Figure 1. Funding availability overview
What’s new in FY2023
Following a summer of intensive stakeholder engagement, FEMA has made some significant changes to the BRIC program. Primarily, program updates are focused on promoting the value of building codes for protecting the built environment, increasing access to funding, and reducing complexity for the most at-risk and in-need jurisdictions.
Doubling down on equity and future conditions
While set-asides for states/territories ($2M) and tribes ($50M) remain the same, FEMA has integrated new CDRZs into the program to better target federal spending on communities deemed most at risk from the effects of natural hazards and climate change. Specifically, FEMA requires at least $400k from either set-aside to benefit a CDRZ community. CDRZ-benefiting projects are eligible for up to 90% federal cost share and may receive up to 40 points from the technical evaluation.
Reducing the BCA burden
In addition to new criteria for set-aside spending, FEMA has made significant reforms to its benefit cost analysis (BCA) requirements to reduce the application burden for disadvantaged communities that may lack capacity and small-scale projects. CDRZ communities, Economically Disadvantaged Rural Communities, and federally recognized tribes can now submit a project application without a BCA and may receive assistance from FEMA upon review.
Additionally, proposed projects under $1M can replace the detailed BCA with a benefits and cost-effectiveness narrative—reinforced using qualitative and quantitative data—and FEMA will estimate a benefit cost ratio (BCR) during review. Finally, FEMA has established a 3% discount rate for all projects requiring a BCA to make it easier for applicants to demonstrate cost-effectiveness. These changes to the BCA portion of the application are intended to increase accessibility of BRIC to ultimately distribute funding more equitably.
Promoting building code adoption and enforcement
FEMA is also reinforcing the importance of adopting and enforcing resilient building codes in this year’s program. A combined $147M has been set-aside for states/territories and tribes to advance building code-specific activities such as updating existing codes to incorporate higher standards and enhancing workforce capabilities related to building codes through technical assistance and training. Note that the new set-asides are coupled with reduced points for building code-specific evaluation criteria. BRIC offers additional points for communities that have locally adopted building codes, making this the first year that earning points is not solely reliant on the applicant’s mandatory state, tribal, or territory-wide adoption.
New scoring for evaluation criteria
FEMA has also made significant changes to its technical and qualitative evaluation criteria compared to the FY2022 BRIC cycle (see Figure 2 and Figure 3).
- Technical evaluation criteria
- 15 points (-5) for critical infrastructure projects.
- 15 points (+5) for nature-based solutions offered on two tiers, with 5 points for neighborhood/site-scale projects and 15 points for watershed or landscape-scale projects.
- 20 points (-20) total for Building code adoption (or adoption of higher standards) and Enforcement (Building Code Effectiveness Grading Schedule Rating).
- 30 points (+30) for projects in or primarily benefiting CEJST communities OR 40 points (+40) for primary benefits to economically disadvantaged rural community, federally recognized tribe, or CDRZ community.
- 0 points (-5) for exceeding the non-federal cost share.
- 0 points (-15) for primary benefits to populations over 3,000 and per capita income less than 80% of the national average, based on the Centers for Disease Control and Prevention (CDC) Social Vulnerability Index (SVI).
- Qualitative evaluation criteria
- 30 points (-5) for risk reduction and resilience effectiveness.
- 5 points (-10) for leveraging partners to ensure projects meet community needs.
Fig. 2 Technical evaluation criteria changes
Fig. 3 Qualitative evaluation criteria changes
Federal policy in action
The key to developing compliant and competitive BRIC applications will be understanding three pieces of federal policy: President Biden’s Executive Order (E.O.) 14008, Tackling the Climate Crisis at Home and Abroad; E.O. 14072, Strengthening the Nation’s Forests, Communities, and Local Economies; and Federal Flood Risk Management Standard (E.O. 13690, reinstated under E.O. 14030).
The Justice40 Initiative and CDRZs
In accordance with E.O. 14008 and the Justice 40 Initiative, FEMA is promoting more BRIC funding for economically disadvantaged communities that are more likely to experience the negative impacts of climate change. Specifically, the program is awarding additional points to (1) economically disadvantaged rural communities, (2) all federally recognized tribes and tribal entities, and (3) all census tracts identified as disadvantaged pursuant to the CEJST. (The CEJST website has multiple ways to offer feedback on the tool and federally-identified disadvantaged census tracts. The public can offer feedback for specific census tracts or submit alternative data sources or ideas for consideration.) Additionally, the program is awarding additional points to projects located within and/or primarily benefit census tracks designated as CRDZs. It will be critical for applicants to use these tools to create data-driven analyses of social vulnerability this application cycle.
Promoting large-scale nature-based solutions in project design
A consistent theme from the stakeholder feedback FEMA received during the summer was prioritizing projects that integrate nature-based solutions. In response, FEMA has significantly increased the maximum total points for projects that incorporate nature-based solutions and offered these points on two distinguishable tiers. For projects that incorporate nature-based solutions at the landscape and watershed scale, FEMA now awards 15 points compared to only five points for neighborhood or site-specific scale projects. These changes are intended to incentivize incorporation of nature-based solutions at a greater scope, scale, and complexity that comprehensively, instead of incrementally, address resilience—a major tenet of system-based mitigation. FEMA has recently released two guides—A Guide for Local Communities (2021) and Strategies for Success (2023)—to help enhance applicants’ understanding of the benefits of using nature-based solutions and equip communities to design and implement these projects to advance natural hazards mitigation and climate adaption. Identifying opportunities, especially those on a larger scale, to integrate nature-based design elements into your projects will be an important differentiator this application cycle.
Federal Flood Risk Management Standard (FFRMS)
FFRMS is intended to improve the nation’s preparedness and resilience against flooding, including the effects of climate change and other threats. According to the Notice of Funding Opportunity (NOFO), all proposed mitigation projects under BRIC must conform with the FFRMS. Flood protection of critical and essential facilities must protect to three feet above the base flood elevation, or the 500-year flood elevation, whichever is lower. Correct application of these design criteria and higher standards are important considerations for a compliant flood risk reduction project application.
Navigating the application process
In addition to new opportunities, the program’s FY2023 cycle also presents novel challenges. Due to FEMA’s Immediate Needs Funding (INF) announcement in August 2023 and congressional delays in passing a federal budget, the delayed NOFO resulted in shifts to the typical BRIC timeline that not been reflected in some state timelines. States often have their own deadlines for pre-applications (or Letters of Interest, Notices of Intent, etc.) and sub-applications that enable them to conduct a thorough review, request additional information, and ultimately approve or deny submission to FEMA. Uncertainty in timing of federal funding coupled with earlier state deadlines forced many prospective sub-applicants to submit pre-applications prior to FEMA’s release of the NOFO and important policy changes, most notably FEMA’s announcement of the CDRZ designation.
As a result, many applicants were not able to reflect the new program priorities within their pre-applications. Some may have been less motivated, given the program’s competitiveness historically, to even submit a pre-application without knowing the new advantages offered to certain communities. If you were required to submit a pre-application prior to the release of the NOFO and feel your project is now more competitive under the new BRIC priorities, or if you missed your state’s deadline but meet the new disadvantaged community criteria and have an eligible project, we encourage you to reach out to your State Hazard Mitigation Office or other state, tribal, or territorial agency for assistance.
The application period opened on October 16, 2023. All applications must be submitted into the FEMA Grant Outcomes (FEMA GO) management system by 3pm ET on February 29, 2024. Interested sub-applicants should consult with their state, tribal, or territorial agency—and monitor their websites—for additional details and deadlines for pre-applications and sub-applications.
We hope this information helps you navigate the complicated recovery funding and mitigation landscape. A successful application will allow you to maximize every dollar to achieve your goals and provide your community a more resilient future when facing natural disasters.