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

• Disaster-related damage
• Cost-effectiveness
• Technical feasibility
• Environmental and historic preservation compliance
• Impact on operations and surrounding area
• Impact on vulnerability to another hazard

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.

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.

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.

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.

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.

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.

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.

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.

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?

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.

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.

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

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.

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.