How can municipalities fund resilience hubs?

Resilience hubs are community serving facilities (such as libraries, civic centers, and places of worship) designed to support residents and coordinate resource distribution before, during, or after a natural hazard event. Subject to the governing regulations, municipalities may fund resilience hubs through the Federal Emergency Management Agency’s (“FEMA”) Hazard Mitigation Assistance (“HMA”) programs, including but not limited to the Building Resilient Infrastructure and Communities (“BRIC”) program and the Hazard Mitigation Grant Program (“HMGP”). The HMA programs should be used to reduce hazard risk to people, structures, and infrastructure.[1] For example, all programs related to “resilience hubs” should reduce hazard risk to hub residents and/or to the structures in which the hubs are housed.

1. The BRIC Program

The BRIC program provides funding to support capability-and-capacity-building (“C&CB”) activities.[2] These C&CB activities can include project scoping activities for resilience hub projects. For example, in Fiscal Year (“FY”) 2021, the New York City Housing Authority submitted a sub-application to the state and FEMA for funding a project scoping activity aimed at identifying needs related to establishing resilience hubs. The New York City Housing Authority’s application was selected for further review for FY 2021 funding.[3]

C&CB activities funding under BRIC can support communities in all aspects of the project scoping and application development process, including but not limited to:

• Identifying which community centers are best positioned to serve as resilience hubs;
• Identifying and designing mitigation measures to be implemented so that the resilience hub can serve the community in times of disaster. This could include:
  • equipping hubs with cooling equipment for times of extreme heat;
  • retrofitting hubs with back-up emergency power, including generators or microgrids; and
  • retrofitting facilities to be used as resilience hubs against seismic activity, wildfires, floods, or other natural hazards.
• Developing a FEMA-ready sub-application, including a Benefit-Cost Analysis (“BCA”). The BCA can be one of the more challenging components of developing a FEMA BRIC application. Sub-applicants can use C&CB activities funding under BRIC to collect the data and develop the methodologies needed to conduct a FEMA BCA.[4]

BRIC funding for C&CB activities is provided as an allocation to states and territories, which have discretion over the types of projects they submit to FEMA under their mitigation plans. In FY 2022, the maximum allocation to states or territories for these activities was $1 million per applicant.[5] If a municipality is interested in project scoping funding for resilience hub development, it is encouraged to contact its State Hazard Mitigation Officer (“SHMO”).[6] In FY 2022, the BRIC National Competition, which awards funds not allocated to states and territories on a competitive basis, made approximately $2.133 billion available for eligible project applications.[7] Eligible mitigation measures and activities relating to resilience hubs include, but are not limited to:

• Purchasing and installing back-up power equipment, including generators, microgrids, and associated equipment;
• Implementing structural and non-structural retrofits to buildings that house resilience hubs;
• Implementing wildfire mitigation measures, including defensible space and ignition resistant construction activities for resilience hub buildings;
• Implementing flood mitigation measures to increase protection to facilities that serve as resilience hubs; and 
• Installing tornado shelters or other wind protective measures for resilience hubs.[8]

Note that all project applications must be eligible, technically feasible, and cost-effective, as determined using FEMA-approved BCA methodologies. Projects are also subject to federal, state, and local environmental and historic preservation laws and regulations. Municipalities should seek to align projects submitted for BRIC funding with the applicable technical and qualitative criteria so that the projects are competitive for funding.[9]

2. The HMGP Program

Like the BRIC program, the HMGP also provides funding to scope resilience hub projects through Advance Assistance funding.[10] Advance Assistance funding should be used in support of project development activities such as engineering, feasibility studies, design plans, environmental and historical surveys, and data collection.

HMGP funding may become available to states and territories when authorized under a presidential Major Disaster Declaration. Recipients are responsible for setting their individual prioritization goals and funding timelines for HMGP funding. As with BRIC, recipients exert certain discretion regarding the use of HMGP funding, though some recipients choose not to utilize Advance Assistance funding at all. Accordingly, municipalities interested in funding for project scoping should contact their SHMO to understand if this opportunity is available and whether a specific project idea aligns with state prioritization and funding goals.

With respect to resilience hub project ideas, HMGP Advance Assistance can generally fund the same activities identified as eligible for BRIC project scoping, as discussed above. The HMGP and BRIC programs also share similar eligibility, feasibility, cost-effectiveness, environmental, and compliance requirements.

One potential benefit of HMGP is that an applicant only competes with other applicants within their own state and not nationally, as is the case with BRIC funding applications. The national competitive criteria generally does not apply to HMGP funding, but many states set state prioritization criteria that municipalities should consider when developing a project application.[11] Because resilience hubs are a novel project type under the FEMA HMA programs, municipalities are highly encouraged to engage their SHMO as early in the application process as possible to clarify any questions or concerns that may arise.

Last Updated: March 2, 2023