By Angie Mettlen, Director of Strategic Funding and Regulatory Affairs, WK Dickson
No. This isn't an article about '70s classic rock. It is an overview of an exciting new Federal Emergency Management Agency (FEMA) program, Building Resilient Infrastructure and Communities (BRIC). The parallel is that music from the '70s changed the rock genre, and BRIC aims to change how mitigation has been done historically.
The passage of the Disaster Recovery Reform Act (DRRA) paved the way for this paradigm shift. In 2018, FEMA estimated that it had expended 90% of its mitigation dollars after declared disasters. Because of this, the DRRA paved the way to allow more pre-disaster mitigation funding to reduce post-disaster expenditures, which are becoming unsustainable. This legislation also emphasizes funding infrastructure resiliency. As a result, the BRIC program was born and is set up to fund infrastructure mitigation of varying types through national competition and capability and capacity-building activities through state set-asides.
Before BRIC, FEMA was dependent on annual appropriations from Congress to fund the pre-disaster mitigation program, and the funding levels were generally low. BRIC is not dependent on appropriations and is funded based on 6% of the previous year's declared disaster dollars. FEMA has committed to making at least $500 million available annually for state set-asides and competitive grants. In 2021, President Biden authorized an additional $500 million for the BRIC program, making $1 billion available for the program's 2nd funding cycle currently in progress. The passage of the historic Infrastructure Investment and Jobs Act in November 2021 included an additional $700 million per year for fiscal years 2022-2026. The great news is that BRIC funding is 75% grant with a 25% non-federal match requirement and a $50 million per project cap. (Note: There is also an opportunity for a 90% grant for small, disadvantaged communities.) That's a lot of BRICs! So, how can you take advantage of this unprecedented opportunity for pre-disaster infrastructure mitigation?
States are the direct applicants to FEMA for BRIC funding. The first step is to understand your state's specific application process. Any unit of local government, tribal governments, state agencies, and tribal agencies are eligible sub-applicants. The annual BRIC application process begins in late September/early October with the issuance of a Notice of Funding Opportunity and opening of the application portal in FEMA GO, FEMA's online grant portal. Each state has a different process for selecting sub-applicant projects and will advertise their processes at the same time. Final applications are due in late January. Here are a few other eligibility criteria:
• The sub-applicant must have a FEMA-approved hazard mitigation plan at the time of application, funding award, and project completion.
• The state in which the sub-applicant is located must have had a declared disaster within the last seven years. (Note: The COVID-19 Pandemic resulted in a national disaster declaration in March 2020; therefore, all states will be eligible in the near term.)
• The project must have a benefit-cost ratio of one or more, which means that the project's benefits must be at least equal to the costs.
As with any grant program, understanding the scoring criteria is critical. The next step is to review the FEMA application elements, which FEMA has made pretty easy to do. They have established technical and qualitative criteria with specific requirements and points values for each. Technical criteria are objective; you either meet the criteria for the points or you don't. Qualitative criteria are subjective and are reviewed by a FEMA review panel. Points for these criteria are given based on how well each is addressed in the application. All criteria are based on protecting one or more of the established Community Lifelines. Community Lifelines are:
• Fundamental services that are critical for a community
• Disruption of them can impact response and resiliency during and following a disaster.
• They allow for the continuous operation of government functions or critical services that protect a community's health, safety, and economy.
The state emergency management agency has selected your project, and you have submitted your full application in FEMA GO. What now? Your application will undergo review, and initial project selection announcements will be made in June/July. If selected, there is a 36-month grant period in which the project will need to be completed. Grant funds are distributed on a reimbursement basis. These are federal funds, so they come with normal federal requirements. These requirements include:
• Environmental/historic preservation review
• Compliance with federal/state/ local procurement
• All other federal contract provisions
Although the normal provisions under the Stafford Act and federal requirements still apply, there are a few things that make BRIC funding different. Project scoping and most pre-award costs are now eligible for funding, and emphasis is being placed on nature-based design elements, green infrastructure, innovation, and multi-layer benefits. Additionally, as previously mentioned, there is a $50 million per project cap and much more annual funding is targeted at pre-disaster activities.
So, this isn't just another BRIC in the wall. It is a way for communities to build resiliency and reduce risk before a disaster strikes and not wait until after it occurs. To be the most prepared you can be for the next funding cycle, here are a few final tips:
• Make sure your unit of local government has active registrations in the System for Award Management (SAM) and in FEMA GO. There are new administrator requirements in SAM and the administrator must be in the same both systems.
• Review the current BRIC Notice of Funding Opportunity and BRIC resources. Use these to evaluate your potential project and start gathering information and documentation to support your application. Complete an initial
self-scoring of your project!
• Reach out to your state BRIC program staff to discuss your project and learn more about their process for approving sub applications. This will allow them to learn more about your project ahead of the application process and provide valuable input and feedback to make your application as competitive as possible. They want your applications to be funded!
ABOUT THE AUTHOR
Angie Mettlen, WK Dickson’s Director of Strategic Funding and Regulatory Affairs, has nearly 30 years of experience in the water industry and, during this time, has become a recognized leader in state and federal infrastructure funding and regulatory programs. During the last decade alone, she has guided co-workers and helped clients to secure over $700 million in funding for a wide variety of infrastructure projects.