Building Resilience, BRIC by BRIC: Summer 2022 Update
FEMA has announced Round 1 of this year's BRIC grant selections. Let's take a look at how these selections compare to last year's.
Hurricane season is once again in full swing—not to mention the ongoing threat of extreme heat, wildfires, and other climate hazards. What better time to check in on FEMA’s Building Resilient Infrastructure and Communities (BRIC) grant program?
Last year, in its first funding cycle, FEMA had $500 million available through the BRIC program and selected 406 projects among 53 states and territories. However, the vast majority of that funding—$377 million—went to just 22 projects, mainly in higher-capacity coastal areas, raising concerns about equity and access. For a summary of last year’s BRIC selections and a quick overview of how the program works, check out my post “Building Resilience, BRIC by BRIC.”
Unlike last year, FEMA is announcing this year’s grant selections in two rounds. In May, FEMA announced the Round 1 selections for Fiscal Year 2021: $65.7 million for BRIC’s state and territory allocations, tribal set-aside, and non-financial technical assistance (see below for more information on each of those funding categories). We expect that the results of the “national competition”—funding for larger, individual projects—will be announced later this summer in Round 2.
Let’s take a look at this first round of selections and highlight some changes in the program compared to the previous year.
Overview of Round 1 BRIC Selections
FEMA’s Round 1 announcement includes a $1 million allocation available to each of the 56 states and territories—which can be used for program management, planning and other capacity-building activities, and small projects—and a $25 million tribal set-aside. This $81 million in available funding is an increase from the $58.6 million available last year ($600,000 state and territory allocations plus a $20 million tribal set-aside) and reflects some increased emphasis on capacity building work. However, it is still a small percentage of the overall $1 billion BRIC funding pool.
FEMA selected 316 projects (officially referred to as “subapplications”) for further review in Round 1, from 53 states and territories and 27 tribal governments. These are referred to as “selections” because the projects have not yet formally received a grant award. However, they will likely advance to the award stage after going through some additional review, for example to meet environmental and historical preservation requirements. In total, these selections represent $65.7 million in requested federal funding.
The maps below show the location of the selected projects in the contiguous United States for which approximate locations were easily determined, with blue dots for the state and territory allocation and yellow dots for the tribal set-aside. Of the eligible states and territories, neither Kentucky nor the Northern Mariana Islands submitted applications for this round of funding, and Puerto Rico did not have any eligible submissions. In some cases, the subapplication title did not indicate where a project was located; in other cases, states only applied for funding on a statewide basis. These non-location-specific or statewide funds are shown with gray shading.
The very large yellow dot on the tribal set-aside map represents a riverbank stabilization project proposed by the Coyote Valley Band of Pomo Indians in Northern California, who requested $5.3 million in federal funds. FEMA also selected a large project from the southwestern Alaska village Napakiak (not shown on the map): $2.2 million in federal funding for the first phase of a managed retreat project.
In Round 1, it appears that FEMA selected all of the eligible projects for further review. This makes sense as states and territories were able to tailor their applications to reflect the allocated amounts. (In contrast, the competitive Round 2 announcement will likely include many eligible projects that do not get selected.)
However, some states had relatively high proportions of ineligible projects. Louisiana, for example, submitted 13 subapplications but FEMA determined that only five met the program’s requirements. Other states only applied for a subset of their available funding, essentially leaving money on the table. For example, FEMA approved all of Tennessee and West Virginia’s proposed projects, but the states only applied for $188,000 and $327,000, respectively, of their available $1 million. Overall, the selected projects account for 82% of the $81 million available during Round 1, meaning that states, territories, and tribes passed up some $14 million.
Distribution of Selected Projects
Policymakers are increasingly turning their attention to what disaster survivors have long recognized: programs intended to reduce disaster risks often serve predominantly whiter, wealthier areas, while failing to address risks and vulnerabilities among marginalized communities and exacerbating pre-disaster inequalities. Groups ranging from local advocates to the federal Government Accountability Office—and even FEMA’s own National Advisory Council—have been pressuring the agency to address its programs’ inequitable outcomes.
Along with the Flood Mitigation Assistance (FMA) program, BRIC is part of the Biden Administration’s Justice40 initiative, meaning that 40 percent of the programs’ benefits must flow to disadvantaged communities. According to FEMA’s website, “These subapplications that have been Identified for Further Review help FEMA set a baseline to achieving the Justice40 Initiative goals.”
I’ll take a closer look at the distribution of this year’s BRIC funding—including the proportion of funding benefiting low-income communities and communities of color—after we learn about the Round 2 selections.
So far, we can see a slightly increased proportion of funding for “economically disadvantaged rural communities,” from $10.5 million (23% of the federal share of selected state allocation/tribal set-aside projects) last year to $16.6 million (28%) this year. Because of its narrow definition (by law, “economically disadvantaged rural communities” only include communities with ≤ 3,000 residents) this designation doesn’t include all of the communities most in need of funding or those that will count toward the Justice40 goals. However, an incremental increase to this subset of communities seems promising.
Capability and Capacity Building
In BRIC’s first year, many stakeholders (including NRDC) pointed to the high percentage of funding received by larger, higher-capacity jurisdictions. While FEMA has added equity-related program criteria for BRIC, giving disadvantaged communities a higher prioritization score is not very helpful if those communities are unable to apply in the first place.
As a result, NRDC and others have called for increased capacity building support within the BRIC program. This funding can help communities prepare for future funding applications as well as generally increase ability to prepare for and respond to hazards.
According to FEMA’s website, “From the previous year, subapplication requests for federal funding for Capability and Capacity Building Activities increased by 49%.” The selected projects in this category total about $42 million in federal funding, with roughly 75% for project scoping and 25% for planning activities. This represents an increase of about $5 million from last year, and continuing to increase funding for capacity building would go a long way towards addressing the capacity shortfall in communities nationwide.
Improved uptake of FEMA’s non-financial technical assistance is also a step in the right direction. Last year, FEMA received no applications for this valuable support from the states in Region 2 and Region 6, which collectively serve seven states, two territories, and 76 tribal nations. This year, FEMA allowed communities to apply directly to the agency for technical assistance. The results were better and FEMA will provide direct technical assistance to 20 communities, including five tribal governments.
We recommend that FEMA continue increasing support for state and local capacity building, for example by creating a dedicated capacity building set-aside within BRIC that is specifically targeted at low-income communities and communities of color that face barriers to accessing federal funds. FEMA should also allow high-priority capability and capacity-building activities to be funded under the national competition and incentivize these activities via scoring and/or cost share advantages.
With the early Round 1 funding announcement, we hope that the selected states, tribes, and localities are already moving ahead to the next phases of their work building resilience and bolstering community capacity. Looking ahead to the Round 2 announcement, we hope that FEMA’s selections reflect the agency’s stated commitments to improve equity in its programs. Stay tuned for an assessment of the Round 2 selections when FEMA makes them public!