetitive damage. Examples of 

projects are listed under Project Implementation. 

Mitigation Funding 

Mitigation grants are separated into three cost categories: 

• Project costs – used to implement the approved mitigation projects. 


• Planning costs – used to fund the cost of plan preparation. 


• Management costs – used to offset recipient’s administrative costs. 


 


Figure 2 shows the total amounts spent for mitigation funding from 2007 through 2011. 


 


Figure 2. Mitigation Funding by Cost Category

Planning 

6% 

Projects 

88% 

Management 

6% 

Total Amount Spent for Planning, 

Projects, and Management 2007-2011

Source: DHS OIG, based on FEMA data. 


www.oig.dhs.gov 5 OIG-12-109
 
 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Review 

Plan Participation 

Although hazard mitigation planning is voluntary, participation in the program 

has been relatively widespread. Presently all 50 States, the District of Columbia, 

and five of the seven U.S. Island Territories have approved plans. More than 

19,000 jurisdictions are currently represented by plans, covering approximately 

70 percent of the Nation’s population. State plans are scheduled to be renewed 

and resubmitted every 3 years, local plans every 5 years. All plans must be 

approved by FEMA. 

Notwithstanding the widespread program participation, some local jurisdictions 

do not participate. According to the State hazard mitigation officers we 

interviewed, common reasons for jurisdictions not participating are (1) lack of 

resources, (2) lack of a perceived threat in areas that have not had a declared 

disaster recently, and (3) an aversion to government programs. 

The current economic environment has strained local jurisdictions’ budgets and 

shrunk staffing levels to the point that program participation is a hardship, even 

with the Federal Government contributing 75 percent of the cost. In locations 

that are not prone to flooding, frequent earthquakes, or hurricanes, and that do 

not have a history of recent disasters, local jurisdictions often decline 

participation, especially if their resources are constrained. A number of 

jurisdictions, typically in rural, sparsely populated areas, display a tradition of 

self-sufficiency and an aversion to participation in voluntary government 

programs. 

Plan Review Process 

FEMA must complete its review and approval of a plan within 45 days of the time 

the FEMA Regional Office receives the plan. The State or governing body of the 

jurisdiction must formally adopt the plan before submitting it to FEMA. 

However, FEMA encourages States and local jurisdictions to submit a final draft 

of the plan for review before adoption so that FEMA can determine if the plan is 

“approvable pending adoption” or identify deficiencies that need to be 

addressed before the plan is formally adopted. States are also encouraged to 

review plans following a disaster to determine if revisions are necessary. 

www.oig.dhs.gov 6 OIG-12-109 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The CFR requires localities to update plans once every 5 years, and States to 

update their plans once every 3 years. This time difference in submitting plans 

was the most common issue we heard from the State mitigation officers. They 

consider the “too-frequent” 3-year update cycle to be burdensome, 

unnecessary, and impractical for the States. 

We were told that usually there are not enough changes in a 3-year period to 

warrant a new plan. State officials report that they are wasting time and money, 

especially because many of them perform annual plan maintenance updates that 

would minimize the frequency of a new plan. They would prefer a 5-year 

reporting cycle for State plans, particularly since the local plans are linked to the 

State plan and it would make sense to have both on the same reporting cycle. 

During a recent DHS regulatory review, FEMA proposed a rule change that would 

lengthen the States’ mitigation plan reporting cycle to 5 years. We commend 

FEMA on its responsiveness to State and local concerns and suggest that it 

continue promoting the proposed rule change. 

Project Implementation 

A mitigation project is a specific undertaking to reduce or eliminate long-term 

risk to people and property from hazards. Eligible projects must provide a longterm solution to a problem; for example, elevating a structure to reduce the 

likelihood of flooding could be eligible, whereas buying sandbags and pumps to 

fight the flood would not be eligible. In addition, a project’s potential savings 

must be more than the cost of implementing the project. Funds may be used to 

protect either public or private property or to purchase property that has been 

subjected to, or is in danger of, repetitive damage. The following are examples 

of eligible projects: 

• Property acquisition and structure demolition 

• Property acquisition and structure relocation 

• Structure elevation 

• Flood reduction projects 

• Soil stabilization 

• Wildfire mitigation 

• Safe-room construction 

• Infrastructure retrofit 

• Retrofitting of existing buildings and facilities 

• Floodproofing of structures 

www.oig.dhs.gov 7 OIG-12-109 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figures 3 through 5 illustrate mitigation projects. 

Figure 3. A home in a flood-prone area has been elevated. 

Source: FEMA Photo Library. 

Figure 4. “Hurricane clips” help anchor roofs to prevent detachment due to severe 

wind. 

Source: FEMA Photo Library. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 5. Structures have been acquired and removed from this flooded former 

residential area. 

Source: FEMA Photo Library. 

Potential projects are identified in the local mitigation plans, selected by the 

State, and forwarded to FEMA for an eligibility review. At minimum, approved 

projects must conform to the State plan, address an identified problem, meet 

environmental requirements, and be cost-effective. 

At the time of our fieldwork, FEMA did not track mitigation projects, but was 

developing a tool to track mitigation actions identified and implemented by 

grant recipients. The tool is expected to be in use sometime in 2012. We 

encourage FEMA to continue with its plans to implement a mitigation project 

tracking tool. 

Conclusion 

We conducted this survey to evaluate FEMA’s hazard mitigation planning 

program’s efficiency and effectiveness, and to determine whether a more 

comprehensive audit was needed. Based on our survey, we determined that 

further audit work is not warranted at this time. Nonetheless, FEMA needs to 

implement a better system to track participants’ progress, and continue ongoing 

efforts to address States’ concerns regarding plan reporting requirements. 

www.oig.dhs.gov 9 OIG-12-109 
 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

We recommend that the Associate Administrator, Federal Insurance and 

Mitigation Administration: 

Recommendation #1: 

Continue ongoing efforts to accomplish a rule change for mitigation plan 

reporting schedule. 

Recommendation #2: 

Proceed with current plans to develop a tool to track identified and 

implemented mitigation actions. 

Management Comments and OIG Analysis 

We received written comments on the draft report from FEMA’s Federal 

Insurance and Mitigation Administration. FEMA agreed with both 

recommendations. A copy of the comments is in appendix B. 

We analyzed FEMA’s comments and agree with the actions FEMA is taking. With 

regard to Recommendation 1, FEMA is taking the necessary preliminary steps to 

engage in rulemaking to change the frequency of plan updates for State 

mitigation plans. This will result in fewer financial and time burdens on the 

states and will allow for linked State and local plans to be on the same reporting 

cycle. We will determine the status of this recommendation once we receive the 

detailed corrective action plan in FEMA’s 90-day letter. 

With regard to Recommendation 2, FEMA has developed and is testing an 

Interim Action Measure Collection Tool for use by FEMA staff to begin to track 

areas where identified mitigation actions have been initiated. The tool was 

deployed in early 2012 to FEMA Regions to begin collecting data. This will allow 

FEMA to track participants’ progress. We will determine the status of this 

recommendation once we receive the detailed corrective action plan in FEMA’s 

90-day letter. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the Department. 

The objectives of our survey were to (1) evaluate the hazard mitigation planning 

program’s efficiency and effectiveness and (2) determine whether a more 

comprehensive audit was warranted. We reviewed agency documents and compared 

program statistics for fiscal years 2007 through 2011. 

Audit fieldwork was conducted in the Washington, DC, and Philadelphia, PA, areas, 

where we interviewed FEMA officials from the Federal Insurance and Mitigation 

Administration; at headquarters; and at Region III. We also conducted telephone 

interviews with regional FEMA officials and State hazard mitigation officers. 

We conducted this performance audit between October 2011 and January 2012 

pursuant to the Inspector General Act of 1978, as amended, and according to generally 

accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based upon our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based upon our audit objectives. 

www.oig.dhs.gov 11 OIG-12-109 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

U.s. ikpartmtll l or lIomtt.lld Stc:urlry Wu hlllglOCl, DC lOS18 

Homeland 

Security 

~AY 3 1 2011 

MEMORANDUM FOR: D. Michael Beard 

Assistant Inspector General 

Office of Emergency Management Oversight 

FROM: David J. Kaufman 

Director / /" 

11k---

Office of Policy and Program Analysis 

SUBJECT: FEMA's Response to OIG Draft Report, Survey 0/ Hazard 

Mitigation Planning OIG Project No. II-OIO-EMO-FEMA 

The Federal Emergency Management Agency (FEMA) appreciates the opportunity to review and 

respond to the Department of Homeland Security (DHS) Office of inspector General (010) Draft 

Report, Survey 0/ Hazard Mitigarioll Planning. Thc report focused on the strengths and 

weaknesses of the Federal Emergency Management Agency's Hazard Mitigation Planning 

program. The objectives of the survey were to (I) evaluate the hazard mitigation planning 

program's efficiency and cffcctiveness and (2) dctcnnine whether a morc comprehcnsive audit 

was warranted. Based on the survey. thc draft Report indicated further audit work on the 

program is not warranted at this time. 

Overall Comments 

FEMA appreciatcs the DHS (G's review of FEMA 's Hazard Mitigation Planning program and 

offcrs the following clarifications in the draft Report. 

• Page I, 2nd paragraph: "The program is voluntary, but all 50 States have 

participatcd since its inccption, and the tribal and local community participation 

accounts for approximately 70% of the Nation's population." Tribal and local 

community participation currenlly accounts for approximately 70% of the 

Nation's population. Since 2000, more than 26,000 jurisdictions have dcveloped 

plans, covering approximately 90% o f the Nation's population. 

• Page 3, bullets 1-3: The first bullct on HMGP suggests the total amount of 

funding (S 1.3 billion) was avail able for planning grants. Howcver, the total 

amounts identified (S 1.3 billion for HMGP, S270 million for POM and S 120 

million for FMA) were available for both mitigation projects and plans, and 

should not be interpreted as the amounts allocated for planning grants alone. 

www.oig.dhs.gov 12 OIG-12-109 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

• Page 6, 1" paragraph: "More than 19,000 jurisdictions are represented by plans, 

covering approximately 70% of the Nation's population." To be clear, more than 

19,000 jurisdictions are currently represented by FEMA-approved plans, covering 

approximately 70% of the Nation's population. Since 2000, more than 26,000 

jurisdictions have developed plans, covering approximately 90% of the Nation's 

population. 

Response to R«ommendations 

R«ommendation #1 : Continue ongoing efforts to accomplish a rule change for 

mitigation plan reporting schedule. 

FEMA Response: FEMA agrees with this recommendation. This issue is a top priority 

for FlMA and we are taking the necessary preliminary steps for FEMA to engage in 

rulemaking to change the frequency of plan updates for State Mitigation Plans. 

R«ommendation #2: Proceed with current plans to develop a tool to track identified 

and implemented mitigation actions. 

FEMA Response: FEMA agrees with this recommendation. FEMA has developed and is 

testing an Interim Action Measure Collection Tool for use by FEMA staff to begin to 

track areas where identified mitigation actions have been initiated. The tool was 

deployed in early 2012 to FEMA Regions to begin collecting data. 

Once again, thank you for the opportunity to comment on the findings and recommendations of 

the OIG Draft Report on Survey of Hazard Mitigation Planning prior to its publication. We look 

forward to working with you on expeditious closure of the recommendations. Please feel free to 

provide any comments/concerns to our Audit Liaison, Ms. Gina Non on, 202-646-4287. 

2 

www.oig.dhs.gov 13 OIG-12-109 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Major Contributors to This Report 

Kaye McTighe, Director 

Paul McPhail, Supervisory Program Analyst 

Stuart Josephs, Acting Audit Manager 

Kimberly Letnaunchyn, Program Analyst 

John Meenan, Program Analyst 

www.oig.dhs.gov 14 OIG-12-109 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

FEMA Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 15 OIG-12-109 
 

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