Local Multi-Hazard 

Mitigation Planning 

Guidance 

July 1, 2008 
This guidance represents FEMA’s interpretation of a statutory or regulatory requirement. The guidance

itself does not impose legally enforceable rights and obligations, but sets forth a standard operating

procedure or agency practice that FEMA employees follow to be consistent, fair, and equitable in the 

implementation of the agency’s authorities. 
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LOCAL MULTI-HAZARD MITIGATION PLANNING GUIDANCE 

TABLE OF CONTENTS..................................................................................................1 

INTRODUCTION.............................................................................................................3 

Purpose ..............................................................................................................3 

Using the Mitigation Planning Guidance..........................................................6 

Plan Submittal and Review Procedures ...........................................................7 

Planning Resources ........................................................................................10 

Flood Mitigation Planning ...............................................................................12 

Multi-Jurisdiction & Other Local Organizations ............................................14 

PREREQUISITES .........................................................................................................17 

Adoption by the Local Governing Body.........................................................17 

Multi-Jurisdictional Plan Adoption .................................................................19 

Multi-Jurisdictional Planning Participation....................................................21 

PLANNING PROCESS .................................................................................................25 

Documentation of the Planning Process........................................................26 

RISK ASSESSMENT ....................................................................................................29 

Identifying Hazards..........................................................................................30 

Profiling Hazards .............................................................................................32 

Assessing Vulnerability: Overview.................................................................36 

Assessing Vulnerability: Identifying Structures............................................39 

Assessing Vulnerability: Addressing Repetitive Loss Properties ..............42 

Assessing Vulnerability: Estimating Potential Losses .................................45 

Assessing Vulnerability: Analyzing Development Trends............................47 

Multi-Jurisdictional Risk Assessment............................................................50 
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MITIGATION STRATEGY.............................................................................................52 

Local Hazard Mitigation Goals ........................................................................53 

Identification and Analysis of Mitigation Actions..........................................56 

Implementation of Mitigation Actions.............................................................61 

Implementation of National Flood Insurance Program (NFIP) ......................63 

Multi-Jurisdictional Mitigation Actions...........................................................65 

PLAN MAINTENANCE .................................................................................................67 

Monitoring, Evaluating, and Updating the Plan .............................................68 

Incorporation Into Existing Planning Mechanisms........................................70 

Continued Public Involvement........................................................................73

LOCAL MITIGATION PLAN REVIEW CROSSWALK.................................................A-1 
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PURPOSE 

Hazard mitigation is any sustained action taken to reduce or eliminate the long-term risk to 

human life and property from hazards. Mitigation activities may be implemented prior to, during, 

or after an incident. However, it has been demonstrated that hazard mitigation is most effective 

when based on an inclusive, comprehensive, long-term plan that is developed before a disaster 

occurs. 

This publication is one of three guidance documents on implementing the Federal Emergency 

Management Agency’s (FEMA) Mitigation Planning regulations under Code of Federal 

Regulations (CFR), Title 44, Part 201. Separate documents are available for the State MultiHazard Mitigation Planning Guidance (Standard and Enhanced, 44 CFR §201.4 and §201.5) 

and Tribal Multi-Hazard Mitigation Planning Guidance (44 CFR §201.7). 

The purpose of this Local Multi-Hazard Mitigation Planning Guidance is to provide guidance to 

local governments to meet the requirements of 44 CFR §201.6, Local Mitigation Plans. This 

Local Multi-Hazard Mitigation Planning Guidance was designed with three major objectives: 

• To help local jurisdictions develop and adopt new mitigation plans or revise existing 

mitigation plans to meet the requirements of 44 CFR Part 201; 

• To help Federal and State reviewers evaluate mitigation plans from different jurisdictions 

in a fair and consistent manner; and 

• To help local jurisdictions conduct comprehensive reviews and prepare updates to their 

plans to meet the requirements of 44 CFR Part 201. 

This Local Multi-Hazard Mitigation Planning Guidance, as interpretation and explanation for the 

Local Mitigation Plan regulations at 44 CFR Part 201, is FEMA’s official source for defining the 

requirements of original and updated Local Mitigation Plans. It includes references to specific 

language in 44 CFR Part 201 and descriptions of the relevant requirement to meet the 

mitigation planning requirements. 

This guidance addresses Local Mitigation Plan requirements for local governments, which are 

defined at 44 CFR §201.2 as: 

any county, municipality, city, town, township, public authority, school district, special 

district, intrastate district, council of governments (regardless of whether the council of 

governments is incorporated as a nonprofit corporation under State law), regional or 

interstate government entity, or agency or instrumentality of a local government; any 

Indian tribe or authorized tribal organization, or Alaska Native village or organization; 

and any rural community, unincorporated town or village, or other public entity. 
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Authorities 

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

Act), 42 U.S.C. 5165, as amended by the Disaster Mitigation Act of 2000 (DMA) (P.L. 106-390), 

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

reducing risks to natural hazards through mitigation planning. The National Flood Insurance Act 

of 1968, as amended, 42 U.S.C. 4001 et seq, reinforced the need and requirement for mitigation 

plans, linking flood mitigation assistance programs to State, Tribal and Local Mitigation Plans. 

FEMA has implemented the various hazard mitigation planning provisions through regulations at 

44 CFR Part 201. These reflect the need for States, Tribal, and local governments to closely 

coordinate mitigation planning and implementation efforts, and describes the requirement for a 

State Mitigation Plan as a condition of pre- and post-disaster assistance, as well as the 

mitigation plan requirement for local and Tribal governments as a condition of receiving FEMA 

hazard mitigation assistance. 

The regulations governing the mitigation planning requirements for local mitigation plans are 

published under 44 CFR §201.6. Under 44 CFR §201.6, local governments must have a 

FEMA-approved Local Mitigation Plan in order to apply for and/or receive project grants under 

the following hazard mitigation assistance programs: 

• Hazard Mitigation Grant Program (HMGP) 

• Pre-Disaster Mitigation (PDM) 

• Flood Mitigation Assistance (FMA) 

• Severe Repetitive Loss (SRL) 

FEMA may require a Local Mitigation Plan under the Repetitive Flood Claims (RFC) program, at 

which time this policy will apply to those governments that apply for and/or receive assistance 

under the RFC program as well. 

Special Consideration: Extraordinary Circumstances 

Under 44 CFR §201.6 (a)(3), FEMA Regional Administrators may grant an exception to the 

Local Mitigation Plan requirement in extraordinary circumstances, such as in a small and 

impoverished community, when justification is provided. In these cases, a plan must be 

completed within 12 months of award of the project grant. 

Key Concepts 

Several key concepts are reflected throughout the mitigation planning regulations at 44 CFR 

Part 201, and are reflected in each of the State, Tribal and Local Mitigation Plan requirements 

and corresponding guidance. The most successful of mitigation plans — where practical, 

meaningful mitigation actions resulted — have two common elements: 

• Comprehensive risk and capability assessments that form a solid foundation for 

decision making; and 

• Participation by a wide range of stakeholders who play a role in identifying and 

implementing mitigation actions. 
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The mitigation plan requirements in 44 CFR Part 201 emphasize greater interaction between 

State and local mitigation activities, and highlight the need for improved linkage between State 

and Local Mitigation Plans. Under 44 CFR §201.4(c)(4), States are required to coordinate 

mitigation planning with Indian Tribal and local jurisdictions, and document funding and 

technical assistance they will provide to these jurisdictions. The information contained in Local 

Mitigation Plans is also useful for States developing their State Mitigation Plans. That is, States 

refer to Local Mitigation Plans to improve the level of detail and comprehensiveness of 

statewide risk assessments and coordinate State hazard mitigation goals and objectives with 

local goals and objectives. Similarly, local governments may refer to their State’s mitigation 

plan where information may be useful for local mitigation strategy development. 

FEMA also has a continuing interest in streamlining the mitigation planning and implementation 

process. In hazard mitigation planning, as with most other planning efforts, the actual process 

of planning is as important as the plan itself. Therefore, FEMA considers the plan as the written 

record, or documentation, of the planning process. This is why some of the plan requirements 

ask for a “discussion” or “description” of a process or development of a planning product (such 

as goals, or hazard identification). The implementation of planned, pre-identified, cost-effective 

mitigation actions based on a sound hazard identification and assessment of risk will make a 

major contribution to such streamlining. 

Special Considerations: 

In reading the mitigation planning regulations at 44 CFR Part 201, an important distinction must 

be made between the words “shall” and “should.” When the word “shall” is used, the 

requirement is mandatory – e.g., “The risk assessment shall include: A description of the type, 

location, and extent of all natural hazards that can affect the jurisdiction.” If the plan does not 

include this description, it will not be approvable by FEMA. It should also be noted that the word 

“must” carries the same mandatory nature as the word “shall.” For example, “The plan must be 

... resubmitted for approval within five (5) years...” This is a mandatory requirement. 

When the word “should” is used, the item is strongly recommended to be included in the plan, 

but its absence will not cause FEMA to disapprove the plan. For example, where the regulation 

says, “The plan should describe vulnerability in terms of ... the types and numbers of existing 

and future buildings ...” this information would make the plan more useful, but the plan could still 

be approved if it is not included (assuming the plan met all the mandatory requirements). 

The use of the words “should,” “shall” and “must” in the Multi-Hazard Mitigation Planning 

Guidance documents is consistent with the use of those words in mitigation planning regulations 

at 44 CFR Part 201. In the Plan Review Crosswalk, the “should” requirements are shaded as a 

reminder that they are not required for plan approval. 

To emphasize the importance of the process, FEMA has taken, to the extent possible, a 

“performance standard,” rather than a “prescriptive” approach to the planning requirements. 

This means that the requirements are designed to identify, generally, what should be done in 

the process and documented in the plan, rather than specify exactly how it should be done. This 

approach recognizes and appreciates the inherent differences that exist among State, Tribal, 

and local governments with respect to size, resources, capability, and vulnerability. It also 

enables the State, Tribal or local government the flexibility to integrate the mitigation plan into 

other daily and long-term planning initiatives and programs. 
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USING THE MITIGATION PLANNING GUIDANCE 

Organization 

The Local Multi-Hazard Mitigation Planning Guidance is divided into six sections following this 

Introduction: 

• Prerequisites 

• Planning Process 

• Risk Assessment 

• Mitigation Strategy 

• Plan Maintenance 

• Local Mitigation Plan Review Crosswalk 

The first five sections contain the language of the mitigation planning regulations, an 

explanation clarifying the intent of the requirements, and references to a series of resources that 

address particular planning issues in more detail. The last section contains the Local Mitigation 

Plan Review Crosswalk for evaluating plans. 

The regulation is published at 44 CFR Part 201. Language in brackets does not appear in the 

regulation, but has been added to provide the proper context. For example: “[The plan must 

include] a description of the planning process.” An ellipsis has been used to indicate that other 

phrases precede or follow the requirement language. 

Plan Updates 

The mitigation planning regulation at 44 CFR §201.6(d)(3) states: 

A local jurisdiction must review and revise its plan to reflect changes in development, 

progress in local mitigation efforts, and changes in priorities, and resubmit it for approval 

within five (5) years in order to continue to be eligible for mitigation project grant funding. 

This Local Multi-Hazard Mitigation Planning Guidance describes elements of the five-year plan 

updates as required at 44 CFR §201.6(d)(3). The Local Mitigation Plan Review Crosswalk also 

reflects both new and updated plan submittals. 

Local Mitigation Plan Review Crosswalk 

This Local Multi-Hazard Mitigation Planning Guidance outlines a process for the review of Local 

Mitigation Plans based on the requirements described in the mitigation planning regulations 

under 44 CFR §201.6. The Local Mitigation Plan Review Crosswalk included in this document 

is an important tool in both the review and development of complete plans, as they mirror the 

requirements in the mitigation planning regulations at 44 CFR §201.6. 

Special Considerations: 

States may insert additional State mitigation planning requirements, tailoring the Local MultiHazard Mitigation Planning Guidance to account for State specific requirements. FEMA 

reviewers will not consider these additional State requirements in their evaluation nor 

disapprove a plan based on any additional information included in a plan. 
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PLAN SUBMITTAL AND REVIEW PROCEDURES 

Plan Submittal Procedures 

The mitigation planning regulations under 44 CFR Part 201 require that local jurisdictions submit 

mitigation plans to the State Hazard Mitigation Officer (SHMO) for initial review and 

coordination, with the State then forwarding the plans to FEMA for formal review and approval. 

Local mitigation plans should be submitted in an electronic format, either through email, or 

through the mail on CD/DVD. The following recommended submission approaches may also be 

helpful: 

• States and communities should coordinate with each other to identify procedures and 

schedules that will facilitate State support of local mitigation planning efforts and initial 

review of Local Mitigation Plans. 

• Local jurisdictions may share drafts of their entire plan, or at least the results of the risk 

assessment (because of the importance of the risk assessment to the quality of the 

overall plan), with the State well in advance of finalizing the plan. Early feedback from 

the State will let the jurisdiction know that it is on the right track, that additional material 

needs to be added, or that major revisions need to be made in time to develop and 

submit an approvable plan by established deadlines.

• Local jurisdictions are encouraged to submit a final draft of the mitigation plan to the 

State and FEMA for review before seeking formal adoption of the plan by the 

appropriate officials, agencies, or organizations. If FEMA determines that their plan is 

“approvable pending adoption” (i.e., the plan meets all requirements except for the 

formal adoption and final submittal), the jurisdiction can then proceed with the adoption 

process, knowing the adopted plan will be approved. If FEMA determines the plan is not 

approvable, the responsible parties will be able to address deficiencies before taking the 

plan through adoption, therefore avoiding unnecessary delays in plan approval. 

• Local jurisdictions should consult with their SHMO early enough to ensure that they will 

be able to obtain FEMA review and approval of their plans in time to meet established 

deadlines. 

Plan Evaluation Methodology 

As required at 44 CFR §201.6(d), Local Mitigation Plans must be submitted to the SHMO for 

initial review and coordination, and then the SHMO may submit the mitigation plan to the 

appropriate FEMA Regional Office for formal review and approval. FEMA reviewers document 

their evaluation of the plan using the Local Mitigation Plan Review Crosswalk. 

Local Mitigation Plans are approved when they receive a “Satisfactory” for all requirements 

under 44 CFR §201.6. Except for prerequisites that are met before the plan can be approved, 

the reviewer evaluates requirements based on the following system: 

• N Needs Improvement: The plan does not meet the minimum for the 

requirement. Reviewer’s comments are provided. 

• S Satisfactory: The plan meets the minimum for the requirement. Reviewer’s 

comments are encouraged, but not required. 
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The final, completed Local Mitigation Plan Review Crosswalk provides the local jurisdiction with: 

• a determination for each requirement; 

• FEMA reviewer comments for requirements that need improvement; 

• FEMA reviewer “recommended revisions” that are not required but offer suggestions on 

areas to enhance the mitigation plan; and, 

• a determination of whether the plan is approved by the State and FEMA. 

In those cases where FEMA reviewers provided “recommended revisions”, the plan update 

process provides an excellent opportunity to incorporate these recommendations into the 

revised plan. When FEMA reviews the updated plan, it will assess whether and how the plan 

addresses these recommendations, although it is not required that the plan does so. 

Special Considerations: 

The Local Mitigation Plan Review Crosswalk includes a column (second from left), “Location in 

the Plan,” that the State or jurisdiction submitting the plan can complete to assist reviewers in 

determining where in the plan the requirements are addressed. When reviewing plans, the 

evaluator may find it helpful to first read the plan and identify the appropriate sections that 

correspond to the Local Mitigation Plan requirements. 

Plan Updates 

The mitigation planning regulations at §201.6(d)(3) directs the update of Local Mitigation Plans: 

A local jurisdiction must review and revise its plan to reflect changes in development, 

progress in local mitigation efforts, and changes in priorities, and resubmit it for approval 

within 5 years in order to continue to be eligible for mitigation project grant funding. 

Local Mitigation Plans must be updated and resubmitted to FEMA for approval every five (5) 

years in order to continue eligibility for FEMA hazard mitigation assistance programs. Plan 

updates must demonstrate that progress has been made in the past 5 years for Local Mitigation 

Plans to fulfill commitments outlined in the previously approved plan. This involves a 

comprehensive review and update of each section of the Local Mitigation Plan and a discussion 

of the results of evaluation and monitoring activities detailed in the Plan Maintenance section of 

the previously approved plan. Plan updates may validate the information in the previously 

approved plan, or may involve a major plan rewrite. A plan update is NOT an annex to the 

previously approved plan; it stands on its own as a complete and current plan. 

Local jurisdictions should develop a schedule that allows a plan update and approval to occur 

within 5 years from the last approval date. All jurisdictions should consider the time needed 

prior to the expiration of the Local Mitigation Plan. Sufficient time should be allotted for all 

activities up to and including adoption, such as: 

• Application and award for mitigation planning grants (if applicable); 

• Contracting for technical or professional services (if applicable); 

• Review of mitigation plan; 

• Planning process to develop the update; 
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• State and/or FEMA reviews; 

• Revising the updated plan, if necessary based on FEMA review comments; and 

• Plan adoption procedures. 

It should be noted that States could choose to establish a schedule for more frequent Local 

Mitigation Plan updates. 

Indian Tribal Governments with Expiring Local Mitigation Plans 

On October 31, 2007 FEMA published amendments to 44 CFR Part 201 at 72 Fed. Reg. 61720 

that created a new type of hazard mitigation plan specific to Indian Tribal governments. Under 

44 CFR §201.7(a), Indian Tribal governments with mitigation plans approved by FEMA on or 

before October 1, 2008, under §201.4 or§201.6 will continue to meet the planning requirements 

in order to be eligible for FEMA assistance. The approval timeframes for these State or Local 

Mitigation Plan types will continue to be recognized, and updates as Tribal Mitigation Plans will 

be required after the approved three years (for plans approved as State Mitigation Plans) or five 

years (for plans approved as Local Mitigation Plans). 

All Indian Tribal governments with mitigation plans approved after October 1, 2008 must follow 

the criteria identified in 44 CFR §201.7, Tribal Mitigation Plans in order to be eligible for FEMA 

assistance. Tribal Mitigation Plans follow the criteria established in 44 CFR §201.7 as a 

condition of receiving non-emergency Stafford Act assistance as a grantee, and the Tribal 

Mitigation Plan also allows an Indian Tribal government to apply through the State as a 

subgrantee for any FEMA mitigation project grant (See the programs affected under the 

Authorities section). In addition, an Indian Tribal government may choose to address severe 

repetitive loss properties as a condition of receiving the reduced cost share for the FMA and 

SRL programs. Tribal Mitigation Plans approved under 44 CFR §201.7 will be approved for a 

period of five years. 

Indian Tribal governments should consult with their FEMA Regional Office early to ensure that 

they will be able to obtain FEMA review and approval of their plans in time to meet established 

deadlines. The separate Tribal Multi-Hazard Mitigation Planning Guidance (44 CFR §201.7) 

document provides guidance for the development, adoption, review and update of Tribal 

Mitigation Plans. 

Timeframe for Review 

Once a final plan is submitted, the FEMA Regional Office will complete the review within 45 

days from the day it is received, whenever possible. In the event that the plan is not approved, 

the FEMA Regional Office will provide comments on the areas that need improvement. FEMA 

will complete the review of each re-submittal of the Local Mitigation Plan within 45 days from the 

day it is received, whenever possible, as well. 
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PLANNING RESOURCES 

Planning Guidance, Tools & Training 

To help States, Tribes, and local governments better understand the mitigation planning 

requirements under 44 CFR Part 201, FEMA prepared the Multi-Hazard Mitigation Planning 

Guidance under the Disaster Mitigation Act of 2000 (March 2004 with revisions November 2006, 

June 2007 & January 2008). This document, Local Multi-Hazard Mitigation Planning Guidance, 

supersedes that previous guidance document for all Local Mitigation Plan requirement under 44 

CFR §201.6. 

In addition to this document, FEMA provides a number of planning tools to assist localities in 

developing a comprehensive, multi-hazard approach to mitigation planning, and in preparing 

plans that will meet the mitigation planning requirements. These tools include: 

• State and Local Mitigation Planning How-to Guides – intended to help States and 

communities plan and implement practical, meaningful hazard mitigation actions 

(FEMA 386-1 through -8); available on the FEMA Web site through 

http://www.fema.gov/plan/mitplanning/planning_resources.shtm#1. 

• Planning for a Sustainable Future (FEMA 364) - provides guidance for integrating 

hazard mitigation and sustainable practices as part of pre- and post-disaster 

mitigation planning efforts; available on the FEMA Web site through 

http://www.fema.gov/plan/mitplanning/planning_resources.shtm#1. 

• Multi-Hazard Identification and Risk Assessment (MHIRA), available on the FEMA 

Web site at http://www.fema.gov/plan/prevent/fhm/ft_mhira.shtm. 

These publications can be ordered through the FEMA Publications Warehouse at 800-480-2520 

or online at FEMA’s Information Resource Library http://www.fema.gov/library/index.jsp. 

• Mitigation Benefit Cost Analysis (BCA) Toolkit Compact Disc includes all the FEMA 

BCA software, technical manuals, BCA training course documentation, and other 

supporting material and BCA guidance. The BCA Toolkit is available through FEMA’s 

toll-free Benefit-Cost Analysis Technical Assistance Helpline: 1-866-222-3580 or email: bchelpline@dhs.gov. 

• HAZUS-MH (Hazards U.S. – Multi- Hazard), a risk assessment software program, 

available to order on the FEMA Web site at http://www.fema.gov/plan/prevent/hazus/. 

• Community Rating System Coordinator’s Manual (FIA-15/2007), available to order 

from NFIP/CRS PO Box 501016, Indianapolis, IN 46250-1016, or by email at 

NFIPCRS@ISO.COM, or for download at http://training.fema.gov/EMIWeb/CRS/. 

In addition, FEMA’s Emergency Management Institute (EMI) also provides mitigation training to 

help Federal, State, local, and tribal governments understand mitigation planning through its

Mitigation Planning Workshop for Local Governments (G318) for the development and review of 

Local Mitigation Plans. 

EMI’s curriculum also includes training in BCA, NFIP, HAZUS, the National Hurricane Program 

and the National Earthquake Hazards Reduction Program. The curriculum includes training 

courses of varying lengths offered in residence, through field courses, and on-line training 

through the independent study program. Information on EMI’s program can be obtained at 

http://www.training.fema.gov/. 
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Special Considerations: 

Both the Stafford Act and the National Flood Insurance Act of 1968 specifically require 

mitigation planning for natural hazards, but not for manmade hazards. However, FEMA supports 

jurisdictions that choose to consider technological and manmade hazards in their respective 

mitigation plans. While it is true that a Local Mitigation Plan does not require manmade hazards 

to be addressed in order to be approved, the Local Multi-Hazard Mitigation Planning Guidance 

can be helpful in developing and evaluating plans that include these hazards as part of a 

comprehensive hazard mitigation strategy. 

For more information on integrating technological and manmade hazards in mitigation plans, 

please See: Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7); available at 

http://www.fema.gov/plan/mitplanning/howto7.shtm. 

Funding for Plan Development 

A Local Mitigation Plan as defined in 44 CFR §201.6 is required for local jurisdictions that elect 

to participate in FEMA hazard mitigation assistance programs as a subapplicant or subgrantee. 

The Stafford Act authorizes up to 7 percent of available HMGP funds for State, Tribal, or local 

mitigation planning purposes. Also, funds from the PDM program may be used to develop 

mitigation plans, and the FMA program provides annual grant funds for flood mitigation 

planning. 

Funding for hazard mitigation planning may be available from other Federal agencies. For 

example, the National Oceanic and Atmospheric Administration’s Coastal Zone Management 

(CZM) Program has funded coastal hazard mitigation activities, including planning. 

The Local Mitigation Plan requirements encourage agencies at all levels, local residents, 

businesses, and the nonprofit sector to participate in the mitigation planning and implementation 

process. This broad public participation enables the development of mitigation actions that are 

supported by these various stakeholders and reflect the needs of the community. Private sector 

participation, in particular, may lead to identifying local funding that would not otherwise have 

been considered for mitigation activities. 
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FLOOD MITIGATION PLANNING 

Flood Mitigation Plans 

In order to be eligible for project funds under the Flood Mitigation Assistance (FMA) program 

authorized by the National Flood Insurance Act of 1968, as amended, communities are required 

under 44 CFR §79.6(d)(1) to have a mitigation plan that addresses flood hazards. Although 

communities are not required to have a multi-hazard mitigation plan for the FMA program, they 

are encouraged to consider all hazards that could impact their community. First, a multi-hazard 

risk assessment may reveal effects or relationships between different hazards. For example, 

hurricanes have a combination of flood and wind impacts. Second, addressing all hazards will 

allow a community to be eligible for a wider range of federal mitigation assistance programs. 

On October 31, 2007 FEMA published amendments to the 44 CFR Part 201 at 72 Fed.l Reg. 

61720 to incorporate mitigation planning requirements for the FMA program. The amendments 

impacted 44 CFR §201.6, Local Mitigation Plans, as follows: 

• Combined the Local Mitigation Plan requirement for all hazard mitigation assistance 

programs under 44 CFR §201.6 to include the FMA as well as the HMGP, PDM and 

SRL programs, thus eliminating duplicative mitigation plan regulations; 

• Incorporated the requirement for communities with National Flood Insurance 

Program (NFIP) insured properties that have been repetitively damaged from floods 

to address such properties in their risk assessment and mitigation strategy; and 

• Incorporated the requirement for communities that participate in the NFIP to include 

a strategy for continued compliance with the NFIP. 

The Local Multi-Hazard Mitigation Planning Guidance includes these new requirements. 

Community Rating System 

The Community Rating System (CRS) is a part of the NFIP. When communities go beyond the 

NFIP’s minimum standards for floodplain management and participate in the CRS, discounts 

may be available on flood insurance premiums for policy holders in those communities. 

One of the activities that communities can take to improve their CRS rating (and subsequently 

lower premiums) is to develop a CRS plan. The CRS 10-step planning process is consistent 

with the multi-hazard planning regulations under 44 CFR Part 201. However, CRS provides 

additional points for activities that communities can take during their planning process that go 

above the minimum described below, thus possibly lowering insurance rates. At a minimum, 

an approved multi-hazard mitigation plan under 44 CFR Part 201 that addresses floods could 

qualify for CRS credit. Although communities are not required to participate in CRS in order to 

receive approval of a Local Mitigation Plan, FEMA encourages jurisdictions to integrate the CRS 

planning steps into their multi-hazard mitigation plans. 
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Special Consideration: Communities interested in receiving CRS credit for their Local 

Mitigation Plan submit a separate review request to the ISO/ CRS Specialist. The ISO/CRS 

Specialist is an employee of the Insurance Services Office, Inc. (ISO). ISO works on behalf of 

FEMA and the insurance companies to review CRS applications, verify the communities' credit 

points, and perform program improvement tasks, including the review of plans for CRS credit. 

The table below illustrates how the CRS 10-step planning process relates to the four phases of 

multi-hazard mitigation planning process. The Local Multi-Hazard Mitigation Planning Guidance

also provides basic guidance on working toward increased CRS points by integrating the CRS 

10-step planning process into the four phases of the multi-hazard mitigation plan. More detailed 

information can be found in Activity 510 of the CRS Coordinator’s Manual or in CRS Example 

Plans which can be accessed on the web at http://training.fema.gov/EMIWeb/CRS/. 

Mitigation Plan 

Requirements 

44 CFR §201.6 

CRS Planning Steps CRS Maximum Points 

Prerequisites 

201.6 (c)(5) 9. Adopt the plan 2 

Phase 1: Planning Process 

201.6(c)(1) 1. Organize 10 

201.6(c)(1) 2. Involve the Public 85 

201.6(b) (2) & (3) 3. Coordinate 25 

Phase 2: Risk Assessment 

201.6 (c)(2)(i) 4. Assess the hazard 20 

201.6 (c)(2) (ii) & (iii) 5. Assess the problem 35

Phase 3: Mitigation Strategy 

201.6 (c)(3) (i) 6. Set Goals 2 

201.6 (c)(3) (ii) 7. Review possible activities 30 

201.6 (c)(3) (iii) 8. Draft an action plan 70 

Phase 4: Plan Maintenance 

201.6 (c)(4) 10. Implement, evaluate, revise 15 

Total: 294 
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MULTI-JURISDICTION & OTHER LOCAL ORGANIZATIONS 

Section 201.2 of 44 CFR defines Local Government as: 

any county, municipality, city, town, township, public authority, school district, special 

district, intrastate district, council of governments (regardless of whether the council of 

governments is incorporated as a nonprofit corporation under State law), regional or 

interstate government entity, or agency or instrumentality of a local government. 

FEMA recognizes that local governance structures vary, and that the authority to implement 

mitigation strategies (e.g., land use planning and zoning, building code enforcement, 

infrastructure improvements, floodplain management, etc.) may not reside within a single 

governmental entity. In addition, certain FEMA hazard mitigation assistance programs accept 

applications from private, nonprofit organizations and other quasi-governmental entities that do 

not necessarily align with traditional geopolitical boundaries. To ensure these potential 

subapplicants to FEMA mitigation assistance programs meet the eligibility requirements for 

mitigation plans under 44 CFR §201.6, FEMA has identified procedures for several of these 

entities. 

Multi-Jurisdictional Mitigation Plans 

FEMA’s Local Mitigation Plan requirements under 44 CFR §201.6 specifically identify criteria 

that allow for multi-jurisdictional mitigation plans. Many issues are better resolved by evaluating 

hazards more comprehensively by coordinating at the county, regional, or watershed level. 

Although economy-of-scale efforts are apparent and encouraged with multi-jurisdictional plans, 

FEMA requires that all participating jurisdictions meet the requirements for mitigation plans 

identified in 44 CFR §201.6. While certain elements are common to all participating jurisdictions 

(e.g., planning process, hazards, goals, and maintenance), there are some elements that are 

unique to each participating jurisdiction, including: 

• risks, where they differ from the general planning area; 

• mitigation actions (actions must be identified for each jurisdiction); 

• participation in the planning process (examples of participation include attending 

meetings, contributing research, data, or other information, commenting on drafts of the 

plan, etc.); and 

• adoption (each jurisdiction must formally adopt the plan). 

Universities 

Under 44 CFR 201, a public college or university may be an active participant in a FEMAapproved State, Tribal or Local Mitigation Plan, or have an approved plan of their own that 

meets the requirements of 44 CFR §201.6 to be eligible for mitigation project grants. 

If a college or university has fully participated in the development and review of a plan in 

accordance with 44 CFR §201.6(b), Documentation of the Planning Process, it is not necessary 

for them to approve/adopt the plan, as long as it is adopted by the appropriate State, Tribal or 

local government. 
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If a college or university chooses to develop their own plan, adoption of the plan can be 

accomplished through a resolution or letter from the institution President, Board of Directors or 

recognized governing body. 

In a large and complex State university system, there may be several component universities, 

each with multiple campuses, extension offices, and other sites. The various universities may 

be subject to different risks, and each individual university may be best served by developing a 

stand-alone, single-jurisdiction plan, or be a participant in the planning process for their local 

government. However, the State university system's Board of Regents or other top-level entity 

may determine that the State would be best served if planning for all of its component 

institutions and campuses were coordinated at the highest possible level in order to facilitate 

capital improvement planning. In such a case, the top-level entity could develop a multijurisdictional plan to which the participating component institutions would then be signatories. 

Regardless of whether planning is distributed or centralized, however, the plans developed will 

be Local Mitigation Plans, not State Mitigation Plans, even if they are developed by and for 

State institutions. 

Similarly, private institutions may opt to participate in local or regional multi-jurisdictional plans, 

or they may develop plans of their own. Either way, the key to success is to ensure that all of 

the requirements established by regulation are met. This includes coordinating the planning 

activities of each campus with those of the surrounding community and, in the case of a multiinstitution plan, ensuring that each institution's unique risks are addressed in addition to those 

risks affecting the entire university system. 

School Districts 

School districts or independent school districts, or other special districts are defined as local 

governments at 44 CFR Part 201.2, and are therefore required to have a FEMA-approved local 

mitigation plan to be eligible for project grants under FEMA hazard mitigation assistance 

programs. A school district may also demonstrate their participation as a separate government 

entity in another local government’s approved mitigation plan to be eligible for project grants 

under FEMA hazard mitigation assistance programs. 

School districts do not fall under the definition of private nonprofit organizations (See the 

definition of private nonprofit organization under the Private Nonprofit (PNP) Organizations 

section below.) 

Private Nonprofit (PNP) Organizations 

Private nonprofit organizations are not considered governmental entities. This distinction is 

important, because current regulations under 44 CFR Part 201 provide only for governments 

(State, Tribal or Local), not PNPs, to meet the planning requirement for having a FEMAapproved Mitigation Plan in order to receive project grant funds. For mitigation planning 

purposes, PNPs are defined consistently with 44 CFR 206.2(a)(19) as: 

Any nongovernmental agency or entity that currently has: (i) An effective ruling letter 

from the U.S. Internal Revenue Service granting tax exemption under section 501 (c), 

(d), or (e) of the Internal Revenue Code of 1954; or (ii) Satisfactory evidence from the 
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State that the organization or entity is a nonprofit one organized or doing business under 

State law. 

Under HMGP regulations at 206.434(a)(1), certain PNPs are eligible subapplicants; however, in 

those cases, the jurisdiction in which the PNP project is located must have a FEMA-approved 

Mitigation Plan to be eligible for grant funds. FEMA strongly recommends that PNPs participate 

in the development of the Local or Tribal Mitigation Plan to ensure that projects funded are 

consistent with the mitigation strategies of the jurisdiction. If they have fully participated in the

development and review of the Local or Tribal Mitigation Plan, it is not necessary for them to 

approve/adopt the plan, as long as it is adopted by the jurisdiction. 

Multi-Jurisdictional Private Nonprofit (PNP) Utilities 

Multi-jurisdictional utility private nonprofit organizations (PNPs), including Rural Electric 

Cooperatives (RECs), are considered PNPs for the purposes of disaster assistance provided by 

FEMA under the Stafford Act. For PNPs such as RECs, special utility districts, or other multijurisdictional utilities, FEMA identifies two ways in which they may meet the mitigation planning 

requirement that ensure that projects funded by the HMGP are consistent with the mitigation 

strategies of the State, Tribal, and/or local jurisdiction in which the project is located. 

First, the local jurisdiction(s) within which the REC mitigation project is located must have a 

FEMA-approved Local or Tribal Mitigation Plan under 44 CFR §201.6. FEMA strongly 

encourages PNPs in general, especially those that may be eligible sub-applicants for mitigation 

projects, such as RECs, to participate in the development of Local or Tribal Mitigation Plans. 

Second, under 44 CFR §201.4, the FEMA approved State Mitigation Plan must address RECs. 

In the State option, the State may prepare an annex to its State Mitigation Plan specific to RECs 

and/or other multi-jurisdictional utilities that provide a critical function. The RECs and similar 

entities must participate with the State in the development of this annex, specifically in the 

identification of hazards potentially affecting their infrastructure, assessment of the 

vulnerabilities of the infrastructure to these hazards and identification of mitigation measures to 

reduce these vulnerabilities. The level of detail of the risk assessment and mitigation strategy of 

the annex must follow the requirements for Local Mitigation Plans (44 CFR §201.6(c)(2) and 

(3)), rather than the requirements for Standard State Mitigation Plans, in order to provide sitespecific information. Coordination with local jurisdictions within which REC infrastructure is 

located must be documented in the annex, whether or not they have FEMA approved Local 

Mitigation Plans. Coordination with these jurisdictions will help ensure that the mitigation 

measures identified in the plan will be acceptable, and not in conflict with development or other 

plans of these jurisdictions. The annex must be approved by the State and FEMA, and the REC 

must participate in future updates of the Plan with respect to the annex. 
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PREREQUISITES 

The local jurisdictions submitting the plan satisfies the following prerequisites before the plan 

can receive approval by FEMA. The official approval date is indicated on the signed FEMA 

approval letter. As well as providing the approval date, it also indicates the expiration date of 

the plan. 

ADOPTION BY THE LOCAL GOVERNING BODY 

Requirement 

§201.6(c)(5): 

[The local hazard mitigation plan shall include] documentation that the 

plan has been formally adopted by the governing body of the jurisdiction 

requesting approval of the plan (e.g., City Council, County 

Commissioner, Tribal Council). 

Explanation: Adoption by the local governing body demonstrates the jurisdiction’s 

commitment to fulfilling the mitigation goals and objectives outlined in the 

plan. Adoption legitimizes the plan and authorizes responsible agencies 

to execute their responsibilities. The plan shall include documentation 

of plan adoption, usually a resolution. 

If the local jurisdiction has not passed a formal resolution, or used some 

other documentation of adoption, the clerk or city attorney must provide 

written confirmation that the action meets their community’s legal 

requirements for official adoption and/or the highest elected official or 

their designee must submit written proof of the adoption. The signature 

of one of these officials is required with the explanation or other proof of 

adoption. 

Minutes of a council or other meeting during which the plan is adopted 

may be sufficient if local law allows meeting records to be submitted as 

documentation of adoption. The clerk of the governing body, or city 

attorney, must provide a copy of the law and a brief, written explanation 

such as, “in accordance with section ___ of the city code/ordinance, this 

constitutes formal adoption of the measure,” with an official signature. 

Formal adoption of the plan may be completed prior to submission to 

FEMA for review. However, if adopted after FEMA review, adoption 

must take place within one calendar year of receipt of FEMA’s “Approval 

Pending Adoption.” If the plan is not adopted within one calendar year 

of FEMA’s “Approval Pending Adoption” the jurisdiction must update the 

entire plan and resubmit it for FEMA review. 

Approval Pending Adoption is a recommended and potentially timesaving process by which jurisdictions submit the final draft mitigation 

plan for a review prior to formal jurisdictional adoption. If the plan meets 

all of the Local Mitigation Plan requirements, the plan would then be 

returned to the jurisdiction with an approvable pending adoption status. 

When the approval pending adoption plan is adopted by the jurisdiction, 

and FEMA has received the documentation of adoption, it would then be 

formally approved through a signed FEMA approval letter. 
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Note: The plan’s crosswalk may contain recommended revisions, 

suggesting improvements to the plan. If the jurisdiction opts to 

incorporate all or some of the recommendations then the plan would be 

resubmitted for another review. 

If the plan is not adopted, the jurisdiction would not be eligible to apply 

for and/or receive project grants under the following hazard mitigation 

assistance programs: Hazard Mitigation Grant Program (HMGP), PreDisaster Mitigation (PDM), Flood Mitigation Assistance FMA), and 

Severe Repetitive Loss (SRL). 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

Therefore, the updated plan shall include a copy of the resolution or 

other documentation of formal adoption of the updated plan dated within 

one year of FEMA’s “approval pending adoption”, regardless of the 

degree of modification. The resolution or adoption for the previously 

approved plan will not be accepted for plan updates. 

Resources: For more information about adopting the mitigation plan, See: 

 Bringing the Plan to Life (FEMA 386-4), Step 1. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 1: Adopt the 

Plan 

The plan shall include 

documentation of plan 

adoption, usually a 

resolution. 

Difference? 

CRS: The documentation must say that 

the plan was adopted rather than 

approved for CRS and the documentation 

must be either a resolution or ordinance. 

Step 9: Adopt the Plan 

Documentation that the plan 

has been formally adopted by 

the governing body of the 

jurisdiction requesting 

approval of the plan. The 

adoption must be either a 

resolution or ordinance. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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MULTI-JURISDICTIONAL PLAN ADOPTION 

Requirement 

§201.6(c)(5): 

For multi-jurisdictional plans, each jurisdiction requesting approval of the 

plan must document that it has been formally adopted. 

Explanation: Each jurisdiction that is included in the plan must have its governing 

body adopt the plan prior to FEMA approval, even when a regional 

agency has the authority to prepare such plans. 

As with single jurisdictional plans, in order for FEMA to give approval to 

a multi-jurisdictional plan, at least one participating jurisdiction must

formally adopt the plan within one calendar year of FEMA’s designation 

of the plan as “approvable pending adoption” (See page 15 for an 

explanation of this process). 

The plan approval date begins the five-year approval period and sets the 

expiration date for the plan. The official approval date is indicated on the 

signed FEMA approval letter. As well as providing the approval date, it 

also indicates the expiration date of the plan. Plans must be reviewed, 

revised and resubmitted for approval within five years in order to 

continue to be eligible for grant project funding (44 CFR §201.6(d)(3)). 

Participants of a multi-jurisdictional plan will assume the expiration date 

five years from the first jurisdiction’s approval date regardless of the 

other participant’s subsequent adoption date(s). FEMA recommends 

that all participating jurisdictions coordinate the adoption process as 

soon as the plan has received “approvable pending adoption” status to 

ensure that all participants are covered by a plan for the full five years. 

The five-year approval period does not get “re-set” each time another 

participating jurisdiction adopts the plan. For example, if jurisdiction #1, 

the first jurisdiction to formally adopt the Blue County Multi-Jurisdictional 

Hazard Mitigation Plan, receives FEMA’s “approval” of the plan on 

January 15, 2008, the plan will also expire on January 15, 2013, exactly 

5-years later. If jurisdiction #2 does not formally adopt the plan until July 

15, 2008, its eligibility would expire on January 15, 2013, the same exact 

date that Blue County’s plan received “approval” when the plan was first 

approved. Thus, jurisdiction #2 does not benefit from the full five-year 

window, but only 41⁄2 years. 

If the plan is not adopted by a participating jurisdiction, that jurisdiction 

would not be eligible for project grants under the following hazard 

mitigation assistance programs: HMGP, PDM, FMA, and SRL. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

Each jurisdiction that is seeking approval for the plan must have its 

governing body adopt the updated plan, regardless of the degree of 
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 modifications. The resolution or adoption for the previously approved 

plan will not be accepted for plan updates. 

Resources: For more information about adopting the mitigation plan, See: 

 Bringing the Plan to Life (FEMA 386-4), Step 1. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 4. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 1: Prerequisites: 

Multi-Jurisdictional 

Plan Adoption 

Each jurisdiction 

requesting approval of 

the plan must document 

that the plan has been 

formally adopted. 

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 9: Adopt the Plan 

When a multi-jurisdictional 

plan is prepared, it must be 

adopted by the governing body 

of each community seeking 

CRS credit. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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MULTI-JURISDICTIONAL PLANNING PARTICIPATION 

Requirement 

§201.6(a)(4): 

Multi-jurisdictional plans (e.g., watershed plans) may be accepted, as 

appropriate, as long as each jurisdiction has participated in the 

process ... Statewide plans will not be accepted as multi-jurisdictional 

plans. 

Explanation: A multi-jurisdictional plan, as prepared by regional planning areas, 

development authorities (e.g. watershed/river basin commission), 

counties or special districts, is acceptable as a Local Mitigation Plan. 

However, those jurisdictions within the planning area that do not 

participate in its development and adopt the mitigation plan will not be 

eligible for project grants. Therefore, the local mitigation plan must 

document how each jurisdiction that is requesting FEMA approval of the 

plan participated in the planning process. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

The updated plan must identify the following: 

• All participating jurisdictions, new or continuing; and, 

• Jurisdictions that no longer participate in the plan 

If jurisdictional participation has changed since approval of the previous 

plan, changes should be discussed in the planning process section of 

the updated plan. 

Resources: For more information on initiating a comprehensive local mitigation 

planning process, See: 

 Getting Started (FEMA 386-1), Steps 1-3 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 8 

Special 

Considerations: 

After a multi-jurisdictional Mitigation Plan has been adopted, and 

approved by FEMA, additional jurisdictions may wish to become part of 

the planning process, or “join” the mitigation plan. Additional 

jurisdictions may be added to an existing, FEMA-approved, mitigation 

plan, only if the conditions below are met (if all three conditions are not 

met, the jurisdiction may develop its own mitigation plan). 
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1. The jurisdiction(s) asking to be included is located within the 

boundaries of, or adjacent to, the area covered by the multijurisdictional mitigation plan. 

2. The organization that was responsible for preparing and 

submitting the multi-jurisdictional mitigation plan to the State and 

FEMA agrees with the addition of the requesting jurisdiction(s) to 

the mitigation plan. 

3. When the multi-jurisdictional mitigation plan was developed, the 

risk assessment included an analysis of the major hazards, 

specifically the natural hazards that have the potential to impact 

the additional jurisdiction(s). 

If these conditions can be met, there are two options that can be used to 

add additional jurisdictions to a FEMA-approved mitigation plan. 

Regardless of the option chosen, each jurisdiction joining a multi-hazard 

planning process and seeking to receive credit from FEMA for an 

approved mitigation plan must satisfy all of the Local Mitigation Plan 

requirements identified at 44 CFR §201.6. 

Option 1 - Approved Plan with Additional Annex or Appendix. This 

option is best suited to situations in which the multi-jurisdictional 

mitigation plan has been recently approved by FEMA and the majority of 

the mitigation plan's five-year lifespan remains. In these cases, the 

jurisdictions that participated in the multi-jurisdictional planning process 

would not be required to take any action. Plan content specific to any 

new jurisdiction is included in a new annex or appendix to the existing 

mitigation plan, and no other changes are made to the previously 

approved mitigation plan. 

The following actions must be taken to add new jurisdictions to the 

existing multi-jurisdictional mitigation plan and enable them to receive 

approval as part of the mitigation plan: 

1. The requesting jurisdiction(s) must review the multi-jurisdictional 

hazard analysis and determine if there are any additional hazards 

that have not been addressed and threaten the jurisdiction(s). If 

none exist, the jurisdiction(s) must document their review process 

and state that no additional hazards exist. If the review reveals 

additional hazards, the jurisdiction(s) must analyze the risks 

it/they face associated with those hazards and include this 

analysis in their written appendix to the multi-jurisdictional 

mitigation plan. The existing risk assessment cannot be 

resubmitted without this additional documentation. 
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Special 

Considerations: 

2. The requesting jurisdiction(s) must document agreement with the 

stated mitigation goals of the multi-jurisdictional mitigation plan. 

Additional goals specific to the requesting jurisdiction may be 

added. Each additional jurisdiction must also develop a list of 

proposed mitigation actions appropriate for that jurisdiction. 

These can include the common actions outlined in the multijurisdictional mitigation plan, but must include specific mitigation 

actions for each profiled hazard the jurisdiction itself. 

3. The requesting jurisdiction(s) must document the involvement of 

both the general public and the local government in the planning 

process in accordance with 44 CFR §201.6. The level of 

participation in the multi-jurisdictional mitigation plan must be 

consistent for the additional jurisdictions. 

4. The annex or appendix, along with the multi-jurisdictional 

mitigation plan, and a letter of concurrence from the agency or 

organization responsible for the mitigation plan, must be 

submitted to the State for formal review. When the State finds 

the mitigation plan approvable, it will forward it to FEMA. When 

FEMA's review finds the mitigation plan "approvable pending 

adoption," the new jurisdiction can formally adopt the full 

mitigation plan and its jurisdiction-specific annex or appendix and 

submit the mitigation plan in final form through the State to FEMA 

for approval. 

The mitigation plan approval date for the added jurisdictions will continue 

to be the date given by FEMA for the multi-jurisdictional mitigation plan. 

This means that the additional jurisdictions will have less than the entire 

5-year plan approval window before they will need to engage in the 

required update for the full multi-jurisdictional mitigation plan. 

Option 2 - Revise and Update Full Plan. This option is best suited to 

situations in which the addition of new jurisdictions to the multijurisdictional mitigation plan is occurring far enough along in the fiveyear lifespan of the original mitigation plan that a full review and revision 

will begin in the very near future. In these cases, the responsible 

agency or jurisdiction for the mitigation plan determines that it is an 

appropriate time for the mitigation plan update process to begin, and the 

new jurisdiction(s) can participate in a mitigation plan update with the 

original jurisdictions. 
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(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 

Multi-Hazard Planning 

Phase

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 1: Prerequisites: 

Multi-Jurisdictional 

Plan Participation 

Multi-jurisdictional plans 

(e.g., watershed plans) 

may be accepted, as 

appropriate, as long as 

each jurisdiction has 

participated in the 

process ... State-wide 

plans will not be 

accepted as multijurisdictional plans.

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 1: Step 1: Organize to 

Prepare the Plan. 

Multi-jurisdictional plans are 

encouraged in CRS. Credit is 

based on each jurisdiction’s 

full participation in the planning 

process. 
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PLANNING PROCESS 

The planning process is as important as the plan itself. Hence, the mitigation planning 

regulation at 44 CFR Part 201 requires a narrative description of the process used to develop 

the mitigation plan—a systematic account about how the mitigation plan evolved from the 

moment the planning team was created and the public participated, to how each section of the 

plan was developed, to what plans or studies were incorporated into the plan, to how it will be 

implemented. 

Any successful planning activity, such as the development of a comprehensive plan, involves 

bringing together a cross-section of the public to reach consensus on how to achieve a desired 

outcome or resolve a community problem. Using this inclusive process, the public gains a 

better understanding of the problem or issue and strives to develop a vision along with goals, 

priorities, and actions. The result is a common set of community 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. An effective and open 

public involvement process ensures that all citizens understand risks and vulnerability so that 

they will work with the jurisdiction and support policies, actions, and tools that over the long-term 

will lead to a reduction in future losses. 

A comprehensive description of the planning process informs citizens and other readers about 

the plan’s development. Leadership, staffing, and in-house knowledge in local government may 

fluctuate over time. Therefore, the description of the planning process serves as a permanent 

record that explains how decisions were reached on a strategy to reduce losses, and that it was 

developed with stakeholder input in a methodical and reasonable way. Leaders can then 

continue to make decisions in a pre- and post-disaster environment to decrease vulnerability to 

community hazards. 

Section 201.6(c)(1) requires the documentation of the planning process, including how the plan 

was prepared, who was involved in the process, and how the public was involved. 

This section includes the following subsection: 

Documentation of the Planning Process 
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DOCUMENTATION OF THE PLANNING PROCESS 

Requirements 

§201.6(b) and 

§201.6(c)(1): 

An open public involvement process is essential to the development of 

an effective plan. In order to develop a more comprehensive approach to 

reducing the effects of natural disasters, the planning process shall 

include: 

(1) An opportunity for the public to comment on the plan during the 

drafting stage and prior to plan approval; 

(2) An opportunity for neighboring communities, local and regional 

agencies involved in hazard mitigation activities, and agencies that 

have the authority to regulate development, as well as businesses, 

academia and other private and non-profit interests to be involved in 

the planning process; and 

(3) Review and incorporation, if appropriate, of existing plans, studies, 

reports, and technical information. 

[The plan shall document] the planning process used to develop the 

plan, including how it was prepared, who was involved in the process, 

and how the public was involved. 

Explanation: The description of the planning process shall: 

• Indicate how the public (residents, businesses, and other 

interested parties) was given the opportunity to comment on the 

plan during the drafting stage and prior to plan approval (e.g.

public meetings, interactive Web pages, storefronts, toll-free 

telephone lines, etc.); 

• Include a discussion of the opportunity provided to neighboring 

communities, governmental agencies, businesses, academia, 

and other relevant private and non-profit interests to be involved 

in the hazard mitigation planning process; and 

• Describe the review of any existing plans, studies, reports, and 

technical information, and how these are incorporated into the 

plan. 

The plan shall document how the plan was prepared (e.g., the time 

period to complete the plan, the type and outcome of meetings), who 

was involved in the planning process (e.g., the composition of the 

planning team), and how the public was involved. 

The plan should also document how the planning team was formed and 

how each party represented contributed to the process. Ideally, the local 

mitigation planning team is composed of local, State, and Federal 

agency representatives, as well as community representatives, local 

business and nonprofit leaders, and educators. 
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The plan should describe how public comments and concerns were 

considered and incorporated into the plan. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

Therefore, the updated plan shall describe the process used to review 

and analyze each section of the plan (i.e., Planning Process, Risk 

Assessment, Mitigation Strategy, and Plan Maintenance). If the 

planning team or committee finds that some sections of the plan warrant 

an update, and others do not, the process the team undertook to make 

that determination must be documented in the plan. 

The plan maintenance section requires a description about how the 

community was kept involved during the plan maintenance process (44 

CFR §201.6(c)(4)(iii)) over the previous five years. Since this 

contributes to the continued planning process, the community may 

choose to describe this within the planning process section of the plan 

update rather than the plan maintenance section. The plan maintenance 

section is intended to be forward-thinking and emphasize future 

community involvement. 

Special 

Considerations: 

The planning team should consider including a current description of the 

jurisdiction in this section or in the introduction of the plan. The general 

description can include a socio-economic, historic, and geographic 

profile to provide a context for understanding the mitigation actions that 

will be implemented to reduce the jurisdiction’s vulnerability. 

Resources: For more information on the planning process; ideas on identifying 

stakeholders and building the planning team, generating public interest, 

enlisting partners, and choosing an appropriate public participation 

model; and advice to local governments seeking to initiate a 

comprehensive local mitigation planning process, See: 

 Getting Started (FEMA 386-1), Steps 1 – 3. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 17 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386), 

Phase 3, Step 4. 
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(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 

Multi-Hazard Planning 

Phase

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 1: Documentation 

of the Planning Process 

Documentation of the 

planning process 

includes: A description of 

the process used to 

prepare the plan and an 

indication of who was 

involved in the process. 

It must also document 

how the public was 

involved and 

demonstrate that an 

opportunity was given for 

neighboring 

communities, local and 

other interested parties 

to be involved in the 

planning process. This 

phase also requires a 

description of the review 

and incorporation of 

existing plans, studies, 

reports, and technical 

information, if 

appropriate.

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 1: Organize to Prepare 

the Plan, Step 2: Involve the 

Public and Step 3: 

Coordinate with other 

Agencies 

Credit is based on how the 

community organizes to prepare 

its floodplain management plan. 

Describe who is involved in the 

planning process and what their 

roll is in the development of the 

plan. The planning process must 

include an opportunity for the 

public, neighboring communities 

and local and regional agencies to 

comment on the plan during the 

drafting stage and before plan 

approval. The term public means 

residents, businesses, property 

owners, and tenants in the 

floodplain and other known 

hazards areas as well as other 

stakeholders in the community, 

such as business leaders, civic 

groups, academia, non-profit 

organizations and major 

employers. The plan must also 

incorporate and document a 

review of existing studies, reports, 

and technical information into the 

community’s needs, goals and 

plans for the area. 
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RISK ASSESSMENT 

Section 201.6(c)(2) of the mitigation planning regulation requires local jurisdictions to provide 

sufficient hazard and risk information from which to identify and prioritize appropriate mitigation 

actions to reduce losses from identified hazards. This includes detailed descriptions of all the 

hazards that could affect the jurisdiction along with an analysis of the jurisdiction’s vulnerability 

to those hazards. Local risk assessments do not need to be based on the most sophisticated 

technology, but do need to be accurate, current, and relevant. Local risk assessments coupled 

with the local mitigation strategies are the basis for the State’s evaluation of its resources and 

facilitate the establishment of statewide goals. 

Data needed to complete risk assessments may not be readily available in order for jurisdictions 

to meet the planning requirements with the submission of their initial plan. Therefore, FEMA 

recommends that plans identify any data limitations and include actions in the mitigation 

strategy of the plan to tell how the data will be obtained. The data would then be included in the 

risk assessment in the next plan update. 

During an update to the risk assessment, local jurisdictions consider current and expected 

future vulnerability to all hazards and to integrate new hazard data such as flood studies. Local 

jurisdictions are encouraged to incorporate updated estimates of cost of living and replacement 

costs for vulnerable buildings, reduced vulnerability due to the completed mitigation actions or 

projects, and impacts of population growth or loss in vulnerable areas. 

Even though maps are generally not required as part of the plan, FEMA recommends the use of 

maps to illustrate the required risk assessment information. To assist communities in hazard 

vulnerability analysis, FEMA has developed HAZUS (HAZUS-MH), a nationally standardized 

geographic information system (GIS) software that can be used to assess vulnerability by 

estimating losses from floods, earthquakes and hurricane wind events. Even though HAZUS is 

not required in Local Mitigation Plans, communities are encouraged to use HAZUS to form a 

scientific basis from which the mitigation strategy is developed. 

Even though the mitigation planning regulation does not require that plans address manmade 

hazards, jurisdictions are encouraged to assess risk to these hazards by using FEMA’s 

Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7). This guide is designed to 

help jurisdictions identify specific actions to reduce loss of life and property from manmade 

hazards by modifying the built environment. It is not intended to help jurisdictions establish 

procedures to respond to disasters, write an emergency operations plan, or create a counterterrorism program. In this context, the goal of mitigation is to decrease the need for response 

as opposed to simply increasing response capability. 

This section includes the following eight (8) subsections as follows: 

Identifying Hazards 

Profiling Hazards 

Assessing Vulnerability: Overview 

Assessing Vulnerability: Identifying Structures 

Assessing Vulnerability: Addressing Repetitive Loss Properties 

Assessing Vulnerability: Estimating Potential Losses 

Assessing Vulnerability: Analyzing Development Trends 

Multi-jurisdictional Risk Assessment 
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IDENTIFYING HAZARDS 

Requirement 

§201.6(c)(2)(i): 

[The risk assessment shall include a] description of the type ... of all 

natural hazards that can affect the jurisdiction ... 

Explanation: The local risk assessment shall identify and describe the hazards likely 

to affect the planning area. It is critical that the plan identify all the 

natural hazards that can affect the jurisdiction, because the hazard 

identification is the foundation for the plan’s risk assessment, which in 

turn is the factual basis for the mitigation strategy. If the hazard 

identification omits (without explanation) any hazards commonly 

recognized as threats to the jurisdiction, this part of the plan cannot 

receive a “Satisfactory” score. 

While not required by the mitigation planning regulation at 44 CFR Part 

201, the plan should describe the sources used to identify hazards. The 

process for identifying hazards could involve the following: 

Reviewing the State hazard mitigation plan and local or regional 

reports, plans, flood ordinances, and land use regulations, among 

others; 

Talking to experts from Federal, State, and local agencies and 

universities; 

Reviewing past events and declared disasters; 

Searching the Internet and newspapers; and 

Interviewing long-time residents and consulting historical societies or 

museums. 

Events which contain multiple hazards should describe each hazard 

separately to provide sufficient information to enable the jurisdiction to 

identify and prioritize appropriate mitigation actions. It is important to 

consider the multiple aspects of each identified hazard. For instance, 

hurricanes and tsunamis have distinctly different types of impacts from 

high winds than flooding and storm surges; severe storms also include 

both flooding and high winds; and wildfires have immediate fire hazards, 

but may also produce mudslide hazards when followed by rain. When 

considering how to approach hazard identification, jurisdictions should

refer to the State’s risk assessment and approach hazard identification 

similarly. 
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Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

Therefore, the local risk assessment update shall address any newly 

identified hazards that have been determined to pose a threat. If 

improved descriptions of hazards are available, they should be 

incorporated into this section. 

Special 

Consideration: 

Using HAZUSMH to Estimate 

Potential Losses 

To assist communities in hazard vulnerability analysis, FEMA has 

developed HAZUS (HAZUS-MH), a nationally standardized geographic 

information system (GIS) software that can be used to assess 

vulnerability by estimating losses from floods, earthquakes and hurricane 

wind events. While HAZUS is not required in Local Mitigation Plans, 

communities are encouraged to use HAZUS to form a scientific basis 

from which the mitigation strategy is developed. 

HAZUS can be used to define the area at risk (the planning area) as well 

as the degree of risk from potential flood, earthquake, and wind hazards. 

HAZUS is based on a geographic information system platform; therefore, 

it is possible to overlay information about other hazards on HAZUS maps 

in order to better understand risk from those hazards. 

Resources: For more information on identifying hazards, See: 

 Understanding Your Risks (FEMA 386-2), Step 1. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

 Phase 3: Risk 

Assessment 

[The risk assessment 

shall include a] 

description of the type ... 

of all natural hazards 

that can affect the 

jurisdiction ...

Difference? 

All appropriate hazards must be identified 

and described in the multi-hazard 

mitigation plan, while the plan for CRS 

must only identify and describe the flood 

hazard. 

Step 4: Assess the Hazard 

CRS requires at the minimum 

that the flood hazard be 

identified including addressing 

the repetitive loss areas. 

However, additional credit can 

be earned for including 

discussion of all other natural 

hazards. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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PROFILING HAZARDS 

Requirement 

§201.6(c)(2)(i): 

[The risk assessment shall include a] description of the ... location and 

extent of all natural hazards that can affect the jurisdiction. The plan shall 

include information on previous occurrences of hazard events and on the 

probability of future hazard events. 

Explanation: The description of each hazard shall include a narrative (and an optional 

map) of the following information: 

The location or geographical areas in the community that would be 

affected. If a hazard location cannot be geographically determined, 

such as tornados that can strike anywhere in the community, the plan 

must describe the entire planning area that can be affected by the 

hazard. However, hazards with known geographic boundaries (e.g., 

flood, earthquake) must specifically identify where the hazard can 

occur. For example: floodplains indicate areas potentially affected by 

flooding; inundation areas represent the boundary on a Flood 

Insurance Rate Map (FIRM) that shows the rising of a body of water 

and its overflowing onto normally dry land; wildland urban interface 

(WUI) are areas potentially affected by wildfire where improved 

property and wildland fuels meet at a well-defined boundary1. 

The extent (i.e., magnitude or severity) of potential hazard events. 

Magnitude is a measure of the strength of a hazard event. The 

magnitude (also referred to as severity) of a given hazard event is 

usually determined using technical measures specific to the hazard2. 

For each identified hazard, plans shall indicate the range of 

magnitude or severity that could be experienced. Discussion of what 

the community could anticipate should be enhanced with scientific 

scales, such as the Fujita Scale, TORRO Hail Scale, Richter Scale, 

Beaufort Wind Scale, Saffir-Simpson Scale, and the Palmer Index or 

by using quantitative measurements such as: miles per hour, flood 

depth, inches of rain, fire danger rating, and acres burned. Others 

classify hazards using terms like high, medium, or low (or major, 

minor, minimum). The plan must clearly define any classification 

methods used to illustrate extent. 

The probability is a statistical measure of the likelihood that the 

hazard event would occur in an area2. 

The plan shall also provide a discussion of past occurrences of hazard 

events in or near the community. For example, in areas where tornadoes 

occur, plans should indicate the recorded intensities and dates of previous 

events. This discussion should include: 

 

1

 Source: National Fire Protection Agency (NFPA) 299, Standard for Protection of Life & Property from 

Wildfire, 1991. 

2 Source: FEMA 433: Using HAZUS-MH for Risk Assessment.
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 Information on the damages that occurred (e.g., costs of recovery, 

property damage, and lives lost) to the extent available; 

 Level of severity (i.e., flood depth, wind speeds, earthquake intensity, 

etc.); 

 Duration of event; 

 Date of occurrence; and 

 Sources of information used or consulted for assembling a history of 

past occurrences. 

The hazard analysis should also identify on a map the areas affected by 

each identified hazard. Additionally, a composite map (i.e., map showing 

combined information from different thematic map layers) should be 

provided for hazards with a recognizable geographic boundary (i.e., 

hazards that are known to occur in particular areas of the jurisdiction, such 

as floods, coastal storms, wildfires, tsunamis, and landslides). 

The characterization of hazards should describe the conditions, such as 

topography, soil characteristics, meteorological conditions, etc., in the 

area that may exacerbate or mitigate the potential effects of hazards. 

The hazard analysis should be detailed enough to allow identification of 

the areas of the jurisdiction that are most severely affected by each 

hazard. 

The plan should describe the analysis or sources used to determine the 

probability, likelihood, or frequency of occurrence as well as the severity or 

magnitude of future hazard events. 

The plan should note any data limitations and identify and include in the 

mitigation strategy actions for obtaining the data to complete and improve 

future risk analysis efforts. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

Therefore, the plan update shall continue to describe occurrences of 

hazards included in the previously approved plan, and discuss new 

occurrences of hazard events. As required under §201.6(d)(3) the 

updated plan shall incorporate any new (i.e., since the previous plan was 

approved) historical records, or hazard data related to profiling hazards, 

such as NFIP maps or studies, HAZUS studies, or reports from other 

Federal or State agencies that describe location, extent, probability, or 

previous occurrences of hazards. 

FEMA recommends that previously approved plans point out any data 

limitations, and identify actions to obtain the data in the mitigation strategy. 

If the previously approved plan identified data deficiencies that would be 

addressed at a later time, then the deficiencies shall be incorporated in 
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the updated risk assessment. However, if the data deficiencies have not 

been resolved, they must be addressed in the updated plan, 

accompanied by an explanation of why they remain and an updated 

schedule to resolve the issue. 

Any maps included in the updated plan must be consistent with the 

updated information. 

Special 

Consideration: 

Using HAZUSMH to Estimate 

Potential Losses 

While HAZUS is not required in Local Mitigation Plans, communities are 

encouraged to use HAZUS to form a scientific basis from which the 

mitigation strategy is developed. 

• HAZUS establishes a base map for both single- and multijurisdictional boundaries and includes important features such as 

critical/essential facilities, lifeline facilities, high potential loss 

facilities, bridges, hazardous materials facilities and limited utilities 

and road segment data. It is based on the geographic area that 

the risk assessment will address. 

• HAZUS includes historical information about earthquake and 

hurricane hazards. 

Special 

Considerations: 

While the mitigation planning regulation at 44 CFR Part 201 does not 

require the inclusion of maps as part of the mitigation plan, they can be a 

valuable tool to illustrate the information provided in the risk assessment. 

If the jurisdiction does not have digital mapping capability (Geographic 

Information System, Internet maps), paper maps can be scanned and 

manipulated manually to include in the plan. 

Maps should address hazards in the planning area specific to the 

jurisdiction(s) or planning area represented in the plan. For example, 

maps at a State or regional scale may not adequately show information 

relevant on the local or County/Parish level. It may be useful to consider 

the following when determining the usefulness of maps: 

• Avoid using state or national scale maps; 

• Maps can have multiple layers to clarify each hazard. This is 

effective for hazards such as flood and hazmat; 

• Maps should clearly show all participating jurisdictional boundaries; 

• Maps should be readable at an 8 1⁄2 by 11 inch letter size; 

• Maps should include a readable legend and scale; 

• Documentation on the limitations of the data used on the map 

should be described the plan. 

Refer to Understanding Your Risks, (FEMA 386-2) for more information on 

maps and mapping techniques. 
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Resources: For more information on profiling hazards, See: 

 Understanding Your Risks (FEMA 386-2) 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7, 

Phase 2, Step 2. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 23. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 3: Risk 

Assessment 

[[The risk assessment 

shall include a] 

description of the ... 

location and extent of all 

natural hazards that can 

affect the jurisdiction. 

The plan shall include 

information on previous 

occurrences of hazard 

events and on the 

probability of future 

hazard events. 

Difference? 

For CRS, the plan must identify and 

describe the flood hazard, including the 

repetitive loss areas. Whereas the multihazard plan must describe the location 

and extent of all natural hazards that can 

affect the jurisdiction. The multi-hazard 

plan must also include information on 

previous occurrences and on the 

probability of future hazard events. (This 

is an option for CRS credit) 

Step 4: Assess the Hazard 

Credit is based on what the 

community includes in its 

assessment of the hazard. 

The minimum requirement is 

for the flood hazard only. 

However, additional credit can 

be earned by identifying and 

including a description of all 

other natural hazards. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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ASSESSING VULNERABILITY: OVERVIEW 

Requirement 

§201.6(c)(2)(ii): 

[The risk assessment shall include a] description of the jurisdiction’s 

vulnerability to the hazards described in paragraph (c)(2)(i) of this 

section. This description shall include an overall summary of each 

hazard and its impact on the community. 

Explanation: An overview of the community’s vulnerability is a summary of the 

hazard’s impact on the community and its vulnerable structures. This 

summary shall include, by type of hazard, a general description of the 

types of structures affected by the hazards. Examples include, but are 

not limited to, buildings, infrastructure, critical facilities, structures that 

house the elderly or disabled, and areas where low-income populations 

reside. 

The overview shall also include a general description of the hazard’s 

impact to the vulnerable structures. Vulnerable structures include those 

located within geographic areas susceptible to a particular hazard. 

However, keep in mind that certain hazards may affect the entire 

community or planning area. 

The summary can be presented in terms of dollar value or percentages 

of damage. If there are any data limitations, 44 CFR §201.6(c)(2)(ii) may 

be met by identifying the particular limitations and including mitigation 

strategy actions for obtaining the data necessary to complete and 

improve future vulnerability assessments. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, progress in local 

mitigation efforts, and changes in priorities, and resubmit it for approval 

within 5 years in order to continue to be eligible for mitigation project 

grant funding 

Therefore, the vulnerability overview in the updated plan shall describe 

any changes, clarifications, or refinements to the overview summary 

described in the previously approved plan. It shall continue to include, 

by type of hazard, a general description of the types of structures 

affected by the hazard. 

The community should take into account the following when updating its 

vulnerability assessment: 

• Updates to inventories of existing structures in hazard areas, 

including new development, redeveloped areas or structures 

located in annexed areas. 

• Potential impacts of future land development, including areas 

that may be annexed in the future. 
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• New buildings that house special high-risk populations (i.e., 

elderly, low-income, disabled) 

• Completed mitigation actions that reduced overall 

vulnerability. 

If the previously approved plan noted data limitations related to the 

vulnerability summary and identified in the mitigation strategy actions to 

resolve the data deficiency, then the updated plan shall discuss how the 

data was collected and incorporated into the updated risk assessment. 

If data deficiencies still remain unresolved, the plan must discuss in the 

mitigation strategy what action will be taken to collect the data for the 

next update. 

Special 

Considerations: 

The mitigation planning regulation at 44 CFR Part 201 does not require 

a discussion about facilities that house special populations at risk, such 

as the elderly, disabled, or others with special needs. However, FEMA 

recommends their consideration in the risk assessment to enable the 

development of appropriate actions to reduce vulnerability to these 

facilities during and after a disaster, thereby potentially saving lives. 

Special 

Consideration: 

Using HAZUSMH to Estimate 

Potential Losses 

HAZUS outputs tables and maps of inventory data and allows the 

incorporation of local data to consider the assets that can be impacted 

by the prioritized hazards. HAZUS includes information compiled from 

national databases to describe the distribution of buildings by their use, 

construction material, replacement cost, and other characteristics. It 

also includes data about the location and characteristics of utilities, 

transportation, populations, and other information that can help 

communities understand their risk from hazards. It is also possible to 

use HAZUS to incorporate locally developed hazard data and 

information about the built and social environment into the risk 

assessment process. It is recommended that communities take 

advantage of this capability in order to produce loss estimations that 

reflect their local conditions as accurately as possible. 

Resources: For a discussion on preparing a vulnerability assessment, See: 

 Understanding Your Risks (FEMA 386-2), Step 3, Worksheet #3a 

Inventory Assets. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 25. 

 HAZUS-MH at www.fema.gov/plan/prevent/hazus. 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-

7), Phase 2, Step 2. 
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Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 3: Risk 

Assessment 

[The risk assessment 

shall include a] 

description of the 

jurisdiction’s vulnerability 

to the hazards described 

in paragraph (c)(2)(i) of 

this section. This 

description shall include 

an overall summary of 

each hazard and its 

impact on the 

community. 

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 5: Assess the Problem 

Credit is based on what is 

included in the assessment of 

vulnerability to the hazards 

identified. At a minimum the 

plan must include an overall 

summary of each hazard and 

its impact on the community. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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ASSESSING VULNERABILITY: ADDRESSING REPETITIVE LOSS PROPERTIES 

Requirement 

§201.6(c)(2)(ii): 

[The risk assessment in all] plans approved after October 1, 2008 must 

also address National Flood Insurance Program (NFIP) insured 

structures that have been repetitively damaged by floods. 

Explanation: Repetitive loss properties are those for which two or more losses of at 

least $1,000 each have been paid under the National Flood Insurance 

Program (NFIP) within any 10-year period since 1978. Local 

governments may obtain information on repetitive loss properties 

within their jurisdiction by contacting their State NFIP Coordinator. Use 

of flood insurance claim and disaster assistance information is subject 

to The Privacy Act of 1974, as amended, which prohibits public release 

of the names of policy holders or recipients of financial assistance and 

the amount of the claim payment or assistance. However, maps 

showing areas where claims have been paid can be made public. The 

data should be used for planning purposes and can be very helpful in 

identifying problem areas that may not be apparent on a floodplain or 

drainage map. 

After October 1, 2008, all Local Mitigation Plans approved by FEMA 

must address repetitive loss structures in the risk assessment by 

describing the types (residential, commercial, institutional, etc.) and 

estimate the numbers of repetitive loss properties located in identified 

flood hazard areas. 

The plan should describe vulnerability in terms of an estimate of the 

potential dollar losses to repetitive loss properties and a description of 

the methodology used to prepare the estimate. 

The plan should describe vulnerability in terms of providing a general 

description of land uses and development trends within repetitive loss 

areas so that mitigation options can be considered in future land use 

decisions. 

The plan should include a map of the known flood hazards, where 

“known flood hazards” means the floodplain shown on the FIRM, 

repetitive loss areas, areas not mapped on the FIRM that have flooded 

in the past, and surface flooding identified in existing studies. No new 

studies need to be conducted for this assessment. 

Along with flood protection and floodplain management, mitigation 

plans should discuss the unique natural features, natural areas, and 

other environmental and aesthetic attributes that may be present in the 

floodplain. Protecting and preserving these natural and beneficial 

floodplain functions yield flood mitigation benefits and also help 

integrate floodplain management efforts with other community goals 

and objectives. 
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Special 

Considerations: 

States and Tribes are encouraged to include a repetitive loss strategy 

in their plans that, if approved, would make them eligible under 44 CFR 

§201.4(c)(3)(v) for a reduced non-Federal cost share under the FMA 

and SRL hazard mitigation assistance programs. In particular, States 

address severe repetitive loss properties, which are a subset of 

repetitive loss. Local jurisdictions are encouraged to also identify and 

address this subset of properties. Severe repetitive loss properties 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. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, progress in local 

mitigation efforts, and changes in priorities, and resubmit it for approval 

within 5 years in order to continue to be eligible for mitigation project 

grant funding. Therefore, the plan update must continue to address 

repetitive loss structures in the risk assessment. 

Resources: For information on repetitive loss properties, See: 

 Understanding Your Risks (FEMA 386-2). 
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Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 3: Risk 

Assessment 

[The risk assessment] 

must also address 

National Flood Insurance 

Program (NFIP) insured 

structures that have 

been repetitively flooded.

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 5: Assess the Problem 

The risk assessment must also 

address National Flood 

Insurance Program (NFIP) 

insured structures that have 

been repetitively flooded. The 

community must also address 

all properties identified in the 

repetitive loss areas as 

defined by the community. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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ASSESSING VULNERABILITY: IDENTIFYING STRUCTURES 

Requirement 

§201.6(c)(2)(ii) 

(A): 

The plan should describe vulnerability in terms of the types and numbers 

of existing and future buildings, infrastructure, and critical facilities located 

in the identified hazard areas ... 

Explanation: This information should be based on an inventory of existing and proposed 

buildings, infrastructure, and critical facilities (structures) located within 

identified hazard area boundaries. The inventory may include but is not 

limited to the following: 

• Building Stock broadly includes residential, commercial, 

industrial, and institutional buildings. 

• Critical Facilities are essential to the health and welfare of the 

whole population and are especially important following hazard 

events. Since vulnerability is based on service losses as well as 

building structure integrity and content value, assess the effects on 

the service function interruption of critical facilities as well as their 

physical aspects. For purposes of this mitigation planning 

guidance, critical facilities may include emergency service facilities 

such as hospitals and other medical facilities, jails and juvenile 

detention centers, police and fire stations, emergency operations 

centers, public works facilities, evacuation shelters, schools, and 

other uses that house special needs populations. 

• Transportation Systems include airways (including airports, 

heliports, etc.), roadways (including highways, bridges, tunnels,

roadbeds, overpasses, transfer centers, etc.), railways and public 

transit (including trackage, tunnels, bridges, rail yards, depots, 

etc.), and waterways (including canals, locks, seaports, ferries, 

harbors, dry-docks, piers, etc.). 

• Lifeline Utility Systems such as potable water, wastewater, oil, 

natural gas, electric power, substations, power lines, etc. 

• Communications Systems and Networks such as telephones, 

emergency service radio systems, repeater sites and base 

stations, television and radio stations, etc. 

• High Potential Loss Facilities include facilities that would have a 

high loss associated with them, such as nuclear power plants or 

dams. 

• Hazardous Material Facilities include facilities housing 

industrial/hazardous materials, such as corrosives, explosives, 

flammable materials, radioactive materials, and toxins. 
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• Economic Elements include major employers, financial centers, 

and other business or retail districts in the community that could 

significantly affect the local or regional economy if interrupted. 

• Special Consideration Areas include areas of high density 

residential, commercial, institutional, and industrial development 

that, if damaged, could result in economic and functional losses 

and in high death tolls and injury rates. 

• Historic, Cultural, and Natural Resource Areas may include 

buildings, structures, objects, sites, national and local historic or 

significant districts, and historical archival storage facilities. 

The structure description should also include construction characteristics 

(e.g., year built, building materials (e.g., light wood frame, concrete frame), 

freeboard, foundation types (e.g., piers, piles, basement, slab-on-grade)). 

The community should determine how best to indicate structures that are

vulnerable to more than one hazard. 

The community should determine how far into the future they wish to go in 

considering proposed buildings, infrastructure, and critical facilities, 

including planned and approved development. The information on future 

structures may be based on and timed with the data gathering phase of 

their comprehensive plan or land use plan. 

If a local comprehensive plan is not available, State agencies or Regional 

Planning Commissions may be able to provide regional data about 

anticipated growth that may affect the community’s vulnerability to 

hazards. 

The plan should document the process and sources used to identify 

existing and future structures. If data are not readily available for buildings 

and infrastructure, the plan should provide information on critical facilities 

within the identified hazard areas and identify the collection of data for 

buildings and infrastructure as an action item in the mitigation strategy. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, and resubmit it for 

approval within 5 years in order to continue to be eligible for mitigation 

project grant funding. 

Therefore, the updated plan should include a current inventory of existing 

and proposed buildings, infrastructure, and critical facilities located within 

identified hazard area boundaries. 

Special 

Considerations: 

In addition to reviewing and incorporating data from comprehensive and 

long-range plans, some communities may opt to conduct a build-out 

analysis. The analysis involves a projection based on full development of 

all land in accordance with existing land use regulations such as the 

zoning ordinance or subdivision regulations. Within this context, the impact 

of growth on vulnerability could be assessed and included in the risk 
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assessment as a means to develop future actions to mitigate the risk.3

Special 

Consideration: 

Using HAZUSMH to Estimate 

Potential Losses 

While HAZUS is not required in Local Mitigation Plans, communities are 

encouraged to use HAZUS to form a scientific basis from which the 

mitigation strategy is developed. 

To consider the assets that can be impacted by the prioritized hazards, 

HAZUS outputs tables and maps of inventory data and allows the 

incorporation of local data. It provides a means by which the user can 

document the populations, buildings, transportation infrastructure, utilities, 

and other elements of the built environment that can be impacted by 

different hazard events. 

Resources: For a discussion on identifying vulnerable structures and preparing a 

detailed inventory, See: 

 Understanding Your Risks (FEMA 386-2), Step 3, Worksheets #3a 

and #3b Inventory Assets. 

 HAZUS-MH at www.fema.gov/plan/prevent/hazus . 

 Integrating Manmade Hazards into Mitigation Planning, (FEMA 386-7), 

Phase 2, Step 3. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS 

Step 

Phase 3: Risk 

Assessment 

For multi-jurisdictional 

plans, the risk 

assessment must 

assess each 

jurisdiction’s risks where 

they vary from the risks 

facing the entire 

planning area.

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase.

Step 4: Step 4: Assess the 

Hazard& Step 5: Assess the 

Problem 

For multi-jurisdictional plans, 

the risk assessment must 

assess each jurisdiction’s risks 

where they vary from the risks 

facing the entire planning area.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 

 

3

 Source: United States Environmental Protection Agency, 

http://www.epa.gov/greenkit/build_out.htm 
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ASSESSING VULNERABILITY: ESTIMATING POTENTIAL LOSSES 

Requirement 

§201.6(c)(2)(ii) 

(B): 

[The plan should describe vulnerability in terms of an] estimate of the 

potential dollar losses to vulnerable structures identified in paragraph 

(c)(2)(i)(A) of this section and a description of the methodology used to 

prepare the estimate ... 

Explanation: Describing vulnerability in terms of dollar losses provides the community 

and the State with a common framework in which to measure the effects 

of hazards on vulnerable structures. The Plan should include an estimate 

of losses for the identified vulnerable structures. A monetary estimate 

should be provided for each hazard, and should include, when resources 

permit, structure, contents, and function losses to present a full picture of 

the total loss for each asset. 

Structure loss is defined as a percentage of the Replacement Value x 

Percentage of Damage. Content loss is defined as a percentage of the 

Replacement Value x Percentage of Damage. Functional Losses are 

indirect effects that usually involve interruptions in asset operations. 

Functional downtime is the average time (in days) during which functions 

(business or service) is unable to provide its service due to a hazard 

event. 

Where data are limited, the planning team can select the most likely 

event for each hazard and estimate the losses for that event. In this way, 

the planning team can identify parts of the jurisdiction that could suffer 

the greatest losses. In addition, the estimated dollar losses as a result of 

hazard events can also be used to assess the benefits and costs of 

proposed mitigation actions. 

The methodology used to determine losses should also be provided in 

the plan. It should note any data limitations and identify and include in 

the implementation strategy actions for obtaining the data to complete 

and improve the future risk assessment analysis efforts. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, and resubmit it for 

approval within 5 years in order to continue to be eligible for mitigation 

project grant funding. 

The loss estimate should be updated to reflect changes to the hazard 

profile and/or to the inventory of structures. The plan should describe 

any new methodology if the approach for determining the losses has 

changed since the previous plan approval. The updated plan should

include, when resources permit, estimates of current structure, contents, 

and function losses to present a full picture of the total loss for each 

asset. 

If the previously approved plan noted data deficiencies in estimating 

potential losses and new data is available , then the new information 
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should be incorporated into the updated plan. However, if the data 

deficiencies have not been resolved, the updated plan should explain 

why the data deficiencies remain and a schedule to resolve the issue. 

Special 

Considerations: 

Creating a composite loss map depicting high potential loss areas (and 

identifying the location of critical facilities within the high potential loss 

areas) from multiple hazards will help the community develop its 

mitigation priorities based on loss potential. 

Special 

Consideration: 

Using HAZUSMH to Estimate 

Potential Losses 

While HAZUS is not required in Local Mitigation Plans, communities are 

encouraged to use HAZUS to form a scientific basis from which the 

mitigation strategy is developed. 

The most important purpose of HAZUS is the ability to estimate losses 

from natural hazards. Descriptions of losses include both social and 

economic considerations and they describe both the location and extent 

of losses. 

Resources: For a step-by-step method for estimating losses, See: 

 Understanding Your Risks (FEMA 386-2), Step 4. 

 HAZUS-MH at www.fema/gov/plan/prevent/hazus . 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 27. 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7), 

Phase 2, Step 4. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 3: Risk 

Assessment 

[The plan should

describe vulnerability in 

terms of an] estimate of 

the potential dollar 

losses to vulnerable 

structures identified in 

paragraph (c)(2)(i)(A) of 

this section and a 

description of the 

methodology used to 

prepare the estimate. 

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase.

Step 5: Assess the Problem 

CRS credit is given for an 

assessment that includes a 

review of all properties that 

received flood insurance 

claims (in addition to repetitive 

loss properties) or an estimate 

of the potential dollar losses to 

vulnerable structures. This is 

optional. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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ASSESSING VULNERABILITY: ANALYZING DEVELOPMENT TRENDS 

Requirement 

§201.6(c)(2)(ii) 

(C): 

[The plan should describe vulnerability in terms of] providing a general 

description of land uses and development trends within the community so 

that mitigation options can be considered in future land use decisions. 

Explanation: The plan should provide a general overview of land uses and types of 

development occurring within each community participating in the plan. 

This can include existing land uses and development densities in the 

identified hazard areas, as well as any anticipated future/proposed land 

uses, including anticipated new development, and redevelopment, and 

anticipated annexation areas. 

An analysis of development trends provides a basis for making decisions 

on the type of mitigation approaches to consider, and the locations where 

these approaches can be implemented. This information can also be used 

to influence decisions regarding future development in hazard areas. A 

land use map would be useful to depict the descriptive information. 

The plan should note any data limitations and identify and include in the 

mitigation strategy actions for obtaining the data necessary to complete 

and improve the risk assessment in the future. 

The Local Mitigation Plan should consider any or all of the following when 

analyzing development trends: 

• Describe trends in terms of the amount of change over time (for 

example, projecting trends based on increases of numbers of 

permits, including demolition, issued per year) and identify where 

the development is occurring; 

• Differentiate land uses of similar types that have distinctly different 

densities (for example, single-family homes, attached housing, and 

multifamily housing); 

• Where the future land uses are likely to occur based on 

comprehensive plans, zoning, redevelopment plans, or proposed 

annexation areas; or 

• The expected growth or redevelopment for some reasonable future 

timeframe (for example, 10 years). The timeframe could be 

coordinated with that of a local comprehensive or long-range plan 

review and update. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, and resubmit it for 

approval within 5 years in order to continue to be eligible for mitigation 

project grant funding. 

The updated plan should include a general overview of land uses and 

types of development occurring within the community, highlighting any 

changes since the previously approved plan. The update should 
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specifically include existing and future land uses in identified hazard 

areas. 

If the previously approved plan noted data deficiencies in analyzing 

development trends and identified actions in the mitigation strategy to 

address them at a later time, then the new information should be 

incorporated. However, if the data deficiencies have not been resolved, 

they should be addressed in the updated plan, accompanied by an 

explanation of why they remain and an updated schedule to resolve the 

issue. 

Special 

Considerations: 

To ascertain which jurisdictions statewide are the most vulnerable and to 

establish priorities for mitigation funding and technical assistance, the 

State is required under 44 CFR §201.4(c)(2)(ii) to review local risk 

assessments and information provided in Local Mitigation Plans regarding 

current and future land uses and anticipated or proposed development. 

Following the review of Local Mitigation Plans, the State may adjust their 

own risk assessment to more accurately reflect vulnerability using more 

detailed data provided in Local Mitigation Plans. States may use this 

information to prioritize mitigation programming and funding. The 

integration includes the analysis of: 

• Areas of the State that have experienced significant population 

increases or decreases and/or shifts in population; 

• Changes in land use or land use activities in vulnerable areas; 

• Implementation of mitigation actions that have ultimately reduced 

vulnerability. 

Special 

Consideration: 

Using HAZUSMH to Estimate 

Potential Losses 

While HAZUS is not required in Local Mitigation Plans, communities are 

encouraged to use HAZUS to form a scientific basis from which the 

mitigation strategy is developed. 

The HAZUS provided inventory reflects current conditions within a 

community based on best available national data sources. It is possible 

for the HAZUS user to replace the out-of-the-box inventory with data that 

reflects projected community change. While this process can be 

potentially time consuming and costly depending on the scale of the area 

under study, it could provide a valuable means by which to assess the risk 

from anticipated development. This information can then be applied 

toward making better informed decisions which can guide development 

within the community. 

Resources: For more information on development trends, consult with your local, 

State, or regional planning officials. Also See: 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 29. 
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Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 3: Risk 

Assessment 

[The plan should 

describe vulnerability in 

terms of] providing a 

general description of 

land uses and 

development trends 

within the community so 

that mitigation options 

can be considered in 

future land use

decisions. 

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 5: Assess the Problem 

The CRS gives credit for a 

description of the 

development, redevelopment, 

and population trends as well 

as a discussion of what the 

future brings for development 

in the community. This is 

optional.. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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MULTI-JURISDICTIONAL RISK ASSESSMENT 

Requirement 

§201.6(c)(2)(iii): 

For multi-jurisdictional plans, the risk assessment must assess each 

jurisdiction’s risks where they vary from the risks facing the entire 

planning area. 

Explanation: The multi-jurisdictional plan must present risk assessment information for 

the planning area as a whole as described in sections 201.6(c)(2)(i) and 

(ii). However, where hazards and associated losses occur in only part of 

the planning area, this information must be attributed to the particular 

jurisdiction in which they occur. 

The larger the planning area and the more communities participating in a 

plan, the more likely that unique and varied risk will occur. Consulting the 

State hazard mitigation plan can help identify the hazards that affect each 

jurisdiction in the planning area. 

Further, where unique construction characteristics or development trends 

occur, they should be indicated in the plan so that appropriate mitigation 

actions are considered. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, and resubmit it for 

approval within 5 years in order to continue to be eligible for mitigation 

project grant funding. 

If new hazards and risks have been identified in the multi-jurisdictional 

risk assessment, the information must be attributed to the appropriate 

jurisdiction (s) or to the whole planning area, whichever applies. 

Where vulnerability to previously identified hazards has changed, the 

plan must incorporate this information into the updated multijurisdictional risk assessment and it must be attributed to the appropriate 

jurisdiction (s) or to the whole planning area, whichever applies. 

Resources: For more information on creating a detailed risk assessment, See: 

 Understanding Your Risks (FEMA 386-2), Steps 1 – 4. 

 HAZUS-MH at www.fema.gov/plan/prevent/hazus. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 21-29. 
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Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 3: Risk 

Assessment 

For multi-jurisdictional 

plans, the risk 

assessment must 

assess each 

jurisdiction’s risks where 

they vary from the risks 

facing the entire 

planning area.

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 4. Assess the Hazard & 

Step 5: Assess the Problem

For multi-jurisdictional plans, 

the risk assessment must 

assess each jurisdiction’s risks 

where they vary from the risks 

facing the entire planning area 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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MITIGATION STRATEGY 

Section 201.6(c)(3) of the mitigation planning regulation requires jurisdictions to develop a 

mitigation strategy. The mitigation strategy serves as the long-term blueprint for reducing the 

potential losses identified in the risk assessment. The mitigation strategy includes the 

development of goals, objectives, and prioritized mitigation actions. 

The development of goals from which specific actions and projects will be derived is based on 

the community’s existing authorities, policies, programs, and resources and its capability to use 

local tools to reduce losses and vulnerability from profiled hazards. Goals are long-term policy 

statements and global visions that support the mitigation strategy. An example of a goal for a 

wildfire hazard is, “Minimize wildfire losses in the wildland urban interface area.” Many 

communities take an extra step and identify objectives that more narrowly define 

implementation steps to attain the goals. Unlike goals, objectives are specific and measurable, 

such as, “Increase educational opportunities for citizens about wildfire defensible space 

actions.” 

Following the identification of goals and objectives, the mitigation planning regulation at 44 CFR 

Part 201 requires that communities identify, analyze, and prioritize alternative actions by profiled 

hazard. The actions are even more specific than objectives. An example of an action for a 

wildfire hazard is “Sponsor a booth at the community fair to promote wildfire defensible space.” 

Local jurisdictions will benefit by reviewing the State’s mitigation strategy to ensure locally 

identified actions are supported by the State’s policies, regulations and programs. 

For multi-jurisdictional plans, each participating jurisdiction identifies the specific actions they 

will undertake for each hazard profiled. Some actions may apply to more than one jurisdiction, 

but specific mitigation actions are identified for each jurisdiction. 

Communities are encouraged to develop actions that can be implemented by using local tools, 

such as capital improvement budgets, special district funds, or implementing changes in 

ordinances, policies, or procedures. In addition, communities are encouraged to consider 

mitigation actions that may not be currently feasible, but may become a realistic possibility 

following a disaster event. Access to State or Federal funds may enable communities to 

accomplish actions during post-disaster recovery. 

After five years of implementing the mitigation strategy, communities update their goals and 

actions. In the plan update, goals and objectives may be reaffirmed or updated based on 

current conditions, including the completion of mitigation initiatives, an updated or new risk 

assessment, or changes in State priorities. It is useful to review the changes in the community 

since the previous plan was approved to determine whether goals have been met or if they 

remain consistent with current conditions. 

This section includes the following five (5) subsections: 

Local Hazard Mitigation Goals 

Identification and Analysis of Mitigation Actions 

Implementation of Mitigation Actions 

Implementation of National Flood Insurance Program (NFIP) 

Multi-jurisdictional Mitigation Actions 
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LOCAL HAZARD MITIGATION GOALS 

Requirement 

§201.6(c)(3)(i): 

[The hazard mitigation strategy shall include a] description of mitigation 

goals to reduce or avoid long-term vulnerabilities to the identified 

hazards. 

Explanation: Goals are broad policy statements that explain what is to be achieved. 

The community’s hazard reduction goals, as described in the plan, along 

with any corresponding objectives, guide the development and 

implementation of mitigation actions. This section shall list the goals 

intended to reduce or avoid the effects of the profiled hazards addressed 

in the risk assessment. 

The description should include how goals were developed. The goals 

could be developed early in the planning process and refined based on 

the risk assessment findings, or developed entirely after the risk 

assessment is completed. They should also be compatible with the goals 

of the community as expressed in other community plan documents, 

such as a comprehensive plan. 

Although the mitigation planning regulation does not require a description 

of objectives, communities are encouraged to include objectives 

developed to achieve the goals so that reviewers understand the 

connection between goals, objectives, and actions. 

The goals and objectives should: 

Be based on the findings of the local and State risk assessments; and 

Represent a long-term vision for hazard reduction or enhancement of 

mitigation capabilities. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect progress in local mitigation efforts and changes in 

priorities, and resubmit it for approval within 5 years in order to continue 

to be eligible for mitigation project grant funding. 

The plan update provides an opportunity for local jurisdictions to 

reconsider the goals and objectives identified in the previously approved 

plan. Goals should be reaffirmed or updated based on current 

conditions, including the completion of mitigation initiatives, an updated 

or new risk assessment, or changes in State priorities. 

It is not necessary to change goals from the previous plan if they remain 

valid; however, the plan must document that goals were re-evaluated 

and that they were determined to remain valid and effective. If the 

previously approved plan included objectives, the updated plan should

document which objectives have been met, and identify new objectives. 
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The planning team should address the following questions when updating 

the mitigation strategy: 

Do the goals and objectives identified in the previously approved plan 

reflect the updated risk assessment? 

Did the goals and objectives identified in the previously approved plan 

lead to mitigation projects and/or changes in policy that helped the 

jurisdiction(s) to reduce vulnerability? 

Do the goals and objectives identified in the previously approved plan 

support any changes in mitigation priorities? 

Are goals identified in the updated Local Mitigation Plan reflective of 

current State goals? 

Special 

Considerations: 

Goals are general guidelines that explain what you want to achieve. 

They are broad policy statements and are usually long-term and 

represent global visions, such as “Protect Existing Property.” 

Objectives define strategies or implementation steps to attain the 

identified goals. Unlike goals, objectives are specific, measurable, and 

may have a defined completion date. Objectives are more specific, such 

as “Increase the number of buildings protected from flooding.” 

The development of effective goals and objectives enables the planning 

team to evaluate the merits of alternative mitigation actions and the local 

conditions in which these activities would be pursued. A potential 

mitigation action that would support the goal and objective goal example 

above is “Acquire repetitive flood loss properties in the Acadia Woods 

Subdivision.” 

Resources: For more information on developing local mitigation goals and objectives, 

See: 

 Developing the Mitigation Plan (FEMA 386-3), Step 1. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 30. 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7), 

Phase 3, Step 1. 
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(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information 

on participation in the Community Rating System.) 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 4: Mitigation 

Strategy 

[The hazard mitigation 

strategy shall include a] 

description of mitigation 

goals to reduce or avoid 

long-term vulnerabilities 

to the identified hazards. 

Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 6: Set Goals 

Credit is based on a statement of 

goals to reduce or avoid long term 

vulnerability to the identified 

hazards. 
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IDENTIFICATION AND ANALYSIS OF MITIGATION ACTIONS 

Requirement 

§201.6(c)(3)(ii): 

[The mitigation strategy shall include a] section that identifies and 

analyzes a comprehensive range of specific mitigation actions and 

projects being considered to reduce the effects of each hazard, with 

particular emphasis on new and existing buildings and infrastructure. 

Explanation: The local jurisdiction shall list potential loss reduction actions it has 

identified in its planning process and analyze various actions that achieve 

the community’s goals and objectives to reduce or avoid the effects of the 

identified hazards. A comprehensive range of specific mitigation actions 

consists of multiple mitigation actions for each profiled hazard. “No 

Action” does not qualify as a mitigation action. Mitigation actions shall

address existing and new buildings and infrastructure. 

Prior to analyzing and prioritizing mitigation actions, it may be useful for 

communities to sort identified mitigation actions into the following groups: 

• Prevention: Government administrative or regulatory actions or

processes that influence the way land and buildings are 

developed and built. These actions also include public activities to 

reduce hazard losses. Examples include planning and zoning, 

building codes, capital improvement programs, open space 

preservation, and storm water management regulations. 

• Property Protection: Actions that involve the modification of 

existing buildings or infrastructure to protect them from a hazard, 

or removal from the hazard area. Examples include acquisition, 

elevation, relocation, structural retrofits, flood proofing, storm 

shutters, and shatter-resistant glass. 

• Public Education & Awareness: Actions to inform and educate 

citizens, elected officials, and property owners about potential 

risks from hazards and potential ways to mitigate them. Such 

actions include outreach projects, real estate disclosure, hazard 

information centers, and school-age and adult education 

programs. 

• Natural Resource Protection: Actions that, in addition to 

minimizing hazard losses also preserve or restore the functions of 

natural systems. These actions include sediment and erosion 

control, stream corridor restoration, watershed management, 

forest and vegetation management, and wetland restoration and 

preservation. 

• Structural Projects: Actions that involve the construction of 

structures to reduce the impact of a hazard. Such structures 

include storm water controls (e.g., culverts), floodwalls, seawalls, 

retaining walls, and safe rooms. 

The plan should describe the process by which the community decides

on particular mitigation actions. This description should include who 

participated in the analysis and selection of actions. Some of the 

mitigation actions initially identified may ultimately be eliminated in the 

community’s action plan due to limited capabilities, prohibitive costs, low 
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benefit/cost ratio, or other concerns. The information will also be 

valuable as part of the alternative analysis for the National Environmental 

Policy Act (NEPA) review required if projects are Federally funded. 

With regard to analyzing mitigation actions, FEMA’s Developing the 

Mitigation Plan (FEMA 386-3) highlights the STAPLEE method—a 

technique for identifying, evaluating, and prioritizing mitigation actions 

based on existing local conditions. 

S Social The public must support the overall implementation 

strategy and specific mitigation actions. Therefore, 

the projects will have to be evaluated in terms of 

community acceptance. 

T Technical It is important to determine if the proposed action is 

technically feasible, will help to reduce losses in the 

long term, and has minimal secondary impacts. 

Determine whether the alternative action is a whole

or partial solution, or not a solution at all. 

A Administrative Under this part of the evaluation criteria, examine

the anticipated staffing, funding, and maintenance 

requirements for the mitigation action to determine

if the jurisdiction has the personnel and 

administrative capabilities necessary to implement 

the action or whether outside help will be needed. 

P Political Understanding how your current community and 

State political leadership feels about issues related 

to the environment, economic development, safety, 

and emergency management. This will provide 

valuable insight into the level of political support 

have for mitigation activities and programs. 

Proposed mitigation objectives sometimes fail 

because of a lack of political acceptability. 

L Legal Without the appropriate legal authority, the action

cannot lawfully be undertaken. When considering 

this criterion, determine whether your jurisdiction

has the legal authority at the State, or local level to 

implement the action, or whether the jurisdiction 

must pass new laws or regulations. Each level of 

government operates under a specific source of 

delegated authority. As a general rule, most local 

governments operate under enabling legislation 

that gives them the power to engage in different 

activities. Identify the unit of government 

undertaking the mitigation action, and include an 

analysis of the interrelationships between local, 

regional, State, and Federal governments. Legal 

authority is likely to have a significant role later in 
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the process when your State, or community will 

have to determine how mitigation activities can best 

be carried out, and to what extent mitigation 

policies and programs can be enforced. 

E Economic Every local and State government experiences 

budget constraints at one time or another. Costeffective mitigation actions that can be funded in 

current or upcoming budget cycles are much more 

likely to be implemented than mitigation actions 

requiring general obligation bonds or other 

instruments that would incur long-term debt to a 

community. States and local communities with tight 

budgets or budget shortfalls may be more willing to

undertake a mitigation initiative if it can be funded, 

at least in part, by outside sources. “Big ticket” 

mitigation actions, such as large-scale acquisition

and relocation, are often considered for 

implementation in a post-disaster scenario when 

additional Federal and State funding for mitigation

is available. 

E Environmental Impact on the environment is an important 

consideration because of public desire for 

sustainable and environmentally healthy 

communities and the many statutory 

considerations, such as NEPA, to keep in mind 

when using Federal funds. You will need to 

evaluate whether, when implementing mitigation 

actions, there would be negative consequences to 

environmental assets such as threatened and 

endangered species, wetlands, and other protected 

natural resources. 

Using criteria such as STAPLEE, local communities can weigh the pros 

and cons of implementing a particular mitigation action. Jurisdictions 

should evaluate actions based on local conditions that may impact 

whether or not the actions identified in the mitigation action plan could be 

accomplished. When identifying and evaluating mitigation actions, the 

following considerations may also be useful: 

• Compatibility with goals and objectives identified in the current 

State hazard mitigation plan; 

• Compatibility with goals and objectives identified in the local 

mitigation strategy; 

• An assessment of the impact of identified actions on other 

jurisdictions within the entire planning area or region (e.g. No 

Adverse Impact4

 watershed area plans) 

• Cost/benefit reviews of potential actions; 
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• Funding priorities identified in the current State hazard mitigation 

plan; and 

• Compatibility with other local or regional plans and programs. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect progress in local mitigation efforts and changes in 

priorities, and resubmit it for approval within 5 years in order to continue 

to be eligible for mitigation project grant funding. 

The plan update provides an opportunity for local jurisdictions to 

reconsider the range of specific actions. If the mitigation actions or 

activities remain unchanged from the previously approved plan the 

updated plan should indicate why changes are not necessary. 

Special 

Considerations: 

In the course of developing the local hazard mitigation plan, your 

community may discover and build consensus on preparedness, 

response, and recovery actions. Although FEMA will not deny a plan for 

including these types of actions, they do not substitute for the mitigation

action requirements of a Local Mitigation Plan. In addition, even though 

actions are listed in the plan, they may not all meet eligibility 

requirements for FEMA’s mitigation grant programs. FEMA encourages 

communities to formally agree upon mitigation actions that will make the 

community safer from natural and man-made hazards. 

Hazard mitigation is defined as sustained action taken to reduce or 

eliminate long-term risk to people and property from hazards and their 

effects. A mitigation action, such as voluntary acquisition and conversion 

to open space in a floodplain protects the property and the removes the 

people from harm’s way for the long-term. A response action that would 

not qualify as a mitigation action would be, “Update Emergency 

Operations Plan” or “Purchase fire trucks.” 

Special 

Considerations: 

The community may review the sections on “State and Local Capability 

Assessment” in their State’s hazard mitigation plan to assess their own 

existing and planned capabilities to implement the identified mitigation 

actions. This assessment should include a discussion of existing 

mitigation activities in the community, existing regulatory standards (e.g.

building codes, zoning ordinances), projects that have already been 

planned, integration with comprehensive planning and capital 

improvement programs, etc., as well as the jurisdiction’s ability to expand 

on and improve these existing tools. 

Resources: For more information on identifying and evaluating mitigation actions and 

preparing a capability assessment, See: 

 Developing the Mitigation Plan (FEMA 386-3), Step 2, Worksheet #1 

Identify Alternative Mitigation Actions, Job Aid #1: Alternative 

Mitigation Actions by Hazard, Worksheet #2 State Mitigation 

Capability Assessment, Worksheet #3 Local Mitigation Capability 
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Assessment, Job Aid #2: Local Hazard Mitigation Capabilities, and 

Worksheet #4 Evaluate Alternative Mitigation Actions. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 31. 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7), 

Phase 3, Step 2. 

 Rebuilding for a More Sustainable Future: An Operational Framework 

(FEMA 365). 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 4: Mitigation 

Strategy 

[The mitigation 

strategy shall include 

a] section that 

identifies and analyzes 

a comprehensive 

range of specific 

mitigation actions and 

projects being 

considered to reduce 

the effects of each 

hazard, with particular 

emphasis on new and 

existing buildings and 

infrastructure. 

Difference? 

The CRS plan must discuss why some 

activities are appropriate for 

implementation and also discuss why 

certain activities are not appropriate for 

implementation. 

Step 7. Review Possible 

Activities 

Credit is based on a 

comprehensive evaluation 

of hazard mitigation 

measures reviewed in the 

plan. The review must 

include a description of why 

certain activities were 

recommended and why 

others were not.

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 
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IMPLEMENTATION OF NATIONAL FLOOD INSURANCE PROGRAM (NFIP) 

Requirement 

§201.6(c)(3)(ii): 

[The mitigation strategy] must also address the jurisdiction’s participation 

in the NFIP, and continued compliance with NFIP requirements, as 

appropriate. 

Explanation: Participation in the NFIP is based on an agreement between 

communities and FEMA. The NFIP has three basic aspects: 1) floodplain 

identification and mapping; 2) floodplain management; and 3) flood 

insurance. First, NFIP participation requires community adoption of flood 

maps. Mapping flood hazards creates broad-based awareness of the 

flood hazards and provides the data needed to administer floodplain 

management programs and to actuarially rate new construction for flood 

insurance. Second, to be a participant, the NFIP requires communities to 

adopt and enforce minimum floodplain management regulations that help 

mitigate the effects of flooding on new and improved structures. Third, 

community participation in the NFIP enables property owners to purchase 

insurance as a protection against flood losses in exchange for State and 

community floodplain management regulations that reduce future flood 

damages. 

All Local Mitigation Plans approved by FEMA after October 1, 2008 must 

describe each jurisdiction’s participation in the NFIP and must identify, 

analyze and prioritize actions related to continued compliance with the 

NFIP. Simply stating an action such as, “The community will continue to 

comply with NFIP,” will not meet this requirement. Basic compliance 

NFIP actions could include, but are not limited to:

• Adoption and enforcement of floodplain management 

requirements, including regulating all and substantially improved 

construction in Special Flood Hazard Areas (SFHAs);

• Floodplain identification and mapping, including any local 

requests for map updates, if needed; or, 

• Description of community assistance and monitoring activities. 

Not all jurisdictions participate in the NFIP either because the community 

has not been identified with Special Flood Hazard Area (SFHA), has not 

been issued a Flood Hazard Boundary Map (FHBM) or a Flood Insurance 

Rate Map (FIRM), or because the community has not adopted the FEMAissued flood maps. NFIP participation is voluntary for communities. 

Jurisdictions that are currently not participating in the NFIP may meet this 

requirement by describing the reasons why the community does not 

participate, particularly where a FHBM or FIRM has been issued. 

Communities are encouraged to take on additional activities that go 

above and beyond the minimum requirements of NFIP participation and 

these are described in the Community Rating System Coordinator’s 

Manual (FIA-15/2007) (See http://training.fema.gov/EMIWeb/CRS/ ). 
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Another innovative program is FEMA’s Cooperating Technical Partners 

Program (CTP). The main objective of CTP is to increase local 

involvement in the flood mapping process. With over 20,000 

communities in the NFIP, the CTP encourages collaboration with NFIP 

communities and regional and State agencies who wish to become more 

active participants in the FEMA flood hazard mapping program. 

Special 

Consideration: 

NFIP participation is a basic eligibility requirement for funding under 

certain hazard mitigation grant programs, including FMA, SRL and PDM. 

Jurisdictions that meet the NFIP requirement under §201.6(c)(3)(ii) in 

their local mitigation plans do not automatically qualify for funding. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect progress in local mitigation efforts and changes in 

priorities, and resubmit it for approval within 5 years in order to continue 

to be eligible for mitigation project grant funding. 

Therefore, the plan update must describe each jurisdiction’s participation 

in the NFIP, including any changes since the previously approved plan 

was adopted, and must identify, analyze and prioritize actions related to 

continued compliance with the NFIP. 

Resources: For additional information on the NFIP, See: 

 National Flood Insurance Program Description 

http://www.fema.gov/about/programs/nfip/index.shtm

 Community Rating Resource Center, 

http://training.fema.gov/EMIWeb/CRS/. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 4: Mitigation 

Strategy 

[The mitigation 

strategy] must also 

address the 

jurisdiction’s 

participation in the 

NFIP, and continued 

compliance with NFIP 

requirements, as 

appropriate.

Difference? 

If the community participates in CRS, they 

are already in full compliance with NFIP 

requirements. 

Step 8: Action Plan 

CRS credits regulations that 

go above and beyond the 

minimum of the NFIP. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information 

on participation in the Community Rating System.)
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IMPLEMENTATION OF MITIGATION ACTIONS 

Requirement: 

§201.6(c)(3)(iii): 

[The mitigation strategy section shall include] an action plan describing 

how the actions identified in section (c)(3)(ii) will be prioritized, 

implemented, and administered by the local jurisdiction. Prioritization 

shall include a special emphasis on the extent to which benefits are 

maximized according to a cost benefit review of the proposed projects 

and their associated costs. 

Explanation: After describing the mitigation actions to be included in the mitigation 

strategy, the local jurisdiction shall describe the method for prioritizing 

the order in which actions will be implemented. Considerations that may 

be used to prioritize the action plan include: social impact, technical 

feasibility, administrative capabilities, political and legal effects, and 

economic, as well as environmental issues. The STAPLEE method may 

be used to evaluate potential actions for the mitigation strategy, but also 

to prioritize those that the community selects as its mitigation actions. 

When prioritizing mitigation actions, local jurisdictions shall consider the 

benefits that would result from the mitigation actions versus the cost of 

those actions. Note that the mitigation planning regulation does not 

require plans to include a benefit cost analysis for projects. However, an 

economic evaluation is essential for selecting one or more actions from 

among many competing ones. The requirement is met as long as the 

economic considerations are summarized in the plan as part of the 

community’s analysis. Among ways to address this requirement are: 

Assessing the economic impact of one action compared to another. 

Showing how one type of action costs more than another to achieve 

the same benefit. 

Showing that funding is available for one type of action but not 

another. 

Demonstrating that the economic goals of your community are better 

served by one action instead of another. 

This section shall also include how actions will be implemented and 

administered, including the department or agency responsible for 

carrying out the actions, the potential funding sources, and the 

implementation timeline. This section should also include a cost estimate 

or budget for each action, when available. If cost estimates are not 

available, jurisdictions may provide comparative costs (such as high, 

medium, or low) with defined scales among actions. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect progress in local mitigation efforts and changes in 

priorities, and resubmit it for approval within 5 years in order to continue 

to be eligible for mitigation project grant funding. 
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Therefore, the updated plan must identify the completed, deleted, or 

deferred actions or activities from the previously approved plan as a 

benchmark for progress. If the mitigation actions or activities remain 

unchanged from the previously approved plan, the updated plan must

indicate why changes are not necessary. Further, the updated plan shall 

include in its prioritization any new mitigation actions identified since the 

previous plan was approved or through the plan update process. 

Resources For more information on the development of the action plan, See: 

 Developing the Mitigation Plan (386-3), Phase 3. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 32. 

 Using Benefit-Cost Review in Mitigation Planning (FEMA 386-5) 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 4: 

Mitigation Strategy 

 [The mitigation strategy 

section shall include] an 

action plan describing 

how the actions 

identified in section 

(c)(3)(ii) will be 

prioritized, implemented, 

and administered by the 

local jurisdiction. 

Prioritization shall 

include a special 

emphasis on the extent 

to which benefits are 

maximized according to 

a cost benefit review of 

the proposed projects 

and their associated 

costs. 

Difference? 

For CRS credit, the action plan must 

identify for each action item who does 

what (what department or agency), when 

it will be done (deadline), and how it will 

be financed (community or outside 

funding). 

Step 8: Draft an Action Plan 

Credit is based on an action 

plan that identifies who does 

what, when it will be done, and 

how it will be financed. 

The actions must be prioritized 

and include a review of the 

benefits of the proposed 

projects and their associated 

costs. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information 

on participation in the Community Rating System.)
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MULTI-JURISDICTIONAL MITIGATION ACTIONS 

Requirement 

§201.6(c)(3)(iv): 

For multi-jurisdictional plans, there must be identifiable action items 

specific to the jurisdiction requesting FEMA approval or credit of the plan. 

Explanation: The multi-jurisdictional plan must link the proposed mitigation actions to 

the applicable jurisdictions. Any jurisdiction within the planning area 

requesting approval for the plan must be able to point to specific 

actions to be pursued. Actions by individual jurisdictions may be part of 

or contribute to an area-wide mitigation action. The scope of any action 

may be entirely within the jurisdiction or may be part of a larger action 

involving some or all of the other jurisdictions covered in the plan. 

Each jurisdiction must have participated in identifying and analyzing a 

comprehensive range of mitigation actions for each profiled hazard, 

which can result in an achievable mitigation action plan (See

§201.6(c)(3)(ii)). As with single-jurisdictional plans, a comprehensive 

range of specific mitigation actions consists of multiple mitigation 

actions for each profiled hazard and for each jurisdiction participating in 

the plan. 

This section must also include how actions will be implemented and 

administered. The plan must include the jurisdiction, department 

responsible for carrying out the actions, the potential funding sources, 

and the implementation timeline. This section should also include a cost 

estimate or budget for each action, when available.

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect progress in local mitigation efforts and changes in 

priorities, and resubmit it for approval within 5 years in order to continue 

to be eligible for mitigation project grant funding. 

The updated multi-jurisdictional plan must identify the completed, 

deleted or deferred actions from the previously approved plan as a 

benchmark for progress. Further, the updated plan shall include any 

new mitigation actions identified in its evaluation and prioritization since 

the previous plan was approved or through the plan update process. 

If the mitigation actions remain unchanged from the previously 

approved plan, the updated plan must indicate why changes are not 

necessary. 

Resources: For more information on the development of the action plan, See: 

 Developing the Mitigation Plan (FEMA 386-3), Phase 3. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 32. 

 Using Benefit-Cost Review in Mitigation Planning, (FEMA 386-5). 

 
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(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 4: 

Mitigation Strategy 

For multi-jurisdictional 

plans, there must be 

identifiable action items 

specific to the jurisdiction 

requesting FEMA 

approval or credit of the 

plan 

Difference? 

The CRS requires that an Action Plan 

must include mitigation measures from at 

least two of the six floodplain 

management review categories. 

Step 8: Draft an Action 

Plan 

 For CRS credit, when a multijurisdictional plan is prepared, 

it must have action items from 

at least two of the six 

categories that directly benefit 

each community seeking CRS 

credit. 
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PLAN MAINTENANCE PROCESS 

Section 201.6(c)(4) of 44 CFR requires a formal plan maintenance process to ensure that the 

mitigation plan remains an active and relevant document. The plan maintenance process 

includes a method and schedule for monitoring, evaluating, and updating the plan at least every 

five (5) years. This also includes an explanation of how local governments intend to incorporate 

their mitigation strategies into existing planning mechanisms, such as comprehensive or capital 

improvement plans, or zoning and building codes. Lastly, this section requires that there be 

continued public participation throughout the plan maintenance process. 

When the plan is updated, local jurisdictions assess how the Local Mitigation Plan maintenance 

process worked and identify whether changes to the process are needed. Taking into 

consideration future updates, adjustments to the method and schedule for maintaining the plan 

may be necessary to ensure its value for comprehensive risk reduction. 

As the mitigation plan evolves through updates, the plan maintenance process serves as the 

basis for the next update, and the process of updating the plan provides local jurisdictions with 

an opportunity to document progress in achieving mitigation goals. 

When the community prepares a plan update, the mitigation planning regulation at 44 CFR Part 

201 requires that the plan discuss how the community was kept involved during the plan 

maintenance process over the previous five years. This discussion may take place within the 

planning process section of the plan update rather than the plan maintenance section. The plan 

maintenance section is intended to be forward-thinking and emphasize future plan maintenance. 

This section includes the following three subsections: 

Monitoring, Evaluating, and Updating the Plan 

Incorporation into Existing Planning Mechanisms 

Continued Public Involvement 
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MONITORING, EVALUATING, AND UPDATING THE PLAN 

Requirement 

§201.6(c)(4)(i): 

[The plan maintenance process shall include a] section describing the 

method and schedule of monitoring, evaluating, and updating the 

mitigation plan within a five-year cycle. 

Explanation: The local jurisdiction shall describe how, when, and by whom the plan 

will be monitored. It is only necessary to provide the department or 

agency responsible for carrying out the actions, not individuals. 

Monitoring may include periodic reports by agencies involved in 

implementing projects or activities, site visits, phone calls, and meetings 

conducted by the person responsible for overseeing the plan, or the 

preparation of annual reports that capture the highlights of the previously 

mentioned activities. 

The plan shall also include a description of how, when, and by whom the 

plan will be evaluated, and should include the criteria used to evaluate the 

plan. The evaluation should assess, among other things, whether: 

The goals and objectives address current and expected conditions. 

The nature, magnitude, and/or type of risks have changed. 

The current resources are appropriate for implementing the plan. 

There are implementation problems, such as technical, political, legal, 

or coordination issues with other agencies. 

The outcomes have occurred as expected (a demonstration of 

progress). 

The agencies and other partners participated as originally proposed. 

The plan shall describe how, when, and by whom the plan will be 

updated. The mitigation planning regulation requires that the plan be 

updated within five years from the date of FEMA approval. FEMA 

recommends that the plan be reviewed and updated on an annual basis or 

after a hazard occurrence to determine the effectiveness of programs, and 

to reflect changes in land development or programs that may affect 

mitigation priorities. Monitoring, evaluation, and updating activities should 

take place continuously within the five-year timeframe. 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

The previously approved plan identified procedures to monitor, evaluate, 

and update its mitigation plan and track mitigation activities. The results 

of this evaluation and monitoring will assist local government in updating 

each section of the plan as part of the established update schedule. In 
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particular, the plan maintenance section of the previously approved plan 

should assist in establishing a process for updating the plan. 

As a part of the planning process, the community reviews and analyzes 

the previously approved plan’s method and schedule for monitoring and 

updating the plan, such as strengths and weaknesses and what elements, 

if any, have changed. The updated plan must include the method and 

schedule to be used over the next five years to monitor, evaluate, and 

update the plan. 

Resources: For guidance on monitoring, evaluating, and updating the plan, See: 

 Bringing the Plan to Life (FEMA 386-4), Steps 2 – 4. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 35. 

 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7), 

Phase 4, Step 3. 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 5: 

Plan Maintenance 

[The plan maintenance 

process shall include a] 

section describing the 

method and schedule of 

monitoring, evaluating, 

and updating the 

mitigation plan within a 

five-year cycle. 

Difference? 

The CRS requires annual progress 

reports as well as an update of the plan 

every five years. 

 Step 10: 

Draft an Action Plan

Credit is based on how a 

community monitors and 

evaluates its plan on an 

annual basis and updates it on 

a five-year cycle. 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information 

on participation in the Community Rating System.)
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INCORPORATION INTO EXISTING PLANNING MECHANISMS 

Requirement 

§201.6(c)(4)(ii): 

[The plan shall include a] process by which local governments incorporate 

the requirements of the mitigation plan into other planning mechanisms 

such as comprehensive or capital improvements, when appropriate. 

Explanation: The plan shall specify how the mitigation strategy, including the goals and 

objectives, and mitigation actions will be incorporated into other planning 

mechanisms. Jurisdictions shall also indicate how information contained 

in the plan, including hazard identification and the risk assessment, will be 

integrated into other planning mechanisms. 

Communities that do not have comprehensive plans, capital improvement 

plans or other long-range plans, should explain how the mitigation actions 

would be implemented into zoning and building codes, subdivision 

regulations, site reviews, permitting, job descriptions, staff training, or 

other planning tools where such tools are the appropriate vehicle for 

implementation. For mitigation actions that may use other means of 

implementation, these other tools should be described. 

Local government functions provide a myriad of methods in which to 

implement actions identified in the mitigation strategy. Among them is the 

comprehensive plan. Others include but are not limited to the following: 

Plans 

Local Comprehensive Plan 

General Land Use Plan 

Sustainability Plan 

Capital Improvements Plan 

Redevelopment Plan 

Post-Disaster Redevelopment / Recovery Plan 

Regional Development Plans 

Watershed Protection/Enhancement Plan 

Open Space Plan 

Flood Mitigation Plan 

Military Base Development/Redevelopment/Reuse Plan 

College Campus Plans 

Land Use 
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Comprehensive Emergency Management Plan 

Evacuation Plan 

Operations 

Emergency 

Codes, Regulations, & Procedures 

Zoning Ordinance 

Subdivision Regulations 

Building Code / Permitting 

Landscape Code 

Solid Waste & Hazardous Materials Waste Regulations 

Property Deed Restrictions 

Tree Protection Ordinance 

Site Plan Review 

Architectural/Design Review 

Storm Water Management 

Soil Erosion Ordinance 

Land Use 

Programs 

Beach Conservation & Restoration Program 

Historic Preservation Program 

Construction/Retrofit Program 

Transportation Improvement/Retrofit Program 

School District Facilities Plan 

Environmentally Sensitive Purchase / Protection Program 

Long-Range Recreation Facilities Program 

Economic Development Authority 

Land Buyout Program 

Downtown Redevelopment Authority 

Local and/or Regional Evacuation Programs 

“Firewise” and other Fire Mitigation 

Fire Rescue Long-Range Programs 

Mutual Aid Agreement 

Temporary Animal Relocation Program 

Land Use 
PLAN MAINTENANCE PROCESS 

L O C A L M U L T I - H A Z A R D M I T I G A T I O N P L A N N I N G G U I D A N C E 

J U L Y 1 , 2 0 0 8 72

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan to reflect changes in development, progress in local 

mitigation efforts, and changes in priorities, and resubmit it for approval 

within 5 years in order to continue to be eligible for mitigation project grant 

funding. 

The updated plan must explain how the local government incorporated 

the mitigation plan into other planning mechanisms, when appropriate, as 

a demonstration of progress in local mitigation efforts. 

The updated plan shall continue to describe how the mitigation strategy, 

including the goals and objectives, and mitigation actions will be 

incorporated into other planning mechanisms, and also indicate how 

information contained in the plan, including hazard identification and the 

risk assessment, will be integrated into other planning mechanisms. 

Resources: For more information on incorporating hazard mitigation activities in other 

initiatives, See: 

 Getting Started (FEMA 386-1), Step 2 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 29. 

 Planning for a Sustainable Future: The Link Between Hazard 

Mitigation and Livability (FEMA 364) 

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information 

on participation in the Community Rating System.) 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 5: 

Plan Maintenance 

[The plan shall include a] 

process by which local 

governments incorporate 

the requirements of the 

mitigation plan into other 

planning mechanisms 

such as comprehensive 

or capital improvements, 

when appropriate. 

 Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 3: Coordination with 

Other agencies. 

If the plan includes a review of 

existing studies, reports, and 

technical information for the 

needs goals and plan for that 

area. 

 
PLAN MAINTENANCE PROCESS 

L O C A L M U L T I - H A Z A R D M I T I G A T I O N P L A N N I N G G U I D A N C E 

J U L Y 1 , 2 0 0 8 73

CONTINUED PUBLIC INVOLVEMENT 

Requirement 

§201.6(c)(4)(iii): 

[The plan maintenance process shall include a] discussion on how the 

community will continue public participation in the plan maintenance 

process. 

Explanation: The plan shall describe what opportunities the broader public (i.e., 

stakeholders who are not part of the planning team) will have during the 

mitigation plan’s periodic review to comment on the progress made to date 

and the proposed plan revisions. Plans should describe the mechanisms 

for keeping the public involved (e.g., holding strategic meetings, posting 

the proposed changes to the plan on the Web, etc.) 

Plan Update: The local jurisdiction is required by 44 CFR §201.6(d)(3) to review and 

revise its plan, and resubmit it for approval within 5 years in order to 

continue to be eligible for mitigation project grant funding. 

When the community prepares a plan update, the mitigation planning 

regulation at 44 CFR Part 201 requires that the plan discuss how the 

community was kept involved during the plan maintenance process over 

the previous five years. It is suggested that this discussion take place 

within the planning process section of the plan update rather than the plan 

maintenance section. The plan maintenance section is intended to be 

forward-thinking and emphasize future community involvement. 

The updated plan shall describe how the community will involve the public 

during the plan maintenance process over the next five years. 

Resources: For more information on keeping the public involved, See: 

 Getting Started (FEMA 386-1), Step 3. 

 Bringing the Plan to Life (FEMA 386-4), Steps 2 and 3. 

 Multi-Jurisdictional Mitigation Planning (FEMA 386-8), p. 38. 
PLAN MAINTENANCE PROCESS 

L O C A L M U L T I - H A Z A R D M I T I G A T I O N P L A N N I N G G U I D A N C E 

J U L Y 1 , 2 0 0 8 74

(See also the CRS Resource Center at http://training.fema.gov/EMIWeb/CRS/ for additional information on 

participation in the Community Rating System.) 

Multi-Hazard Planning 

Phase 

A Comparison of the Community 

Rating System & 

Hazard Mitigation Planning 

CRS Step 

Phase 5: 

Plan Maintenance 

[The plan maintenance 

process shall include a] 

discussion on how the 

community will continue 

public participation in the 

plan maintenance 

process. 

 Difference? 

CRS Step is consistent with Multi-Hazard 

Planning Phase. 

Step 10: Impalement, 

evaluate and revise 

The community must have 

procedures for monitoring 

implementation, reviewing 

progress, and recommending 

revisions to the plan in and 

annual evaluation report. 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 INSTRUCTIONS FOR USING THE PLAN REVIEW CROSSWALK FOR REVIEW OF LOCAL MITIGATION PLANSAttached is a Plan Review Crosswalk based on the Local Multi-Hazard Mitigation Planning Guidance, published by FEMA in JuCrosswalk is consistent with the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), as amended by S

Mitigation Act of 2000 (P.L. 106-390), the National Flood Insurance Act of 1968, as amended by the National Flood Insurance Refo

and 44 Code of Federal Regulations (CFR) Part 201 – Mitigation Planning, inclusive of all amendments through October 31, 2007. 

SCORING SYSTEM N – Needs Improvement: The plan does not meet the minimum for the requirement. Reviewer’s comments must be prov

S – Satisfactory: The plan meets the minimum for the requirement. Reviewer’s comments are encouraged, but not requi

Each requirement includes separate elements. All elements of a requirement must be rated “Satisfactory” in order for the requireme

summary score of “Satisfactory.” A “Needs Improvement” score on elements shaded in gray (recommended but not required) will n

passing. When reviewing single jurisdiction plans, reviewers may want to put an N/A in the boxes for multi-jurisdictional plan requirements. Wjurisdictional plans, however, all elements apply. States that have additional requirements can add them in the appropriate section

Mitigation Planning Guidance or create a new section and modify this Plan Review Crosswalk to record the score for those requiremassisting in the review of sections on profiling hazards, assessing vulnerability, and identifying and analyzing mitigation actions are Review Crosswalk. The example below illustrates how to fill in the Plan Review Crosswalk.:

Assessing Vulnerability: OverviewRequirement §201.6(c)(2)(ii): [The risk assessment shall include a] description of the jurisdiction’s vulnerability to the hazards described in pa

This description shall include an overall summary of each hazard and its impact on the community. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan include an 

overall summary description of the jurisdiction’s vulnerability to each 

hazard? 

Section II, pp. 4-10 The plan describes the types of assets that are located within geographica

hazard areas as well as those that would be affected by winter storms. 

B. Does the new or updated plan address 

the impact of each hazard on the 

jurisdiction? 

Section II, pp. 10-20 

The plan does not address the impact of two of the five hazards addressed 

Required Revisions: 

• Include a description of the impact of floods and earthquakes on the a

Recommended Revisions: This information can be presented in terms of dollar value or percentages 

SUMM
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 LOCAL MITIGATION PLAN REVIEW SUMMARY The plan cannot be approved if the plan has not been formally adopted. Each requirement includes separate elements. All elements of the requirement must be rated “Satisfactory” in order for the requirement to be fulfilled and receive a score of “Satisfactory.” Elements of each requirement are listed on the following pages of the Plan Review Crosswalk. A “Needs Improvement” score on elements shaded in gray (recommended but not required) will not preclude the plan from passing. Reviewer’s comments must be provided for requirements receiving a “Needs Improvement” 

score. 

Prerequisite(s) (Check Applicable Box) NOT MET MET 1. Adoption by the Local Governing Body: §201.6(c)(5) OR 2. Multi-Jurisdictional Plan Adoption: §201.6(c)(5) 

AND 

3. Multi-Jurisdictional Planning Participation: §201.6(a)(3) Planning Process N S 4. Documentation of the Planning Process: §201.6(b) and §201.6(c)(1) Risk Assessment N S 5. Identifying Hazards: §201.6(c)(2)(i) 6. Profiling Hazards: §201.6(c)(2)(i) 7. Assessing Vulnerability: Overview: §201.6(c)(2)(ii) 8. Assessing Vulnerability: Addressing Repetitive 

Loss Properties. §201.6(c)(2)(ii) 

9. Assessing Vulnerability: Identifying Structures, 

Infrastructure, and Critical Facilities: §201.6(c)(2)(ii)(B) 

10. Assessing Vulnerability: Estimating Potential Losses: §201.6(c)(2)(ii)(B) 11. Assessing Vulnerability: Analyzing Development Trends: §201.6(c)(2)(ii)(C) 12. Multi-Jurisdictional Risk Assessment: §201.6(c)(2)(iii) 

*States that have additional requirements can add them in the appropriate sections of the Local Multi-Hazard Mitigation Planning Guidance or create a new section and 

modify this Plan Review Crosswalk to record the score for those requirements. 

SCORING SYSTEMPlease check one of the following for each require

N – Needs Improvement: The plan does n

requirement. Reviewer’s comments must 

S – Satisfactory: The plan meets the minim

Reviewer’s comments are encouraged, b

Mitigation Strategy 13. Local Hazard Mitigation Goals: §201.6(c)(3)(i) 

14. Identification and Analysis of Mitigation Actions: §201.6(c)(3)(ii) 15. Identification and Analysis of Mitigation Actions: NFIP Compliance. §201.6(c)(3)(ii) 16. Implementation of Mitigation Actions: §201.6(c)(3)(iii) 17. Multi-Jurisdictional Mitigation Actions: §201.6(c)(3)(iv) Plan Maintenance Process 18. Monitoring, Evaluating, and Updating the Plan:§201.6(c)(4)(ii) 19. Incorporation into Existing Planning Mechanisms: §201.6(c)(4)(ii) 20. Continued Public Involvement: §201.6(c)(4)(iii)Additional State Requirements* Insert State Requirement Insert State Requirement Insert State Requirement LOCAL MITIGATION PLAN APPROVAL STAT

PLAN NOT A

See Reviewer’s 

PLAN A
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

Local Mitigation Plan Review and Approval Status 

Jurisdiction: Title of Plan: Date of Plan: Local Point of Contact: Title: Agency: 

Address: 

Phone Number: E-Mail:State Reviewer: Title: Date: FEMA Reviewer: Title: Date: 

Date Received in FEMA Region [Insert #]

Plan Not Approved

Plan Approved

Date Approved

NFIP 

Jurisdiction: Y N 1. 2. 3. 4. 5. [ATTACH PAGE(S) WITH ADDITIONAL JURISDICTIONS] 

* Notes: Y = Participating N = Not Participating N/A = Not Mapped 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 PREREQUISITE(S)

1. Adoption by the Local Governing Body Requirement §201.6(c)(5): [The local hazard mitigation plan shall include] documentation that the plan has been formally adopt

the jurisdiction requesting approval of the plan (e.g., City Council, County Commissioner, Tribal Council). 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Has the local governing body adopted new or 

updated plan? 

B. Is supporting documentation, such as a resolution, 

included? 

SUMMAR

3. Multi-Jurisdictional Planning Participation Requirement §201.6(a)(3): Multi-jurisdictional plans (e.g., watershed plans) may be accepted, as appropriate, as long as each ju

the process ... Statewide plans will not be accepted as multi-jurisdictional plans. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan describe how each 

jurisdiction participated in the plan’s development? 

B. Does the updated plan identify all participating 

jurisdictions, including new, continuing, and the jurisdictions that no longer participate in the plan? 

SUMMARY 

2. Multi-Jurisdictional Plan AdoptionRequirement §201.6(c)(5): For multi-jurisdictional plans, each jurisdiction requesting approval of the plan must document that it Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan indicate the 

specific jurisdictions represented in the plan? 

B. For each jurisdiction, has the local governing 

body adopted the new or updated plan? 

C. Is supporting documentation, such as a resolution, 

included for each participating jurisdiction? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 PLANNING PROCESS: §201.6(b): An open public involvement process is essential to the development of an effective plan. 

4. Documentation of the Planning Process Requirement §201.6(b): In order to develop a more comprehensive approach to reducing the effects of natural disasters, the pla

(1) An opportunity for the public to comment on the plan during the drafting stage and prior to plan approval; (2) An opportunity for neighboring communities, local and regional agencies involved in hazard mitigation activities, and agencies 

regulate development, as well as businesses, academia and other private and non-profit interests to be involved in the plannin

(3) Review and incorporation, if appropriate, of existing plans, studies, reports, and technical information. 

Requirement §201.6(c)(1): [The plan shall document] the planning process used to develop the plan, including how it was prepa

process, and how the public was involved. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the plan provide a narrative description of the 

process followed to prepare the new or updated plan? 

B. Does the new or updated plan indicate who was 

involved in the current planning process? (For example, who led the development at the staff level and were there any external contributors such as contractors? Who participated on the plan committee, provided information, reviewed drafts, etc.?) 

C. Does the new or updated plan indicate how the public 

was involved? (Was the public provided an opportunity to comment on the plan during the drafting stage and prior to the plan approval?) 

D. Does the new or updated plan discuss the 

opportunity for neighboring communities, agencies, businesses, academia, nonprofits, and other interested parties to be involved in the planning process? 

E. Does the planning process describe the review and 

incorporation, if appropriate, of existing plans, studies, reports, and technical information? 

F. Does the updated plan document how the planning 

team reviewed and analyzed each section of the plan and whether each section was revised as part of the update process? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 RISK ASSESSMENT: §201.6(c)(2): The plan shall include a risk assessment that provides the factual basis for activities proposed 

from identified hazards. Local risk assessments must provide sufficient information to enable the jurisdiction to identify and priori

actions to reduce losses from identified hazards. 

5. Identifying Hazards Requirement §201.6(c)(2)(i): [The risk assessment shall include a] description of the type ... of all natural hazards that can affeElement 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan include a description 

of the types of all natural hazards that affect the 

jurisdiction? 

SUMMARY 

6. Profiling Hazards Requirement §201.6(c)(2)(i): [The risk assessment shall include a] description of the ... location and extent of all natural hazard

jurisdiction. The plan shall include information on previous occurrences of hazard events and on the probability of future hazard e

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the risk assessment identify the location (i.e., 

geographic area affected) of each natural hazard addressed in the new or updated plan? 

B. Does the risk assessment identify the extent (i.e., 

magnitude or severity) of each hazard addressed in the 

new or updated plan? 

C. Does the plan provide information on previous 

occurrences of each hazard addressed in the new or 

updated plan? 

D. Does the plan include the probability of future events 

(i.e., chance of occurrence) for each hazard addressed in 

the new or updated plan? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

7. Assessing Vulnerability: Overview Requirement §201.6(c)(2)(ii): [The risk assessment shall include a] description of the jurisdiction’s vulnerability to the hazards d

of this section. This description shall include an overall summary of each hazard and its impact on the community. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan include an overall 

summary description of the jurisdiction’s vulnerability to 

each hazard? 

B. Does the new or updated plan address the impact of 

each hazard on the jurisdiction? 

SUMMARY 

8. Assessing Vulnerability: Addressing Repetitive Loss Properties 

Requirement §201.6(c)(2)(ii): [The risk assessment] must also address National Flood Insurance Program (NFIP) insured struc

repetitively damaged floods.

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan describe vulnerability 

in terms of the types and numbers of repetitive loss properties located in the identified hazard areas? 

Note: This requirement becomes effective for plans approved after October 1, 2008. 

SUMMARY 

9. Assessing Vulnerability: Identifying Structures 

Requirement §201.6(c)(2)(ii)(A): The plan should describe vulnerability in terms of the types and numbers of existing and future 

critical facilities located in the identified hazard area ... . 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan describe vulnerability in 

terms of the types and numbers of existing buildings, infrastructure, and critical facilities located in the identified hazard areas? 

Note: A “Needs Improvement” score on this reqnot preclude the plan from passing. 

B. Does the new or updated plan describe vulnerability in 

terms of the types and numbers of future buildings, infrastructure, and critical facilities located in the identified hazard areas?

Note: A “Needs Improvement” score on this req

not preclude the plan from passing. 

SUMMAR
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

10. Assessing Vulnerability: Estimating Potential Losses Requirement §201.6(c)(2)(ii)(B): [The plan should describe vulnerability in terms of an] estimate of the potential dollar losses to 

identified in paragraph (c)(2)(ii)(A) of this section and a description of the methodology used to prepare the estimate ... . 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan estimate potential 

dollar losses to vulnerable structures? 

Note: A “Needs Improvement” score on this req

not preclude the plan from passing. 

B. Does the new or updated plan describe the 

methodology used to prepare the estimate? 

Note: A “Needs Improvement” score on this req

not preclude the plan from passing. 

SUMMARY 

11. Assessing Vulnerability: Analyzing Development Trends Requirement §201.6(c)(2)(ii)(C): [The plan should describe vulnerability in terms of] providing a general description of land use

within the community so that mitigation options can be considered in future land use decisions. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan describe land uses and 

development trends? 

Note: A “Needs Improvement” score on this reqnot preclude the plan from passing. 

SUMMARY 

12. Multi-Jurisdictional Risk Assessment Requirement §201.6(c)(2)(iii): For multi-jurisdictional plans, the risk assessment must assess each jurisdiction’s risks where the

entire planning area. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan include a risk 

assessment for each participating jurisdiction as needed to reflect unique or varied risks? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 MITIGATION STRATEGY: §201.6(c)(3): The plan shall include a mitigation strategy that provides the jurisdiction’s blueprint for r

identified in the risk assessment, based on existing authorities, policies, programs and resources, and its ability to expand on and im

13. Local Hazard Mitigation Goals Requirement §201.6(c)(3)(i): [The hazard mitigation strategy shall include a] description of mitigation goals to reduce or avoid lo

identified hazards. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A Does the new or updated plan include a description 

of mitigation goals to reduce or avoid long-term 

vulnerabilities to the identified hazards? 

SUMMARY 

14. Identification and Analysis of Mitigation Actions 

Requirement §201.6(c)(3)(ii): [The mitigation strategy shall include a] section that identifies and analyzes a comprehensive rang

and projects being considered to reduce the effects of each hazard, with particular emphasis on new and existing buildings and in

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan identify and analyze a 

comprehensive range of specific mitigation actions and projects for each hazard? 

B Do the identified actions and projects address 

reducing the effects of hazards on new buildings and 

infrastructure? 

C. Do the identified actions and projects address 

reducing the effects of hazards on existing buildings 

and infrastructure? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

15. Identification and Analysis of Mitigation Actions: National Flood Insurance Program (NFIP) Compliance Requirement: §201.6(c)(3)(ii): [The mitigation strategy] must also address the jurisdiction’s participation in the National Flood In

continued compliance with NFIP requirements, as appropriate. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan describe the 

jurisdiction (s) participation in the NFIP? 

Note: This requirement becomes effective 

mitigation plans approved after October 1, 

B. Does the mitigation strategy identify, analyze and 

prioritize actions related to continued compliance with the NFIP? 

Note: This requirement becomes effective 

mitigation plans approved after October 1, 

SUMMARY 

16. Implementation of Mitigation Actions Requirement: §201.6(c)(3)(iii): [The mitigation strategy section shall include] an action plan describing how the actions identifie

prioritized, implemented, and administered by the local jurisdiction. Prioritization shall include a special emphasis on the extent to 

according to a cost benefit review of the proposed projects and their associated costs. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated mitigation strategy include 

how the actions are prioritized? (For example, is there 

a discussion of the process and criteria used?) 

B. Does the new or updated mitigation strategy address 

how the actions will be implemented and administered, including the responsible department , existing andpotential resources and the timeframe to complete each action? 

C. Does the new or updated prioritization process include 

an emphasis on the use of a cost-benefit review to 

maximize benefits? 

D. Does the updated plan identify the completed, deleted 

or deferred mitigation actions as a benchmark for progress, and if activities are unchanged (i.e., 

deferred), does the updated plan describe why no changes occurred? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

17. Multi-Jurisdictional Mitigation Actions Requirement §201.6(c)(3)(iv): For multi-jurisdictional plans, there must be identifiable action items specific to the jurisdiction req

credit of the plan. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A Does the new or updated plan include identifiable action 

items for each jurisdiction requesting FEMA approval of 

the plan? 

B. Does the updated plan identify the completed, deleted or 

deferred mitigation actions as a benchmark for progress, and if activities are unchanged (i.e., deferred), does the 

updated plan describe why no changes occurred? 

SUMMARY 

PLAN MAINTENANCE PROCESS

18. Monitoring, Evaluating, and Updating the Plan Requirement §201.6(c)(4)(i): [The plan maintenance process shall include a] section describing the method and schedule of mo

updating the mitigation plan within a five-year cycle. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan describe the method and 

schedule for monitoring the plan, including the responsible 

department? 

B. Does the new or updated plan describe the method and 

schedule for evaluating the plan, including how, when and by 

whom (i.e. the responsible department)? 

C. Does the new or updated plan describe the method and 

schedule for updating the plan within the five-year cycle? 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

19. Incorporation into Existing Planning Mechanisms Requirement §201.6(c)(4)(ii): [The plan shall include a] process by which local governments incorporate the requirements of the 

planning mechanisms such as comprehensive or capital improvement plans, when appropriate. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan identify other local planning 

mechanisms available for incorporating the mitigation requirements of the mitigation plan? 

B. Does the new or updated plan include a process by which 

the local government will incorporate the mitigation strategy and other information contained in the plan (e.g., risk 

assessment) into other planning mechanisms, when appropriate? 

C. Does the updated plan explain how the local government 

incorporated the mitigation strategy and other information contained in the plan (e.g., risk assessment) into other 

planning mechanisms, when appropriate? 

SUMMARY 

Continued Public Involvement Requirement §201.6(c)(4)(iii): [The plan maintenance process shall include a] discussion on how the community will continue p

maintenance process. 

Element 

Location in the Plan (section or annex and page #) Reviewer’s Comments 

A. Does the new or updated plan explain how continued 

public participation will be obtained? (For example, will there be public notices, an on-going mitigation plan committee, or annual review meetings with stakeholders?) 

SUMMARY 
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 MATRIX A: PROFILING HAZARDSThis matrix can assist FEMA and the State in scoring each hazard. Local jurisdictions may find the matrix useful to ensure that thehazard that can affect the jurisdiction. Completing the matrix is not required. Note: First, check which hazards are identified in requirement §201.6(c)(2)(i). Then, place a checkmark in either the N or S 

hazard. An “N” for any element of any identified hazard will result in a “Needs Improvement” score for this requirement. 

shortcoming in the comments section of the Plan Review Crosswalk. 

Hazards Identified

Per Requirement 

§201.6(c)(2)(i) 

A. Location B. Extent C. Previous Occurrences D. Probability of Hazard Type Future Events 

Yes N S N S N S N S 

Avalanche Coastal Erosion Coastal Storm Dam Failure Drought Earthquake Expansive Soils Levee Failure Flood Hailstorm Hurricane Land Subsidence Landslide Severe Winter Storm Tornado Tsunami Volcano Wildfire Windstorm Other Other Other 

Legend: §201.6(c)(2)(i) Profiling Hazards A. Does the risk assessment identify the location (i.e., geographic area affected) of each hazard addressed in the new or updated plan? 

B. Does the risk assessment identify the extent (i.e., magnitude or severity) of each hazard addressed in the new or updated plan? 

C. Does the plan provide information on previous occurrences of each natural hazard addressed in the new or updated plan? 

D. Does the plan include the probability of future events (i.e., chance of occurrence) for each hazard addressed in the plan?
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 MATRIX B: ASSESSING VULNERABILITYThis matrix can assist FEMA and the State in scoring each hazard. Local jurisdictions may find the matrix useful to ensure that the each requirement. Completing the matrix is not required. 

Note: First, check which hazards are identified in requirement §201.6(c)(2)(i). Then, place a checkmark in either the N or S box fo

“N” for any element of any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its 

comments section of the Plan Review Crosswalk. Note: Receiving an N in the shaded columns will not preclude the plan from pas

Hazards 

Identified Per 

Requirement 

§201.6(c)(2)(i)

A. Overall 

Summary 

Description of 

Vulnerability 

B. Hazard 

Impact 

A. Types and Number 

of Existing Structures 

in Hazard Area 

(Estimate) 

B. Types and 

Number of Future 

Structures in Hazard 

Area (Estimate) 

A. Loss Estimate B. 

Hazard Type 

Yes N S N S N S N S N S 

Avalanche Coastal Erosion Coastal Storm Dam Failure Drought Earthquake Expansive Soils Levee Failure Flood Hailstorm Hurricane Land Subsidence Landslide Severe Winter Storm Tornado Tsunami Volcano Wildfire Windstorm Other Other Other 

§201.6(c)(2)(ii) Assessing Vulnerability: Overview 

§201.6(c)(2)(ii) Assessing Vulnerability: Identifying Structures 

§201.6(c)(2)(ii) Assessing Vulnerability: Estimating Potential Losses 

Legend: §201.6(c)(2)(ii) Assessing Vulnerability: Overview 

A. Does the new or updated plan include an overall summary description of the jurisdiction’s 

vulnerability to each hazard? 

B. Does the new or updated plan address the impact of each hazard on the jurisdiction? 

§201.6(c)(2)(ii)(A) Assessing Vulnerability: Identifying Structures 

A. Does the new or updated plan describe vulnerability in terms of the types and numbers of 

existing buildings, infrastructure, and critical facilities located in the identified hazard areas?

B. Does the new or updated plan describe vulnerabili

future buildings, infrastructure, and critical facilities 

§201.6(c)(2)(ii)(B) Assessing Vulnerability: Estimating PoteA. Does the new or updated plan estimate potential dollar 

B. Does the new or updated plan describe the metho
LOCAL MITIGATION PLAN REVIEW CROSSWALK 

J U L Y 1 , 2 0 0 8 

MATRIX C: IDENTIFICATION AND ANALYSIS OF MITIGATION ACTIONSThis matrix can assist FEMA and the State in scoring each hazard. Local jurisdictions may find the matrix useful to ensure consieach hazard. Completing the matrix is not required.

Note: First, check which hazards are identified in requirement §201.6(c)(2)(i). Then, place a checkmark in either the N or S box 

“N” for any identified hazard will result in a “Needs Improvement” score for this requirement. List the hazard and its related shortof the Plan Review Crosswalk. 

Hazards Identified

Per Requirement 

§201.6(c)(2)(i) 

A. Comprehensive 

Range of Actions 

and Projects Hazard Type 

Yes N S 

Avalanche Coastal Erosion Coastal Storm Dam Failure Drought Earthquake Expansive Soils Levee Failure Flood Hailstorm Hurricane Land Subsidence Landslide Severe Winter Storm Tornado Tsunami Volcano Wildfire Windstorm Other Other Other 

Legend: §201.6(c)(3)(ii) Identification and Analysis of Mitigation Actions A. Does the new or updated plan identify and analyze a comprehensive range of specific mitigation actions and projects for 

each hazard?

To chec

click o

change th

to “c