Element C4
The hazard mitigation strategy shall include a section that identifies and analyzes a comprehensive range of specific mitigation actions and projects being considered to reduce the effects of each hazard, with particular emphasis on new and existing buildings and infrastructure.
44 CFR §201.6(c)(3)(ii)
Federal mitigation planning regulations (see Element C4) require that each participating jurisdiction identify and analyze a comprehensive range of specific mitigation actions and projects to reduce the impacts of the hazards identified in the risk assessment. The emphasis is on the impacts or vulnerabilities identified in the risk assessment, not on the hazards themselves. As described in Task 5, these impacts and vulnerabilities may be summarized in problem statements. Some hazards may not have many impacts, or the impacts may already be mitigated. In this case, fewer mitigation actions may be identified than for a hazard causing more frequent or severe impacts.
Mitigation Ideas
To find effective solutions, innovative ideas, and best practices for mitigating risks, consult the following resources:
Ask subject matter experts. Experts on the planning team and among stakeholders can help evaluate actions that provide long-term solutions. For example, if the problem is repetitive flood damage in a specific location, but you are unsure if the flooding is caused by undersized culverts, inadequate storm drainage, or debris, you could ask an engineer to evaluate the flooding and recommend potential solutions.
Collect ideas from stakeholders and public. The outreach strategy developed as part of Task 3 provides opportunities for gathering ideas and input from the public. Surveys and questionnaires are effective tools for gathering information on alternative mitigation actions that would be preferred by community members.
Research existing guides and resources. Many publications and web-based resources are available for identifying mitigation actions. Some states have prepared technical guides to assist local communities. The State Hazard Mitigation Plan describes state funding sources and priorities for mitigation. FEMA’s website includes a Mitigation Best Practices Portfolio that provides mitigation success stories and case studies from communities across the country and Mitigation Ideas: A Resource for Reducing Risk to Natural Hazards that lists potential mitigation actions by hazard type.
Review FEMA Hazard Mitigation Assistance (HMA) eligible activities. HMA grant programs provide funding for eligible mitigation activities that reduce disaster losses and protect life and property from future disaster damages. The most recent Hazard Mitigation Assistance Unified Guidance provides information on eligible project activities.
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A comprehensive range means that communities analyze, or evaluate, different types of mitigation actions. For example, building retrofits, infrastructure protection, and changes in local ordinances represent a mix of structural and non-structural approaches. In addition, each jurisdiction must consider actions that reduce risk to existing buildings and infrastructure, as well as limit risk to new development and redevelopment.
The planning team may identify low-cost mitigation actions that can be readily implemented, such as developing an outreach program to encourage homeowners to secure furnishings and utilities to prevent injuries and damage during an earthquake. Other actions may depend on available funding, such as retrofitting critical infrastructure. Though funding and support may not be immediately available for every action, including the actions in the plan may lead to future opportunities for implementation. For example, some actions can be implemented following a disaster, when additional funding and political and public support are available, such as acquiring homes in a flood hazard area. Additionally, if actions are not included in the plan, securing funding may be more difficult once it becomes available.
To identify potential mitigation actions, the planning team should review the risk assessment and assess capabilities
1. Review Risk Assessment
The planning team should start with the problem statements developed from the risk assessment. For each problem statement, consider different types of mitigation actions for addressing the problem.
You may have multiple ideas that are categorized under one type (e.g., education and awareness or local plans and regulations) and no ideas under another type. However, the intent is to think comprehensively when identifying potential actions and to consider future development.
2. Assess Capabilities
Balancing Mitigation with Private Property Rights
While evaluating and prioritizing mitigation actions, and particularly regulatory activities, it is important to consider any potential impact to the rights or interests of private property owners. Generally, states delegate the authority to enact regulations designed to protect the public health, safety, and welfare to local governments through local police power. While regulations have been enacted in many places to mitigate natural disasters, these powers are not without limitation and may need to strike a balance with private property rights. If your evaluation of a mitigation action raises any such concerns, you should consult with your appropriate legal counsel.
The mitigation strategy is based on existing local authorities, policies, programs, and resources, as well as the ability to expand on and improve these existing tools. As part of Task 4, the planning team reviewed existing capabilities for reducing long-term vulnerability to hazards. Those capabilities can be assessed to identify gaps to be addressed and strengths to enhance through new mitigation actions. For instance, can gaps in design or enforcement of existing regulations be addressed through additional personnel or a change in procedure or policy? Could an existing education program be improved to cover the most significant hazards and better target non-English speakers? Are additional studies, reports, or plans needed to understand risk?
Jurisdictions participating in the National Flood Insurance Program (NFIP) can consider actions to enhance their floodplain management program, such as addressing repetitive loss properties and improving standards beyond the minimum requirements for NFIP participation.
Communities also must consider actions that reduce risk to future development. The planning team can evaluate the effects of current growth plans and regulations (i.e., comprehensive plans, zoning and subdivisions ordinances, building codes, and capital improvement programs) on community safety and consider how these could be updated to reduce the community’s vulnerability. For instance, development review procedures may be revised to include a hazard assessment for new development. The types of questions that the community should ask include:
- Will population growth and future land use changes put more people in hazardous areas?
- Will current plans and development policies increase the population and property vulnerable to hazards?
- Will planned infrastructure extensions encourage unsafe development by facilitating access to hazardous areas?
Element C5
The hazard mitigation strategy shall include an action plan, describing how the actions identified will be prioritized, implemented, and administered by each local jurisdiction. Prioritization shall include a special emphasis on the extent to which benefits are maximized according to a cost benefit review of the proposed projects and their associated costs.
44 CFR §201.6(c)(3)(iii)
For multi-jurisdictional plans, there must be identifiable action items specific to the jurisdiction requesting FEMA approval or credit of the plan.
44 CFR §201.6(c)(3)(iv)
Benefit-Cost Review
The one criterion that must be part of the evaluation and prioritization process is benefit-cost review. That is, the planning team must consider the benefits that would result from a mitigation action versus the cost. This does not mean a full benefit-cost analysis, such as the FEMA BCA Module, but a planning level assessment of whether the costs are reasonable compared to the probable benefits. Cost estimates do not have to be exact, but can be based on experience and judgment.
Benefits include losses avoided, such as the number and value of structures and infrastructure protected by the action and the population protected from injury and loss of life. Qualitative benefits, such as quality of life and natural and beneficial functions of ecosystems, can also be included in the review.
Best Practice
Pinellas County, FL Pinellas County weighted mitigation actions based on their suitability, risk reduction and cost. It considered 16 variables within these three factors. The cost scoring criteria used is pictured below.
- Life safety. How effectively will the action protect lives and prevent injuries?
- Property protection. How significant will the action be at eliminating or reducing damage to structures and infrastructure?
- Technical. Is the mitigation action technically feasible? Is it a long-term solution? Eliminate actions that, from a technical standpoint, will not meet the goals.
- Political. Does the public support the mitigation action? Is there the political will to support it?
- Legal. Does the community have the authority to implement the action?
- Environmental. What are the potential environmental impacts of the action? Will it comply with environmental regulations?
- Social. Will the proposed action adversely affect one segment of the population? Will the action disrupt established neighborhoods, break up voting districts, or cause the relocation of lower income people?
- Administrative. Does the community have the personnel and administrative capabilities to implement the action and maintain it, or will outside help be necessary?
- Local champion. Is there a strong advocate for the action or project among local departments and agencies who will support the action’s implementation?
- Other community objectives. Does the action advance other community objectives, such as capital improvements, economic development, environmental quality, or open space preservation? Does it support the policies of the comprehensive plan?
Action Identification and Prioritization
- Form workgroups of planning team members and/or stakeholders to identify actions to address a set of problems statements from the risk assessment, which could be grouped by hazard or action type.
- Ask the planning team to agree upon the criteria and process for evaluating and prioritizing the actions.
- Present mitigation action alternatives and criteria to the public, elected officials, and other stakeholders for feedback and acceptance.
- Develop a worksheet and/or conduct a facilitated process to evaluate the list of alternatives based on the identified criteria and plan goals.
- Ask the planning team to vote on or rank their highest priority actions for implementation.
Best Practice
Roseville, CA Roseville is considered a best practice because its plan clearly prioritized actions based on the number of objectives each action met, the benefits versus the costs of implementing the action and funding sources for the project. The table below, excerpted from Roseville's plan, illustrates the prioritizing of a few of the City's identified initiatives.