ASFPM Board Passes Resolution Outlining Deficiencies in BRIC Program, Makes Recommendations for Improvements

An exceedingly complex application process, a significant bias toward large infrastructure projects, a lack of transparency in the selection process, and proportionally less money available in state set-asides.

These are just some of the concerns identified in a resolution unanimously approved by the ASFPM Board of Directors at its November 10 meeting. Nearly four pages in length, the resolution methodically outlines what the association believes are shortcomings of FEMA’s new Building Resilient Communities and Infrastructure (BRIC) grant program and makes detailed recommendations on how the program could be improved.

Fiscal Year 2020 was the first year for BRIC. The pre-disaster hazard mitigation program replaced the PreDisaster Mitigation (PDM) program and upped funding to $500 million. Although ASFPM was cautiously optimistic that BRIC would routinely fund flood mitigation efforts for buildings, like elevation, buyouts, and small floodproofing projects, after the FY2020 grant winners were announced, it was clear that would not be the case.

“Most of the traditional flood mitigation projects as well as mitigation planning and capacity building grants were funded through the state set aside, not from the competitive grants,” ASFPM’s Larry Larson wrote in his Policy Matters column in August. “Especially discouraging is that state priorities for mitigation grants were replaced with FEMA priorities, which seem to favor large infrastructure projects.”

The resolution notes that FEMA was granted significant discretion to shape BRIC and in the end it created a program with a significantly different focus and priorities—including a focus on community infrastructure and lifelines as well as FEMA pre-disaster mitigation priorities, as compared to the legacy PDM program. In fact, soon after the law was changed in 2018 as part of the Disaster Recovery Reform Act, ASFPM spoke numerous times to FEMA leadership detailing concerns and opportunities as the BRIC program was being created. 

“Two primary concerns we had at the time were the loss of focus on traditional flood mitigation —techniques that we know are effective—and the need to have more stable and enhanced funding for state mitigation programs which could, in turn, result in much greater capacity to provide technical assistance to communities,” said Chad Berginnis, ASFPM’s Executive Director.  “Realizing that the formula for BRIC could mean dramatically more funding in the future, especially in significant disaster years, we knew early on that there needed to be much more capacity nationwide to apply for, manage, and distribute future BRIC funds. ASFPM suggested modeling a program, that would be funded under BRIC, based on the successful Community Assistance Program.”

“CAP has made a real difference in our nation’s capacity to administer the floodplain management part of the National Flood Insurance Program (NFIP) and it wouldn’t be difficult to do the same for state mitigation programs so that they could more effectively manage BRIC and other FEMA hazard mitigation programs,” he said.   

Resolution Outlines Concerns with BRIC

During the months following the announcement of FY 2020 selections for funding, ASFPM continued to hear from numerous members who were unhappy with how things played out in the BRIC program’s first year and the association felt it was important to take additional action.

“An official resolution with specific recommendations helps elevate the discussion and demonstrates both the seriousness of the issue and our willingness to work with FEMA to help improve this important program,” said Berginnis.

Some of the key concerns with BRIC that were identified in the resolution:

• A proportionally significant reduction in the state set aside amount when considering the total funding available.
• Significant limitations on the eligibility of mitigation planning funding (including a complete disallowance of mitigation planning projects from the competitive grants).
• A complex application process, which makes it difficult for disadvantaged communities to apply.
• A significant bias toward large-scale infrastructure projects rather than more traditional “incremental” hazard mitigation projects.
• An award bias toward coastal communities vs. inland communities ($474.6 million awarded for projects in coastal communities vs. only $27.3 million for non-coastal projects).
• More dollars and projects went to wealthier, greater resourced communities rather than to less wealthy communities with fewer resources.
• A review of the grant projects that have been identified for further review demonstrates that FEMA did not prioritize vulnerable communities even though it expressed a desire to do so.

ASFPM leadership worked with a handful of members of its Flood Mitigation Committee in developing the resolution. Since sharing the resolution, the feedback has been overwhelmingly positive. Ron Davis, CFM, with the Illinois Office of Water Resources, wrote in an email: “This captures what I have been hearing from the locals about the program. Many feel left out and don’t see a reason to keep applying.” Like the rest of the Midwest, Illinois can expect to see very little FY 2020 funding from BRIC, with only a 0.6% application success rate, according to analysis from Headwaters Economics. 

Recommendations for Improving BRIC

The resolution features seven recommendations for how BRIC can be improved. We’re outlining them briefly here, but encourage you to download the resolution to read them in their entirety.

• FEMA should allow states, communities, tribes, and territories decide which projects are awarded.
• FEMA should minimize adding its priorities to BRIC funding.
• BRIC competitive grants should include eligibility for mitigation planning and capacity building projects.
• FEMA should adjust the BRIC grant scoring criteria involving building codes to ensure consideration of non-building code standards that have equal or higher success in reducing overall hazard risk.
• The BRIC grant selection process should be made more transparent.
• FEMA should continue to simplify the grant program processes so that more applications can be submitted by less resourced communities, and to streamline program delivery.
• FEMA should use BRIC funding to create a program, similar to FEMA’s Community Assistance Program State Services Support Element (CAP-SSSE).

ASFPM shared the resolution with FEMA in mid-November and is looking forward to engaging with FEMA, Congress, and partner organizations to build support for and make improvements to the BRIC program. 

Read the resolution.

This article appeared in the December issue of News & Views. Download the entire issue.