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Partial Implementation of the Federal

Flood Risk Management Standard for 

Hazard Mitigation Assistance Programs 

FEMA Policy 206-21-003-0001

BACKGROUND

This policy partially implements the Federal Flood Risk Management Standard (FFRMS) for

projects funded under all the Federal Emergency Management Agency’s (FEMA) Hazard 

Mitigation Assistance (HMA) grant programs, as follows: Hazard Mitigation Grant Program 

(HMGP), HMGP Post Fire, Building Resilient Infrastructure and Communities (BRIC), PreDisaster Mitigation (PDM), and Flood Mitigation Assistance (FMA). In its HMA programs,

FEMA utilizes the American Society of Civil Engineers (ASCE) 24-141, or latest edition, to 

establish minimum design and construction requirements for structure elevation, dry

floodproofing, and mitigation reconstruction.2 The FFRMS is a flood standard, established in

Executive Order (EO) 136903, to increase community resilience to flooding. EO 140304

directs FEMA to implement the FFRMS. FEMA plans to fully implement the FFRMS by

rulemaking. This policy partially implements the FFRMS with respect to covered projects

within existing floodplains.

This policy supersedes FP 206-21-0003, Partial Implementation of the Federal Flood Risk 

Management Standard for Hazard Mitigation Assistance Programs (Interim).

PURPOSE

This policy provides elevation requirements for critical5 and non-critical actions involving 

structures6, as defined in 44 CFR Part 9.4, located in a designated floodplain. The policy

1 ASCE 24 - Flood Resistant Design and Construction, published by the American Society of Civil Engineers establishes 

required protection levels for structures of various flood design classes. The flood protection levels are generally equal to 

the Base Flood Elevation (BFE) plus 1 or 2 feet of freeboard or another Design Flood Elevation (DFE), whichever is 

higher. For more information, visit https://www.fema.gov/sites/default/files/2020-07/asce24-14_highlights_jan2015.pdf. 2 2015 Hazard Mitigation Assistance Guidance and Hazard Mitigation Assistance Guidance Addendum.

3 Executive Order 13690, Establishing a Federal Flood Risk Management Standard and a Process for Further Soliciting

and Considering Stakeholder Input, visit https://www.govinfo.gov/content/pkg/FR-2015-02-04/pdf/2015-02379.pdf

4 Executive Order 14030, Climate-Related Financial Risk, visit

https://www.federalregister.gov/documents/2021/05/25/2021-11168/climate-related-financial-risk. 5 Under 44 CFR § 9.4, Critical Action means an action for which even a slight chance of flooding is too great. Critical 

actions include, but are not limited to, those which create or extend the useful life of structures or facilities such as: (a) 

those which produce, use, or store highly volatile, flammable, explosive, toxic or water-reactive materials; (b) hospitals 

and nursing homes, and housing for the elderly, which are likely to contain occupants who may not be sufficiently mobile 

to avoid the loss of life or injury during flood and storm events; (c) emergency operation centers, or data storage centers 

which contain records or services that may become lost or inoperative during flood and storm events; and (d) generating 

plants, and other principal points of utility lines.

6 Under 44 CFR § 9.4, Structures means walled or roofed buildings, including mobile homes and gas or liquid storage 

tanks.

This policy was effective from December 7, 2020 

through March 22, 2023. 
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establishes requirements for elevating and floodproofing7 structures funded under HMA 

programs.

PRINCIPLES

By partially implementing the FFRMS and requiring a higher vertical flood elevation, FEMA 

will:

A. Ensure that communities affected by future flooding are less vulnerable to the loss of life

and property.

B. Ensure that HMA program funds for projects in the floodplain are used to protect structures

from flood risk.

C. Ensure that structures are elevated or floodproofed to address current and future flood risk.

D. Implement this policy in a consistent and equitable manner.

REQUIREMENTS

A. SCOPE

In accordance with Section 2(a)(1) of EO 11988, before taking an action, FEMA must 

determine whether a proposed action will occur in a floodplain. The provisions of this policy 

apply when FEMA determines an action is within the 1% annual chance floodplain for noncritical action projects, or within the or 0.2% annual chance floodplain for critical action 

projects.

For implementation of the FFRMS, HMA programs will identify the appropriate flood hazard 

information that is applicable to the specific HMA program as follows:

1. FEMA uses the best available flood hazard information to determine the 1% and 0.2%

annual chance floodplains. This information may be found in flood insurance rate maps

(FIRM)8 or flood insurance studies (FIS)9.

a. If the FIRM is up to date and available, and FEMA determines that the best flood hazard

information is the FIRM, then applicants must use the 1% and 0.2% annual chance

floodplains on that map to apply this policy.

7 Under 44 CFR § 9.4, Floodproofing means the modification of individual structures and facilities, their sites, and their 

contents to protect against structural failure, to keep water out, or to reduce effects of water entry.

8 Under 44 CFR § 59.1, Flood Insurance Rate Map (FIRM) means an official map of a community, on which the Federal 

Insurance Administrator has delineated both the special hazard areas and the risk premium zones applicable to the 

community. A FIRM that has been made available digitally is called a Digital Flood Insurance Rate Map (DFIRM).

9 Flood Insurance Study (FIS) is an official FEMA document. It is a compilation and presentation of flood risk data for 

specific watercourses, lakes, and coastal flood hazard areas within a community. When a flood study is completed for the 

National Flood Insurance Program (NFIP), the information and maps are assembled into an FIS. The FIS report contains 

detailed flood elevation data in flood profiles and data tables.
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b. If FEMA has provided advisory flood hazard information because the effective FIRM is

out of date, FEMA will designate the advisory information to be used if the advisory

information is at least as restrictive as the effective information. If assistance is provided

subsequent to a disaster event such as HMGP assistance, FEMA will communicate the

availability of floodplain maps or advisory flood hazard information to be used.10

B. APPLICABILITY

Outcome: Applicants and sub-applicants implement this policy based on applicable 

standards outlined below.

1. For the HMGP, this policy applies to any major disaster declaration declared on or after the

effective date of this policy.

2. For the HMGP Post Fire, this policy applies to Fire Management Assistance Grant

declarations issued or published on or after the effective date of this policy.

3. For BRIC, PDM, and FMA, this policy applies to the Fiscal Year 2023 Notices of Funding

Opportunity (NOFOs) and future application cycles, unless stated otherwise in subsequent

NOFOs.

4. This policy applies to:

a. All structure elevation, mitigation reconstruction, and dry floodproofing projects;

and

b. All projects where HMA funds are used for new construction11, substantial

improvement12, or to address substantial damage13 to structures.

C. APPLICABLE MINIMUM DESIGN STANDARD

Outcome: Applicants and sub-applicants understand the elevation requirements for different 

types of structures in floodplains. The design standard differs depending on whether the 

action is a critical or non-critical action and whether the structure is in a 1% or 0.2% annual

10 See FEMA Policy #104-008-2: Guidance on the Use of Available Flood Hazard Information for additional information.

11 Under 44 CFR § 9.4, New Construction means the construction of a new structure (including the placement of a mobile 

home) or facility or the replacement of a structure or facility which has been totally destroyed.

12 Under 44 CFR § 9.4, Substantial Improvement means any repair, reconstruction or other improvement of a structure or 

facility, which has been damaged in excess of, or the cost of which equals or exceeds, 50% of the market value of the 

structure or replacement cost of the facility (including all “public facilities” as defined in the Disaster Relief Act of 1974) (a) 

before the repair or improvement is started, or (b) if the structure or facility has been damaged and is proposed to be 

restored, before the damage occurred. If a facility is an essential link in a larger system, the percentage of damage will be 

based on the relative cost of repairing the damaged facility to the replacement cost of the portion of the system which is 

operationally dependent on the facility. The term “substantial improvement” does not include any alteration of a structure or 

facility listed on the National Register of Historic Places or a State Inventory of Historic Places.

13 Under 44 CFR § 59.1, Substantial Damage means damage of any origin sustained by a structure whereby the cost of 

restoring the structure to its before damaged condition would equal or exceed 50 percent of the market value of the 

structure before the damage occurred.
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chance floodplain.

1. For non-critical actions in a 1% annual chance floodplain:

a. Applicants must elevate or floodproof14 the structures to the 0.2% annual chance 

flood elevation15 or an additional 2 feet above the base flood elevation (BFE), 

whichever is lower. 

b. For those areas where the 0.2% annual chance flood elevation has not been 

established, applicants must elevate or floodproof the structures an additional 2 feet 

above the BFE.

2. For critical actions in the 1% annual chance floodplain:

a. Applicants must elevate or floodproof the structures to the 0.2% annual chance flood 

elevation or an additional 3 feet above the BFE, whichever is higher. 

b. For those areas where the 0.2% annual chance flood elevation has not been 

established, applicants must elevate or floodproof the structures an additional 3 feet 

above the BFE.

3. For critical actions in the 0.2% annual chance floodplain, applicants must elevate or 

floodproof the structures to the 0.2% annual chance flood elevation or an additional 3 

feet above the BFE, whichever is higher. 

4. This policy does not affect non-critical actions involving structures that are within the 

0.2% annual chance floodplain but outside the 1% annual chance floodplain.

5. If a state, local, tribal, or territorial government, or federal agency has adopted a higher 

standard applicable to the specific project, FEMA will require the higher standard.

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D. COORDINATION WITH OTHER FEDERAL AGENCIES

Outcome: FEMA coordinates with other federal agencies when engaging with or 

implementing projects in the same area as another federal agency.

1. When multiple federal agencies are conducting, supporting (including funding), or 

permitting projects in the same geographic area, early coordination is essential to 

avoid the potential for conflicting standards being applied within the same geographic 

area or on the same project.

14 Under 44 CFR § 9.11(d)(3)(iii), the floodproofing option is limited to nonresidential structures. This limitation applies 

wherever floodproofing is referenced in this policy.

15 In coastal locations, there may be occasions in which the established 0.2% annual chance flood elevation is lower than 

the established 1% flood elevation. In those circumstances, applicants must elevate or floodproof the structures an 

additional 2 feet above the BFE.

16 Under 44 CFR § 9.11(d)(6), no action may be taken if it is inconsistent with the criteria of the National Flood Insurance 

Program (44 CFR part 59 et seq.) or any more restrictive Federal, State, or local floodplain management standards.
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a. Accordingly, when FEMA is funding an action with or in the same geographic area

as another federal agency, FEMA will coordinate with the applicable federal

agencies as early in the planning process as possible.

b. When coordinating with other federal agencies, FEMA may elect to use the

FFRMS approach of another federal agency to establish the vertical flood

elevation requirement.

2. In a declared major disaster, the Unified Federal Review (UFR) process offers

additional coordination opportunities for FEMA and other federal agencies. The

mission of UFR is to expedite and unify the process for completing environmental and

historic preservation reviews required for disaster recovery projects, while maintaining

the technical rigor and public participation associated with those reviews. This is done

by developing agreements and tools which assist Federal agencies in coordinating

their reviews to streamline the decision-making process and improve delivery of

disaster-related services and assistance. For more information on the UFR Process,

see FEMA’s website at Unified Federal Environmental and Historic Preservation

Review (UFR) Library.

E. NON-DISCRIMINATION AND EQUITY

Outcome: HMA is delivered in a non-discriminatory and equitable manner.

1. In accordance with section 308 of the Stafford Act; sections 503, 504 and 508 of the

Rehabilitation Act of 1973, as amended; and Title VI of the Civil Rights Act of 1964, all

HMA programs are administered in an equitable and impartial manner, without

discrimination on the grounds of race, color, religion, national origin, sex, age, disability,

English proficiency, or economic status. In addition, federal assistance distributed by

state and local governments is to be implemented in compliance with all applicable laws

and regulations.

2. FEMA has committed in its 2022-2026 Strategic Plan17 to pursuing the installation of

equity as a foundation of emergency management by (1) cultivating a FEMA that

prioritizes and harnesses a diverse workforce; (2) removing barriers to FEMA programs

through a people first approach; and (3) achieving equitable outcomes for those we

serve. These goals and FEMA’s definition of equity are consistent with Executive Order

13985.18

3. Certain HMA programs covered by this policy are also covered under the Justice40

Initiative, which aims to deliver 40% of the overall benefits of climate, clean energy,

affordable and sustainable housing, clean water, and other investments to

disadvantaged communities that are marginalized, overburdened, and underserved.19

17 See 2022-2026 FEMA Strategic Plan for additional information.

18 Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal

Government. 19 See FEMA Announces Programs Included in the Biden-Harris Administration’s Justice40 Initiative to Increase Equity,

Community Resilience (July 15, 2022) for additional information.
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The Justice40 Initiative was established pursuant to Executive Order 14008.20

MICHAEL M 

GRIMM

Digitally signed by 

MICHAEL M GRIMM

Date: 2022.12.07 13:11:41 

-05'00'

Michael Grimm

Deputy Associate Administrator (Acting)

Federal Insurance and Mitigation 

Administration, Resilience

Federal Emergency Management Agency

12/07/2022

Date

20 Executive Order 14008, Tackling the Climate Crisis at Home and Abroad.
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ADDITIONAL INFORMATION

REVIEW CYCLE

FEMA Policy FP-206-21-003-0001, Partial Implementation of the Federal Flood Risk 

Management Standard for Hazard Mitigation Assistance Programs, will be reviewed, reissued, 

revised, and/or rescinded within four years of the issue date.

AUTHORITIES

• Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5121-

5207, as amended

• Section 1366 of the National Flood Insurance Act (42 U.S.C. § 4104c).

• 44 CFR Part 9

REFERENCES

• Executive Order 11988, Floodplain Management

• Executive Order 13690, Establishing a Federal Flood Risk Management Standard and a

Process for Further Soliciting and Considering Stakeholder Input

• Executive Order 14030, Climate-Related Financial Risk

DEFINITION

Non-Critical Action: Non-critical actions are any actions that are not defined as a critical 

action in 44 CFR § 9.4. (See footnote 5 on page 1)

MONITORING AND EVALUATION

FEMA will closely monitor the implementation of this policy through coordination with regional 

and field staff, as appropriate, as well as interagency partners and state, local, tribal, and 

territorial stakeholders.

QUESTIONS

Direct questions to HMA Policy, Tools, and Training Branch at fema-hma-grantspolicy@fema.dhs.gov.