FEMA selected an ineligible project for further review. I couldn’t believe it. But I’d take a quick rejection over a delayed denial any day.
It was an early Wednesday morning last February. I just finished three sub-applications for my client communities - fittingly named, as these municipalities are sub-applicants to their state, who is the applicant to Federal Emergency Management Agency (FEMA). For months, my days were inundated with my favorite tasks: technical writing, modeling, mapping, and analysis. Every piece of documentation is meticulously constructed, like an intricate drainage system, and conveyed to the State before the rapidly approaching deadline.
That year I prepared three sub-applications. Two of them proposed purchasing and demolishing flood-prone residential homes. The third was an infrastructure project that included drainage improvements to reduce the future flood risk in a neighborhood constructed in the 1950’s without modern stormwater infrastructure, resulting in frequent flooding.
Just as the grant season floodwaters receded and I was no longer inundated with urgent tasks, a plea for help appeared in my inbox. It was from a LinkedIn contact - someone I hadn’t met. A consultant navigating the tricky currents of FEMA's Building Resilient Infrastructure and Communities (BRIC) Program. The previous year, he submitted a sub-application to reduce future flood risk for a local fire station. With my experience on similar projects and the BRIC Program, this project was a natural fit. I felt compelled to help protect this critical life-saving facility, a high priority for FEMA. After exchanging a few emails, I agreed to a consultation.
So, 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 for Personal Protective Equipment (PPE) through FEMA’s COVID-19 Assistance to Firefighters Grant Program. He also gave me a brief history of the project, which was “Selected for Further Review” by FEMA. It was one of only 65 percent of sub-applications FEMA advanced to the technical review stage. The sub-application had been flowing through the FEMA process for over a year and was on the cusp of approval for $500,000.
He needed assistance responding to FEMA's request for information. This project seemed perfectly tailored to my expertise, promising to channel my skills towards an impactful project and I was excited to help him when I returned from vacation the following Monday.
A Search for Answers
I plunged into the murky waters of the year-old sub-application, trying to identify the name of the submitting entity. Was it the sewer district, the City, or the County? The maps, engineering studies, historical flooding records, photos of flooding, and repair receipts were bizarrely missing, washed away without a trace. Then, I searched for any hint of the severity of flooding to the existing building and again found nothing. FEMA’s Map Service Center showed the existing building wasn’t in the Special Flood Hazard Area, so FEMA’s maps show a minimal risk of flooding. There was no documentation 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!
BRIC funds can 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 two sub-applications that year, each over 2,000 pages of documentation, while this sub-application had only a dozen pages. 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.
The High Price of Miscommunication
All these years I had been assured that all 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 said that the sub-applicant’s claim of flooding to the existing structure was not supported by mapping or any hard data. It also stated that the project was not an eligible activity. Exactly! They had the same questions I had and realized that the project type was ineligible. The sub-applicant was required to forfeit the grant and withdraw the sub-application.
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 their project would not receive funding. I knew they were disappointed. Like making it to the championship only to come home without a trophy, the initial selection led them to believe they would receive funding only to be rejected later. Adding insult to injury, they also missed the annual deadline for the following fiscal year, setting them 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 how to properly document their project. In this case, an incomplete sub-application for an ineligible project was selected for further review and later denied funding once FEMA received the missing documentation.
At least now I know that all sub-applications ARE reviewed under the same criteria and held to the same standards. This experience reminded me that understanding the technical aspects is only part of the equation. Clearly communicating technical information is equally important.
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