Center for American Progress

How FEMA Can Build Rural Resilience Through Disaster Preparedness

How FEMA Can Build Rural Resilience Through Disaster Preparedness

The Federal Emergency Management Agency is vital to the nation’s climate resilience, but pre-disaster resilience funds are not reaching the rural communities most vulnerable to climate risk and least able to prepare.

In this article
Photo shows a flooded street in Kentucky.
A street in Jackson, Kentucky, is severely flooded following heavy rainfall in July 2022. (Getty/Michael Swenson)

Introduction and summary

The Federal Emergency Management Agency (FEMA) spent $1.5 billion through the Building Resilient Infrastructure and Communities (BRIC) program in the past two years to increase the resilience of communities to natural disasters before those disasters occur.1 These dollars represent an important shift in FEMA’s approach to pre-disaster funding. Until recently, most disaster funding was only available after a flood, wildfire, or hurricane. Following costly and deadly disasters in 2017—including Hurricanes Harvey, Irma, and Maria, which cost a combined $245 billion2—Congress passed BRIC, a flagship national competition designed to inspire and build the very best climate resilience projects across the country to prepare communities for disasters before they strike.

BRIC’s focus on pre-disaster resilience is a paradigm shift. Yet the results of the program’s first two years raise concerns about its ability to deliver assistance to communities most susceptible to natural disasters and least able to prepare for and respond to them. In the past two years, fewer than 10 percent of nationally competitive BRIC grant proposals received funding, and communities in relatively populous and wealthy states won more than 80 percent of those dollars.3 As natural disasters become more frequent and intense, rural places will need to restore and conserve the forests, grasslands, and wetlands that protect them—and the nation—from intensifying natural disasters. However, rural states and communities have won few of BRIC’s competitive grants.

The Infrastructure Investment and Jobs Act of 2021, also known as the bipartisan infrastructure law, provides BRIC with new funding—double previous levels—and a new focus on equity.4 Yet FEMA must learn from past failures to ensure that the next round of BRIC grants reach and benefit rural communities.

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The failures of BRIC investments are just one example of a larger threat facing the United States as it attempts to support community safety and build resilience in the face of a changing climate. Rural communities are often the most susceptible to climate disasters, including flooding, wildfires, drought, and increasingly extreme weather. Many government programs have attempted to reach these communities, but they have been largely unsuccessful. Most rural places lack the basic capacity to access competitive federal grants: They do not have the people, the financial resources, the expertise, or the time to do so. Over time, these barriers to accessing basic assistance have exacerbated geographic inequality and eroded trust in the federal government—as well as in the elected officials who label these programs successes. All told, the United States will not be able to achieve climate resilience or build equitable economies if rural communities are not included in the solutions.

BRIC is designed to inspire and build the very best climate resilience projects across the country to prepare communities for disasters before they strike.

This report is one of two reports released together that explore how missed opportunities in implementing federal resilience programs exemplify the challenges facing rural communities. This report examines how the BRIC program can better serve rural areas facing significant risk of natural disasters and includes findings gleaned from interviews with various experts and federal, state, and local officials. It also offers recommendations for decision-makers as they design and implement programs to include rural communities in efforts to prepare for the effects of climate change. The Infrastructure Investment and Jobs Act provides substantial new resources to BRIC and prioritizes equity in grantmaking. Capitalizing on this new opportunity is crucial as communities, businesses, and families experience the accelerating and damaging effects of extreme weather fueled by climate change.

Read the other report in this series

Read the fact sheet

Limited capacity and social vulnerability are barriers to rural resilience

Rural leaders and scholars argue, rightfully, that rural communities are diverse, productive, and vibrant places.5 Many are succeeding, creating jobs and attracting new residents seeking high quality of life and access to outdoor recreation.6 A common truth behind most of these success stories, however, is that a small group—or even just one remarkable individual leader—often drives this progress in their community, despite overwhelming odds. For example, a small-town mayor may sit on multiple local boards, run a small business, and be the community’s primary grant writer and advocate. Rural places are often stretched thin, and they lack resilience because they have limited capacity to prepare for a predictable natural disaster or respond in one’s wake.7Isolation can be a barrier in disaster resilience as emergency services must travel longer distances. Infrastructure in rural areas is often in relatively poor condition, and rural places have fewer assets and resources to deploy before or after a natural disaster. Limits and barriers such as these mean many rural places are starting with lower adaptive capacity.8

Although climate change is driving extreme weather events with greater destructive power, climate alone does not explain the rising cost of damages. A community’s susceptibility to extreme events is dictated in large part by its social vulnerability.9 Communities with greater social vulnerability—those with more people living in poverty, a disproportionate share of old or young people, larger minority populations, or those that are relatively isolated—are disproportionately harmed by extreme weather.10

Furthermore, communities with greater social vulnerability are more likely to be located in areas more susceptible to disasters.11 For example, historic racial discrimination and growing economic inequality that segregates communities have often pushed poorer residents into marginal and low-lying tracts of land, such as floodplains, river deltas, and coastal wetlands. One analysis found that populations that are both environmentally and socially vulnerable to flooding are disproportionately Black or African American and Native American.12 Nineteen million people live in these hotspots of high flood risk, which are clustered in rural parts of Southern states.13

Learn more about how FEMA can advance equity in disaster responses:

Low government capacity in rural places exacerbates risk. Fiscal stress, declining tax bases, unequal revenue sharing, staffing shortages, and inadequate and insufficient institutional knowledge can hamper the ability of state, county, and local governments to provide adequate goods and services.14 In addition, rural nonprofit organizations that may fill this gap are chronically underfunded and face highly constrained resources.15 Since federal spending programs frequently provide funds in the form of competitive grants, the ability of rural communities to secure funding is contingent on their ability to compete against areas of the country with far greater resources.16 Many communities with low government capacity are also highly vulnerable to flooding,17 often because government capacity and flood vulnerability are both linked to socioeconomic status. The populations that are most in need of flood mitigation funds are frequently governed by institutions poorly equipped to secure or administer this aid.

U.S. flood mitigation policy is moving from post-disaster recovery to pre-disaster resilience

The Federal Emergency Management Agency leads most pre- and post-disaster aid in the United States. The largest amount of funds goes to state and local governments in the form of post-disaster emergency services, debris removal, and infrastructure repair18 through the Disaster Relief Fund.19 FEMA also coordinates aid on the ground funded through the Department of Housing and Urban Development’s Community Development Block Grants for Disaster Recovery. A smaller portion of post-disaster aid goes to individuals, and an even smaller portion of funds goes to pre-disaster mitigation. Historically, assistance tends to be inequitable—FEMA delivers more post-disaster aid to relatively wealthy communities and individuals—and too little is devoted to increasing community resilience to disasters before they occur.20 It is worth noting that $1 in pre-disaster hazard mitigation and preparedness spending avoids at least $6 in disaster response and rebuilding costs.21

In 2017, historic damages from natural disasters22 heightened awareness that pre-disaster funding to prepare communities for natural disasters was inadequate and often inequitable.23 In response, Congress passed the Disaster Recovery Reform Act (DRRA) in 2018 to increase funding for FEMA’s pre-disaster programs.24 The DRRA reflected new goals and purposes set out in FEMA’s 2018 strategic plan: “building a culture of preparedness, readying the nation for catastrophic disasters, and reducing the complexity of FEMA.”25 The DRRA also created a new program to help accomplish these goals: the Building Resilient Infrastructure and Communities program. BRIC is branded as a “transformational” way to “support states and communities to undertake new and innovative infrastructure projects that reduce the risks they face from disasters.”26 BRIC was designed to be the new face of sustainable natural disaster mitigation, prioritizing long-term resilience, community partnerships, and nature-based solutions.

How BRIC is structured and the problems this structure creates

The Building Resilient Infrastructure and Communities program provides federal assistance to communities to help them reduce the risk they face from natural disasters. The program has two primary components: a state/territory allocation that funds planning and capacity grants, and a national competition that awards grants for implementation projects. BRIC also includes a Tribal set-aside that funds planning and capacity grants for federally recognized Tribal governments. The Tribal set-aside is functionally equivalent to the state/territory allocation and is important to ensure that Tribal governments do not have to compete with non-Tribal governments for capacity grants.27 In 2020 and 2021, a total of $1.5 billion was made available. More than 90 percent of funding is allocated to the national competition, and the remainder is allocated to the state/territory and Tribal set-asides.28

This report gleans key structural aspects of BRIC from expert interviews, assessments of BRIC conducted by academics and policy experts, and conversations with Federal Emergency Management Agency state hazard mitigation officers (SHMOs). SHMOs are uniquely positioned to understand the opportunity and barriers BRIC presents for rural communities because of the unique authority BRIC extends to states to apply on behalf of communities. The authors interviewed 12 SHMOs and other state emergency management officials from Arizona, Delaware, Idaho, Louisiana, North Dakota, North Carolina, Utah, and Wyoming. Similar themes emerged across these interviews and are summarized below.29

The state/territory allocation

The BRIC state/territory allocation category provides an equal amount of noncompetitive funding to each U.S. state and territory for community flood mitigation priorities.30 In 2020 and 2021, each state and territory was able to apply for $600,000 and $1 million, respectively.31 This allocation can technically be used for flood mitigation projects, but the high cost of even a single mitigation project can exceed the entire amount. Instead, most of the allocation goes to capability and capacity building grants, which fund “activities to improve the administration of mitigation assistance.”32 Effectively, communities use the state/territory allocation to fund planning, engineering studies, project scoping, and other activities that assist communities in preparing an application for the national competition. For example, many communities use allocation grants to complete hazard mitigation plans, a prerequisite to apply to any FEMA program. Communities may also use the allocation to fund project scoping activities intended for other funding sources.

The national competition

The national competition awards grants to implement large flood mitigation projects. National grants are typically larger, up to $50 million for a single project, and every state and territory may submit an unlimited number of project subapplications.33 BRIC requires applications to be “shovel ready,” meaning that a substantial amount of work must be completed before communities can even submit applications, such as the following:34

  • A pre-existing FEMA-approved hazard mitigation plan
  • A completed environmental planning and historic preservation review
  • A cost-benefit analysis that demonstrates net-positive results
  • All required engineering feasibility studies
  • Approval of necessary federal, state, and local permits
  • A 25 percent local funding match—and for some disadvantaged communities, a 10 percent match
  • A project budget
  • National Environmental Policy Act compliance information
  • Achievement of “Go/No-Go” milestones35

The national competition is highly competitive. In 2020, 22 projects in only 10 states were selected from a total of 569 individual applications, a success rate of 4 percent.36 Three states— California, Washington, and New Jersey—received 57 percent of national competition funding.37 In 2021, 53 projects from 19 states received project funding from a total of 788 individual applications, a success rate of 7 percent. BRIC’s 2021 results show marked improvement from 2020, with nearly half of all project funding going to at-risk communities. However, most of the at-risk communities that received funding in 2021 were neighborhoods within larger cities—cities that are more likely to have the capacity to navigate the complex BRIC application and secure grants for at-risk neighborhoods. BRIC’s 2021 results make clear that being at risk and low capacity are not the same. In short, at-risk neighborhoods situated within large cities are more likely to receive nationally competitive grants than their peers in low-capacity rural regions.

The high number of applications in 2021 and the low success rate indicate that there is a tremendous need and desire among local governments to build resilience and not enough resources to support them. The bipartisan infrastructure law added new dollars to BRIC and related programs, including funding for coastal resilience, but disaster preparedness remains underfunded.

BRIC gives substantial authority to states

BRIC gives substantial authority to states for implementation. States are responsible for assisting communities in developing grants, and states prioritize and submit grants to FEMA on behalf of local government applicants.38 The state role is coordinated by a FEMA state hazard mitigation officer, a state employee who serves as the primary point of contact between state governments and FEMA. The capacity of an SHMO’s office to assist local governments with generating applications and reviewing and providing feedback, as well as the way projects are scored, helps determine which communities eventually receive funding.

BRIC attempts to influence state policy

FEMA is required to implement BRIC in particular ways due to pre-existing regulations. For example, FEMA’s insistence on using BRIC funding to nudge states to adopt and enforce building codes is included both in FEMA’s statutory authority as well as the Stafford Act amendments that established the BRIC program.39 Building codes reduce loss of life and property during natural disasters40 and contribute to a culture of preparedness that FEMA is trying to build nationally.41Because FEMA has no legal jurisdiction over state and municipal building code adoption, the agency attempts to incentivize adoption and standardization through grant programs such as BRIC.

BRIC incentivizes building codes by awarding points to projects in states that mandate and enforce building codes that meet FEMA’s standards, meaning that projects in these states are more likely to receive funding. Building code compliance is a strong enough factor in the total scoring to make applications from noncompliant states almost certain to fail in the national competition.42 Only 15 states qualify for the full 20 points for statewide building code adoption, 13 qualify for partial points, and 22 do not qualify at all. States in the interior West, Midwest, and South are less likely to have statewide building codes in place. In 2020, no state lacking building codes received a competitive BRIC grant. Smaller, low-capacity communities are also less likely to comply with local building code standards.43

SHMOs report that FEMA grants are unlikely to change behavior and instead penalize some applicants for circumstances largely outside their control. The adoption and enforcement of statewide building codes is a result of complex interactions among local, county, and state governments, as well as public and private stakeholders. BRIC is simply not important enough to change the political calculus in most states.

FEMA’s tactic may be misplaced. Statewide building code enforcement mandates may not necessarily reflect actual levels of building code adoption. Several SHMOs argued that although their state lacked a statewide building code mandate, they had levels of local building code adoption that were similar to the levels of states that were awarded the full point value.44 Because states use different mechanisms to enforce codes, losing points in the code mandate criteria may simply reflect a difference in regulatory language rather than any actual difference in building code implementation.

In addition, awarding points based on the local Building Code Effectiveness Grading Schedule (BCEGS) score effectively denies aid to the least resilient communities and awards it to those that are already highly resilient. Communities that receive a low BCEGS score may have many abandoned or older structures or lack enforcement capacity. It is unlikely that a municipality can change the entire built environment just to comply with BRIC criteria. When asked if they could change one aspect of the program, SHMOs overwhelmingly suggested eliminating or relaxing the building code criteria in the national competition. These criteria continue to deny aid to the areas that need it most.

BRIC is designed to improve equitable outcomes

More recently, BRIC has become a key component of the Biden administration’s efforts to build equitable climate resilience. In 2021, the administration issued Executive Order 14008, creating the Justice40 initiative, which attempts to direct 40 percent of climate and infrastructure investment benefits to disadvantaged communities.45 BRIC was identified as one of the 21 pilot programs through which the administration intends to immediately implement Justice40 and gather lessons learned to share widely across federal agencies.46

BRIC’s complexity and cost exceed rural capacity

Applying for a BRIC national competition grant requires a high degree of technical knowledge, time, money, and persistence that many rural and underserved communities lack. SHMOs frequently identified limited capacity as the biggest barrier facing rural communities in applying for BRIC grants.

The cost-benefit analysis requirement is a specific and common obstacle for applicants. Completing a cost-benefit analysis almost always requires a civil engineer to estimate project costs, which local governments seldom have on staff. More generally, the requirement that communities have a completed disaster mitigation plan, complete project scoping, budgeting, and approval of necessary permits often exceeds the capacity of rural communities. Matching-fund requirements are also often difficult for small communities to meet.

State/territory allocation grants can be used to pay for planning, project scoping, and other expenses incurred during the application process—such as an engineer’s report or a planning consultant—but generally also require a 25 percent local match, which is reduced to 10 percent for small, economically disadvantaged communities. It is likely to take several rounds of funding cycles and planning grants to complete a project application that could be submitted to the national competition.

Taken together, the complexity, cost, and time required to complete an application for FEMA’s competitive grants discourages some communities from applying.

Taken together, the complexity, cost, and time required to complete an application for FEMA’s competitive grants discourages some communities from applying, even with funding available through the state/territory allocation.

BRIC may erode, not build, rural capacity

BRIC’s complex and costly application demands create the need for capacity. Communities require staff, expertise, time, and money to successfully complete a BRIC grant. BRIC makes noncompetitive funds available through the state/territory allocation to fund the capacity needs created by the national competition for project grants. However, this funding may consume more capacity than it builds if the completed work and resources cannot be used for other purposes, such as applying for other sources of FEMA money or for related economic development, conservation, and infrastructure grants from other agencies. SHMOs reported that too few alternative funding sources exist, and that federal grants are too siloed and specific for work on BRIC to be useful for other applications.47

States with fewer funding opportunities—or greater difficulty accessing available funding—see low and reduced uptake of state/territory grants as a result. In both 2020 and 2021, several smaller, more rural states—including Kentucky, which suffered historic floods in the summer of 202248—failed to utilize their full state allocation, leaving guaranteed money on the table. In 2021, BRIC received allocation and set-aside applications totaling only 82 percent of available funding.49 Several SHMOs noticed a decline in interest between 2020 and 2021, reflecting a growing pessimism about the efficacy of drafting flood mitigation projects that cannot be realized.50

Other mitigation funding exists but is constrained and difficult to obtain. BRIC largely replaced the Pre-Disaster Mitigation (PDM) grant program, which SHMOs reported was a much simpler application and more suited to fund smaller projects.51 The PDM still partially exists in the form of earmarks.52 Receiving earmarks tends to be contingent on the amount of influence communities have over congressional members, raising concerns that this money is mostly going to wealthy, white communities.53 Other flood mitigation programs, such as the Hazard Mitigation Grant Program or Flood Mitigation Assistance, have specific requirements such as a current disaster declaration or community participation in the National Flood Insurance Program. Communities with mitigation projects that are too big for a state/territory allocation grant—which were capped at $600,000 in 2020 and $1 million in 2021—but too small to be competitive in BRIC’s national competition have few other options.

Competitive grants are still biased against rural applicants

Criteria used to score national competition projects create additional hurdles for rural communities. The score is made up of several technical and qualitative criteria, including the building codes discussed earlier. In addition to the building code criteria, five points are awarded for projects that exceed matching-fund requirements, again favoring high-income communities more capable of meeting cost-share requirements. Programs that aim to target disadvantaged and vulnerable urban or rural communities should simply not have a cost-share requirement.

BRIC seeks to encourage and reward the best disaster mitigation projects nationwide. Projects that incorporate nature-based solutions, engage a high number of partners, include effective outreach activities, anticipate future conditions in design, and advance equity score highest across multiple qualitative criteria. In aggregate, the many good criteria generally favor larger infrastructure projects over smaller ones, thereby excluding smaller communities where appropriately scaled and designed projects may not tic as many boxes and therefore receive lower scores.

Finally, if the costs of a project exceed the perceived benefits, the cost-benefit analysis requirement may disqualify communities that are small, poor, relatively isolated, or for other reasons have lower property values relative to labor and project costs, even if the benefits are crucial to community survival. For example, nearly every SHMO the authors interviewed was able to describe a particular community in their state with specific challenges and needs that would not meet enough of BRIC’s criteria or could not pass the cost-benefits test, and which would therefore be unable to receive funding.54

Since the state/territory allocation is generally viewed as a pipeline to generate future BRIC project grants, it replicates biases present in the national competition. In states where the allocation is overprescribed, meaning that grant requests exceed available funding, SHMOs must decide which subapplications are most likely to be successful in the national competition and forward those to FEMA. To do so, most states have adopted internal scoring systems that replicate the scores used by the national advisory board, meaning that states tend to replicate FEMA’s process—and its biases.55

State resources and capacity determine community outcomes

BRIC’s devolution of authority to states to assist, score, and submit community applications means program success is contingent on states’ ability to direct resources to the application process. Recent BRIC results demonstrate that successful projects are generally from states and communities that have access to professional grant writers, and particularly staff with extensive experience writing FEMA grants. National competition grants are reviewed by a volunteer-staffed national review board that is given a fairly short period of time to review hundreds of competitive applications. Many SHMOs volunteer during this process and shared that out of necessity, reviewers often look for specific buzzwords and phrases that signal compliance. An inability to describe a project using “FEMA language” likely means a grant is denied or scored poorly despite the merits of the proposal.56

Although every SHMO interviewed for this report stated a desire and effort to help communities, their level of capacity to do so varies drastically. Types of assistance include hiring contractors such as professional grant writers or civil engineers for communities and having a panel of experts conduct multistage reviews of draft grant applications. Some states are unable to provide these services and may only be able to offer a cursory read. One state has even discouraged their office from providing high levels of technical assistance due to the worry that they lack the necessary expertise and may be blamed if the grant application is rejected. Each state’s available resources, staff time, and knowledge of FEMA largely determines a community’s success in the program.57

BRIC’s 2021 competition awarded nearly half of grant dollars to “disadvantaged” communities.58 BRIC’s focus on equity is important, and the success of so many at-risk communities reflects a strong commitment and effective criteria for targeting dollars to them. However, the state results still show that mostly communities in states with high capacity are winning grants. Large urban areas received most of the funding, and the disadvantaged populations that will benefit from national competition projects are mostly located in major urban centers such as New York, Boston, and Philadelphia.59 At-risk communities in rural and low-capacity states are continuing to lose out on these competitive grants.

To make up for limited state capacity, a combination of governmental and nongovernmental organizations (NGOs) has stepped up to provide technical assistance in some communities and regions. Regional planning entities, regional councils of government, and other government organizations, such as county government associations, may help disseminate information and draft applications. Universities may provide free services as part of course requirements for engineering students. Charities and nonprofits may raise money for the local cost share or contribute to project design and community outreach. Because historical inequalities and low capacity are likely to determine the availability of these types of resources, small and disadvantaged communities are less likely to have well-capitalized and effective NGOs in their region.60

Technical assistance is not capacity

Contracting with consulting engineers, grant writers, and communications experts does not build sustainable capacity among local leaders and institutions. BRIC’s low application success rate, the lack of other FEMA pre-disaster resilience funding, and poor coordination among federal grants—which makes BRIC application materials unhelpful for other opportunities—mean that time and effort spent on unsuccessful BRIC grants may undermine limited rural capacity. Communities may become exhausted and frustrated and may not reapply.

BRIC’s low application success rate, the lack of other FEMA pre-disaster resilience funding, and poor coordination among federal grants mean that time and effort spent on unsuccessful BRIC grants may undermine limited rural capacity.

Since the national competition is so selective, there is little incentive to secure multiple rounds of planning grants to build a project that has a small chance of being approved. Local leaders are extremely reluctant to invest resources and political capital into a project that is highly unlikely to be funded, leaving them to pay for a portion of a multiyear planning process that was not implemented and reinforcing negative perceptions of federal government programs. Community leaders are highly aware that the vast majority of 2020 funding went to three states—California, New Jersey, and Washington.61

BRIC is unlikely to be the first experience community leaders have with federal spending programs, and many community leaders find BRIC to mirror their previous experiences. SHMOs report that many communities question why they should participate in a complex, costly, and time-consuming process if all the money is just going to go to coastal states anyway.62 For example, Delaware’s SHMO related how a county official in his state who failed to secure BRIC funding expressed a too-common sentiment: “Anything but FEMA.”63

Policy recommendations

As a result of the barriers described above, past rounds of Building Resilient Infrastructure and Communities funding have disproportionately gone to coastal, densely populated states. Recently, an independent analysis commissioned by the Federal Emergency Management Agency found that subapplications from low-income communities susceptible to flooding were substantially less likely to be approved and awarded funding.64 Many state hazard mitigation officers expressed skepticism that their states will ever succeed in the national competition. However, SHMOs have identified improvements that can increase the equity of future rounds of funding. The following recommendations emerged as common themes from the authors’ interviews with SHMOs and other state emergency management state officials:65

  • Provide more noncompetitive project funding and better align BRIC with related federal resilience and rural development grant programs. Recent FEMA reorganization and funding increases through the bipartisan infrastructure law have been important steps, yet funding for climate resilience remains inadequate. FEMA could provide more noncompetitive funding for small disaster-mitigation projects. To address capacity limits, FEMA could improve coordination among grants and agencies related to climate resilience and adaptation. And to boost capacity of rural communities, FEMA could align and package resilience funding with federal block and competitive grants for rural development—for example, from U.S. Department of Agriculture Rural Development, the Economic Development Administration, and the Department of Energy’s community transition programs.
  • Provide additional technical assistance, guidance, and review. FEMA could offer clearer guidance, including effective feedback on rejected grants. FEMA could increase staff and resources at the federal and state levels to deliver technical assistance and provide block grant funding to regional hubs that can provide outreach, training, application review, small grants for expert needs, and direct grant writing assistance to rural communities.
  • Complete some application tasks on behalf of communities. Barriers to applying for communities include compiling necessary data and reviewing FEMA grant requirements and compliance. Rather than task each community with similar responsibilities, FEMA could complete certain data and application requirements for communities, such as disadvantaged designations using federal data on income, poverty, and race. FEMA could offer maps and scores related to aspects of compliance with FEMA strategic goals. Receiving data and assistance directly from FEMA would reduce the burden on communities.
  • Build capacity in rural communities to apply for, manage, and leverage projects for resilient and equitable economies. Technical assistance, temporary consultants, and one-time grants are not capacity; capacity is local and long-term staffing, resources, and expertise. Examples of how federal agencies have tried to boost rural capacity include allowing local nongovernmental organizations to apply on behalf of communities; allowing states to opt out of program implementation in favor of agency or regional hubs better able to provide services; devoting more resources to noncompetitive funding for small projects appropriate to rural needs and capacity; and integrating direct assistance, such as AmeriCorps volunteers, into planning and project management. Rural leaders and foundations believe grant programs should allow 20 percent of funding to go toward capacity, in addition to administrative overhead.66
  • Align and streamline federal grantmaking. FEMA should streamline and align BRIC’s application with other federal grant applications and align the criteria and process for developing a hazard mitigation plan with other federal disaster mitigation and resilience plans, such as community wildfire protection plans. Streamlining and aligning federal planning and grant requirements ensures that work completed for BRIC is additive and not repetitive for low-capacity communities.
  • Remove criteria that disadvantage rural communities. FEMA could reduce the weight of cost-benefit analyses on determining project eligibility, and the analyses could use metrics, including safety and adaptive capacity of nature, that recognize the nonmonetary benefits of community resilience at local and national scales. FEMA should also relax or eliminate criteria around building code compliance or use other metrics that better measure a culture of preparedness.
  • Increase rural competitiveness in national grants. FEMA could award national project grants using multiple methods, including the existing competition; use an alternate scoring method that accounts for projects with exceptionally high scores on a few criteria but a low total score; or award grants to communities that have related resilience, economic development, and conservation grants that leverage the benefits of BRIC projects. FEMA could also set aside some funds for smaller projects and/or select for applications that package multiple small projects at the watershed scale, allowing for regional applications to be developed for communities by a regional hub.

The opportunity provided by the BRIC program should not be understated: BRIC is designed to inspire and build the best climate resilience projects across the country to prepare communities for disasters before they strike. The Infrastructure Investment and Jobs Act provides substantial new resources to BRIC and prioritizes equity in grant-making. Yet as noted previously, the results of BRIC’s first two years raise concerns about the program’s ability to deliver assistance to the communities most susceptible to natural disasters and least able to prepare for and respond to them—communities with limited capacity. The recommendations offered here can improve BRIC’s implementation by ensuring that resources reach rural and low-capacity communities.


As climate-driven natural disasters become more frequent and dangerous, Congress is recognizing the need to build the resilience of communities in advance of extreme events. Since establishing the Building Resilient Infrastructure and Communities program, Congress has increased funding for it each year, with BRIC receiving $2.3 billion for fiscal year ­­2022.

BRIC represents a new approach to pre-disaster planning by encouraging innovative and large-scale resilience projects; addressing equity by prioritizing funding for at-risk communities; and allocating noncompetitive planning and capacity funding to states, territories, and tribes. BRIC projects will undoubtedly increase the climate resilience of the states and communities in which they are located. However, policymakers should be concerned that most states and communities are effectively excluded from these benefits.

BRIC’s shortcomings highlight the need for government capacity in rural areas. Much-needed aid can often only be accessed through esoteric federal grant programs. The resources available to the communities attempting to navigate this process vary greatly across states. More funding is needed to bridge capacity gaps to help rural communities succeed.

While Justice40 implementation may divert more BRIC funding to vulnerable populations, it will likely only go to vulnerable populations in wealthy, high-capacity states. To fully implement Justice40 and other similar initiatives, it is not sufficient to just change the selection process for an existing pool of applicants. Policymakers must also remove barriers for those who struggle to make it into the applicant pool at all.

For many communities, the new BRIC program is the same old story. Improving BRIC and other FEMA programs is essential to building equitable climate resilience and repairing trust in the federal government.


  1. Diane P. Horn, “FEMA Pre-Disaster Mitigation: The Building Resilient Communities and Infrastructure (BRIC) Program” (Washington: Congressional Research Service), available at (last accessed September 2022).
  2. Centre for Research on the Epidemiology of Disasters, “Natural Disasters 2017” (Brussels, 2018), available at,to%20the%20annual%2098%20average.
  3. Kris Smith, “Capacity-limited states still struggle to access FEMA BRIC grants,” Headwaters Economics, August 4, 2022, available at
  4. The White House, “FACT SHEET: President Biden’s Executive Actions on Climate to Address Extreme Heat and Boost Offshore Wind,” July 20, 2020, available at; Coral Davenport and Christopher Flavelle, “Infrastructure Bill Makes First Major U.S. Investment in Climate Resilience,” The New York Times, November 10, 2021, available at; The White House, “FACT SHEET: Biden Administration Announces Nearly $5 Billion in Resilience Funding to Help Communities Prepare for Extreme Weather and Climate-Related Disasters,” Press release, August 9, 2021, available at
  5. Olugbenga Ajilore and Caius Z. Willingham, “The Path to Rural Resilience in America” (Washington: Center for American Progress, 2020), available at
  6. Stephen J. Goetz, Mark D. Partridge, and Heather M. Stephens, “The Economic Status of Rural America in the President Trump Era and Beyond,” Applied Economic Perspectives and Policy 40 (1) (2018): 97–118, available at
  7. Sarah Kackar and Susan Fitter Harris, “Building Local Capacity in Rural People, Places and Systems,” in Andrew Dumont and Daniel Paul Davis, eds., Investing in Rural Prosperity (St. Louis: Federal Reserve Bank of St. Louis, 2022), available at
  8. Andrew Dumont and Sam Evans, “Building Rural Capacity for an Inclusive Recovery,” Federal Reserve Bank of St. Louis, May 18, 2022, available at
  9. Barry E. Flanagan and others, “Measuring Community Vulnerability to Natural and Anthropogenic Hazards: The Centers for Disease Control and Prevention’s Social Vulnerability Index,” Journal of Environmental Health 80 (10) (2018): 34–36, available at
  10. Beth Tellman and others, “Using Disaster Outcomes to Validate Components of Social Vulnerability to Floods: Flood Deaths and Property Damage Across the USA,” Sustainability 12 (15) (2020): 6006, available at
  11. Thomas Frank, “Flooding Disproportionately Harms Black Neighborhoods,” Scientific American, June 2, 2020, available at,less%20flood%20protection%20and%20are%20given%20lower%20priority.%E2%80%9.
  12. Eric Tate and others, “Flood exposure and social vulnerability in the United States,” Natural Hazards 106 (1) (2021): 435–457, available at
  13. Ibid.
  14. Linda Labao and Paige Kelly, “Local Governments across Rural America: Status, Challenges and Positioning for the Future,” in Andrew Dumont and Daniel Paul Davis, Investing in Rural Prosperity (St. Louis: Federal Reserve Bank of St. Louis, 2022), available at; Mark N. Haggerty and Julia H. Haggerty, “Rethinking Fiscal Policy for Inclusive Rural Development,” in Andrew Dumont and Daniel Paul Davis, Investing in Rural Prosperity (St. Louis: Federal Reserve Bank of St. Louis, 2022), available at
  15. Anne Kubisch and others, “The Role of Philanthropy in Rural Community Development,” in Andrew Dumont and Daniel Paul Davis, Investing in Rural Prosperity (St. Louis: Federal Reserve Bank of St. Louis, 2022), available at
  16. Headwaters Economics, “A Rural Capacity Map,” available at (last accessed August 2022).
  17. Headwaters Economics, “Rural Capacity Hazards 2022 – Flooding,” available at accessed August 2022).
  18. Congressional Research Service, “A Brief Overview of FEMA’s Public Assistance Program” (Washington), available at (last accessed September 2022); Congressional Research Service, “The Disaster Relief Fund: Overview and Issues” (Washington), available at (last accessed September 2022).
  19. The Disaster Relief Fund was authorized by the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988. For a good overview, see Congressional Research Service, “Congressional Primer on Recovering from and Responding to Major Disasters and Emergencies” (Washington), available at (last accessed September 2022).
  20. Gary Rivlin, “White New Orleans Has Recovered from Hurricane Katrina. Black New Orleans Has Not.”, Talk Poverty, August 19, 2016, available at
  21. National Institute of Building Sciences, “Natural Hazard Mitigation Saves Interim Report” (Washington: Federal Insurance and Mitigation Administration, 2018), available at
  22. Adam B. Smith, “2017 U.S. billion-dollar weather and climate disasters: a historic year in context,”, January 8, 2018, available at
  23. Guillermo Ortiz and Cathleen Kelly, “The High Price of Inaction,” Center for American Progress, February 20, 2019, available at; Justin Dorazio, “How FEMA Can Prioritize Equity in Disaster Recovery Assistance” (Washington: Center for American Progress, 2022); Kris Smith, “Mobile home residents face higher flood risk,” Headwaters Economics, February 10, 2022, available at; Junia Howel and James R. Elliott, “Damages Done: The Longitudinal Impacts of Natural Hazards on Wealth Inequality in the United States,” Social Problems 66 (3) (2019): 448–467, available at; Bradley Wilson, Eric Tate, and Christopher T. Emrich, “Flood Recovery Outcomes and Disaster Assistance Barriers for Vulnerable Populations,” Frontiers in Water 3 (2021): 1–15, available at; Hannah Dreier and Andrew Ba Tran, “‘The real damage’: Why FEMA is denying aid to Black families that have lived for generations in the Deep South,” The Washington Post, July 11, 2021, available at
  24. Congressional Research Service, “The Disaster Recovery Reform Act of 2018 (DRRA): Implementation Updates for Select Provisions” (Washington: 2021), available at
  25. Federal Emergency Management Agency, “Disaster Recovery Reform Act (DRRA) Annual Report” (Washington: U.S. Department of Homeland Security, 2019), available at
  26. Peter Gaynor, “The Disaster Recovery Reform Act has made such a big difference,” The Hill, October 5, 2019, available at
  27. This report does not attempt to assess the effectiveness of the Tribal set-aside program. For more information, see Federal Emergency Management Agency, “Before You Apply for Building Resilient Infrastructure and Communities (BRIC) Funds,” available at (last accessed September 2022).
  28. Anna Weber, “Building Resilience, BRIC by BRIC: Summer 2022 Update,” Natural Resources Defense Council, July 12, 2022, available at
  29. The authors conducted these interviews with state hazard mitigation officers and other state emergency management officials from June 27, 2022, to August 3, 2022. All interviews are on file with the authors.
  30. The state/territory allocation was $600,000 in 2020 and $1 million in 2021. Eligible territories include American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands. See Federal Emergency Management Agency, “Before You Apply for Building Resilient Infrastructure and Communities (BRIC) Funds,” available at (last accessed September 2022).
  31. Diane P. Horn, “FEMA Pre-Disaster Mitigation: The Building Resilient Communities and Infrastructure (BRIC) Program” (Washington: Congressional Research Service), available at (last accessed September 2022).
  32. Federal Emergency Management Agency, “Before You Apply for Building Resilient Infrastructure and Communities (BRIC) Funds.”
  33. U.S. Department of Homeland Security, “Notice of Funding Opportunity (NOFO): FY 2020 Building Resilient Infrastructure and Communities” (Washington: 2020), available at
  34. Ibid.
  35. A “Go/No-Go” milestone is a critical milestone in the project that if not completed on time may result in a cancellation of the subaward. See Federal Emergency Management Agency, “When You Apply for Building Resilient Infrastructure and Communities (BRIC) Funds,” available at (last accessed September 2022).
  36. Federal Emergency Management Agency, “Building Resilient Infrastructure and Communities FY 2020 Subapplication Status,” available at (last accessed August 2022). Federal Emergency Management Agency, “Fiscal Year 2020 Building Resilient Infrastructure and Communities (BRIC) Competitive Project Selections,” available at (last accessed August 2022).
  37. Horn, “FEMA Pre-Disaster Mitigation.”
  38. Each individual community application is referred to as a subapplication. The package of subapplications that each state submits to the Federal Emergency Management Agency is referred to as the state’s application.
  39. Congressional Research Service, “The Disaster Recovery Reform Act of 2018 (DRRA): A Summary of Selected Statutory Provisions” (Washington: 2019), available at
  40. Examples of these building codes include recent editions of the International Building Code and the International Residential Code. See Federal Emergency Management Agency, “Building Codes Save: A Nationwide Study” (Washington: U.S. Department of Homeland Security, 2020), available at
  41. Federal Emergency Management Agency, “Building Cultures of Preparedness: Report for the Emergency Management Higher Education Community” (Washington: 2019), available at
  42. Scoring for building codes works as follows: Twenty points are awarded for projects located in a state with mandatory statewide building code adoption and 20 points are awarded for having a high-level compliance with building codes at the local level. Compliance with local building code standards is measured through the Building Code Effectiveness Grading Schedule. Federal Emergency Management Agency, “Building Resilient Infrastructure and Communities (BRIC) Fiscal Year 2021 Technical and Qualitative Criteria,” September 8, 2021, available at
  43. Verisk Community Hazard Mitigation Services, “National Building Code Assessment Report” (Jersey City, NJ: Insurance Services Office Inc, 2019), available at
  44. State hazard mitigation officers with the Federal Emergency Management Agency and state emergency management officials, interviews with authors via Zoom, June 27, 2022–August 3, 2022, on file with authors.
  45. The White House, “Executive Order on Tackling the Climate Crisis at Home and Abroad,” January 27, 2021, available at
  46. Shalanda D. Young, Brenda Mallory, and Gina McCarthy, “Memorandum For The Heads of Departments and Agencies: Interim Implementation Guidance for the Justice40 Initiative” (Washington: U.S. Office of Management and Budget, 2020), available at
  47. State hazard mitigation officers and state emergency management officials, interviews with authors.
  48. Anisha Kohli, “Kentucky Floods Destroyed Homes That Had Been Safe for Generations. Nobody’s Sure What to Do Next,” Time, August 13, 2022, available at
  49. Weber, “Building Resilience, BRIC by BRIC: Summer 2022 Update.”
  50. State hazard mitigation officers and state emergency management officials, interviews with authors.
  51. Ibid.
  52. Federal Emergency Management Agency, “Pre-Disaster Mitigation (PDM) Grant,” available at (last accessed September 2022).
  53. Thomas Frank, “Congress earmarks climate grants for rich, white areas,” E&E News, March 21, 2022, available at
  54. State hazard mitigation officers and state emergency management officials, interviews with authors.
  55. Ibid.
  56. Ibid.
  57. Ibid.
  58. Federal Emergency Management Agency, “Building Resilient Infrastructure and Communities FY 2021 Subapplication and Selection Status,” available at (last accessed August 2022).
  59. Federal Emergency Management Agency, “Fiscal Year 2021 BRIC and FMA Competitive Selections Project Overviews,” available at (last accessed August 2022).
  60. Kubisch and others, “The Role of Philanthropy in Rural Community Development.”
  61. Smith, “Capacity-limited states still struggle to access FEMA BRIC grants.”
  62. State hazard mitigation officers and state emergency management officials, interviews with authors.
  63. Phillip Cane, Delaware state hazard mitigation officer, Federal Emergency Management Agency, interview with authors via Zoom, July 20, 2022, on file with authors.
  64. Noreen Clancy and others, “The Building Resilient Infrastructure and Communities Mitigation Grant Program: Incorporating Hazard Risk and Social Equity into Decisionmaking Processes” (Santa Monica, CA: 2022), available at
  65. State hazard mitigation officers and state emergency management officials, interviews with authors.
  66. Heidi Khokhar, “Economic Development Strategies for Rural Communities,” session during Rural Voices for Conservation Coalition Annual Meeting, YouTube, June 1, 2022, available at Author Mark Haggerty moderated this panel.

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Kevin Manuele

Former Intern, Energy and Environment

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Senior Fellow, Energy and Environment


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