Local Mitigation Planning Policy Side-by-Side Comparison
April 2022 1
This document shows, side by side, the changes in required elements in the updated 2022
Local Mitigation Planning Policy Guide (FP 206-21-0002) with respect to two policies:
The 2011 Local Mitigation Plan Review Guide
The 2020 HHPD Grant Guidance (FP 104-008-7)
Staff who review and approve local mitigation plans can quickly see where policies
changed. This document includes only the requirements. FEMA also updated the narratives
in the 2022 version. New and updated wording is highlighted. Minor differences in
grammar and capitalization are not highlighted. Material deleted from the 2011 version is
not called out in the 2022 column.
Standard Elements
Element A: Planning Process
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A1. Does the Plan document the planning process, including how it was prepared and who was involved in the
process for each jurisdiction? 44 CFR 201.6(c)(1)
Documentation of how the plan was prepared
must include the schedule or timeframe and
activities that made up the plan’s development as
well as who was involved. Documentation typically
is met with a narrative description, but may also
include, for example, other documentation such as
copies of meeting minutes, sign‐in sheets, or
newspaper articles.
Document
means provide the factual evidence for
how the jurisdictions developed the plan.
The plan must list the jurisdiction(s) participating
in the plan that seek approval.
The plan must identify who represented each
jurisdiction. The Plan must provide, at a minimum,
A1-a. The plan must describe the current planning
process. Documentation requirements typically are met
with a narrative description, but may also include other
records such as copies of meeting minutes, sign-in
sheets or newspaper articles. When a narrative
description is provided, supporting documentation such
as meeting minutes, sign-in sheets, etc., does not need
to be included in the plan itself. Planners are
encouraged to retain supporting documentation in a
Plan Appendix as a record of how decisions were made
and who was involved.
Document means to provide factual evidence for how
the participants developed/updated the plan.
Involvement means being engaged and actively
participating in the development of the plan; providing
input and directly providing, affecting or editing plan
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the jurisdiction represented and the person’s
position or title and agency within the jurisdiction.
For each jurisdiction seeking plan approval, the
plan must document how they were involved in the
planning process. For example, the plan may
document meetings attended, data provided, or
stakeholder and public involvement activities
offered. Jurisdictions that adopt the plan without
documenting how they participated in the planning
process will not be approved.
Involved in the process
means engaged as
participants and given the chance to provide input
to affect the plan’s content. This is more than
simply being invited (See “opportunity to be
involved in the planning process” in A2 below) or
only adopting the plan.
Plan updates must include documentation of the
current planning process undertaken to update the
plan.
content as the representative of the participating
jurisdiction(s) or organization.
If applicable, ensure that participating Community
Rating System (CRS) jurisdictions maximize points
throughout the planning process.
A1-b. The plan must list the representatives from each
of the participants in the current plan that will seek
approval, and how they participated in the planning
process.
The plan must identify who participated, by agency and
title. (Formerly A1-c)
Participant means any local government or entity
developing or updating a local mitigation plan.
Participation means being engaged and having the
chance to provide input on the plan. It can be defined
and met in a variety of ways (such as attendance at
meetings, reviewing and commenting on drafts, etc.).
A2. Does the Plan document an opportunity for neighboring communities, local and regional agencies involved in
mitigation activities, agencies that have the authority to regulate development as well as businesses, academia,
and other private and non-profit interests to be involved in the planning process? (44 CFR § 201.6(b)(2))
The plan must identify all stakeholders involved or
given an opportunity to be involved in the planning
process. At a minimum, stakeholders must
include:
Local and regional agencies involved in hazard
mitigation activities;
Agencies that have the authority to regulate
development; and
Neighboring communities.
An
opportunity to be involved in the planning
process
means that the stakeholders are engaged
or invited as participants and given the chance to
provide input to affect the plan’s content.
The Plan must provide the agency or organization
represented and the person’s position or title
within the agency.
The plan must identify how the stakeholders were
invited to participate in the process.
Examples of stakeholders include, but are not
limited to:
A2-a. The plan must provide documentation of an
opportunity for stakeholders to be involved in the
current planning process. Documentation of this
opportunity must identify how each of the following
types of stakeholders were presented with this
opportunity, as applicable.
Local and regional agencies involved in hazard
mitigation activities: Examples include public works,
emergency management, local floodplain
administration and Geographic Information Systems
(GIS) departments.
Agencies that have the authority to regulate
development: Examples include: zoning, planning,
community and economic development
departments; building officials; planning
commissions; or other elected officials.
Neighboring communities: Examples include
adjacent local governments, including special
districts, such as those that are affected by similar
hazard events or may share a mitigation action or
project that crosses boundaries. Neighboring
communities may be partners in hazard mitigation
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Local and regional agencies involved in hazard
mitigation include public works, zoning,
emergency management, local floodplain
administrators, special districts, and GIS
departments.
Agencies that have the authority to regulate
development include planning and community
development departments, building officials,
planning commissions, or other elected officials.
Neighboring communities include adjacent
counties and municipalities, such as those that
are affected by similar hazard events or may be
partners in hazard mitigation and response
activities.
Other interests may be defined by each
jurisdiction and will vary with each one. These
include, but are not limited to, business,
academia, and other private and non‐profit
interests depending on the unique
characteristics of the community.
and response activities, or may be where critical
assets, such as dams, are located.
Representatives of businesses, academia, and other
private organizations: Examples include private
utilities or major employers that sustain community
lifelines.
Representatives of nonprofit organizations,
including community-based organizations, that work
directly with and/or provide support to underserved
communities and socially vulnerable populations,
among others: Examples include housing,
healthcare or social service agencies.
An opportunity to be involved in the planning process
means that these stakeholders are invited to be
engaged or are asked to provide information or input to
inform the plan’s content. Different communities may
necessitate more targeted outreach and engagement,
especially underserved communities.
Community Lifelines are the most fundamental
services in the community that, when stabilized, enable
all other aspects of society to function. The integrated
network of assets, services and capabilities that
provide community lifeline services are used day to day
to support recurring needs. Lifelines enable the
continuous operation of critical government and
business functions and are essential to human health
and safety or economic security, as described in the
National Response Framework, 4th Edition.
The specific entities may be defined by each
jurisdiction based on the unique characteristics of the
local government, including special districts. The
purpose of inviting input is to integrate natural hazard
risk reduction across all community systems, as well as
encourage implementation of mitigation actions.
A3. Does the plan document how the public was involved in the planning process during the drafting stage and
prior to plan approval? (Requirement 44 CFR § 201.6(b)(1))
The plan must document how the public was given
the opportunity to be involved in the planning
process and how their feedback was incorporated
into the plan. Examples include, but are not limited
to, sign‐in sheets from open meetings, interactive
websites with drafts for public review and
comment, questionnaires or surveys, or booths at
popular community events.
A3-a. The plan must document how the public had an
opportunity to be involved in the current planning
process, and what that participation entailed, including
how underserved communities and vulnerable
populations within the planning area were provided an
opportunity to be involved.
The opportunity must occur during the plan’s
development, which means prior to the plan’s
submission for formal review. In addition, the plan must
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The opportunity for participation must occur during
the plan development, which is prior to the
comment period on the final plan and prior to the
plan approval / adoption.
document how public feedback was included
throughout the planning process.
Examples of documentation include, but are not limited
to, narratives, materials from open meetings,
screenshots of social media postings and/or
interactive websites with drafts for public review and
comment, questionnaires or surveys through utility
bills, etc.
A4. Does the plan describe the review and incorporation of existing plans, studies, reports, and technical
information? (Requirement 44 CFR § 201.6(b)(3))
The plan must document
what
existing plans,
studies, reports, and technical information were
reviewed. Examples of the types of existing
sources reviewed include, but are not limited to,
the state hazard mitigation plan, local
comprehensive plans, hazard specific reports, and
flood insurance studies.
The plan must document
how
relevant information
was incorporated into the mitigation plan.
Incorporate
means to reference or include
information from other existing sources to form the
content of the mitigation plan.
A4-a. The plan must document what existing plans,
studies, reports and technical information were
reviewed and how they were incorporated, if
appropriate, into the development/update of the plan.
For jurisdictions with structures for which National
Flood Insurance Program (NFIP) coverage is available,
regulatory flood mapping products are required to be
incorporated, if appropriate.
Participants may use other jurisdiction-specific
materials, including non-regulatory flood mapping
products, that improve upon NFIP regulatory flood
mapping products.
Gaps and limitations may be addressed as actions in
the mitigation strategy, in particular for items that
require additional assistance.
Incorporate means to reference or include information
from other existing sources to form the content of the
mitigation plan.
The documentation requirement may be met with
narrative or citations (i.e., footnotes, in-text citations or
a bibliography). Examples of the types of existing
sources include, but are not limited to: the state hazard
mitigation plan; local plans (such as
comprehensive/master/general land use, economic
development, capital improvement, affordable housing,
resource management, resilience, climate, etc.); and
hazard-specific reports and plans (such as Community
Wildfire Protection Plans).
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Element B: Risk Assessment
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B1 (formerly B1 and B2). Does the plan include a description of the type, location, and extent of all natural
hazards that can affect the jurisdiction? Does the plan also include information on previous occurrences of
hazard events and on the probability of future hazard events? (Requirement 44 CFR § 201.6(c)(2)(i))
Note: Elements B1 and B2 of the 2011 PRT were combined into Element B1 in the 2022 PRT.
B1.
The plan must include a description of the natural
hazards that can affect the jurisdiction(s) in the
planning area.
A
natural hazard
is a source of harm or difficulty
created by a meteorological, environmental, or
geological event. The plan must address natural
hazards. Manmade or human‐caused hazards may
be included in the document, but these are not
required and will not be reviewed to meet the
requirements for natural hazards. In addition, FEMA
will not require the removal of this extra information
prior to plan approval.
The plan must provide the rationale for the
omission of any natural hazards that are
commonly recognized to affect the jurisdiction(s)
in the planning area.
The description, or profile, must include
information on location, extent, previous
occurrences, and future probability for each
hazard. Previous occurrences and future
probability are addressed in sub‐element B2.
The information does not necessarily need to be
described or presented separately for location,
extent, previous occurrences, and future probability.
For example, for some hazards, one map with
explanatory text could provide information on
location, extent, and future probability.
Location
means the geographic areas in the
planning area that are affected by the hazard. For
many hazards, maps are the best way to illustrate
location. However, location may be described in
other formats. For example, if a geographically‐
specific location cannot be identified for a hazard,
B1-a. The plan must include a description of all natural
hazards that can affect the jurisdiction(s) in the
planning area and their assets, such as dams, located
outside of the planning area. This requirement may be
met with either a narrative description or definition.
The plan must provide the rationale if omitting any
natural hazards that are commonly recognized to affect
the participant(s) in the planning area. There is no
prescribed method for explaining the omission, but the
plan must demonstrate the lack of risk to the
participant(s) that omits the hazard.
Natural hazards are a source of harm or difficulty
created by a meteorological, environmental or
geological event. Natural hazards, such as flooding and
earthquakes, impact the built environment, including
dams and levees.
Identifying hazards includes identifying all the types of
hazards that can occur, e.g., the different types of flood
hazards (flash, riverine, storm surge, debris flows, ice
jams, dam/levee failure, etc.).
B1-b. The plan must include information on location for
each identified hazard.
Location is defined as the unique geographic
boundaries within the planning area, or assets outside
of geographic boundaries that may be affected by the
identified hazard. Maps are an efficient way to illustrate
location. However, location may be described through
plan narratives or other formats.
If maps are used, provide sufficient detail and scale to
clearly identify the hazard locations within and/or
affecting assets owned by the participating
jurisdiction(s). If narrative descriptions are used, they
must contain enough detail to clearly identify the
area(s) (and assets, as applicable) that will be affected
by the hazard.
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such as tornados, the plan may state that the entire
planning area is equally at risk to that hazard.
Extent
means the strength or magnitude of the
hazard. For example, extent could be described in
terms of the specific measurement of an
occurrence on a scientific scale (for example,
Enhanced Fujita Scale, Saffir‐Simpson Hurricane
Scale, Richter Scale, flood depth grids) and/or other
hazard factors, such as duration and speed of
onset. Extent is not the same as impacts, which are
described in sub‐element B3.
For participating jurisdictions in a multi‐
jurisdictional plan, the plan must describe any
hazards that are unique and/or varied from those
affecting the overall planning area.
B2.
The plan must include the history of previous
hazard events for each of the identified hazards.
The plan must include the probability of future
events for each identified hazard.
Probability
means the likelihood of the hazard
occurring and may be defined in terms of general
descriptors (for example, unlikely, likely, highly
likely), historical frequencies, statistical
probabilities (for example: 1% chance of
occurrence in any given year), and/or hazard
probability maps. If general descriptors are used,
then they must be defined in the plan. For example,
“highly likely” could be defined as equals near
100% chance of occurrence next year or happens
every year.
Plan updates must include hazard events that
have occurred since the last plan was developed.
B1-c. The plan must provide the extent of the hazards
that can affect the planning area. When describing
extent using charts or scales (e.g., Saffir-Simpson scale
for hurricane wind speed; Enhanced Fujita scale for
tornado), the plan must document how the scale
applies to each jurisdiction.
Extent is defined as the range of anticipated intensities
of the identified hazards. The information must relate
to each of the plan participants or the planning area,
depending on the hazard. Extent is most commonly
expressed using various scientific scales.
B1-d. The plan must include information on previous
hazard events for each hazard that affects the planning
area. At a minimum, this includes any state and federal
major disaster declarations for the planning area since
the last update.
Previous occurrences can be included in a variety of
ways, but should include an emphasis on significant
events, as determined by the community. If no events
have occurred for a hazard, this must be stated.
B1-e. The plan must include the probability of future
events for the identified hazards that can affect the
planning area. Probability may be met in a variety of
ways; however, general descriptors must be
quantitatively defined.
Probability must include the effects of future
conditions, including climate change (e.g., long-term
weather patterns, average temperature and sea levels),
on the type, location and range of anticipated
intensities of identified hazards.
Probability of future hazard events means the
likelihood of the hazard occurring or reoccurring. It may
be defined in historical frequencies, statistical
probabilities, hazard probability maps and/or general
descriptors (e.g., unlikely, likely, highly likely). If general
descriptors are used, they must be quantified or
defined in the plan. For example, “highly likely” could
be defined as “100% chance of occurrence next year”
or “one event every year.”
B1-f. For multi-jurisdictional plans, when hazard risks
differ across the planning area and between
participating jurisdictions, the plan must specify the
unique and varied risk information for each applicable
jurisdiction and their assets outside the planning area.
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B2 (formerly B3 and B4). Does the plan include a summary of the jurisdiction’s vulnerability and the impacts on
the community from the identified hazards ? Does this summary also address NFIP-insured structures that have
been repetitively damaged by floods? (Requirement 44 CFR § 201.6(c)(2)(ii))
Note: Elements B3 and B4 of the 2011 PRT were combined into Element B2 in the 2022 PRT.
B3.
For each participating jurisdiction, the plan must
describe the potential impacts of each of the
identified hazards on the community.
Impact
means the consequence or effect of the
hazard on the community and its assets. Assets are
determined by the community and include, for
example, people, structures, facilities, systems,
capabilities, and/or activities that have value to the
community. For example, impacts could be
described by referencing historical disaster impacts
and/or an estimate of potential future losses (such
as percent damage of total exposure).
The plan must provide an overall summary of each
jurisdiction’s vulnerability to the identified
hazards. The overall summary of vulnerability
identifies structures, systems, populations or other
community assets as defined by the community
that are susceptible to damage and loss from
hazard events. A plan will meet this sub‐element
by addressing the requirements described in
§201.6(c)(2)(ii)(A‐C).
Vulnerable assets and potential losses is more than
a list of the total exposure of population, structures,
and critical facilities in the planning area. An
example of an overall summary is a list of key
issues or problem statements that clearly describes
the community’s greatest vulnerabilities and that
will be addressed in the mitigation strategy.
B4.
The plan must describe the types (residential,
commercial, institutional, etc.) and estimate the
B2-a. The plan must describe the vulnerability of each
participant to the identified hazards. The description
must include current and future assets (including
people) and the risk that makes them susceptible to
damage from the identified hazards.
For plan updates, the risk assessment must meet
element E1-a.
The risk assessment must describe the vulnerability of
plan participant(s) to each identified hazard. The
vulnerability description must include a summary (such
as a problem statement) of the hazard and its
consequences or effects on the participant(s) and their
assets. A list of assets without context is not sufficient.
Vulnerability is a description of which assets, including
structures, systems, populations and other assets as
defined by the community, within locations identified to
be hazard prone, are at risk from the effects of the
identified hazard(s).
Assets are determined by the community and include,
but are not limited to:
People (including underserved communities and
socially vulnerable populations).
Structures (including facilities, lifelines and critical
infrastructure).
Systems (including networks and capabilities).
Natural, historic, and cultural resources.
Activities that have value to the community.
To form the vulnerability description, plan participant(s)
may identify which specific assets are most important
and most susceptible to damage or loss from hazards.
(For example, this may be expressed as replacement
cost).
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numbers of repetitive loss properties located in
identified flood hazard areas.
Repetitive loss properties
are those for which two or
more losses of at least $1,000 each have been
paid under the National Flood Insurance Program
(NFIP) within any 10
‐
year period since 1978.
Severe repetitive loss
properties are residential
properties that have at least four NFIP payments
over $5,000 each and the cumulative amount of
such claims exceeds $20,000, or at least two
separate claims payments with the cumulative
amount exceeding the market value of the building.
Use of flood insurance claim and disaster
assistance information is subject to The Privacy Act
of 1974, as amended, which prohibits public
release of the names of policy holders or recipients
of financial assistance and the amount of the claim
payment or assistance. However, maps showing
general areas where claims have been paid can be
made public. If a plan includes the names of policy
holders or recipients of financial assistance and the
amount of the claim payment or assistance, the
plan cannot be approved until this Privacy Act
covered information is removed from the plan.
B2-b. The plan must describe the potential impacts on
each participating jurisdiction and its identified assets.
Impacts must include the effects of climate change,
changes in population patterns (migration, density, or
the makeup of socially vulnerable populations), and
changes in land use and development.
Impacts are the consequences or effects of each
hazard on the participant’s assets identified in the
vulnerability assessment. For example, impacts could
be described by referencing historical disaster
damages with an estimate of potential future losses
(such as percentage of damage vs. total exposure).
Gaps and limitations may be addressed as actions in
the mitigation strategy, in particular for items that
require additional assistance.
B2-c. The plan must address repetitively flooded NFIP-
insured structures by including the estimated numbers
and types (residential, commercial, institutional, etc.) of
repetitive/severe repetitive loss properties.
Participants should consider addressing all properties
at high risk of flooding that may not be NFIP repetitive
loss properties. For example, properties in the Special
Flood Hazard Area (SFHA) with their lowest floor below
the established Base Flood Elevation are at risk of flood
damage from the base flood and potentially from more
frequent flood events.
Repetitive loss structure means a structure covered
under an NFIP flood insurance policy that (1) has
incurred flood-related damage on two occasions, in
which the cost of repair, on average, equaled or
exceeded 25% of the value of the structure at the time
of each such flood event; and (2) at the time of the
second incidence of flood-related damage, the contract
for flood insurance contains increased cost of
compliance coverage. (44 CFR § 77.2(i))
Severe repetitive loss structure means a structure
that is covered under an NFIP flood insurance policy
and has incurred flood-related damage (1) for which
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four or more separate claims have been made under
flood insurance coverage, with the amount of each
claim (including building and contents payments)
exceeding $5,000 and with the cumulative amount of
such claims payments exceeding $20,000; or (2) for
which at least two separate flood insurance claims
payments (building payments only) have been made,
with cumulative amount of such claims exceeding the
value of the insured structure. (44 CFR § 77.2(j))
Use of flood insurance claim and disaster assistance
information is subject to The Privacy Act of 1974, as
amended, which prohibits public release of the names
of policyholders or recipients of financial assistance
and the amount of the claim payment or assistance.
However, maps showing general areas where claims
have been paid can be made public. If a plan includes
the names of policyholders or recipients of financial
assistance, or the amount of the claim payment or
assistance, the plan cannot be approved until the
information covered by the Privacy Act is removed
from the plan or is properly protected per the Privacy
Act.
Element C: Mitigation Strategy
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C1. Does the plan document each participant’s existing authorities, policies, programs and resources and its
ability to expand on and improve these existing policies and programs? (Requirement 44 CFR § 201.6(c)(3))
The plan must describe each jurisdiction’s existing
authorities, policies, programs and resources
available to accomplish hazard mitigation.
Examples include, but are not limited to: staff
involved in local planning activities, public works,
and emergency management; funding through
taxing authority, and annual budgets; or regulatory
authorities for comprehensive planning, building
codes, and ordinances.
C1-a. The plan must describe how the existing
authorities, policies, programs, funding and resources
of each participant are available to support the
mitigation strategy. This must include a discussion of
the existing building codes and land use and
development ordinances or regulations. Capabilities
may be described in a table or narrative.
Discussion means a narrative or other materials that
provide context on a section of the plan.
Describing the current capabilities provides a rationale
for which mitigation projects can be undertaken to
address the vulnerabilities identified in the Risk
Assessment.
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C1-b. The plan must describe the ability of each
participant to expand on and improve the capabilities
described in the plan.
If the participants do not have the ability or authority to
expand and/or improve their capabilities, the plan must
describe this lack of ability or authority.
Gaps and limitations for each participant may be
addressed as actions in the mitigation strategy.
C2. Does the plan address each jurisdiction’s participation in the NFIP and continued compliance with NFIP
requirements, as appropriate? (Requirement 44 CFR § 201.6(c)(3)(ii))
The plan must describe each jurisdiction’s
participation in the NFIP and describe their
floodplain management program for continued
compliance. Simply stating “The community will
continue to comply with NFIP,” will not meet this
requirement. The description could include, but is
not limited to:
Adoption and enforcement of floodplain
management requirements, including regulating
new construction in Special Flood Hazard Areas
(SFHAs);
Floodplain identification and mapping, including
any local requests for map updates; or
Description of community assistance and
monitoring activities. Jurisdictions that are
currently not participating in the NFIP and where
an FHBM or FIRM has been issued may meet
this requirement by describing the reasons why
the community does not participate.
C2-a. The plan must describe participation in the NFIP
for each participant, as applicable, in accordance with
NFIP regulatory requirements. The following information
must be provided for each participant.
1. Adoption of NFIP minimum floodplain management
criteria via local regulation.
2. Adoption of the latest effective Flood Insurance
Rate Map (FIRM), if applicable.
3. Implementation and enforcement of local floodplain
management regulations to regulate and permit
development in SFHAs.
4. Appointment of a designee or agency to implement
the addressed commitments and requirements of
the NFIP.
5. Description of how participants implement the
substantial improvement/substantial damage
provisions of their floodplain management
regulations after an event.
Simply stating, “The community will continue to comply
with the NFIP” is not sufficient to meet the requirement.
Jurisdictions not currently participating in the NFIP,
where a Flood Hazard Boundary Map or FIRM has been
issued, may meet this requirement by describing why
the community does not participate in the NFIP.
For jurisdictions that voluntarily participate in the CRS,
it is highly recommended that this description also
include related activities and address any issues raised
during community assistance and monitoring activities.
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C3. Does the plan include goals to reduce/avoid long-term vulnerabilities to the identified hazards? (Requirement
44 CFR § 201.6(c)(3)(i))
The plan must include general hazard mitigation
goals that represent what the jurisdiction(s) seeks
to accomplish through mitigation plan
implementation.
Goals
are broad policy statements that explain
what is to be achieved.
The goals must be consistent with the hazards
identified in the plan.
C3-a. The plan must include goals to reduce the risk of
the identified hazards. The goals must be consistent
with the hazards identified in the plan. Goals may be
presented as general statements applying to more than
one hazard, or they may be itemized to each of the
identified hazards.
Goals are broad, long-term policy and vision statements
that explain what is to be achieved by implementing the
mitigation strategy.
C4. Does the plan identify and analyze a comprehensive range of specific mitigation actions and projects for each
jurisdiction being considered to reduce the effects of hazards, with emphasis on new and existing buildings and
infrastructure? (Requirement 44 CFR § 201.6(c)(3)(ii))
The plan must include a mitigation strategy that 1)
analyzes actions and/or projects that the
jurisdiction considered to reduce the impacts of
hazards identified in the risk assessment, and 2)
identifies the actions and/or projects that the
jurisdiction intends to implement.
Mitigation actions and projects
means a hazard
mitigation action, activity or process (for example,
adopting a building code) or it can be a physical
project (for example, elevating structures or
retrofitting critical infrastructure) designed to
reduce or eliminate the long term risks from
hazards. This sub‐element can be met with either
actions or projects, or a combination of actions and
projects.
The mitigation plan may include non‐mitigation
actions, such as actions that are emergency
response or operational preparedness in nature.
These will not be accepted as hazard mitigation
actions, but neither will FEMA require these to be
removed from the plan prior to approval.
A
comprehensive range
consists of different hazard
mitigation alternatives that address the
vulnerabilities to the hazards that the jurisdiction(s)
determine are most important.
Each jurisdiction participating in the plan must
have mitigation actions specific to that jurisdiction
C4-a. The mitigation strategy must include an analysis
of a comprehensive range of actions or projects that
the participants considered to specifically address
vulnerabilities identified in the risk assessment.
Actions considered must emphasize reducing risk to
existing buildings, structures and infrastructure, as well
as limiting risk to new development and
redevelopment.
The range of actions considered should include
mitigation actions that benefit underserved
communities and socially vulnerable populations.
It is important for all actions considered to be
documented, be as specific as possible, and be clearly
linked to the vulnerabilities and impacts identified in
the risk assessment. This includes actions for
alleviating data deficiencies or building up capabilities
related to mitigation implementation. Documenting all
ideas provides a record of what actions were
considered, and why. Additionally, this creates a list of
actions that can be reconsidered as conditions change.
Analyzing a comprehensive range means considering
mitigation alternatives spanning all types of solutions.
These may include local plans and regulations,
structure and infrastructure projects, natural systems
protection, and education and awareness programs.
This analysis helps a jurisdiction select actions based
on its own capabilities, as well as the social, technical
and economic feasibility of the action.
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that are based on the community’s risk and
vulnerabilities, as well as community priorities.
The action plan must reduce risk to existing
buildings and infrastructure as well as limit any
risk to new development and redevelopment.
With
emphasis on new and existing building and
infrastructure
means that the action plan includes
a consideration of actions that address the built
environment.
A mitigation action is a measure, project, plan or
activity proposed to reduce current and future
vulnerabilities described in the risk assessment.
C4-b. Each plan participant must identify one or more
mitigation actions the participant(s) intends to
implement for each hazard addressed in the risk
assessment.
The actions must be achievable and demonstrate how
the mitigation activities reduce the risks identified in
the risk assessment.
The actions may apply to physical infrastructure, as
well as the populations within the planning area.
Actions may apply to one or more participants, as long
as each participant is clearly associated with one or
more actions.
Non-mitigation actions can be included in a plan but
will not be considered as part of the mitigation action
requirement. These include actions that do not
contribute to a long-term solution for the problem they
are intended to address.
Plan updates may validate and include previously
included actions if those actions are being
reconsidered for implementation to reduce the risks of
identified hazards in the plan’s current risk
assessment.
C5. Does the plan contain an action plan that describes how the actions identified will be prioritized (including a
cost-benefit review), implemented, and administered by each jurisdiction? (Requirement 44 CFR §
201.6(c)(3)(iv)); (Requirement §201.6(c)(3)(iii))
The plan must describe the criteria used for
prioritizing implementation of the actions.
The plan must demonstrate when prioritizing
hazard mitigation actions that the local
jurisdictions considered the benefits that would
result from the hazard mitigation actions versus
the cost of those actions. The requirement is met
as long as the economic considerations are
summarized in the plan as part of the community’s
analysis. A complete benefic‐cost analysis is not
required. Qualitative benefits (for example, quality
of life, natural and beneficial values, or other
“benefits”) can also be included in how actions will
be prioritized.
The plan must identify the position, office,
department, or agency responsible for
C5-a. The plan must describe the criteria used for
prioritizing the implementation of the actions. The
criteria must include an emphasis on the extent to
which benefits are maximized, in relation to the
associated costs of the action.
Although a full benefit-cost analysis is not necessary,
the plan must demonstrate that proposed mitigation
actions will be prioritized by weighing the cost of the
action versus the benefits the action will produce, in
addition to other prioritization factors. Another example
of a prioritization method may be that jurisdictions
establish a minimum threshold for the dollar amount,
types or number of benefits an action must have to be
considered for implementation. Or they could simply
prioritize actions with more benefits than other
alternatives.
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implementing and administering the action (for
each jurisdiction), and identify potential funding
sources and expected timeframes for completion.
Other methodologies are acceptable if the plan
demonstrates that the action’s monetary and non-
monetary benefits were specifically emphasized and
considered in the community’s decision-making
process. Qualitative benefits (quality of life, natural and
beneficial values, etc.) may be used, especially in
considering mitigation actions that alleviate long-term
risk from future conditions, including climate change,
and benefit underserved communities.
C5-b. The action plan must identify who is responsible
for administering each action, along with the action’s
potential funding sources and expected time frames for
completion.
The plan must provide the position, office, department
or agency responsible for implementing/administrating
the identified mitigation actions. Names are not
required, but the plan must provide enough detail for
users to determine who within the jurisdiction will
implement or administer the mitigation action.
The plan must identify applicable potential funding
sources, with details beyond generic terms such as
“federal,” “state” and/or “local.” The identified funding
sources must be relevant to implementing the
associated actions.
The plan must identify expected time frames for
completion. General terms like “short-term,” “medium-
term” and “long-term” must be defined. “Ongoing” is
acceptable when used appropriately (e.g., for multi-
phased projects).
Element D: Plan Maintenance (Formerly Plan Review, Evaluation, and Implementation)
Element D reflects plan review, evaluation, and implementation in the 2011 PRT but reflects plan maintenance in
the 2022 PRT.
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D1 (formerly A5). Is there discussion of how each community will continue public participation in the plan
maintenance process? (Requirement 44 CFR § 201.6(c)(4)(iii))
The plan must describe how the jurisdiction(s) will
continue to seek public participation after the plan
has been approved and during the plan’s
implementation, monitoring and evaluation.
D1-a. The plan must describe how the participant(s) will
continue to seek public participation after the plan has
been approved and during the plan’s implementation,
monitoring, and evaluation.
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Participation
means engaged and given the chance
to provide feedback. Examples include, but are not
limited to, periodic presentations on the plan’s
progress to elected officials, schools or other
community groups, annual questionnaires or
surveys, public meetings, postings on social media
and interactive websites.
The plan may contain a narrative description or an
itemized list of steps, demonstrating the prescribed
method that will be followed to obtain future public
participation.
Special consideration should be given to identifying
and using unique and meaningful ways to keep the
public engaged in the process.
Examples include, but are not limited to: periodic
presentations on the plan’s progress to elected
officials, schools or other community groups; annual
questionnaires or surveys; public meetings; postings on
social media; and interactive websites.
D2 (formerly A6). Is there a description of the method and schedule for keeping the plan current (monitoring,
evaluating and updating the mitigation plan within a five-year cycle)? (Requirement 44 CFR § 201.6(c)(4)(i))
The plan must identify how, when, and by whom
the plan will be monitored.
Monitoring
means tracking the implementation of
the plan over time. For example, monitoring may
include a system for tracking the status of the
identified hazard mitigation actions.
The plan must identify how, when, and by whom
the plan will be evaluated.
Evaluating
means assessing the effectiveness of
the plan at achieving its stated purpose and goals.
The plan must identify how, when, and by whom
the plan will be updated.
Updating
means reviewing and revising the plan at
least once every five years.
The plan must include the title of the individual or
name of the department/agency responsible for
leading each of these efforts.
D2-a. The plan must identify how, when and by whom
the plan will be tracked for implementation over its five-
year cycle (monitoring).
Monitoring may be described by including a narrative
description or an itemized list of steps demonstrating
the prescribed method that will be followed to monitor
the plan after plan approval and during the plan's
implementation.
Monitoring means tracking the implementation of the
plan over time. For example, monitoring may include a
system for tracking the status of the identified hazard
mitigation actions.
D2-b. The plan must identify how, when and by whom
the plan will be assessed for effectiveness at achieving
its stated purpose and goals (evaluating).
The evaluation method may be described by including a
narrative description or an itemized list of steps
demonstrating the prescribed method that will be
followed to evaluate the plan after plan approval and
during the plan's implementation, and prior to the
plan's update.
Evaluating means assessing the effectiveness of the
plan at achieving its stated purpose and goals.
D2-c. The plan must identify how, when and by whom
the plan will be reviewed and revised at least once
every five years (updating).
The update method may be described by including a
narrative description or an itemized list of steps that
will be followed to update the plan prior to
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resubmission for approval and during the plan's
implementation.
Updating means reviewing and revising the plan at
least once every five years.
D3 (formerly C6). Does the plan describe a process by which each community will integrate the requirements of
the mitigation plan into other planning mechanisms, such as comprehensive or capital improvement plans, when
appropriate? (Requirement 44 CFR § 201.6(c)(4)(ii))
The plan must describe the community’s process
to integrate the data, information, and hazard
mitigation goals and actions into other planning
mechanisms.
The plan must identify the local planning
mechanisms where hazard mitigation information
and/or actions may be incorporated.
Planning mechanisms
means governance
structures that are used to manage local land use
development and community decision
‐
making,
such as comprehensive plans, capital improvement
plans, or other long
‐
range plans.
A multi‐jurisdictional plan must describe each
participating jurisdiction’s individual process for
integrating hazard mitigation actions applicable to
their community into other planning mechanisms.
The updated plan must explain how the
jurisdiction(s) incorporated the mitigation plan,
when appropriate, into other planning
mechanisms as a demonstration of progress in
local hazard mitigation efforts.
The updated plan must continue to describe how
the mitigation strategy, including the goals and
hazard mitigation actions will be incorporated into
other planning mechanisms.
D3-a. The plan must describe the community’s process
to integrate the plan’s data, information, and hazard
mitigation goals and actions into other planning
mechanisms.
Integrate means to include hazard mitigation
principles, vulnerability information and mitigation
actions into other existing community planning to
leverage activities that have co-benefits, reduce risk
and increase resilience.
Planning mechanisms refers to the governance
structures used to manage local land use development
and community decision-making, such as budgets,
comprehensive plans, capital improvement plans,
economic development strategies, climate action plans
or other long‐range plans.
D3-b. The plan must identify the local planning
mechanisms where hazard mitigation information/
actions may be integrated. The identified list of
planning mechanisms must be applicable to the plan
participant(s) and not contradict the identified
capabilities.
D3-c. A multi-jurisdictional plan must describe each
participant's individual process for integrating
information from the mitigation strategy into their
identified planning mechanisms.
This element may be met with a general narrative
description if the process is applicable to each of the
plan participants; however, any participant who cannot
apply the same process as other plan participants must
include their unique process for integration.
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Element E: Plan Update
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E1 (formerly D1). Was the plan revised to reflect changes in development? (Requirement 44 CFR § 201.6(d)(3))
The plan must describe changes in development
that have occurred in hazard prone areas and
increased or decreased the vulnerability of each
jurisdiction since the last plan was approved. If no
changes in development impacted the
jurisdiction’s overall vulnerability, plan updates
may validate the information in the previously
approved plan.
Changes in development
means recent development
(for example, construction completed since the last
plan was approved), potential development (for
example, development planned or under consideration
by the jurisdiction), or conditions that may affect the
risks and vulnerabilities of the jurisdictions (for
example, climate variability, declining populations or
projected increases in population, or foreclosures). Not
all development will affect a jurisdiction’s vulnerability.
E1-a. The plan must describe changes in development
that have occurred in hazard-prone areas and how they
have increased or decreased the vulnerability of each
jurisdiction since the previous plan was approved. If no
development changes affected the jurisdiction’s overall
vulnerability, this must be stated with the plan.
Changes in development means recent development
(for example, construction completed since the last
plan was approved), potential development (for
example, development planned or under consideration
by the jurisdiction), or conditions that may affect the
risks and vulnerabilities of the jurisdictions (for
example, climate change, declining populations or
projected increases in population, or foreclosures) or
shifts in the needs of underserved communities or gaps
in social equity. This can also include changes in local
policies, standards, codes, regulations, land use
regulations and other conditions.
E2 (formerly, D3-a, B2-a, and C6-d). Was the plan revised to reflect changes in priorities and progress in local
mitigation efforts? (Requirement 44 CFR § 201.6(d)(3))
D3-a. The plan must describe if and how any priorities
changed since the plan was previously approved. If
no changes in priorities are necessary, plan updates
may validate the information in the previously
approved plan.
D2-a. The plan must describe the status of hazard
mitigation actions in the previous plan by identifying
those that have been completed or not completed.
For actions that have not been completed, the plan
must either describe whether the action is no longer
relevant or be included as part of the updated
action plan.
C6-d. The updated plan must explain how the
jurisdiction(s) incorporated the mitigation plan,
when appropriate, into other planning mechanisms
as a demonstration of progress in local hazard
mitigation efforts.
E2-a. The plan must describe how it was revised due to
a change in priorities for each jurisdiction. This can be
done as a narrative or with detailed statements in the
appropriate sections of the plan. The priorities to be
considered are defined by the participant(s). If the
participant(s) has no change in priorities since the last
approval of the mitigation plan, this must be stated.
E2-b. The plan must describe the status of all hazard
mitigation actions in the previous plan by identifying
whether they have been completed or not, for each
jurisdiction. For actions that are not complete, the plan
must state whether the action is no longer relevant or
will be included in the updated action plan.
E2-c. The updated plan must explain how the
jurisdiction(s) integrated information from the
mitigation plan into other planning mechanisms, as a
demonstration of progress in local hazard mitigation
efforts. If information from the previous plan was not
integrated into other planning mechanisms, this must
be stated.
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Element F: Plan Adoption (formerly Element E of the 2011 PRT)
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F1 (formerly E1). For single-jurisdictional plans, has the governing body of the jurisdiction formally adopted the
plan to be eligible for certain FEMA assistance? (Requirement 44 CFR § 201.6(c)(5))
The plan must include documentation of plan
adoption, usually a resolution by the governing
body or other authority.
If the local jurisdiction has not passed a formal
resolution, or used some other documentation of
adoption, the clerk or city attorney must provide
written confirmation that the action meets their
community’s legal requirements for official adoption
and/or the highest elected official or their designee
must submit written proof of the adoption. The
signature of one of these officials is required with
the explanation or other proof of adoption.
Minutes of a council or other meeting during which
the plan is adopted will be sufficient if local law
allows meeting records to be submitted as
documentation of adoption. The clerk of the
governing body, or city attorney,
must provide a
copy of the law and a brief, written explanation such
as, “in accordance with section ___ of the city
code/ordinance, this constitutes formal adoption of
the measure,” with an official signature.
If adopted after FEMA review, adoption must take
place within one calendar year of receipt of FEMA’s
“Approval Pending Adoption.” See Section 5, Plan
Review Procedure for more information on
“Approvable Pending Adoption.”
F1-a. The jurisdiction must provide documentation of
plan adoption, usually a resolution by the governing
body or other authority, to receive approval.
Documentation may be provided in the form of meeting
minutes, resolutions, signed letter or any other method
to demonstrate that official adoption by the participant
has occurred.
See Section 6, Plan Review and Approval, for more
information on the process to adopt the plan after
review by the state and FEMA.
F2 (formerly E2). For multi-jurisdictional plans, has the governing body of each jurisdiction officially adopted the
plan to be eligible for certain FEMA assistance? (Requirement 44 CFR § 201.6(c)(5))
Each jurisdiction that is included in the plan must
have its governing body adopt the plan prior to
FEMA approval, even when a regional agency has
the authority to prepare such plans.
As with single jurisdictional plans, in order for FEMA
to give approval to a multi‐jurisdictional plan, at
least one participating jurisdiction must formally
adopt the plan within one calendar year of FEMA’s
designation of the plan as “Approvable Pending
Adoption.” See Section 5, Plan Review Procedure
for more information on “Approvable Pending
Adoption.”
F2-a. To receive approval, the participants must adopt
the plan and provide documentation that the adoption
has occurred.
Participants that submit their adoption documentation
separately from the other multi-jurisdictional plan
participants will not receive a new expiration date.
Participating jurisdictions that adopt the plan more
than one year after Approvable Pending Adoption (APA)
status has been issued must either:
Validate that their information in the plan remains
current with respect to both the risk assessment (no
recent hazard events, no changes in development)
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and their mitigation strategy (no changes
necessary); or
Make the necessary updates before submitting the
adoption resolution to FEMA.
Element G: High Hazard Potential Dams (Optional)
The 2022 Local Policy incorporates existing mitigation planning requirements for the Rehabilitation of High Hazard
Potential Dams (HHPD) Grant Program. The policy expanded the types of dams that must be planned for from
“eligible HHPDs” to all “HHPDs.” This change came from consultation with the National Dam Safety Review Board.
The table below compares the 2020 HHPD Grant Guidance
with the requirements established in the 2022 Local
Mitigation Planning Policy Guide.
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HHPD1. Did the plan describe the incorporation of existing plans, studies, reports and technical information for
HHPDs?
To meet this requirement with a specific focus on
eligible high hazard potential dams, the mitigation plan
must include descriptions of:
HHPD1-a: How the state dam safety agency
coordinated with the jurisdiction and/or local dam
owners.
NOTE: Ensure sensitive and/or personally identifiable
information is protected
HHPD1-b: Information shared by the state and/or local
dam owners. Examples may include:
Location and size of the PAR, as well as potential
impacts to institutions and critical
infrastructure/facilities/lifelines.
Inundation maps, emergency action plans,
floodplain management plans, and/or data or
summaries provided by dam breach modeling
software such as HEC-RAS, DSS-WISE HCOM, DSS-
WISE Lite, FLO-2D, as well as more detailed studies.
To meet this requirement with a specific focus on
eligible HHPDs, the mitigation plan must include
descriptions of:
HHPD1-a: How the local government coordinated with
local dam owners and/or the state dam safety agency.
NOTE: Ensure sensitive and/or personally identifiable
information is protected.
HHPD1-b: Information shared by the state and/or local
dam owners. Examples may include:
Location and size of the population at risk, as well
as potential impacts to institutions and critical
infrastructure/facilities/lifelines.
Inundation maps, emergency action plans,
floodplain management plans and/or data or
summaries provided by dam breach modeling
software, such as HEC-RAS, DSS-WISE HCOM, DSS-
WISE Lite, FLO-2D, as well as more detailed studies.
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HHPD2. Did the plan address HHPDs in the risk assessment?
To meet this requirement with a specific focus on
eligible HHPDs, the mitigation plan must:
HHPD2-a: Describe the risks and vulnerabilities to and
from eligible high hazard potential dams, including:
Potential cascading impacts of storms, seismic
events, landslides, wildfires, etc. on dams that might
affect up and downstream flooding potential in
terms of breach, non- breach, and residual risks.
Potential significant economic, environmental, or
social impacts as well as multi- jurisdictional
impacts from a dam incident.
Location and size of populations at risk from eligible
HHPDs as well as potential impacts to institutions
and critical infrastructure/facilities/lifelines.
Methodology and/or assumptions for risk data and
inundation modeling should be noted.
HHPD2-b: Document limitations and describe the
approach to address deficiencies.
To meet this requirement with a specific focus on
HHPDs, the mitigation plan must:
HHPD2-a: Describe the risks and vulnerabilities to and
from eligible HHPDs, including:
Potential cascading impacts of storms, seismic
events, landslides, wildfires, etc. on dams that might
affect upstream and downstream flooding potential.
Potential significant economic, environmental or
social impacts, as well as multi-jurisdictional
impacts, from a dam incident.
Location and size of populations at risk from HHPDs,
as well as potential impacts to institutions and
critical infrastructure/facilities/lifelines.
Methodology and/or assumptions for risk data and
inundation modeling.
HHPD2-b: Document the limitations and describe the
approach for addressing deficiencies.
HHPD3. Did the plan include mitigation goals to reduce long-term vulnerabilities from HHPDs?
To meet this requirement with a specific focus on
eligible high hazard potential dams, the mitigation plan
must:
HHPD3-a. Address a reduction in vulnerabilities to and
from eligible high hazard potential dams as part of their
own goals or with other long-term strategies.
HHPD3-b. Link proposed actions to reducing long-term
vulnerabilities consistent with the goals.
To meet this requirement with a specific focus on
eligible HHPDs, the mitigation plan must:
HHPD3-a: Address a reduction in vulnerabilities to and
from HHPDs as part of its own goals or with other long-
term strategies. The plan does not need to include a
goal specific to HHPDs alone.
HHPD3-b: Link proposed actions to reducing long-term
vulnerabilities consistent with the goals.
HHPD4-a. Did the plan include actions that address HHPDs and prioritize mitigation actions to reduce
vulnerabilities from HHPDs?
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To meet this requirement with a specific focus on
eligible high hazard potential dams, the mitigation plan
must:
HHPD4-a: Describe a range of specific actions, such as:
Rehabilitating and/or removing dams.
Adopting and enforcing land use ordinances in
inundation zones.
Acquiring and/or elevating structures, and/or
acquiring easements in inundation zones.
Flood protection, such as berms, floodwalls, or
floodproofing, in inundation zones.
HHPD4-b. Describe the criteria used for prioritizing
actions related to eligible high hazard potential dams.
HHPD4-c: Identify the position, office, department or
agency responsible for implementing and administering
the action related to mitigating hazards to or from
eligible HHPDs high hazard potential dams.
To meet this requirement with a specific focus on
eligible HHPDs, the mitigation plan must:
HHPD4-a: Describe a range of specific actions, such as:
Rehabilitating/removing dams.
Adopting and enforcing land use ordinances in
inundation zones.
Elevating structures in inundation zones.
Adding flood protection, such as berms, floodwalls
or floodproofing, in inundation zones.
HHPD4-b: Describe the criteria used for prioritizing
actions related to eligible HHPDs.
HHPD4-c: Identify the position, office, department or
agency responsible for implementing and administering
the action related to mitigating hazards to or from
eligible HHPDs.
Element H: Additional State Requirements (Optional)
(Formerly Element F.) This space is for the state to include additional requirements.
