Local Mitigation Planning Policy Guide — Requirement Checklist

The plan must describe the current planning process, documenting how the plan was prepared — including the schedule or time frame and activities that made up the plan's development — as well as who was involved.

• Describes the CURRENT planning process (not a prior cycle's process)
• Documents how the plan was prepared, including schedule/time frame and activities
• Documents who was involved in development
• Provides factual evidence (narrative and/or records such as minutes, sign-in sheets, articles)

Documentation requirements are typically met with a narrative description, but may also include other records such as copies of meeting minutes, sign-in sheets, or newspaper articles. When a narrative is provided, supporting documentation does not need to be included in the plan itself; planners are encouraged to retain it in a Plan Appendix. If applicable, ensure participating CRS jurisdictions maximize points throughout the planning process.

The plan must list the representatives from each of the participants in the current plan that will seek approval, and how they participated in the planning process. The plan must identify who participated, by agency and title.

• Lists representatives for EVERY participant seeking approval
• Identifies participants by agency and title
• Describes how each participated in the planning process

Participation can be defined and met in a variety of ways, such as attendance at meetings or reviewing and commenting on drafts.

The plan must provide documentation of an opportunity for stakeholders to be involved in the current planning process, identifying how each of the following stakeholder types was presented with this opportunity, as applicable: (1) local and regional agencies involved in hazard mitigation activities; (2) agencies that have the authority to regulate development; (3) neighboring communities; (4) representatives of businesses, academia, and other private organizations; (5) representatives of nonprofit organizations, including community-based organizations.

• Documents an opportunity for stakeholders in the CURRENT planning process
• Addresses all five stakeholder categories, as applicable
• Identifies HOW each stakeholder type was presented with the opportunity

Examples: (1) public works, emergency management, floodplain administration, GIS departments; (2) zoning, planning, community/economic development departments, building officials, planning commissions, elected officials; (3) adjacent local governments including special districts affected by similar hazards or sharing cross-boundary actions or critical assets such as dams; (4) private utilities or major employers sustaining community lifelines; (5) housing, healthcare, or social service agencies. An opportunity to be involved means stakeholders are invited to be engaged or asked to provide information or input to inform the plan's content.

The plan must document how the public had an opportunity to be involved in the current planning process and what that participation entailed. The opportunity must occur during the plan's development — prior to the plan's submission for formal review. The plan must also document how public feedback was included throughout the planning process.

• Documents a public involvement opportunity during drafting, BEFORE submission for formal review
• Describes what the public participation entailed
• Documents how public feedback was included in the plan

Examples of documentation include narratives, materials from open meetings, screenshots of social media postings and/or interactive websites with drafts for public review and comment, and questionnaires or surveys through utility bills.

The plan must document what existing plans, studies, reports and technical information were reviewed and how they were incorporated, if appropriate, into the development/update of the plan. For jurisdictions with structures for which NFIP coverage is available, regulatory flood mapping products are required to be incorporated, if appropriate.

• Documents which existing plans, studies, reports, and technical information were reviewed
• Documents how they were incorporated, if appropriate
• Incorporates NFIP regulatory flood mapping products where NFIP coverage is available, if appropriate

May be met with narrative or citations (footnotes, in-text citations, or a bibliography). Example sources: the state hazard mitigation plan; local plans (comprehensive/master/general land use, economic development, capital improvement, affordable housing, resource management, resilience); hazard-specific reports and plans (such as Community Wildfire Protection Plans). Participants may use jurisdiction-specific materials, including non-regulatory flood mapping products that improve on NFIP regulatory products. Gaps and limitations may be addressed as actions in the mitigation strategy.

The plan must include a description of all natural hazards that can affect the jurisdiction(s) in the planning area and their assets (such as dams) located outside of the planning area. The plan must provide the rationale if omitting any natural hazards commonly recognized to affect the participant(s), demonstrating the lack of risk to the participant that omits the hazard.

• Describes ALL natural hazards that can affect the planning area
• Covers assets outside the planning area (e.g., dams) where applicable
• Provides a rationale demonstrating lack of risk for any omitted commonly recognized hazard
• Distinguishes hazard sub-types where relevant (e.g., flood sub-types)

May be met with a narrative description or definition. Identifying hazards includes all types that can occur — e.g., the different types of flood hazards (flash, riverine, storm surge, debris flows, ice jams, dam/levee failure).

The plan must include information on location for each identified hazard.

• Location information present for EACH identified hazard
• Maps or narratives have sufficient detail/scale to clearly identify affected areas and assets

Maps are an efficient way to illustrate location, but narratives or other formats are acceptable. If maps are used, provide sufficient detail and scale to clearly identify hazard locations within and/or affecting assets owned by the participating jurisdiction(s). If narratives are used, they must contain enough detail to clearly identify the affected area(s) and assets.

The plan must provide the extent of the hazards that can affect the planning area. When describing extent using charts or scales (e.g., Saffir-Simpson for hurricane wind, Enhanced Fujita for tornado), the plan must document how the scale applies to each jurisdiction.

• Extent (range of anticipated intensities) provided for each hazard
• Where scales are used, the plan documents how the scale applies to EACH jurisdiction

Extent is the range of anticipated intensities of the identified hazards, most commonly expressed using scientific scales. The information must relate to each plan participant or the planning area, depending on the hazard.

The plan must include information on previous hazard events for each hazard that affects the planning area — at a minimum, any state and federal major disaster declarations for the planning area since the last update. If no events have occurred for a hazard, this must be stated.

• Previous events documented for EACH hazard
• Includes state and federal major disaster declarations since the last update, at minimum
• Explicitly states when no events have occurred for a hazard

• Silence on a hazard's history (absence of events must be affirmatively stated)

Previous occurrences can be included in a variety of ways, but should emphasize significant events, as determined by the community.

The plan must include the probability of future events for the identified hazards that can affect the planning area, including the type, location and range of anticipated intensities. General descriptors, if used, must be quantitatively defined.

• Probability of future events provided for each identified hazard
• Probability includes type, location, and range of anticipated intensities
• Any general descriptors (unlikely/likely/highly likely) are quantitatively defined in the plan

• Qualitative descriptors (e.g., 'likely') used without quantitative definitions

Probability may be defined in historical frequencies, statistical probabilities, hazard probability maps, and/or general descriptors (e.g., unlikely, likely, highly likely). If general descriptors are used, they must be quantified or defined in the plan — for example, 'highly likely' could be defined as '100% chance of occurrence next year' or 'one event every year.'

For multi-jurisdictional plans, when hazard risks differ across the planning area and between participating jurisdictions, the plan must specify the unique and varied risk information for each applicable jurisdiction and their assets outside the planning area.

• Jurisdiction-specific risk variation identified where risks differ
• Covers each applicable jurisdiction's assets outside the planning area

Applies whenever hazards are unique to and/or vary from those affecting the overall planning area.

The plan must describe the vulnerability of each participant to the identified hazards. The description must include current and future assets (including people) and the risk that makes them susceptible to damage. The vulnerability description must include a summary (such as a problem statement) of the hazard and its consequences or effects on the participant(s) and their assets. A list of assets without context is not sufficient.

• Vulnerability described for EACH participant, for each identified hazard
• Covers current AND future assets, including people
• Includes a summary/problem statement of the hazard and its consequences
• Goes beyond an asset list without context

• A list of assets without context

For plan updates, the risk assessment must also meet element E1-a. Participants may identify which specific assets are most important and most susceptible to damage or loss (for example, expressed as replacement cost).

The plan must describe the potential impacts on each participating jurisdiction and its identified assets.

• Potential impacts described for EACH participating jurisdiction
• Impacts connect hazards to the assets identified in the vulnerability assessment

Impacts could be described by referencing historical disaster damages with an estimate of potential future losses (such as percentage of damage vs. total exposure). Gaps and limitations may be addressed as actions in the mitigation strategy.

The plan must address repetitively flooded NFIP-insured structures by including the estimated numbers and types (residential, commercial, institutional, etc.) of repetitive loss / severe repetitive loss properties.

• Estimated NUMBERS of repetitive loss and severe repetitive loss properties included
• TYPES of properties identified (residential, commercial, institutional, etc.)
• No Privacy Act-protected information (policyholder names, claim amounts) disclosed

• Inclusion of Privacy Act-protected policyholder details blocks approval

Participants should consider addressing all properties at high flood risk beyond NFIP repetitive loss properties (e.g., SFHA properties with lowest floor below Base Flood Elevation). Privacy Act constraint: names of policyholders/assistance recipients and claim/assistance amounts are prohibited from public release; a plan containing such information cannot be approved until it is removed or properly protected. Maps showing general areas where claims were paid can be public.

The plan must describe how the existing authorities, policies, programs, funding and resources of each participant are available to support the mitigation strategy. This must include a discussion of the existing building codes and land use and development ordinances or regulations.

• Existing capabilities described for EACH participant
• Explicitly discusses existing building codes
• Explicitly discusses land use and development ordinances or regulations
• Connects capabilities to supporting the mitigation strategy

Capabilities may be described in a table or narrative. Describing current capabilities provides a rationale for which mitigation projects can be undertaken to address the vulnerabilities identified in the risk assessment.

The plan must describe the ability of each participant to expand on and improve the capabilities described in the plan. If participants do not have the ability or authority to expand and/or improve their capabilities, the plan must describe this lack of ability or authority.

• Ability to expand/improve capabilities described for EACH participant
• Lack of ability or authority is explicitly described where it exists

Gaps and limitations for each participant may be addressed as actions in the mitigation strategy.

The plan must describe participation in the NFIP for each participant, as applicable, providing for each: (1) adoption of NFIP minimum floodplain management criteria via local regulation; (2) adoption of the latest effective Flood Insurance Rate Map (FIRM), if applicable; (3) implementation and enforcement of local floodplain management regulations to regulate and permit development in SFHAs; (4) appointment of a designee or agency to implement NFIP commitments and requirements; (5) description of how participants implement the substantial improvement / substantial damage provisions of their floodplain management regulations after an event. Simply stating 'the community will continue to comply with the NFIP' is not sufficient.

• All five NFIP participation items addressed per participant, as applicable
• More than a generic compliance statement
• Non-participating jurisdictions with issued maps explain why they do not participate

• A bare statement that 'the community will continue to comply with the NFIP'

Jurisdictions not currently participating in the NFIP, where a Flood Hazard Boundary Map or FIRM has been issued, may meet this requirement by describing why the community does not participate. For CRS participants, it is highly recommended the description include related activities and address issues raised during community assistance and monitoring activities.

The plan must include goals to reduce the risk of the identified hazards. The goals must be consistent with the hazards identified in the plan.

• Goals present in the plan
• Goals are consistent with (cover) the hazards identified in the risk assessment

Goals may be presented as general statements applying to more than one hazard, or itemized to each identified hazard.

The mitigation strategy must include an analysis of a comprehensive range of actions or projects the participants considered to specifically address vulnerabilities identified in the risk assessment. Actions considered must emphasize reducing risk to existing buildings, structures and infrastructure, as well as limiting risk to new development and redevelopment.

• Analysis of a comprehensive range (multiple solution types) documented
• Actions linked to vulnerabilities/impacts from the risk assessment
• Emphasis on existing buildings/structures/infrastructure AND new development/redevelopment

All actions considered should be documented, specific, and clearly linked to vulnerabilities and impacts in the risk assessment — including actions for alleviating data deficiencies or building capabilities. A comprehensive range spans all solution types: local plans and regulations, structure and infrastructure projects, natural systems protection, and education and awareness programs.

Each plan participant must identify one or more mitigation actions the participant intends to implement for each hazard addressed in the risk assessment. Actions must be achievable and demonstrate how they reduce the risks identified in the risk assessment.

• At least one mitigation action per hazard per participant
• Each participant clearly associated with one or more actions
• Actions are achievable and demonstrably reduce identified risks
• Only true mitigation actions (long-term solutions) counted

• Response/preparedness actions counted as mitigation
• A participant with no associated action for a profiled hazard

Actions may apply to physical infrastructure and populations; an action may apply to multiple participants as long as each participant is clearly associated with one or more actions. Non-mitigation actions (those that do not contribute to a long-term solution) can appear in the plan but do NOT count toward this requirement. Plan updates may validate and carry forward previous actions being reconsidered against the current risk assessment.

The plan must describe the criteria used for prioritizing implementation of the actions. The criteria must include an emphasis on the extent to which benefits are maximized in relation to the associated costs of the action.

• Prioritization criteria described
• Criteria emphasize benefits relative to costs (cost-benefit review)
• Benefits consideration is demonstrated in the decision-making process

A full benefit-cost analysis is not necessary, but the plan must demonstrate actions are prioritized by weighing cost versus benefits alongside other factors. Acceptable approaches include minimum benefit thresholds or simply prioritizing actions with more benefits than alternatives. Other methodologies are acceptable if monetary and non-monetary benefits were specifically emphasized in decision-making; qualitative benefits (quality of life, natural and beneficial values) may be used.

The action plan must identify who is responsible for administering each action, along with the action's potential funding sources and expected time frames for completion. The plan must provide the position, office, department or agency responsible (names not required). Funding sources must have details beyond generic terms such as 'federal,' 'state' and/or 'local,' and must be relevant to the associated actions. General time-frame terms like 'short-term,' 'medium-term' and 'long-term' must be defined; 'ongoing' is acceptable when used appropriately (e.g., multi-phased projects).

• Responsible position/office/department/agency identified per action
• Funding sources specific and relevant (not just 'federal/state/local')
• Time frames identified; general terms quantitatively defined; 'ongoing' used only where appropriate

• Generic funding labels ('federal', 'state', 'local') without specifics
• Undefined 'short/medium/long-term' time frames

The plan must provide enough detail for users to determine who within the jurisdiction will implement or administer each mitigation action.

The plan must describe how the participant(s) will continue to seek public participation after the plan has been approved and during the plan's implementation, monitoring and evaluation.

• Describes a method for continued PUBLIC participation post-approval
• Covers the implementation/monitoring/evaluation period, not just the next update

May be a narrative or an itemized list of steps demonstrating the prescribed method for obtaining future public participation. Examples: periodic progress presentations to elected officials, schools, or community groups; annual questionnaires or surveys; public meetings; social media postings; interactive websites. Special consideration should be given to unique, meaningful engagement methods.

The plan must identify how, when and by whom the plan will be tracked for implementation over its five-year cycle (monitoring).

• Monitoring method identified (HOW)
• Monitoring schedule identified (WHEN)
• Responsible party identified (BY WHOM)

May include a system for tracking the status of identified hazard mitigation actions.

The plan must identify how, when and by whom the plan will be assessed for effectiveness at achieving its stated purpose and goals (evaluating). The process must identify the criteria used to evaluate the information in the plan.

• Evaluation method and criteria identified (HOW)
• Evaluation schedule identified (WHEN)
• Responsible party identified (BY WHOM)

May be a narrative or itemized list covering evaluation after approval, during implementation, and prior to update.

The plan must identify how, when and by whom the plan will be reviewed and revised at least once every five years (updating).

• Update method identified (HOW)
• Update schedule within five-year cycle (WHEN)
• Responsible party identified (BY WHOM)

May be a narrative or itemized list of steps followed to update the plan prior to resubmission for approval.

The plan must describe the community's process to integrate the plan's data, information, and hazard mitigation goals and actions into other planning mechanisms.

• Integration process described (data, information, goals, actions)

Integration leverages activities with co-benefits to reduce risk and increase resilience.

The plan must identify the local planning mechanisms where hazard mitigation information/actions may be integrated. The identified list must be applicable to the plan participant(s) and not contradict the identified capabilities.

• Specific planning mechanisms identified per participant
• Mechanisms consistent with the capabilities documented in C1

• Listing mechanisms that contradict the jurisdiction's documented capabilities

Planning mechanisms include budgets, comprehensive plans, capital improvement plans, economic development strategies, or other long-range plans.

A multi-jurisdictional plan must describe each participant's individual process for integrating information from the mitigation strategy into their identified planning mechanisms.

• Each participant's integration process covered (shared narrative acceptable when truly shared)
• Unique processes documented for participants that differ

May be met with a general narrative description if the process applies to each participant; any participant who cannot apply the same process must include their unique process.

The plan must describe changes in development that have occurred in hazard-prone areas and how they have increased or decreased the vulnerability of each jurisdiction since the previous plan was approved. If no development changes affected the jurisdiction's overall vulnerability, this must be stated in the plan.

• Development changes in hazard-prone areas described per jurisdiction since previous approval
• Effect on vulnerability (increase/decrease) analyzed
• Explicit statement where no changes affected vulnerability

• Silence on development changes (absence must be affirmatively stated)

Changes in development include recent construction, planned development, or conditions affecting risk (declining or growing populations, foreclosures), as well as changes in local policies, standards, codes, regulations, and land use regulations.

The plan must describe how it was revised due to a change in priorities for each jurisdiction. Priorities are defined by the participant(s). If the participant has no change in priorities since the last approval, this must be stated.

• Priority changes and resulting revisions described per jurisdiction
• Explicit statement where priorities are unchanged

May be a narrative or detailed statements in the appropriate sections of the plan.

The plan must describe the status of all hazard mitigation actions in the previous plan by identifying whether they have been completed or not, for each jurisdiction. For actions that are not complete, the plan must state whether the action is no longer relevant or will be included in the updated action plan.

• Status provided for ALL previous-plan actions, per jurisdiction
• Incomplete actions dispositioned: no longer relevant OR carried into updated action plan

A full status disposition for every prior action: completed, discontinued (no longer relevant), or carried forward.

The updated plan must explain how the jurisdiction(s) integrated information from the mitigation plan into other planning mechanisms, as a demonstration of progress in local hazard mitigation efforts. If information from the previous plan was not integrated into other planning mechanisms, this must be stated.

• Actual integration into other mechanisms explained
• Explicit statement where no integration occurred

This is the retrospective counterpart to D3: what integration actually happened over the last cycle.

The jurisdiction must provide documentation of plan adoption — usually a resolution by the governing body or other authority — to receive approval.

• Adoption documentation present
• Adoption performed in accordance with local laws

Documentation may be meeting minutes, resolutions, a signed letter, or any other method demonstrating official adoption per local laws. Flexible adoption resolution language is encouraged so post-adoption required revisions don't force re-adoption (see Appendix B sample).

To receive approval, the participants must adopt the plan and provide documentation that adoption has occurred. Participants submitting adoption documentation separately from other participants will not receive a new expiration date. Participating jurisdictions adopting more than one year after Approvable Pending Adoption (APA) status must either (a) validate that their information remains current for both the risk assessment (no recent hazard events, no changes in development) and their mitigation strategy (no changes necessary), or (b) make the necessary updates before submitting the adoption resolution to FEMA.

• EACH participating jurisdiction adopted and documented adoption
• Late adopters (>1 year post-APA) validated currency or updated the plan

All participating jurisdictions share the same plan expiration date regardless of individual adoption dates. APA is not the same as approved; a jurisdiction in APA status does not meet the approved-plan requirement for FEMA assistance.

The plan must describe how the local government coordinated with local dam owners and/or the state dam safety agency.

• Coordination with dam owners and/or state dam safety agency described
• Sensitive/PII protected

Ensure sensitive and/or personally identifiable information is protected.

The plan must describe information shared by the state and/or local dam owners.

• Shared information incorporated and described

Examples: location and size of the population at risk; potential impacts to institutions and critical infrastructure/facilities/lifelines; inundation maps; emergency action plans; floodplain management plans; data or summaries from dam breach modeling software (HEC-RAS, DSS-WISE HCOM, DSS-WISE Lite, FLO-2D) or more detailed studies.

The plan must describe the risks and vulnerabilities to and from HHPDs, including: potential cascading impacts of storms, seismic events, landslides, wildfires, etc. on dams affecting upstream and downstream flooding potential; potential significant economic, environmental or social impacts, as well as multi-jurisdictional impacts, from a dam incident; location and size of populations at risk, and potential impacts to institutions and critical infrastructure/facilities/lifelines; methodology and/or assumptions for risk data and inundation modeling.

• Cascading-impact scenarios addressed
• Economic/environmental/social and multi-jurisdictional impacts addressed
• Populations at risk and critical infrastructure impacts described
• Methodology/assumptions for risk data and inundation modeling documented

Summary descriptions suffice; detailed technical engineering analyses (USACE/USBR level) are not required.

The plan must document the limitations and describe the approach for addressing deficiencies.

• Limitations documented
• Approach to addressing deficiencies described

The plan must address a reduction in vulnerabilities to and from HHPDs as part of its own goals or with other long-term strategies. The plan does not need to include a goal specific to HHPDs alone.

• HHPD vulnerability reduction covered by goals or long-term strategies

Goals do not need to mention specific actions, specific dams, or use the term 'high hazard potential dam.'

The plan must link proposed actions to reducing long-term vulnerabilities consistent with the goals.

• Actions linked to long-term vulnerability reduction consistent with goals

Projects submitted for HHPD funding must be consistent with the goals and actions in the current approved plan.

The plan must describe a range of specific actions, such as: rehabilitating/removing dams; adopting and enforcing land use ordinances in inundation zones; elevating structures in inundation zones; adding flood protection (berms, floodwalls, floodproofing) in inundation zones.

• Range of specific HHPD-related actions described

The plan must describe the criteria used for prioritizing actions related to HHPDs.

• HHPD action prioritization criteria described

The plan must identify the position, office, department or agency responsible for implementing and administering the action related to mitigating hazards to or from HHPDs.

• Responsible party identified for each HHPD-related action