PRE-DISASTER MITIGATION (PDM)

FEMA GRANTS AND PROGRAMS PRE-DISASTER MITIGATION (PDM) FEMA s Pre-Disaster Mitigation (PDM) program provides funds to States, U.S. Territories, tribes, and communities for hazard mitigation planning and for the implementation of mitigation projects prior to a disaster event. The PDM program provides a significant opportunity to raise risk awareness and reduce the Nation s disaster losses through predisaster mitigation planning and the implementation of feasible and cost-effective mitigation measures. The PDM program provides funding to reduce loss of life as well as damage and destruction to property from natural hazards. Summary of Findings The Analysis of Federal Requirements Team conducted cooperative discussions with 20 States regarding their perceptions of the PDM grant program. The majority (95%) of the respondents believed the PDM grant is a positive program and the program helps reduce the requirements for response through mitigation, thus allowing responders to focus on other threats. Each of the jurisdictions were asked to reply to a series of questions pertaining to reporting requirements, timeline requirements, grant guidance, grant approval process, resource requirements, and program summary issues. Reporting Requirements Of the States surveyed, the great majority responded the frequency of the reporting requirements was not a concern. The majority of the States believed there were no unnecessary reporting requirements associated with the PDM grant program. There were some concerns raised over the use of the electronic reporting system, in that it took too long and was not accessible at all times. The States offered the following suggestions to improve the reporting requirements: institute a Web-based system and substitute Grants.gov for the egrant system. They would also like to see the egrant system modified to allow local authorities access. One State raised concerns that it has to enter data for 200 sub-grantees. Timeline Requirements Most States strongly felt the timeline requirements are not acceptable for the program application. Complicating the short timeframes are the short notice, guidance coming out late, all three mitigation program s guidance released simultaneously, and the application period scheduled over the holidays. Many projects are complex and require professional engineering, letters of approval, and finding cost shares. Six months was recommended by one State for the application period. The majority (65%) of the States said the timeline requirements for financial reporting were acceptable. Other comments focused on the slowness of project approvals. AFR Final Report PDM 1 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

Grant Guidance The clear majority of the States believed the guidance is not overly lengthy. One of these favorable reporting States suggested that more definition of project eligibility is needed. One State called the guidance the most thorough and comprehensive of any mitigation program. The States, by a 4-to-1 margin, agreed the guidance is understandable, and a common theme from the States (90%) is that the guidance is very consistent year to year. The issue of timeliness brings out the strongest negative response. One State cited the National Environmental Policy Act (NEPA) review as a cause for the process being slow while others complained that it comes out too late and unnecessary confusion occurs when deadlines change midstream. Grant Approval Process Thirteen States (65%) expressed specific concerns over the length of the grant approval process, including NEPA reviews taking too long and too many stages in the process. Only 45% of the States believed the Peer Review process is a good process because it allows the States an opportunity to give input and see other funded projects. One State indicated it had improved in fiscal year 2007 because States were told why projects were disapproved. Resource Requirements Twelve of the States have identified a need for more personnel to administer the PDM program, while seven indicated the staffing levels were sufficient. States identified funding as an obstacle to obtaining full-time support for the program. Funding of personnel in States is hampered by the 5% maximum for Management and Administrative (M&A) of the total grant funding. It was recommended that States should be provided a minimum set-aside amount of funding (noncompetitive) to implement the planning program. This will allow plans to be started before the request for project funds have been approved and speed up the mitigation process. Program Summary Issues The large majority (95%) of States make a positive connection between mitigation and preparedness. Specifically, PDM removes people and property from floodplains. Many recommendations were offered focusing on application difficulties, time for actions and timeliness of decisions, funding, and transparency of the decision-making process. Some of these recommendations included the following: Award project grants in a timely manner and use the Concurrence of Understanding agreement similar to the Hazard Mitigation Grant Program (HMGP) so that limited activities may proceed. Also, waiting a year or more for NEPA review slows the process unacceptably. Applications for the Flood Mitigation Assistance (FMA) and Repetitive Flood Claims (RFC) programs should follow approximately 2 weeks after the PDM for further review announcements are made. This would allow eligible, but unsuccessful, applications to be modified and entered for potential consideration under the FMA and RFC programs. Impact of Federal Program Requirements PDM 2 AFR Final Report FEMA Grants and Programs October 2007

Provide definitive feedback. Technical assistance should include trying to make all applications better and more competitive. Lastly, national competition is not having a positive result. The application and planning process is too difficult, the decision-making process too long, the availability and timing of local budget match funds take many communities out of the competition, and, of much concern, the funding decisions do not appear consistent. Program Requirements Impacting State Emergency Management/Homeland Security Agencies 1. Reporting Requirements a. Is the frequency of the reporting requirements a concern of the State? Yes 1 No 18 Unanswered 1 Of the States responding, 18 responded the frequency of the reporting requirements was not a concern. Only one State felt that quarterly reports were too much. b. Are there any unnecessary reporting requirements? Yes 3 No 16 Unanswered 1 One State felt there are too many ad hoc requests for information. Another felt that egrant reporting should be eliminated. c. Are any of these reporting requirements covered in other Federal program requirements? Yes 3 No 16 Unanswered 1 One State felt they were also covered in the U.S. Army Corps of Engineers (USACE), NEPA, and the Department of Justice. d. Is the electronic reporting submittal process for this program a concern? Yes 6 No 14 The assessment tool collected data in four categories: 20% of the respondents said it takes too long to input data. 25% indicated they had system availability issues. AFR Final Report PDM 3 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

20% indicated they have lost data previously entered. 10% have experienced the system timing out during use. In addition, States pointed out the egrant system is slow and cumbersome. Another said it involves too much paper and the fact that it is not Web-based is a problem. However, one State pointed out that once a State is familiar with the system, it is actually user-friendly. e. Suggested improvements. The States offered the following suggestions to improve the reporting requirements: Institute a Web-based system. Substitute Grants.gov for the egrant system. Modify the egrant system to allow local authorities access. Presently, one State complained it has to enter data for 200 sub-grantees. 2. Timeline Requirements a. Are timeline requirements acceptable for submitting the program application? Yes 4 No 16 Most States strongly felt the timeline requirements are not acceptable for the program application. Complicating the short timeframes are the short notice, guidance coming out late, all three mitigation program s guidance released simultaneously, and the application period scheduled over the holidays. Many projects are complex, which requires engineering, letters of approval, and finding cost shares. Six months was recommended by one State for the application period. b. Are timeline requirements acceptable for Investment Justification plans? Yes 4 No 1 N/A 15 No other comments were received. c. Are timeline requirements acceptable for financial reporting? Yes 14 No 3 Unanswered 3 A majority of the States said the timeline requirements for financial reporting were acceptable. No other comments were received. Impact of Federal Program Requirements PDM 4 AFR Final Report FEMA Grants and Programs October 2007

d. Are timeline requirements acceptable for program reporting? Yes 16 No 3 Unanswered 1 Most States said the timeline requirements for program reporting were acceptable. One State suggested semi-annual or annual reports. e. Are there other timeline issues? Application approval has been very slow. f. What recommended improvements do you have regarding the timeline requirements? Recommended improvements included the following: Provide longer timeframes to apply. Consider keeping open the application period all year. Proactively advise States when the guidance is released. Schedule RFC and FMA application periods after PDM. Establish consistent application windows for all the mitigation programs. Allow FEMA Regions to approve extension requests. Provide timeline flexibility when States are having disasters. Simplify application process and speed up approval decisions. 3. Grant Guidance a. Is the grant guidance too lengthy? Yes 7 No 13 The clear majority of the States believed the guidance is not overly lengthy. One of these favorable reporting States suggested an improved definition of project eligibility is needed. One State called the guidance the most thorough and comprehensive of any mitigation program. Another suggested it is far too overwhelming for sub-grantees. b. Is the grant guidance understandable? Yes 16 No 4 The States, by a 4-to-1 margin, agreed the guidance is understandable. One State commented that it gives a good review. Of the four States that found the guidance difficult to AFR Final Report PDM 5 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

understand, two cited the problems that local officials have dealing with it, as it is vague and not concise. c. Is the grant guidance consistent? Yes 18 No 2 A common theme from the States is that the guidance is very consistent year to year. One State mentioned this is not true with the HMGP. Two States commented that the rules change yearly; therefore, the guidance is inconsistent. d. Is the grant guidance timely? Yes 7 No 13 Of the four questions posed to the States regarding grant guidance, the issue of timeliness brings out the strongest negative response. One State cited the NEPA review as a cause for the process being slow. Others complained that it comes out too late, and unnecessary confusion occurs when deadlines change midstream. e. Are there other grant guidance issues? Other grant guidance issues included the following: There is not enough time between receipt of guidance and the application deadline. Overlapping timelines among mitigation grants overload staff and preclude the submittal of projects for other grant programs where the applicant fails to be selected for a PDM. Guidance is weak in the Public Works, Transportation, and Information Sharing Capability sections. Grants.gov is confusing to applicants. Projects should be identified ahead of time. The Benefit-Cost Analysis (BCA) program is difficult to use and should be made simpler. f. Any recommended changes for grant guidance improvement? Recommended changes to grant guidance included the following: FMA and RFC should follow PDM, as PDM needs at least 120 days from publication of guidance to application deadline. Impact of Federal Program Requirements PDM 6 AFR Final Report FEMA Grants and Programs October 2007

Create a consistent timeframe for publication of grant guidance and annual deadlines so applicants can prepare and meet suspense dates. FEMA guidance, where possible, should remain fixed. Spanish language conversion for grants would be helpful to Spanish-speaking jurisdictions. Offer more training on the egrant system. Use one application for FMA, PDM, and HMGP. 4. Grant Approval Process a. Do you have any concerns regarding the length of the grant approval process? Yes 11 No 8 Unanswered 1 Eleven States expressed specific concerns regarding the length of the grant approval process. Their concerns were in three areas: Overall length of approval process is too long (five States). NEPA or environmental review takes too long (three States). Too many stages in the process (three States). b. If used, is the Peer Review an acceptable process? Yes 9 No 5 Unanswered 6 Only 45% indicated the Peer Review process is a good process. States get an opportunity to give input and see other funded projects. One State indicated the process was better this year since the State was told why projects were disapproved. States responses also included the process needs more local government participation and the process is not consistent. c. Are there other grant approval process issues? Over half (60%) of the States indicated they had other grant approval process issues with the PDM grant program. Examples of their comments follow: There is an inconsistency in the national review from application to application and year to year. The BCA is a problem; FEMA should pick an engineering firm for consistency of modeling decisions and training. AFR Final Report PDM 7 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

In PDM, there is a meaningless volunteer participation form that is hard to complete because it requires the State to track down individual grant participants and get their signature. The level of project design required slows the process. There are too many front-loaded requirements (e.g., the applicant has to expend funds prior to project approval). The reason for non-approval is rarely given. d. Do you have any recommended improvements to the grant approval process for the program? Almost half (45%) of the States recommended improvements to the PDM grant approval process. Specific comments included: The Federal Government needs to provide additional funding for applicants to do preliminary permitting and studies. DHS/FEMA needs to fix the disconnect (inconsistency) between national and regional level reviews. Best practices and decisions on grant results need to be shared with everyone so requestors and reviewers alike learn from the experience and improve both requests and results. There should be feedback to the applicant when their application is disapproved. There needs to be more initial clarity on application requirements, and the applications need to be evaluated on those criteria. FEMA needs to apply more resources to this grant program. 5. Resource Requirements a. How many full-time equivalents (FTEs) are required to administer this program? The FTE numbers below summarize the range of personnel requirements identified by State population. FTE for the five large population States (greater than 10 million): Range 1.7 to 6 FTE for the eight medium population States (3 to 10 million): Range 0.8 to 5 FTE for the seven small population States (less than 3 million): Range 1 to 5 Impact of Federal Program Requirements PDM 8 AFR Final Report FEMA Grants and Programs October 2007

b. Number of FTEs currently assigned to this program. The FTE numbers below summarize the range of personnel currently assigned to this program by population size. FTE for the five large population States (greater than 10 million): Range 1 to 2.5 FTE for the eight medium population States (3 to 10 million): Range 0.5 to 3.5 FTE for the seven small population States (less than 3 million): Range 0.1 to 1 The majority (12) of the States have identified a need for more personnel to administer the PDM program. Seven States felt the manning levels were sufficient to administer the program. c. If the FTEs required to administer this program are less than the FTEs currently assigned, why is there a difference? Several variables affect the difference between the number of FTEs assigned to the program and the number required. In those States that had a requirement for additional personnel, the primary reasons are noted below. This is a 3-year cycle program. With this type program, management problems are compounded in the second and third year as late approval causes interruption in the flow of the funding and the subsequent authority to hire. States identified funding as an obstacle to obtaining full-time support to the program. Funding of personnel in States is hampered by the 5% maximum for M&A of the total grant funding. Some States cannot hire staff with available Federal funds because of State-imposed hiring caps. This results in money being available for temporary personnel/contractors, but not for hiring full-time personnel. Contractors are used to offset personnel requirements as they can be hired on a yearly contract and are not affected by State personnel caps. States do not have the matching funds even though Federal dollars are available. d. Are additional non-personnel resources needed to accomplish this program? Yes 10 No 10 Additional non-personnel resources are required for the successful accomplishment of the PDM program. These resources include the following: Courses previously taught at the Emergency Management Institute (EMI), such as Mitigation Grants Management and BCA are required. AFR Final Report PDM 9 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

The States need funding for outreach workshops to explain to disaster-prone area residents the options available for predisaster mitigation. States have a need for Geographic Information System equipment and training to provide digitized flood mapping. States identified several training programs such as Web-based equipment and media training as being important to the operation and administration of the PDM program. States have identified travel as a non-personnel requirement. To administer the program properly, additional travel funds to assist various local jurisdictions are needed. Technical assistance for doing the BCA would be extremely helpful to the States. e. Other issues related to the personnel/resources for this program. The States have identified other related issues that affect and are related to the program: The States can administer this program, but they need additional personnel to do it effectively. Small towns and villages cannot fully use this program as they have limited resources and lack the necessary skills and equipment for the complicated BCA and application processes. States would like outreach materials developed in coordination with the States. Grant funds from the Emergency Management Performance Grant (EMPG) are being used to finance personnel needs for the PDM grant, which, in turn, affects the overall number of personnel available. Field work is being done with EMPG funds. f. Recommended improvements for the personnel/resources for this program. The States recommended several important considerations for the PDM program that could improve personnel and other resourcing: The States should be provided a minimum set-aside amount of funding (noncompetitive) to implement the planning program. This will allow plans to be started before the request for project funds have been approved and speed up the mitigation process. FEMA needs to provide better training on the egrant program. Courses previously taught at EMI, such as Mitigation Grants Management and BCA need to be reinstituted or alternate training methods need to be provided. An increase in M&A from 5% to a higher amount would help to alleviate the manpower shortage that exists in administering the grant. Impact of Federal Program Requirements PDM 10 AFR Final Report FEMA Grants and Programs October 2007

The program software is not user-friendly, and a better system should be created to query and manipulate the data. It is very difficult to determine whether properties are eligible for PDM, especially the determination of insurance. 6. Program Summary Issues a. Does this program improve preparedness in your State? Yes 19 No 1 The large majority of States make a positive connection between mitigation and preparedness. Comments included the reduction in requirements for response allows responders to focus on other threats. It reduces the potential need to evacuate people from vulnerable locations. Specifically, PDM removes people and property from floodplains. b. Does this program support your State s Homeland Security Strategy? Yes 16 No 4 The majority of States replied positively saying the program improves citizen knowledge and preparedness. It helps provide situational awareness and shelters for all disasters. A few States said that mitigation, per se, was not part of their State Strategy although deter, prevent, and protect were key parts of it. c. Does the program support the National Preparedness Goal? Yes 17 No 2 Unanswered 1 The majority of States believed the PDM program directly supports the National Preparedness Goal. Three disagreed or did not believe mitigation is, in fact, part of the Goal. d. Are there any program requirements or items related to this program not previously discussed? Yes 5 No 15 The issues that were raised focused on the difficulty of applying and that local governments do not have the time or skill in spending the effort and committing funds for programs that may never be approved. The decisions are not transparent nor explained and do not appear consistent. The planning requirements are difficult to understand, and funding levels from year to year are inconsistent. AFR Final Report PDM 11 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

e. What recommendations for improvement does the State have for this program? Many recommendations were offered focusing on application difficulties, time for actions and timeliness of decisions, funding, and transparency of the decision-making process. Specific recommendations included the following: Structures that have flooded repeatedly or are in the floodway should qualify for funding. These structures should not even need a BCA. Award project grants in a timely manner and use the Concurrence of Understanding agreement similar to HMGP so that limited activities may proceed. Also, waiting a year or more for NEPA review slows the process unacceptably. Applications for the FMA and RFC programs should follow after the PDM for further review announcements are made. This would allow good but unsuccessful applications to be modified and entered for FMA and RFC programs. Provide definitive feedback. Technical assistance should include trying to make all applications better and more competitive. The egrant system cannot be used by communities with only dial-up access systems. Consideration should be given to alternatives. National competition is not producing the positive results desired. The application and planning process is too difficult for some States to understand, the decisionmaking process too long, the availability and timing of local budget match funds take many communities out of the competition, and, of much concern, the funding decisions do not appear consistent. Move the funding and process closer to the community need; set parameters for regional, State, and community criteria; and let the process proceed. The Federal role should be policy and receiving all the good reports of success. f. Has the State identified any other requirements from Federal agencies other than DHS and FEMA that can be associated with or related to this program? USACE requires a NEPA report. Environmental Protection Agency: NEPA and the National Historic Preservation Act require review and approval of projects. Impact of Federal Program Requirements PDM 12 AFR Final Report FEMA Grants and Programs October 2007

PDM PROGRAM Y/N COUNT SUMMARY WORKSHEET Summary Small States (8 Sites Surveyed) Medium States (7 Sites Surveyed) Large States (5 Sites Surveyed) # AFR Impact/Response (Template 3) Y/N Criteria Yes No N/A U Yes No N/A U Yes No N/A U Yes No N/A U 10. Reporting Requirements A. Is the frequency of the reporting requirements a concern of the State? 1 18 1 1 7 0 0 6 1 0 5 0 C. Are there any unnecessary reporting requirements? 3 16 1 2 6 0 0 6 1 1 4 0 E. Are any of these reporting requirements covered in other Federal Program requirements? 3 16 1 2 6 0 0 6 1 1 4 0 G. Is the electronic reporting submittal process for this program a concern? 6 14 0 3 5 0 2 5 0 1 4 0 11. Are Timeline Requirements acceptable for submitting: A. The application for this program? 4 16 0 1 7 0 2 5 0 1 4 0 C. Investment Justification plan? 4 1 15 0 1 1 6 0 2 0 5 0 1 0 4 0 E. Financial reporting? 14 3 3 6 1 1 3 2 2 5 0 0 G. Program reporting? 16 3 1 6 2 0 5 1 1 5 0 0 12. Is the Grant Guidance: A. Too lengthy? 7 13 0 4 4 0 3 4 0 0 5 0 C. Understandable? 16 4 0 7 1 0 5 2 0 4 1 0 E. Consistent? 18 2 0 7 1 0 6 1 0 5 0 0 G. Timely? 7 13 0 3 5 0 2 5 0 2 3 0 13. Grant Approval Process: A. Do you have any concerns regarding the length of the Grant approval process? 11 8 1 4 4 0 3 3 1 4 1 0 C. Is used, is the Peer Review an acceptable process? 9 5 6 4 1 3 3 2 2 2 2 1 14. Resource Requirements: E. Are additional non-personnel resources needed to accomplish this program? 10 10 0 5 3 0 3 4 0 2 3 0 15. Program Summary Issues: A. Does this program improve preparedness in your State? 19 1 0 8 0 0 7 0 0 4 1 0 C. Does this program support your State s Homeland Security Strategy? 16 4 0 7 1 0 6 1 0 3 2 0 E. Does this program support the National Preparedness Goal? 17 2 1 8 0 0 6 0 1 3 2 0 G. Are there any program requirements or items related to this program not previously discussed? 5 15 0 2 6 0 2 5 0 1 4 0 TOTALS 186 164 15 15 81 61 6 4 60 58 5 10 45 45 4 1 AFR Final Report PDM 13 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs

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