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Facts and figures aren’t enough.

Updated: 8 hours ago

After working around the clock for months, I was exhausted but decided to take the call anyway. A LinkedIn connection, someone I hadn’t worked with, needed help responding to comments from the Federal Emergency Management Agency (FEMA). Only 65 percent of sub-applications made it to the technical review and his was one of them. He was on the cusp of approval for $500,000. Initially, I was giddy with excitement. I could help him, I thought.

Later, when I saw his sub-application was only twelve pages long, I lost all enthusiasm. It missed all the important details explaining what was flooded, the severity of the flooding, and flood damages; instead, it restated the same generic information from the U.S. Census Bureau in section after section without answering the questions being asked. My sub-applications are typically over 2,000 pages of calculations, reports, memos, photos, and supporting documentation. Puzzled and intrigued, I had to know how this incomplete sub-application made it this far in the process.

It was an early Wednesday morning last February. I had just wrapped up my annual sub-applications for my client communities and was on a much-needed vacation. Grant season is always stressful and exhausting. Every year there is at least one solid month where I’m scurrying around like Sherlock Holmes, piecing together documentation at breakneck speed to complete each sub-application before the deadline.

Part of FEMA grant writing is following clues from the community’s files, finding the missing pieces hidden on websites and buried in reports and calculations, and putting them together in a comprehensive package. Each sub-application must document the existing flooding (flood depth, duration of flooding, and impacts on existing buildings) and quantify the benefits of the proposed project. For the sub-application to be eligible for funding, a detailed benefit-cost analysis with supporting documentation is required, showing the benefits outweigh the costs.

I had just finished preparing three sub-applications. Two were for purchasing and demolishing flood-prone residential homes, one inside and one outside FEMA’s Special Flood Hazard Area (SFHA). The third project was an infrastructure project to improve the stormwater conveyance and detention systems, also outside the SFHA. Projects outside the SFHA are more complex because FEMA’s studies and mapping cannot be used to demonstrate the existing flood risk. An independent engineering study is required for these projects with significantly more detailed documentation. There is a lot of work to do in a short time. It can be exhausting, but I enjoy the challenge of finding the gems buried in their files and pulling all the documentation together before the deadline.

I desperately needed some time off but when I received this plea for help in my inbox. Though the project scope was not clear to me, I knew it involved the flooding of a fire station. I had a previous project with another community that was very similar. Reducing flooding of any critical facility such as a fire station, police station, or hospital is a high priority for FEMA. These are important projects that affect life-saving public services and, knowing the importance of these projects, I felt compelled to help. We exchanged a few emails and even though some of his comments didn’t add up, I agreed to a consultation.

There I was, seeking a quiet corner with a steady internet connection for the video call. He told me about his experience working on other, less technical, FEMA grant applications and gave me a brief history of the project and the status of the sub-application. I felt more comfortable working with him knowing he had successfully prepared FEMA grant applications in the past. His previous sub-applications were for Personal Protective Equipment (PPE) through FEMA’s COVID-19 Assistance to Firefighters Grant Program. Though he had previous FEMA grant experience, a BRIC sub-application requires a much higher level of detail and analysis. He had received comments from FEMA and didn’t know how to address them. I could tell he was out of his depth. Knowing the importance of the project and how close they were to an award, I agreed to help him when I returned home on Monday.


A Helpless Sub-Application

As I started reviewing the year-old sub-application, I was immediately thrown into a quest for the name of the entity submitting. There were inconsistent clues throughout. Was it the sewer district, the City, or the County?  As I continued my search, the maps, engineering studies, historical flooding records, photos of flooding, and repair receipts were bizarrely missing. Then, I searched for any hint of the severity of flooding to the existing building since it wasn’t in the SFHA, so FEMA’s maps show a minimal risk of flooding. No documentation was provided to show otherwise (i.e. an engineering study and supporting documentation).

Most egregiously, I discovered that the proposed project type was ineligible for BRIC funding. The sub-application stated they wanted to reconstruct and elevate the existing structure. The wording was confusing. As I dug deeper into the sub-application, I realized that the FEMA reviewer misinterpreted their project scope as a demolition or elevation of the existing structure, but they were actually proposing new construction. They wanted to demolish an existing building and construct a new one at a higher elevation. This is not an eligible project type!

FEMA’s BRIC Program allows grant funding to be used to demolish an existing flood-prone structure, but the land must be deed-restricted and remain open space in perpetuity. Constructing a new building is not an eligible activity.

I was appalled at what I saw. I couldn’t believe this project was selected for further review when my painstakingly detailed sub-applications were not. I submitted three sub-applications that year, each over 2,000 pages of documentation. I received excellent feedback on my sub-applications. They were thorough and met all the requirements, but Illinois, where my projects were located, had not adopted State Building Codes, which lowered my scores. Still, I wanted to know how this garbled mess made it so far in the review process. 


A Search for Answers 

All these years I had been assured that all FEMA BRIC sub-applications were reviewed under the same criteria. Was it all a lie? I kept digging. Then I received an email from the State reviewer that answered all my questions. It said that the sub-applicant’s claim of flooding the existing structure was not supported by mapping or any hard data. It also stated that the project was not a BRIC-supported activity. They had the same questions I had and realized that the project type was ineligible. The sub-applicant was required to forfeit the grant.


Justice was restored.

I felt so validated reading that email, and my frustration melted away as I realized my sub-applications were denied more quickly because they were CLEAR. The consequence of his unclear communication was that he had to wait six additional months to learn the project would not receive funding. I knew he was disappointed. Like making it to the championship only to come home without a trophy, the initial selection led them to believe the project would receive funding only to be rejected later. Adding insult to injury, he also missed the annual deadline for the following fiscal year, setting the project back an additional year.

In the highly technical world of FEMA grant applications, the grant writer must possess the expertise and the ability to translate engineering studies and calculations into a clear and thorough scope of work.

The grant criteria are designed to standardize the sub-applications and level the playing field, but only some sub-applications meticulously follow the criterion. FEMA scores and prioritizes the sub-applications, but not everyone understands proper documentation procedures. At least now I know that when a sub-application slips through the cracks, the problem eventually surfaces, and the sub-application is withdrawn. This experience reminded me that understanding the technical aspects is only part of the equation. Clearly communicating the technical information is equally important.


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