Is FEMA’s Mitigation funding an Unrestricted ATM for States?

I spent four years inside FEMA reviewing the environmental compliance of hazard mitigation infrastructure projects. I’ve seen hundreds of applications for great ideas on paper, such as roads elevated above floodplains, ports wired with backup power, levees, libraries retrofitted for earthquakes, and even entire villages relocating away from flood prone areas.

I posit that many states consciously or subconsciously view FEMA’s mitigation programs as a very flexible infrastructure funding stream. A kind of ATM for local infrastructure, one that dispenses billions of dollars each year.

Generated by ChatGPT, March 2026

This is how I personally understood the intensity of the current litigation conflict between states and the federal government over FEMA’s mitigation programs. But it also highlights something that nagged at me for four years. Who, exactly, evaluates the efficacy and efficiency of these projects? How do we know whether these billions of dollars actually work?

Disclaimer: the views expressed in this post are solely my own, published under my first amendment rights, and do not necessarily reflect the views of the United States Government or any of its current or former federal agencies. 

The Mitigation Money

Several states have recently sued FEMA and the current administration for slowing or freezing certain grant programs. I was surprised by the scope of these programs. 

FEMA's grant programs cover everything covering everything from disaster preparedness and emergency communications to firefighter training, dam safety, and security for places of worship. Check out the long list here.

I'm focusing on three large, broad mitigation infrastructure-focused programs:

• Hazard Mitigation Grant Program (HMGP) [uncompeted]
• Building Resilient Infrastructure and Communities (BRIC) [competed]
• Legislative Pre-Disaster Mitigation (LPDM) [earmarked]

BRIC and HMGP derive their authority from the Stafford Act, while LPDM is funded through annual congressional appropriations. Before 2025, these three programs together distributed somewhere between $3 and $6 billion per year, depending largely on how many disasters the President declared in preceding years. 

Using FEMA’s open data portal, I estimated that between 2022 and 2025 FEMA awarded roughly $17 billion in hazard mitigation grants across all states and territories. That’s just over $4 billion per year, matching the general estimate.**

During that same period, while working at FEMA, I reviewed environmental compliance for projects totaling about half a billion dollars in four western states.

How Communities Get the Money

Cities, counties, and other local jurisdictions have several ways to access FEMA mitigation funding. Regardless of the pathway, however, the applications must pass through the state government (or a tribal authority).

Imagine that I am the mayor of a small rural town. Our regional high school desperately needs a seismic retrofit and the only road serving a residential neighborhood floods every year.

There are three ways I might pursue FEMA funding for these two projects:

The first option is through the Hazard Mitigation Grant Program, which is tied to a specific disaster declarations. In practice, the state collects applications from local governments, ranks them, and forwards its top selections to FEMA. FEMA staff then funds the project after conducting a compliance and eligibility review.

The key point is that the state decides which projects are submitted. FEMA doesn’t even see what applications the states receive. Human nature being what it is, local politics probably plays at least some role in those selections. Note that the December 2025 FEMA 2.0 proposal does not propose revisions to this selection process. 

If that attempt fails, I can try again through one of FEMA’s national competitive programs, such as BRIC.  In March 2025, responding to a court order, FEMA began inviting applications for $1 billion under the BRIC program. For BRIC, the state still selects and forwards some applications, but FEMA ranks proposals against submissions from across the country. Review panels evaluate the written proposal, focusing on its quality, the logic of the project as written, and whether the benefits appear to justify the costs. There is no triangulation or ground-truthing of the proposal. To avoid conflicts of interest, regional staff with local expertise do not review proposals from their own regions. 

There is also a third path, one that rarely appears in FEMA program descriptions but is well known in Washington: congressional earmarks. As the mayor, I can cajole my elected representative’s staff to write my project into the annual FEMA appropriations bill and direct FEMA to fund it. At that point FEMA has very little discretion beyond confirming that the project meets basic eligibility rules.

How often does this happen? In 2024 alone, Congress earmarked over $12 billion for more than 7,000 projects across nineteen federal agencies. I processed around eight each year for four western states.

FEMA’s Role

Regardless of how the project enters the pipeline, FEMA’s review is largely administrative. The agency confirms that the applicant is eligible, that the proposed costs are allowable under the grant program, that the project produces a positive benefit-cost ratio, and that there are no major environmental or hydrological concerns.

FEMA does not build infrastructure. It co-funds it. Typically the federal government covers between 75 and 90 percent of project costs. Local governments propose the projects, hire contractors, manage construction, and submit invoices. FEMA reviews the paperwork and reimburses the expenses. 

Why Do I Think Communities Pursue FEMA Grants

FEMA's grant process is long and cumbersome. As the mayor, I would need to have designed the projects and be able to answer all questions about costs, environmental compliance, local permits, and hydrology. This costs time and money.

Local governments across the country are under increasing fiscal pressure. Many communities develop capital plans that stretch ten or even twenty years into the future, but those plans often depend on very uncertain funding streams. Local staff, volunteers, and consultants are very savvy in tailoring applications for funding. They apply their private sector and non-profit proposal writing experience to the federal grant processes to help fill the funding gaps. 

Compared with the massive infrastructure funding programs run by the Department of Transportation, the Department of Housing and Urban Development, Department of Agriculture (rural utilities), or the Environmental Protection Agency (water systems), FEMA’s mitigation grants are relatively modest, but they are also unusually flexible. But I think they are unusually flexible.

Here is the summary from the March 2026 BRIC $1 billion funding opportunity on grants.gov:

BRIC aims to shift the focus of federal investments away from reactive post-disaster spending towards proactive infrastructure-focused hazard mitigation. For this funding opportunity, the program prioritizes investment in infrastructure and construction projects that deliver immediate, measurable risk reduction to communities vulnerable to natural hazards. 

Pretty board, but vague. If you download the 55-page document and you will find this on page 10:

Hazard Mitigation Projects – cost-effective infrastructure and construction projects designed to increase resilience and public safety; reduce injuries and loss of life; and reduce damage and destruction to property, critical services, facilities, and infrastructure (including natural systems) from a multitude of natural hazards, including drought, wildfire, earthquakes, and the effects of natural weather disasters. 

With a bit of creativity, almost any public infrastructure project can be framed as disaster mitigation. With more creativity (and I hats off to some of the best ones I saw), a very large municipal infrastructure project can be divided into smaller "independent" components and funded by multiple grant programs or over multiple years.

In addition, many American communities also grew up along rivers and streams, leaving older infrastructure exposed to flooding and erosion. Relocation projects therefore become both mitigation, expansion, and modernization.

As a result, FEMA grants have funded a remarkably wide range of projects. Between 2022 and 2026, I reviewed proposals involving generators for emergency operations centers, seismic retrofits for libraries and schools, backup power systems for ports, relocation of waste transfer stations, elevated roads and culvert replacements, levee improvements, fiber-optic hardening, electrical transmission upgrades, landslide stabilization, and even the relocation of entire villages. I loved the diversity! 

Browse this 2024 list of selected projects.

My Biggest Surprise

Early in my time at FEMA I began asking questions that fell outside my environmental reviewer's lane. 

Having worked at two other grant-awarding federal agencies, I was not concerned about financial fraud or abuse. Financial reporting is extensive. Final payments require strict compliance with federal accounting rules and federal employees do it well.

But what did the quarterly project reports look like? What happened after construction finished? Did FEMA ever evaluate whether these projects actually reduced disaster risk and loss?

I found that the actual outcomes of projects are rarely evaluated, and never in a systematic way. No one at FEMA or the State knew whether a particular mitigation project reduced damage during the next flood, wildfire, or earthquake. Did the infrastructure performed as expected. How did communities actually become more resilient. In no case did I find that FEMA knew.

The agency claims to maintain a collection of mitigation case studies. At least that's what I was told. but check it out yourself, there are fewer than one hundred of them, many more than a decade old. And read them closely; they are essentially communications pieces rather than independent evaluations with systematic data, studies, and interviews.

A Contrast with USAID

Before FEMA, I spent ten years working at USAID where independent evaluations were a standard feature of program design. Project teams, on which I served, routinely set aside up to ten percent of project budgets for monitoring and evaluation under USAID’s evaluation policy. We would issue contracts just to provide third party evaluations of our programs.

Congress reinforced this approach through the Foreign Aid Transparency and Accountability Act of 2016, which requires federal agencies to establish measurable goals, performance metrics, and evaluation plans for foreign assistance programs.

That is for foreign assistance, what about domestic programs? The Foundations for Evidence-Based Policymaking Act of 2018 applies to all federal agencies. It requires agencies to develop multi-year plans identifying priority research and evaluation questions (5 U.S.C. §306) and annual evaluation plans describing significant evaluations they will conduct (5 U.S.C. §312). I never saw those at FEMA. Do they exist?

I think it's ironic that our elected officials demand more evaluation from programs operating overseas than from some programs operating at home. Or, with a slice of reality, perhaps the votes won with  announcements of dollars for an elected official’s community is the primary purpose. I've winced when I hear politicians talk about projects already completed when they haven't even started, or money for planning and design being spun as money for construction. See for example the Congressmen at former President Biden's visit to Portland, announcing FEMA earmarked funding for seismic improvements for the airport runway. There was no construction money involved. 

What GAO Has Said

The Government Accountability Office has repeatedly pointed out this gap at FEMA.

• In 2025 GAO reported that FEMA lacks a systematic process to evaluate the effectiveness of certain mitigation programs.
• Another 2025 report noted that FEMA has not evaluated its role in helping governments mitigate risks associated with extreme heat.
• Earlier reviews (2022) reached similar conclusions. FEMA assesses project cost-effectiveness but has not developed broader measures of how mitigation projects affect communities.
• A 2021 report was even titled “FEMA Should Take Additional Steps to  Streamline Hazard Mitigation Grants and Assess Program Effects.” The GAO even noted, “FEMA officials stated that they would like to expand these studies but do not have specific plans to do so. In addition, FEMA requires some states to assess the effectiveness of their mitigation projects, but does not share these studies.”

In other words, billions of dollars in mitigation funding flow through FEMA every year, yet the agency still appears to lack any approach for evaluating the long-term outcomes.

Why Should You Care?

FEMA mitigation grants are an excellent idea. Many of the projects I reviewed were thoughtful, necessary, and long overdue. Roads were moved out of flood prone areas, critical facilities gained backup power, communities claimed to reduce risks. And, at the same time, infrastructure was upgraded and expanded to meet current demand. 

But are good intentions the same as evidence? When billions of federal dollars flow into infrastructure projects every year, basic questions should follow. Did the projects actually reduce disaster losses? Did they perform as expected during the next storm or earthquake? Did they make communities measurably safer? Did FEMA's mitigation grants in Alaska or Washington demonstrably protect communities during recent flooding events? What is the evidence and would it stand up to a peer reviewed journal, not just a media release. 

At FEMA, those questions are surprisingly hard to answer. Or, at least, for the public (and GAO) to find the answers if they exist. As long as the answers remain elusive, the agency risks cannot shake the perception that FEMA mitigation funding is less a carefully evaluated resilience program and more a very large flexible federal ATM.

Notes

The funding for HMGP is tied to a specific disaster in a specific State or Tribe. The funding for BRIC is tied to the national declared disaster total. Over the same period, FEMA awarded $7 billion in public assistance grants (fixing or relocating infrastructure damaged by disasters). Totals do not include other preparedness grants, some of which FEMA manages on behalf of other DHS components. 

Territories: Guam, US Virgin Islands, Puerto Rico, Northern Mariana islands, District of Columbia, and American Samoa.