Course Overview, Course Goal, and Objectives

This course will provide an overview of Public Assistance hazard mitigation project eligibility. By the end of the course, State, Local, Tribal, and Territorial Applicants and Recipients will be able to understand all aspects of Section 406 Mitigation of the Robert T. Stafford Act (sometimes referred to as Public Assistance or PA Mitigation)

Upon successfully completing the course, you will be able to:
  • Define Section 406 Mitigation
  • Explain which types of projects are eligible for FEMA Public Assistance grant funding under Section 406 authority
  • Identify the benefits and opportunities to reduce repetitive disaster losses by pursuing projects authorized under Section 406 Hazard Mitigation
  • Discuss examples of potential mitigation work across damage categories C through G (Permanent Work)
  • Explain the various methods to determine cost effectiveness of hazard mitigation proposal eligibility
Lesson 1 Overview and Objectives

This lesson introduces hazard mitigation. It provides an overview of the different hazard mitigation programs authorized under the Robert T. Stafford Act and discusses common Section 406 Hazard Mitigation projects for Permanent work.

At the end of this lesson, participants will be able to:
  • Identify the administrative requirements of the course
  • State the goals and objectives of the course
  • Define hazard mitigation as it relates to Section 406 of the Stafford Act
  • Discuss the types of mitigation measures eligible for Public Assistance funding under Section 406 of the Stafford Act
Hazard Mitigation

Hazard mitigation is defined as any sustained action taken to reduce or eliminate long-term risk to people and property from natural hazards and their effects. Merely repairing at-risk facilities to their pre-disaster condition does not protect the community from future disaster damages or reduce long-term costs.

Mitigation improvements should always be considered in the rebuilding process. FEMA has the authority to provide Public Assistance funding for cost-effective hazard mitigation measures for facilities damaged by an incident.*

*Robert T. Stafford Act 406(e), 42 U.S.C. 5172 (e), and 44 C.F.R. 206.226(e).

The FEMA Disaster Recovery Center in North Port used storm shutters to mitigate the destructive winds of Hurricane Charley.
Why Mitigate?

As disasters have grown in frequency and severity, the costs of response and recovery have escalated to unsustainable levels. Nationwide natural disasters cost over $50 billion each year.

The most effective way to reduce potential losses is through disaster preparedness and mitigation. Mitigation can reduce excessive losses by:

  • Breaking the disaster-rebuild-disaster cycle
  • Strengthening existing infrastructure and facilities
  • Addressing natural hazards
Hazard Mitigation Funding (1 of 2)

FEMA provides hazard mitigation funding under both the Public Assistance and Hazard Mitigation Assistance programs. These programs have different eligibility criteria, procedures, and timelines for implementation.

National Flood Insurance Act of 1968 NFIA

Hazard Mitigation Assistance 

Non-Disaster Related Programs

Stafford Act Section 203

Hazard Mitigation Assistance 

Non-Disaster Related Programs

Flood mitigation for insured propertiesPre-Disaster Mitigation: Multi-hazard project-specific
Hazard Mitigation Funding (2 of 2)

FEMA provides hazard mitigation funding under both the Public Assistance and Hazard Mitigation Assistance programs. These programs have different eligibility criteria, procedures, and timelines for implementation.

Stafford Act Section 406

Public Assistance Disaster-Related Programs

Stafford Act Section 404

Public Assistance Programs-Disaster-Related Programs

Public Assistance: Mitigation of incident-caused damageHazard Mitigation Grant Program: Multi-hazard statewide mitigation

Funding: Available for disaster-damaged facilities only*

*See exceptions for Alternative Projects in Chapter 8, Section IV.B.2 of the Public Assistance Program and Policy Guide v4

Funding: Available for damaged and non-damaged facilities based on a percentage of dollars obligated to the Public Assistance and Individual Assistance programs
Section 404 vs Section 406

The different hazard mitigation programs are authorized by separate sections of the Robert T. Stafford Act. The Hazard Mitigation Grant Program is authorized by Section 404. Hazard mitigation funded by the Public Assistance Program is authorized by Section 406.

Section 406 focuses on mitigation measures for facilities that have actually been damaged in a particular disaster. Section 404 has a broader scope and funds mitigation projects for both damaged and non-damaged facilities.

404 Mitigation406 Mitigation
  • Hazard Mitigation Branch/State Program
  • May apply statewide
  • Includes preventative measures
  • Public and private properties
  • Benefit-Cost Ratio > 1.0
  • Limited funding
  • Public Assistance Program
  • Applies only to declared counties
  • Includes only damaged facilities
  • Public and Private Non-Profit facilities only
  • 15% rule, 100% rule, or Benefit-Cost Analysis
  • No program funding limits
Section 404: Hazard Mitigation Grant Program

Section 404 assists in implementing long-term hazard mitigation planning and projects following a Presidential major disaster declaration. It provides funds to States, Territories, Tribes, and local communities to protect public or private property through various mitigation measures.

Section 404 Recipients have the primary responsibility for prioritizing, selecting, and administering state and local hazard mitigation projects. Because Recipients have different approaches to executing the Hazard Mitigation Grant Program, you should consult with the local government in question to learn more about Section 404 procedures in a particular case.

For more details, read FEMA's Hazard Mitigation Assistance Guidance or visit the FEMA Hazard Mitigation Assistance page.

A house elevated on pylons, with plywood storm shutters protecting its windows.
Combining Funding

Applicants may use both 406 and 404 mitigation funds to implement mitigation measures on the same facility, but not for the same work. Funds from one of these mitigation programs also cannot be used to meet the non-Federal cost share of work funded under the other mitigation program.

A combination of Sections 404 and 406 funding may be appropriate where:

  • Section 406 hazard mitigation funding is used to provide protection to the parts of the facility that were damaged by the event
  • Section 404 hazard mitigation funding is used to provide protection to the undamaged parts of the facility
The ground below this street paving was washed away by Hurricane Ike's storm surge, causing the road to collapse. Miles of this Galveston Island highway are destroyed and completely washed away.
Combined Funding Case Study (1 of 3)

A FEMA Site Inspector determined that a 3-mile section of a 10-mile long storm water pipe was damaged during a Presidentially declared disaster.

Damage to a road caused by flood water. The road collapsed around a drainage pipe that ran under it.
Combined Funding Case Study (2 of 3)

Repair and mitigation of the 3 miles of damaged pipe would be eligible for Public Assistance funding and Section 406 Hazard Mitigation funding.

These damages and the mitigation proposal for the 3 miles of pipe would be documented in the Public Assistance Grants Portal. The Applicant can begin work on the repair and mitigation of the 3 miles of pipe before the project is approved.

A staging area where different types of pipe are laid out
Combined Funding Case Study (3 of 3)

The additional 7 miles of undamaged (or undamaged by the declared event) may be eligible for Section 404 Hazard Mitigation funding.

The Applicant would have to follow the State's application process for these funds and can only begin mitigation of the 7 miles of undamaged pipe once the application is approved.

A FEMA Public Assistance Site Inspector reviews repairs made to corrugated pipe drain system damaged during the severe storm and flood in September 2009.
Common Hazard Mitigation Measures

Hazard mitigation can only be applied to permanent work. Some examples of common hazard mitigation measures include:

  • Increasing the number or size of drainage structures to prevent roadway destruction and washout
  • Adding wing walls, riprap, stone, gabion baskets (wire mesh filled with stone), or bioengineering to control erosion
  • Elevating facilities above the flood elevation
  • Securing equipment with hurricane straps
  • Elevating electrical transformers to avoid utility damage
A construction crew builds Gabion walls to stabilize the road bank and creek along Route 10 in New York state that was washed away by Hurricane Irene.
Hazard Mitigation Example: Elevation of Standby Generators

Elevate or dry flood-proof components or systems vulnerable to flood damage, including:

  • Equipment controls
  • Electrical panels
  • Heating, ventilation, and air conditioning/machinery rooms
  • Emergency generators
  • Fuel tanks

When wiring cannot be elevated, replace with equipment suitable for submerged applications.

Left: A CAT generator at ground-level. Right: A generator elevated on a concrete platform.
Hazard Mitigation Example: Low Water Crossings

Bridges vulnerable to flood damage can sometimes be replaced with low-water crossings if traffic counts are low. As the term suggests, low-water crossings are dry when water levels are low but likely to submerge during floods, becoming unsafe for traffic.

A car driving over a flooded low-water crossing. A low-water bridge crossing a body of water during non-flood conditions.
Hazard Mitigation Example: Hurricane Winds

Hurricane winds and wind-blown debris can cause significant damage to structures. If windows are broken in high winds, the building's contents become vulnerable to damage.

Storm shutters are one of the most common methods of protection against damage from high winds. They are fastened over windows or other vulnerable openings to protect them and can be made from materials such as corrugated metal, plastic, wood or plywood, and polycarbonates.

Corrugated metal hurricane shutters on a building in Wrightsville, NC.
Lesson 1 Summary

This lesson introduced hazard mitigation. It provided an overview of the different hazard mitigation programs authorized under the Stafford Act and discussed common Section 406 Hazard Mitigation projects for Permanent work.

In this lesson, participants learned how to:
  • Identify the administrative requirements of the course
  • State the goals and objectives of the course
  • Define hazard mitigation as it relates to Section 406 of the Robert T. Stafford Act
  • Discuss the types of mitigation measures eligible for Public Assistance funding under Section 406 of the Robert T. Stafford Act
Lesson 2 Overview and Objectives

This lesson addresses what measures can be taken to mitigate the risks and effects of different types of hazards. It also identifies resources available for Applicants and Recipients to learn more about developing mitigation proposals, including innovative ways to use Section 406 Hazard Mitigation funding.

In this lesson, you will learn how to:
  • Identify and define the threats and hazards that cause damage to infrastructure
  • Describe how to minimize future damage
  • Identify resources available for applicants and recipients to learn more about developing mitigation proposals, including innovative ways for using 406 mitigation funding
Threats and Hazards

A wide range of threats and hazards can cause an incident and result in damage that needs to be repaired.

For an Emergency Declaration, an incident is defined as any instance that the President determines warrants supplemental emergency assistance to save lives and protect property and public health and safety, or to lessen or avert the threat of a catastrophe.

For a Major Disaster Declaration, an incident is defined as any natural catastrophe, or regardless of cause, any fire, flood, or explosion.

Several Road Closed barricades block Highway 6 in Houston.
The Three Types of Threats and Hazards

FEMA organizes threats and hazards into three groups, so they can be better understood and addressed. They are:

  • Natural hazards, which result from acts of nature
  • Human-caused incidents, which result from the intentional actions of an adversary
  • Technological hazards, which result from accidents or the failures of systems and structures
Flooding in Puerto Rico. Rescue workers standing on twisted girders from the World Trae Center. A HAZMAT rescue team training in protective gear.
Types of Hazards
Below are some examples of types of hazards:

Natural

Human-caused

Technological

  • Avalanche
  • Disease outbreak
  • Drought
  • Earthquake
  • Epidemic
  • Flood
  • Hurricane
  • Landslide
  • Tornado
  • Tsunami
  • Volcanic eruption
  • Wildfire
  • Wind
  • Winter storm
  • Civil disturbance
  • Cyber incident
  • Sabotage
  • School violence
  • Terrorist act
  • Airplane crash
  • Dam/levee failure
  • Hazardous materials release
  • Power failure
  • Radiological release
  • Train derailment
  • Urban conflagration
Hazard Mitigation Measures: Category C - Roads and Bridges
  • Repair of roads, bridges, and associated features, such as shoulders, ditches, culverts, lighting, and signs
  • Mitigation examples:
    • Adding a headwall and wing walls to an existing culvert after a flooding event to prevent future damage to the road surface
    • Increasing the size of a culvert to prevent future overtopping/washout of the culvert
A headwall and wing wall with a tractor and workers in the background.
Hazard Mitigation Measures: Category D - Water Control Facilities
  • Repair of drainage channels, pumping facilities, and some irrigation facilities
  • Repair of levees, flood control dams, and flood control
    • The eligibility of these facilities is dependent upon the Applicant providing documentation to establish the pre-disaster capacity and maintains the facility on a regular schedule
  • Mitigation examples:
    • Elevating equipment and controls of pumping facilities above flood elevations
    • Placing riprap at an irrigation canal to prevent a washout
From below, emergency personnel inspect two large pipes that are part of the All American Canal.
Hazard Mitigation Measures: Category E - Buildings and Equipment
  • Repair or replacement of buildings, including their contents and systems, heavy equipment, and vehicles
  • Mitigation examples:
    • Building floodwalls around buildings to prevent flooding
    • Reinforcing buildings with shear walls to withstand seismic forces in an earthquake
A flood wall protecting a hospital from flooding.
Hazard Mitigation Measures: Category F - Utilities
  • Repair of water treatment and delivery systems, power generation facilities and distribution facilities, sewage collection and treatment facilities, and communications
  • Mitigation examples:
    • Elevating sewer system access covers to the hydraulic grade line
    • Replacing flooded pumps with submersible pumps
A new pump at a sewage station
Hazard Mitigation Measures: Category G - Parks, Recreation, and Other
  • Repair and restoration of parks, playgrounds, pools, cemeteries, mass transit facilities, beaches, and marinas
  • This category is also used for any work or facility that cannot be adequately characterized by Categories C-F
  • Mitigation examples:
    • Elevating filter and pump equipment for pools
    • Replacing wood piers or hardening with steel bumpers
A crowd of people in the water at a community swimming pool.
Comprehensive Mitigation

It is good practice to implement mitigation measures that fully address the hazard that caused the damage to the facility. Mitigation measures for a damaged facility don't have to be limited to addressing only the specific components of the facility that were damaged.

Construction crews work on the frame of a new building
Comprehensive Mitigation - How to Apply this Policy

Mitigation measures MUST mitigate the damaged portion(s) of a facility, but they may also protect portions that are undamaged.

  • A floodwall built to protect a school with flood damage to its gymnasium may protect the entire building, including undamaged classrooms.
Building windows from Tectra roofing group
Similar Examples of Comprehensive Mitigation Measures

Constructing floodwalls around damaged facilities

  • Installing new drainage facilities (including culverts) along a damaged road
  • Dry floodproofing both damaged and undamaged buildings that contain components of a system that are functionally interdependent
Building windows from Tectra roofing group
Comprehensive Mitigation Example: Hurricane

Components that could be damaged but aren't immediately apparent:

  • Electrical systems, insulation, flooring

Measures that can be taken to prevent or reduce damage:

  • Wet-proofing, dry-proofing, installation of backflow devices
  • Hurricane straps (roof-framing and walls), securing roof sheathing, anchoring ancillary structures to their foundations
  • Strengthening window glass, installing hurricane shutters
  • Replacing gable vents, reinforcing entry doors

Other hazards the above mitigation methods are effective against:

  • Flooding, storm surge, hydrodynamic forces, debris impact forces, high winds

 

 

Building windows from Tectra roofing group
Bio-Engineering in Hazard Mitigation

Advantages of bioengineering solutions are:

  • Low cost and lower long-term maintenance cost than traditional methods;
  • Low maintenance of live plants after they are established
  • Environmental benefits of wildlife habitat, water quality improvement and aesthetics
  • Improved strength over time

Bio-engineering includes the use of vegetation in civil engineering construction. It also extends to environmental modifications such as:

  • Surface soil protection
  • Slope stabilization
  • Watercourse and shoreline protection
  • Windbreaks
  • Vegetation barriers (including noise barriers and visual screens)
  • The ecological enhancement of an area
A ground-level view of sea grass planted in rows to stabilize reconstructed dunes on a beach.
Applying Hazard Mitigation

Think about what types of damage your community could sustain during an incident. What measures can you take in advance to prepare for and mitigate future damage?

Now consider what kinds of repetitive losses you sustain. These are areas where mitigation could benefit your community.

It is also worth trying to mitigate hazards that have only happened once, since an incident that's happened before could recur in the future.

A Preliminary Damage Assessment Team surveys a building damaged by Tropical Storm Harvey while volunteers work on site.
Hazard Mitigation Resources

To learn more about hazard mitigation program development, you can explore the following resources:

A FEMA Public Assistance Branch Chief answers a question from a local government official during an applicant briefing.
Lesson 2 Summary

This lesson addressed what measures can be taken to mitigate the risks and effects of different types of hazards. It also identified resources available for Applicants and Recipients to learn more about developing mitigation proposals, including innovative ways to use Section 406 Hazard Mitigation funding.

In this lesson, you learned how to:
  • Identify and define the threats and hazards that cause damage to infrastructure
  • Describe how to minimize future damage
  • Identify resources available for applicants and recipients to learn more about developing mitigation proposals, including innovative ways for using 406 mitigation funding
Lesson 3 Overview and Objectives

This lesson will discuss the eligibility and documentation requirements for Section 406 Hazard Mitigation projects.

In this lesson, you will learn how to:
  • Explain the eligibility requirements for Section 406 mitigation projects
  • Describe the documentation requirements for Section 406 mitigation projects
Eligibility Considerations

FEMA considers a number of different factors when making determinations of eligibility.

These include:
  • Disaster-related damage
  • Cost-effectiveness
  • Technical feasibility
  • Environmental and historic preservation compliance
  • Impact on operations and surrounding area
  • Impact on vulnerability to another hazard
Aerial view of hurricane damage on a shoreline, including a partially submerged boat.
Disaster-Related Damage (1 of 2)

Mitigation measures must directly reduce the potential of future, similar damage to the facility. In general, hazard mitigation projects authorized under Section 406 focus on mitigation measures for the damaged parts of damaged facilities.

In some cases, Section 406 funds may be applied to mitigation measures on undamaged portions of a facility. These measures should provide protection for the damaged portions of the facility and be reasonable based on the extent of the damage.
Washington Harbor's built-in flood wall is raised in the face of high water.
Disaster-Related Damage (2 of 2)

Some examples of comprehensive mitigation measures include:

  • Constructing floodwalls around damaged facilities
  • Installing new drainage facilities (including culverts) along a damaged road
  • Dry flood-proofing both damaged and undamaged buildings that contain components of a system that are functionally interdependent (i.e., cases where the entire system is jeopardized if any one component of the system fails)

FEMA evaluates this type of proposal on a case-by-case basis. If FEMA determines mitigation measures to undamaged portions ineligible as 406 Hazard Mitigation, the Applicant may request Section 404 funding from the Recipient to provide protection to undamaged portions, while utilizing Section 406 mitigation funds to provide protection to damaged portions.

A FEMA supervisor documents the 09/08/2011 high water mark on Our Lady of Lourdes Memorial Hospital's flood wall.
Cost-Effectiveness

Mitigation measures must be cost-effective. FEMA defines cost-effectiveness as:

  • The benefits of a hazard mitigation project exceed the costs
  • The Benefit-Cost Ratio is greater than one (BCR > 1)

Cost-effectiveness does not mean always selecting the least expensive alternative. The long-term costs and benefits need to be assessed.

A set of scales balancing a building on one side and a dollar sign on the other.
Determining Cost-Effectiveness

Three different methods may be used to determine cost-effectiveness:

  • 15-percent rule
  • 100-percent rule (Appendix J in the Public Assistance Program and Policy Guide)
  • Benefit-Cost Analysis

Determining cost-effectiveness will be discussed more in the next lesson.

A pie chart with two sections: 15% and 85%. A pie chart with one section: 100%. A set of scales balancing a building on one side and a dollar sign on the other.
Technical Feasibility

The goal of mitigation is to support Applicant implementation of good projects that will reduce the risk of damage during and against future incidents without compromising a facility against other types of disasters. A mitigation measure should:

  • Address the hazard that occurred
  • Be realistic and feasible

Find out whether the Applicant has any requirements or preferences for mitigation. Understanding Applicant requirements and preferences for mitigation is critical to the selection of suitable measures that will be technically feasible and cost-effective.

Example: The owner and occupants of a local government building may not wish to mitigate against earthquakes using exterior cross bracing for aesthetic reasons or because the bracing can block windows.

A group from FEMA inspects damage to the De Anza Hotel in Calexico
Environmental and Historic Preservation Compliance

Most mitigation measures alter the pre-disaster condition of a facility, which affects compliance with environmental and historic preservation laws, regulations, and Executive Orders.

Environmental and historic preservation compliance includes cultural considerations and public outreach, accounting for how the changes will affect the rest of the community.

As 406 Hazard Mitigation opportunities are identified, Public Assistance staff should initiate efforts to begin identifying environmental or historic preservation compliance issues associated with the proposed action.
Granite blocks in a river retain ice and reduce risk of flooding with minimal disruption of the natural environment.
Example: Environmental and Historic Preservation Compliance

A historic building in Missouri, owned by a city government, has flooded several times and is located in the floodplain. This building is on the National Historic Register and is visited by tourist, which generates additional income for the city.

Due to the historical significance and revenue generation of the building, the Applicant does not want to relocate the building out of the floodplain. As a mitigation measure, they decided to elevate the structure at its current location.
Flood waters rising nearly to the roof of a historic park structure.
Impact on Operations and Surrounding Area

Hazard mitigation measures often impact more than the facility that has been damaged. They can affect the hazard risk to other facilities, the function of services, and the local economy.

Applicants need to understand the impact that their projects will have on the surrounding area. Hazard mitigation for one facility can affect future protective measures for others, potential need for temporary facilities, and impact the function for utilities or basic infrastructure facilities during future disasters.

Example: Water control measures to prevent flooding in one area might divert water to another location, damaging a power plant or water supply utility. In this case, the benefits of the initial mitigation measure would be outweighed by the collateral damage.

Aerial view of a dam being built, changing the water flow and possible flood plan.
Collateral Impact of Mitigation: Sewage Treatment Plant

The 26th Ward Wastewater Treatment Plant in New York City during Hurricane Sandy, was flooded. Effluent from the plant contaminated the flood waters, and the plant was closed.

Consider:

  • What is the impact on the economy?
  • Will school need to be closed?
  • Will traffic need to be diverted?
A view over water the water tanks of a sewage treatment plant
Collateral Impact of Mitigation: Rockaway Boardwalk (1 of 2)

Many times, mitigation measures will impact more than the facility that is damaged. The surrounding facilities can be part of the impact or become impacted, based on mitigation measures.

Rockaway Boardwalk in New York City was flooded in Hurricane Sandy. The city decided to elevate the boardwalk and construct sand barriers to mitigate the risks of future flood damage.
Repairs to the Rockaway Boardwalk in NYC after Hurricane Sandy. A row of pilings line the shore.
Collateral Impact of Mitigation: Rockaway Boardwalk (2 of 2)

These mitigation measures have the further effect of helping to protect buildings inland from the boardwalk debris, sea level rise, tidal flooding, and storm surge.

In addition, the Rockway Boardwalk repairs and mitigation funds were part of a larger plan set by FEMA that lead to growth in the economy and environment resilience.
A map of hazard mitigation project sites in NYC after Hurricane Sandy. Labels: B 9th St, 1: B 30th St, 2: B 40th St, 3, 7: B 60th St, 4: B 69th St, 6: B 90th St
Impact on Other Hazard Vulnerability

A mitigation measure designed to reduce the risk from one hazard can sometimes increase vulnerability to another. For example, a proposed method of fireproofing a door or windows might have the unintended effect of trapping people inside if the building floods.

The failure of a mitigation measure can also have a cascading effect on hazards it was not designed to address. Levees are designed to hold back flood water, but when New Orleans levees were overwhelmed during Hurricane Katrina, flood damage was not the only result.

Flooded streets were impassable, hindering evacuation and limiting the mobility of emergency response personnel. Additionally, flood damage to utilities such as electricity, water, and sewage were interrupted and in some cases created more safety concerns.

A New Orleans neighborhood flooded by Hurricane Katrina. Crews work on areas where there have been breaks in the levee in order to avoid additional flooding.
Eligibility Considerations Example

Consider the following hazard mitigation measures. Which mitigation measures are likely to impact vulnerability to other hazards? Are any likely to affect the community in a negative way?

Examples:

  • Constructing floodwalls around damaged facilities
  • Installing new drainage facilities along a damaged road (e.g. culverts)
  • Dry flood-proofing both damaged and undamaged buildings that contain components of a system that would be jeopardized if any one component of the system fails
  • Slope stabilization to protect facilities:
    • Riprap
    • Retaining walls or gabion baskets
    • Geotextile fabric
  • Use of disaster-resistant materials for power poles
Cars driving under damaged utility poles on Smith Bay Road in the Virgin Islands. Retaining wall made of tires in Puerto Rico.
Section 406 Documentation Requirements

The following should be included in the Hazard Mitigation Proposal process:

  • Demonstration of event-related damage
  • A pre-disaster cost estimate; or what it will cost to restore the facility to its pre-disaster condition
  • Documentation of cost of historical damages for the Benefit-Cost Analysis, if required
  • Consideration of environmental and historic preservation
  • Documents submitted to FEMA's 406 mitigation specialist
  • Posting all documents to Grants Portal

Depending on your project, certain documentation may be required outside of what is listed here.

A tall stack of file folders
Section 406 Mitigation Projects

When applying to use Public Assistance funds to repair a facility, you must inform FEMA if you wish to include changes or improvements. Failure to do so can negatively impact your funding.

By definition, Section 406 Hazard Mitigation measures generally involve making changes to the original facility.

A calculator, pencil, and small construction paraphernalia laying on top of blueprints and a list labeled Estimate.
Lesson 3 Summary

This lesson discussed the eligibility and documentation requirements for Section 406 Hazard Mitigation projects.

In this lesson, you learned how to:
  • Explain the eligibility requirements for Section 406 mitigation projects
  • Describe the documentation requirements for Section 406 mitigation projects
Lesson 4 Overview and Objectives

This lesson will discuss how to determine the cost-effectiveness of a hazard mitigation project.

At the end of this lesson, you will be able to:

  • Describe FEMA's criteria for determining cost effective mitigation measures funded under Section 406 of the Robert T. Stafford Act
  • Identify the components and methodology for calculating a benefit-cost analysis
Cost-Effectiveness

Cost effectiveness relates to the financial feasibility of technically feasible hazard mitigation measures. It is an assessment comparing pre-disaster repair cost to the increased costs associated with implementing various mitigation methods for a single project. FEMA determines whether a measure is financially feasible using its cost-effectiveness.

Example: Repairs to restore a facility to its pre-disaster condition will cost $10,000. Adding hazard mitigation measures that would prevent or reduce future damage costs will cost $1 million. Is hazard mitigation cost-effective?

Determining Cost-Effectiveness

The Public Assistance Program and Policy Guide establishes three methods to determine whether a project is cost-effective. The cost-effectiveness of most 406 Hazard Mitigation projects is determined by either the 15% or 100% rule. However, these rules may exclude some otherwise cost-effective projects.

If the mitigation measure is not cost-effective based on the first two criteria, FEMA, Recipient, and Applicant will work together to develop a Benefit-Cost Analysis to determine whether it is cost-effective.

Two pie graphs, the top showing two sections, 15% and 85% and the bottom showing one section, 100%. The bottom image is a set of scales balancing a building on one side and a dollar sign on the other.
The 15 Percent Rule

FEMA considers mitigation measures to be cost-effective if the cost for the mitigation measure does not exceed 15% of the total eligible repair cost (prior to any insurance reductions) of the facility or facilities for which the mitigation measure applies.

If the costs exceed 15% of the total eligible repair cost, consider the 100% rule.

A pie chart with two sections, 15% and 85%.
The 100 Percent Rule

FEMA also considers mitigation measures to be cost-effective if:

  • The mitigation measure is specifically listed in Appendix J: Cost-Effective Hazard Mitigation Measures of the Public Assistance Program and Policy Guide
  • The cost of the mitigation measure does not exceed 100% of the eligible repair cost (prior to any insurance reductions) of the facility or facilities for which the mitigation measure applies

The items listed in Appendix J were derived from historical mitigation measures FEMA has determined to be cost effective.

If the project costs more than 15% of the total eligible repair cost or 100% of the damaged element repairs, then conduct a Benefit-Cost Analysis.

A pie chart with one section: 100%.
Benefit-Cost Analysis

Many mitigation measures that do not meet either the 15% or 100% rule prove to be cost-effective based on a Benefit-Cost Analysis. The Applicant must demonstrate through an acceptable benefit-cost analysis methodology that the benefits of the mitigation measure exceed the cost of implementing it.

A Benefit-Cost Analysis is based on a comparison of the total eligible cost for the mitigation measure to the total value of expected benefits to society.

Benefits include reductions in:

  • Damage to the facility and its contents
  • The need for Emergency Protective Measures
  • The need for temporary facilities
  • Loss of function
  • Casualties (typically included only for earthquake, tornado, and wildfire mitigation)
A set of scales balancing a building on one side and a dollar sign on the other.
Benefit-Cost Analysis Considerations

Some factors that a Benefit-Cost Analysis should also take into account include:

  • The population affected
  • Historical data
  • Historical damage records
  • Hydrology and hydraulics studies
  • Damage frequency assessment
  • Change in development of land
A FEMA inspector meeting with a disaster survivor and his grandchildren, who play on the bank of the Yukon river.
Benefit-Cost Analysis Specialist

Each disaster should have access to a Benefit-Cost Analysis specialist. This specialist makes the Benefit-Cost Analysis calculations. Most counties will have someone in engineering and planning who can do the same.

Applicants and Recipients can also hire a consultant to develop the Benefit-Cost Analysis for them before delivering it to FEMA for review.
Two FEMA specialists work together at a laptop.
Benefit-Cost Analysis Development Resources

There are a number of other tools and resources you can use to develop a Benefit-Cost Analysis:

  • Benefit-Cost Analysis software: Make sure the version you are using is up to date and has the most current national guidelines for cost codes
  • Third-party professionals: Individuals, such as the State Public Assistance Representative, can provide further guidance
  • Recipient: The Recipient can also provide useful guidance when developing a Benefit-Cost Analysis
  • FEMA courses:
    • E0239: 406 Hazard Mitigation
    • E0276: Benefit-Cost Analysis: Entry Level
  • FEMA has Benefit-Cost Analysis software that provides appropriate Benefit-Cost Analysis methodologies. However, it is the Applicant or Recipient's responsibility to gather the necessary information and provide it to FEMA. FEMA Benefit Cost Analysis
A FEMA official giving a presentation in a large conference room.
Applicant Prepared Benefit-Cost Analysis

Once the Benefit-Cost Analysis has been calculated, it can be submitted to FEMA along with the other documentation for your hazard mitigation project.

Do not simply submit the Benefit-Cost Analysis number from the calculations. You must also record the documented sources, method used to calculate the final total, and enclose a signed copy of the Benefit-Cost Analysis.
A neat stack of documents held together with colorful clips and marked with tabs.
FEMA Validation of Applicant Prepared Benefit-Cost Analysis

FEMA validates the Benefit-Cost Analysis by reviewing the methodology and the supporting documentation provided by the Applicant.

FEMA will perform a thorough review.
A FEMA specialist working on a laptop with papers on the table beside it.
Lesson 4 Summary

This lesson discussed how to determine the cost-effectiveness of a hazard mitigation project.

In this lesson, you learned how to:

  • Describe FEMA's criteria for determining cost effective mitigation measures funded under Section 406 of the Robert T. Stafford Act
  • Identify the components and methodology for calculating a benefit-cost analysis
Lesson 5 Overview and Objectives

This lesson defines active and passive mitigation measures and provides several examples of successful Section 406 hazard mitigation projects.

At the end of this lesson, you will be able to:

  • Describe elements of successful Section 406 active and passive hazard mitigation projects
Active vs. Passive Mitigation

There are two general types of mitigation: active and passive.

  • Active mitigation: Mitigation measure that require human intervention (or power) to operate properly
  • Passive mitigation: Mitigation measures that require no human intervention (or power) to operate properly

Passive measures are preferable and tend to be more sustainable; active mitigation measures should be avoided if possible, especially for natural hazards where there is little or no warning time, such as flash floods, tornadoes, or earthquakes.

Numbered plywood panels are secured in place to protect the store front windows as merchants make preparations for Hurricane Rita's arrival. A construction crew with heavy equipment working on gabion walls to stabilize a road bank.
Active Mitigation

Active hazard mitigation measures require some degree of human intervention to be fully effective. Active migration is considered 406 Hazard Mitigation if it is tied to a damaged element.

Examples of active mitigation:

  • Flood - Flood-proofing techniques that require the installation of flood shields over doors and other openings prior to the event
  • Wind - Installing or securing storm shutters
Numbered plywood panels are secured in place to protect the store front windows as merchants make preparations for Hurricane Rita's arrival.
Passive Mitigation

Passive hazard mitigation measures do not require any human intervention to be fully effective.

Examples of passive mitigation:

  • Flood - Elevation and relocation of structures
  • Wind - Improving roof sheathing and the connections between roof framing and walls
  • Earthquake - Installing or securing shear walls or cross bracing
A building that says "Modern Woodman Park" with a floodwall surrounded by water.
Case Study: Hurricane Zena (1 of 4)

As a result of Hurricane Zena, the windows of the Hazard County Courthouse were impacted and shattered by flying debris. During the recovery process, the Applicant has claimed this damage and is requesting funds to replace the windows. The Applicant wishes to request 406 Hazard Mitigation in order to prevent the failure of the courthouse windows during a future disaster event.

Debris visible through the broken windows of a multi-story building
Case Study: Hurricane Zena (2 of 4)

The Applicant is considering the following two options for 406 Hazard Mitigation:

  • Active Mitigation: Installation of accordion roll-down shutters to be placed on the building and deployed prior to a hurricane
  • Passive Mitigation: Glass upgrade to impact-resistant glass

Note: Mitigation options to protect windows from wind events include, but are not limited to, the Applicant's considerations.

A woman rolling down a hurricane shutter over a pair of French doors. A row of new windows in a beach-front building.
Case Study: Hurricane Zena (3 of 4)

Direct and indirect benefits of the mitigation:

  • Direct benefit: Limiting and/or preventing failure of the building windows and the need to replace them following an event
  • Indirect benefit: Limiting and/or preventing the destruction of components and contents inside the building that would be exposed to storm winds and rain if the windows break
A row of new windows in a beach-front building.
Case Study: Hurricane Zena (4 of 4)

The Applicant is making the following considerations in selecting active and passive hazard mitigation measures:

  • Active Mitigation: The measure is effective as long as there is enough pre-event lead time and staff are available to deploy the measure
  • Passive Mitigation: Impact resistant glass is robust, but still may break upon impact during extreme events

Applicants should propose the mitigation method that is most advantageous to their specific need and capability.

A woman rolling down a hurricane shutter over a pair of French doors.
Case Study: Elevate Generator (1 of 2)

During Hurricane Sandy, both the New York University Langone Medical Center and LaGuardia Airport lost power. Each facility had generators to provide emergency power, but neither was adequately prepared for the flooding that occurred.

When the generators were flooded, the medical center and airport lost back-up power, interrupting service and endangering lives.

A view of the NYU Medical Center and Hospital Row down FDR Drive, along the East River.
Case Study: Elevate Generator (2 of 2)

In response, the Langone Medical Center and LaGuardia Airport have used Section 406 Hazard Mitigation funding to elevate their back-up generators and reduce the risk of power-loss during any future flooding.

An elevated CAT generator
Case Study: Pipe Blow-Out

The town of Beaver Creek, Kansas is subject to flooding and runoff resulting in heavy water flow through buried pipes, exceeding their capacity.

The system of corrugated metal pipes experienced blow-outs three times in a five-year period. After studying the problem, the town used hazard mitigation funding to add vents to the surface where the system was vulnerable. These vents allow air to escape, preventing pressure from building up and reducing the risk of blow-outs.
Underground pipes being installed with pressure-relief vents to the surface.
Case Study: Sewage Treatment Plant Flood Wall (1 of 2)

The 26th Ward Wastewater Treatment Plant in New York City was damaged by flooding during Hurricane Sandy. Effluent from the plant entered the flood water and contaminated other nearby sites. A combination of 404 and 406 mitigation measures was provided to protect the plant but did not cover the entire cost of repairs.

Aerial view of NYC 26th Ward wastewater treatment plant. PA funding eligibility of different elements is marked. PA 406 eligible: zones 5, 6, 7, 9; Applied under 404: 2, 4; Unprotected: 1, 3, 8.
Case Study: Sewage Treatment Plant Flood Wall (2 of 2)

However, wastewater treatment is considered an integrated and interdependent process. Damage to an ineligible component of the plant affects the function of the whole system, including eligible components.

After reviewing the case, the Recovery Branch approved dry floodproofing for the entire wastewater treatment plant as Section 406 Hazard Mitigation.

A view over water the water tanks of a sewage treatment plant
Lesson 5 Summary

This lesson defined active and passive mitigation measures and provided several examples of successful Section 406 hazard mitigation projects.

In this lesson, you learned how to:

  • Describe elements of successful Section 406 active and passive hazard mitigation projects
Lesson 6 Overview and Objectives

This lesson will review the course objectives. Participants will take a Post-Course Assessment at its conclusion.

At the end of this lesson, participants will be able to summarize the content of the course.

Course Objectives

This course provided an overview of Public Assistance project eligibility. State, Local, Tribal, and Territorial Applicants and Recipients should now be able to understand all aspects of Section 406 Mitigation of the Robert T. Stafford Act.

In this course, you learned how to:
  • Define Section 406 Mitigation
  • Explain which types of projects are eligible for FEMA Public Assistance grant funding under Section 406 authority
  • Identify the benefits and opportunities to reduce repetitive disaster losses by pursuing projects authorized under Section 406 Hazard Mitigation
  • Discuss examples of potential mitigation work across damage categories C through G (Permanent Work)
  • Explain the various methods to determine cost effectiveness of hazard mitigation proposal eligibility
Lesson 1 Objectives

This lesson introduced hazard mitigation. It provided an overview of the different hazard mitigation programs authorized under the Stafford Act and discussed common Section 406 Hazard Mitigation projects for Permanent work.

In this lesson, participants learned how to:
  • Identify the administrative requirements of the course
  • State the goals and objectives of the course
  • Define hazard mitigation as it relates to Section 406 of the Robert T. Stafford Act
  • Discuss the types of mitigation measures eligible for Public Assistance funding under Section 406 of the Stafford Act
Lesson 2 Objectives

This lesson addressed what measures can be taken to mitigate the risks and effects of different types of hazards. It also identified resources available for Applicants and Recipients to learn more about developing mitigation proposals, including innovative ways to use Section 406 Hazard Mitigation funding.

In this lesson, you learned how to:
  • Identify and define the threats and hazards that cause damage to infrastructure
  • Describe how to minimize future damage
  • Identify resources available for Applicants and Recipients to learn more about developing mitigation proposals, including innovative ways for using 406 mitigation funding
Lesson 3 Objectives

This lesson discussed the eligibility and documentation requirements for Section 406 Hazard Mitigation projects.

In this lesson, you learned how to:
  • Explain the eligibility requirements for Section 406 mitigation projects
  • Describe the documentation requirements for Section 406 mitigation projects
  • Lesson 4 Objectives

    This lesson discussed how to determine the cost-effectiveness of a hazard mitigation project.

    In this lesson, you learned how to:

    • Describe FEMA's criteria for determining cost effective mitigation measures funded under Section 406 of the Robert T. Stafford Act
    • Identify the components and methodology for calculating a benefit-cost analysis
    Lesson 5 Objectives

    This lesson defined active and passive mitigation measures and provided several examples of successful Section 406 mitigation projects.

    In this lesson, you learned how to:

    • Describe elements of successful Section 406 active and passive hazard mitigation projects
    Course Summary

    Congratulations! This course is complete.

    The course provided you with an overview of Section 406 Hazard Mitigation.