U.S. Government Affairs

On October 1, 2024, FEMA finally released its interim cost-share incentive policy, implementing Section 406(b)(3) of the Stafford Act as required by the Bipartisan Budget Act of 2018. This original law was intended to increase the federal cost share for states and tribal governments that take proactive steps to enhance disaster resilience, raising it from 75% to 85% for those that adopt risk-reduction measures. Originally fast-tracked through the 2018 Budget Act in response to the 2017 major disasters, the provision aimed to reduce federal disaster spending by encouraging states to invest in resilience.

The Government Affairs Committee welcomes feedback on FEMA's guidance and encourages interested parties to submit comments to FEMA before the deadline of January 29, 2025.  In the meantime, please post your thoughts and comments on this thread.

For additional context, I have cut and pasted comments that IAEM member Scott Carpenter posted on another thread.  Here is Scott's post in its entirety...

---------------------------

On October 1^st, FEMA published Interim Policy (FP-104-24-002) Public Assistance Mitigation Cost Share Incentives,.  This policy provides a cost share incentive for projects that include mitigation funding and additional incentive for those projects located in communities that have adopted resilient building and electric conservation codes.  The policy is immediately effective for all disasters declared on or after September 26, 2024.

Key in this Interim Policy are the following:

• An increase of 5% of Federal cost share for Public Assistance (PA) permanent work projects which:
• have an eligible Hazard Mitigation Proposal (HMP) which is equal to or greater than 20% of the total eligible repair/ restoration cost of the project at time of obligation.
• An increase of 10% of Federal cost share for PA permanent work projects which:
• have an eligible HMP which is equal to or greater than 20% of the total eligible repair/ restoration cost of the project at time of obligation; AND
• the Applicant has adopted the current 2024 edition or the previous 2021 edition of the International Building Code (IBC) and the International Energy Conservation Code (IECC) for commercial buildings or equivalent code or standard, such as ASHRAE Standard 90.1

 

------------------------------
Thad Huguley
Government Affairs Director
IAEM
Falls Church VA
(615) 870-9316
------------------------------

I am attaching, with permission, an analysis of FEMA's guidance that was drafted by the executive director of the BuildStrong Coalition.  In the view of BuildStrong, FEMA's cost-share incentive policy, "does not fully promote proactive state and tribal investments in disaster resilience.  Instead, it may lead to increased federal spending after disasters, which could diminish the law's intended focus on reducing long-term disaster costs."

------------------------------
Thad Huguley
Government Affairs Director
IAEM
Falls Church VA
(615) 870-9316
------------------------------

Original Message:
Sent: 10-08-2024 15:12
From: Thad Huguley
Subject: Public Assistance Mitigation Cost Share Incentives Policy (Interim)

On October 1, 2024, FEMA finally released its interim cost-share incentive policy, implementing Section 406(b)(3) of the Stafford Act as required by the Bipartisan Budget Act of 2018. This original law was intended to increase the federal cost share for states and tribal governments that take proactive steps to enhance disaster resilience, raising it from 75% to 85% for those that adopt risk-reduction measures. Originally fast-tracked through the 2018 Budget Act in response to the 2017 major disasters, the provision aimed to reduce federal disaster spending by encouraging states to invest in resilience.

The Government Affairs Committee welcomes feedback on FEMA's guidance and encourages interested parties to submit comments to FEMA before the deadline of January 29, 2025.  In the meantime, please post your thoughts and comments on this thread.

For additional context, I have cut and pasted comments that IAEM member Scott Carpenter posted on another thread.  Here is Scott's post in its entirety...

---------------------------

On October 1^st, FEMA published Interim Policy (FP-104-24-002) Public Assistance Mitigation Cost Share Incentives,.  This policy provides a cost share incentive for projects that include mitigation funding and additional incentive for those projects located in communities that have adopted resilient building and electric conservation codes.  The policy is immediately effective for all disasters declared on or after September 26, 2024.

Key in this Interim Policy are the following:

• An increase of 5% of Federal cost share for Public Assistance (PA) permanent work projects which:
• have an eligible Hazard Mitigation Proposal (HMP) which is equal to or greater than 20% of the total eligible repair/ restoration cost of the project at time of obligation.
• An increase of 10% of Federal cost share for PA permanent work projects which:
• have an eligible HMP which is equal to or greater than 20% of the total eligible repair/ restoration cost of the project at time of obligation; AND
• the Applicant has adopted the current 2024 edition or the previous 2021 edition of the International Building Code (IBC) and the International Energy Conservation Code (IECC) for commercial buildings or equivalent code or standard, such as ASHRAE Standard 90.1

 

------------------------------
Thad Huguley
Government Affairs Director
IAEM
Falls Church VA
(615) 870-9316
------------------------------