MITIGATION PLANNING: A HIGHER STANDARD
By Carolyn Sudduth
Hazard mitigation involves sustainable actions that lessen the impact of natural hazards on communities by adjusting the built environment to better withstand the elements. In order to be eligible for Federal Emergency Management Agency’s (FEMA) hazard mitigation assistance grant funding for mitigation projects, a local government must be a participant in a local mitigation action plan. This requirement has been in place since 2004, authorized by the Stafford Act as amended by the Disaster Mitigation Act of 2000 and codified in the 44 Code of Federal Regulations section 201.
Yet, because local officials have much on their plates already, mitigation planning has sometimes taken a back seat to more pressing immediate needs. Lately the responsibility of organizing the communities and creating mitigation plans has fallen to outside contractors, often leaving the communities with minimal hands-on participation or responsibility.
FEMA recognizes that without more active participation in the planning process, communities may never fully utilize the power of mitigation planning. To overcome the problem, FEMA is in the midst of retooling their guidance and has issued new review tools. The Regulation Checklist, which replaces the current FEMA Crosswalk, is used by both the Texas Division of Emergency Management (TDEM) and FEMA reviewers to grade whether or not a plan has met each element required per the 44CFR. Beginning June 1, 2012, TDEM requires that each plan submitted for review arrive with a completed Regulation Checklist. FEMA is expected to issue a manual this summer for plan developers to replace the current FEMA local mitigation planning guidance and how-to books. In the meantime, a Regulation Checklist form can be downloaded from the TDEM website.
Unlike the emergency operations plans, there is no template for a mitigation action plan. The Regulation Checklist is the most succinct source of information on how to organize both the planning process and the plan document. The reference to a higher standard is reflected in the need for each and every community to address its participation, local hazards, strategy, and maintenance of the plan. The plan does not have to be a highly technical document but rather a basic narrative of the planning process as undertaken by the locals, an identification of the hazards that will impact each community, a strategy by each community to mitigate those impacts, and a system within each community to use what was discovered through the process.
At any time, the mitigation section of TDEM probably has about 50 county or city plans in various stages of review and revision. TDEM encourages cities and special districts to join with the county to create county-wide plans. The goal is to have both the metropolitan areas and the lesser populated but high hazard areas covered by mitigation action plans, ensuring that FEMA hazard mitigation assistance grants will be available to those communities.
TDEM’s role is to work with the plan developers to create a document that FEMA will deem approvable. TDEM reviewers know what FEMA Region 6 reviewers find acceptable in meeting 44 CFR 401.6 compliance and work with the plan developers to revise their plans to meet compliance before the plans are submitted to FEMA. The review process necessitates collaboration and exchange between TDEM mitigation section staff and plan developers, which is why the review process is often lenthy. Plans must be submitted both hard and soft copy. FEMA also requires hard and soft copy when the state submits a plan to them.