PA Mitigation (aka 406 Mitigation)
Mitigation measures are defined as any sustained action taken to reduce or eliminate long-term risk to people and property from natural hazards and their effects.
Following a major declaration, FEMA has the authority to provide PA funding for cost-effective hazard mitigation measures for facilities damaged by a declared incident. If a culvert is washed-out from flooding or a building is destroyed from a tornado, enlarging the culvert or strengthening the replacement building may be eligible for funding under PA Mitigation. Unlike FEMA’s Hazard Mitigation Assistance (HMA) grants, PA Mitigation is non-competitive and there is no overall funding limit. PA Mitigation depends on the estimated cost of the repair and the vulnerability of the damaged facility.
This webpage will outline the parameters of PA Mitigation Eligibility. The information provided comes from the Public Assistance Program and Policy Guide, which is the same information used following a declaration by the Federal Emergency Management Agency (FEMA) Public Assistance field staff when working with applicants on projects.
To be eligible for PA funding, the mitigation measures must directly reduce the potential of future damage to the damaged portion(s) of the facility. If the Applicant proposes mitigation measures that are distinct and separate from the damaged portion(s) of the facility, FEMA evaluates the proposal and determines eligibility on a case-by-case basis considering how the mitigation measure protects the damaged portion(s) of the facility and whether the mitigation measure is reasonable based on the extent of damage. Some examples of such measures include:
• Constructing floodwalls around damaged facilities;
• Installing new drainage facilities (including culverts) along a damaged road;
• Adding fire suppression systems at facilities damaged by wildfire; and
• Dry floodproofing both damaged and undamaged buildings that contain components of a system that are functionally interdependent (i.e., when the entire system is jeopardized if any one component of the system fails).
Mitigation measures should be FEMA-approved prior to construction. However, in some instances, the Applicant may implement mitigation measures after the incident occurs but before the incident is declared or before FEMA can evaluate the measure for eligibility. In these cases, the mitigation work may still be eligible for PA funding if it is cost-effective and FEMA confirms compliance with applicable environmental and historic preservation laws, regulations, and executive orders.
PA mitigation measures must also be cost-effective. FEMA considers PA mitigation measures to be cost-effective if any of the following criteria are met:
• The cost for the mitigation measure does not exceed 15 percent of the total eligible repair cost (prior to any insurance reductions) of the facility or facilities for which the mitigation measure applies. What this means is if repairing a building cost $100,000, adding mitigation to the design would allow up to an additional $15,000 ($100,000 x 15%) for a total project cost of $115,000. If the additional cost to mitigate was higher than 15 percent, placing the total project cost above $115,000, then proceed to the next two criteria to check for cost-effectiveness.
• The mitigation measure is specifically listed in the Public Assistance Program and Policy Guide (PAPPG), Appendix J: Cost-Effective Public Assistance Hazard Mitigation Measures, AND the cost of the mitigation measure does not exceed 100 percent of the eligible repair cost (prior to any insurance reductions) of the facility or facilities for which the mitigation measure applies. This means that a repair budget for $100,000 prior to mitigation could include mitigation if the total cost does not exceed $200,000. Again, this only applies to projects listed in Appendix J in the PAPPG.
• The Recipient or Applicant demonstrates through an acceptable benefit-cost analysis (BCA) methodology that the measure is cost-effective. FEMA’s Benefit-Cost Analysis software provides appropriate BCA methodologies.
Access Appendix J of the PAPPG for detailed information on the predetermined cost-effective PA Mitigation measures mentioned above. The areas covered include drainage structures, culverts, transportation facilities, mechanical-electrical-plumbing components, pipes, water/wastewater, electric power systems, storage tanks, buildings and structures, and signage.
Hazard mitigation measures are identified at a damaged site before, during or after the PA site inspection and captured through a Hazard Mitigation Proposal (HMP). If the damaged site has been repaired or replaced, including hazard mitigation measures if any, prior to FEMA being able to schedule a PA site inspection, the hazard mitigation measures should be identified when the PA Project is established. Additionally, ‘add on’ mitigation may be eligible based on FEMA PA and FEMA Mitigation involvement with the PA Project after the initial eligible repair or replacement work has been completed. The HMP is simply a proposal to reduce future damages at a site through hazard mitigation. The HMP consists of a scope of work and cost estimate of the repairs needed to reduce or prevent similar damage from happening again. If the HMP is approved, it is attached to the PA Project and modifies the total scope of work and cost. If you are currently recovering from a disaster, contact your assigned FEMA Public Assistance Program Delivery Manager (PDMG) for more detailed information. Please find more information in the FEMA Public Assistance Program and Policy Guide V4 or for more general information on PA Mitigation please view the FEMA PA 406 Mitigation Brochure.
As you are trying to decide where to apply for 406 PA Mitigation or 404 Hazard Mitigation Grant Program (HMGP), try to maximize PA Mitigation funding to the fullest extent possible for mitigation measures on damaged facilities eligible for PA permanent work before trying to utilize HMGP (404) on facilities. This preserves HMGP funding for other projects.