MITIGATION POLICY 

FEMA Policy 205-080-01– Elevated Foundation Systems

Page 1

I. TITLE: Pilot Activity - Elevated Foundation Systems under the Hazard Mitigation Grant 

Program (HMGP) for Hurricane Sandy Major Disaster Declarations

II. DATE OF ISSUANCE: March 18, 2013

III. POLICY STATEMENT: An Elevated Foundation System is an eligible activity under the 

Hazard Mitigation Grant Program.

IV. PURPOSE: The purpose of this policy is to describe a pilot mitigation activity which will 

assist in the recovery from the devastating effects of Hurricane Sandy and help create more

resilient and sustainable communities.

V. SCOPE AND EXTERNAL AUDIENCE: This policy is applicable for all HMGP Grants 

made available for Hurricane Sandy major disaster declarations.

VI. AUTHORITY: FEMA has authority under Section 404 of the Robert T. Stafford Disaster 

Relief and Emergency Assistance Act (Stafford Act), 42 U.S.C. § 5170c, to provide funding 

through the Hazard Mitigation Grant Program (HMGP) for hazard mitigation measures that 

are cost effective and substantially reduce the risk to life and property. 

VII. OBJECTIVE: To assist local communities in recovering from Hurricane Sandy by 

providing flexibility in the implementation of HMGP. Some property owners may choose 

to demolish their existing damaged residential structures and build new ones instead of 

repairing and elevating the existing residential structures. This policy provides funds under 

HMGP to pay part of the cost of elevating the new structure to the base flood elevation or 

higher.

VIII. ABBREVIATIONS: 

ABFE Advisory Base Flood Elevation

ASCE American Society of Civil Engineers

BFE Base Flood Elevation

CFR Code of Federal Regulations

EHP Environmental and Historic Preservation

FEMA Federal Emergency Management Agency

FIMA Federal Insurance and Mitigation Administration

FIRM Flood Insurance Rate Map 

FMA Flood Mitigation Assistance program 

HMA Hazard Mitigation Assistance
MITIGATION POLICY 

FEMA Policy 205-080-01– Elevated Foundation Systems

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HMGP Hazard Mitigation Grant Program

ICC International Code Council

NFIP National Flood Insurance Program

OMB Office of Management and Budget

SFHA Special Flood Hazard Area

SRL Severe Repetitive Loss 

Stafford Act Robert T. Stafford Disaster Relief and Emergency Assistance Act

IX. POLICY DETAILS:

A. Eligibility Requirements

In addition to all other HMGP eligibility requirements, including cost effectiveness, the 

Elevated Foundation System must satisfy the following requirements:

1. The elevated structure must be a single family, detached, residential structure 

that was substantially damaged or destroyed by Hurricane Sandy. Properties 

located in a Sandy declared State and that are included on the National Flood 

Insurance Program (NFIP) validated Severe Repetitive Loss (SRL) list are also 

eligible. 

2. The project must result in a structure suitable for occupancy that meets the 

minimum required elevation level and foundation type utilizing the best 

available flood hazard data. The construction of an Elevated Foundation 

System alone does not constitute a complete hazard mitigation solution as 

required by 44 CFR 206.434 Eligibility. Prior to closeout, an Elevation 

Certificate and a Certificate of Occupancy from the authority having jurisdiction 

demonstrating the completed structure is suitable for occupancy and conforms 

to NFIP requirements must be submitted to FEMA.

3. This activity is only available to property owners who owned the property at the 

time of the event for which funding is authorized. This extends to successors 

and assigns who gained title to the property as a result of death or incapacity of 

that property owner.

B. Eligible Costs

1. Eligible costs for the Elevated Foundation System include costs for the vertical 

and horizontal elements necessary to construct the foundation system up to but 

not including the lowest finished floor such as posts, beams, joists, anchorage, 

connections and subfloor. Other eligible costs include access for ingress/egress, 
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FEMA Policy 205-080-01– Elevated Foundation Systems

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and elevating utility hookups, and heating, ventilation, and air conditioning 

(HVAC) components.

2. The Federal share of the Elevated Foundation System funding may be up to 20 

percent of the total structure construction cost or $45,000,

1 whichever is less. 

The Federal share cost limit is based on national average construction costs. 

The Federal share construction cost limit may be adjusted using an industry 

accepted locality adjustment factor such as RS Means, Standard & Poor, or 

other acceptable industry standard. 

3. Non-construction costs associated with the Elevated Foundation System project 

such as costs for demolition, survey, design fees and permits, are eligible project 

costs. These costs will be considered outside the construction cost limit on the 

Federal share for the Elevated Foundation System.

4. Increased Cost of Compliance (ICC) funds may be used for eligible project 

activities and is an allowable source of local match for HMGP.

5. If the project application includes mixed mitigation activities, the costs for 

additional approved mitigation actions not associated with the foundation 

system such as mitigation for high winds are eligible project costs. However, 

these costs must be delineated in the application cost estimate as separate line 

items and they will not be deducted from the construction cost limit for the new 

elevated foundation system.

C. Project Design Recommendation & Structure Size

1. FEMA recommends the Elevated Foundation System project be designed and 

constructed in conformance with the design criteria of the American Society for 

Civil Engineers (ASCE) Flood Resistant Design and Construction (ASCE 24-

05) or newer version, as a minimum standard. FEMA will consider a project 

application stating that ASCE 24-05 or a newer version will be used, as being 

consistent with HMA engineering feasibility and effectiveness requirements. 

Project applications that do not indicate the use of ASCE 24-05 may need to 

submit documentation to demonstrate the project meets the engineering 

feasibility and effectiveness requirement. 

2. FEMA recommends the 2006 or newer International Building Code or 

International Residential Code, published by the International Code Council, or 

the local or state building code, whichever is most stringent, be used as the 

minimum construction standard for the non-foundation structure components 

such as the main living areas and roof.
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FEMA Policy 205-080-01– Elevated Foundation Systems

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3. Neither the new structure square footage nor the footprint shall be more than 10 

percent greater than that of the pre-event overall structure square footage or preevent footprint. For example, a 2,000 square foot, two-story home with a 1,000 

square foot footprint, when rebuilt, may not exceed 2,200 square feet for the 

whole structure and the footprint may not be greater than 1,100 square feet.

4. The new foundation footprint may be altered or relocated within the same 

property lot. The application review process may be streamlined if the new 

footprint overlaps the pre-event footprint by at least 50 percent. Otherwise, the 

application review may take longer in order to evaluate the potential for 

increased impacts to environmental and historic resources. The new footprint 

location cannot result in an increased risk to the structure.

D. Floodplain Management

1. The Elevated Foundation System activity is not allowed in any regulatory 

floodway, V-Zone, or Coastal Barrier Resource Area Zone. 

2. The project must utilize the best available flood hazard data (e.g. ABFE or 

preliminary flood maps, if available) to determine the required foundation 

system design and elevation. FEMA staff at the Joint Field Office or FEMA 

Regional Office may be contacted for information regarding the best available 

data. 

3. If the best available data identifies the new mitigated structure is located in a 

Special Flood Hazard Area (SFHA), flood insurance must be maintained for the 

life of the structure to an amount at least equal to the project cost or to the 

maximum insurable limit under the National Flood Insurance Program (NFIP), 

whichever is less. 

4. A deed restriction describing the flood insurance requirement must be filed and 

include the following language:

This property has received Federal hazard mitigation 

assistance pursuant to 42 U.S.C. §5170c. Federal law 

requires that insurance coverage on this property must be 

maintained during the life of the property regardless of 

transfer of ownership of such property. Pursuant to 42 

U.S.C. §5154a, failure to maintain flood insurance on 

this property may prohibit the owner from receiving 
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FEMA Policy 205-080-01– Elevated Foundation Systems

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Federal disaster assistance with respect to this property 

in the event of a flood disaster.

5. Elevated Foundation System projects must be implemented and maintained in 

compliance with the minimum floodplain management and land use standards 

in 44 CFR Part 59 General Provisions and Part 60 Criteria for Land 

Management and Use. 

E. Other General Requirements

1. Cost associated with implementation of the activity but incurred prior to grant 

award are not eligible. Projects initiated or completed prior to FEMA grant 

award are not eligible. 

2. Pre-award costs directly related to developing the subapplication may be 

considered for eligibility only if they are identified as separate line items in the 

cost estimate of the subapplication. Pre-award costs are those costs incurred 

after the date of the disaster declaration and prior to the application approval. 

These may or may not be eligible for reimbursement under HMGP in 

accordance with the Office of Management and Budget (OMB) Circular A-87 

Cost Principles for States, Local, and Indian Tribal Governments.

3. Projects must adhere to all statutes, regulations, and requirements that apply to 

HMGP funding, including but not limited to the Stafford Act, 42 U.S.C. §5121 

et seq.,Title 44 CFR Emergency Management and Assistance, and all other 

applicable federal, state, and local environmental, historic preservation, cost 

effectiveness, and grants management requirements, as well as applicable 

program guidance.

4. This policy represents FEMA’s interpretations of a statutory or regulatory 

requirement and/or sets forth standard operating procedures. The policy 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.

X. ROLES & RESPONSIBILITIES: Roles and responsibilities for all Federal, State, Tribal 

and local parties are consistent with those outlined in the Uniform Administrative 

Requirements (44 CFR Part 13), Hazard Mitigation Grant Program (44 CFR Part 206 

Subpart N), and the HMA Unified Guidance.
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FEMA Policy 205-080-01– Elevated Foundation Systems

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XI. MONITORING AND EVALUATION: The grantee must submit financial and 

performance reports to FEMA in accordance with the reporting requirements outlined in 

the Uniform Administrative Requirements (44 CFR Part 13), Hazard Mitigation Grant 

Program (44 CFR Part 206 Subpart N), and the HMA Unified Guidance. Grantees must 

comply with the administrative and audit requirements of the Uniform Administrative 

Requirements (44 CFR Part 13), and the Hazard Mitigation Grant Program (44 CFR Part 

206 Subpart N), as well as the terms and conditions of the grant award agreement.

XII. RESPONSIBLE OFFICE: The FIMA Risk Reduction Division Grants Policy Branch is 

the originating office for this policy document, with the overall responsibility for policy 

updates and enforcement. If you have any questions, please contact Kayed Lakhia, Deputy 

Director, Risk Reduction Division at (202) 646-3458.

XIII. SUPERSESSION: There are no previous mitigation policies or guidance related to this 

subject. 

XIV. REVIEW DATE: This policy is only applicable to HMGP resulting from Hurricane 

Sandy declarations. It will expire five (5) years from the date in paragraph II above.

_____________________________

David L. Miller

Associate Administrator

Federal Insurance and Mitigation Administration

Federal Emergency Management Agency

 1 Elevated foundation construction costs are based on average costs for standard construction for 

a 2,000 square foot, two-story, wood framed home. Costs are based on the national average for 

construction costs and validated against RS Means 2012 Residential Repair & Remodeling 

Costs. The $45,000 construction limit includes costs for the foundation elements up to the 

lowest finished floor including the bottom of the lowest floor framing and subfloor, access for 

ingress/egress for first floor entry, and costs to elevate utility hookups, and electrical and HVAC 

equipment. These costs assumed an elevation of 10 feet; the minimum required elevation and 

foundation type will vary for each structure and generally will be lower than 10 feet.