Federal Emergency Management Agency

FEMA Strategic Plans

The Federal Emergency Management Agency (“FEMA”) regularly issues overarching “Strategic Plans,” which establish agency-wide strategic goals for rolling five-year windows. Under Presidents Obama, Trump, and Biden, FEMA’s strategic plans have paid varying levels of attention to climate change.

On December 9, 2021, FEMA released the 2022-2026 FEMA Strategic Plan. This plan restores climate change considerations that were absent from the 2018-2022 strategic plan issued during the Trump administration. The Plan outlines three strategic goals:

  • Strategic Goal 1: Instill Equity as a Foundation of Emergency Management
  • Strategic Goal 2: Lead Whole of Community in Climate Resilience
  • Strategic Goal 3: Promote and Sustain a Ready FEMA and Prepared Nation

Strategic Goal 2, “Lead Whole of Community in Climate Resilience,” includes three sub-goals:

  • Sub-goal 1: Increase climate literacy among the emergency management community;
  • Sub-goal 2: Build a climate resilient nation; and
  • Sub-goal 3: Empower risk-informed decision making.

Biden Administration (2021-2025)

2022-2026 FEMA Strategic Plan

On December 9, 2021, FEMA released the 2022-2026 FEMA Strategic Plan. This plan restores climate change considerations that were absent from the 2018-2022 strategic plan issued during the Trump administration. The Plan outlines three strategic goals:

  • Strategic Goal 1: Instill Equity as a Foundation of Emergency Management
  • Strategic Goal 2: Lead Whole of Community in Climate Resilience
  • Strategic Goal 3: Promote and Sustain a Ready FEMA and Prepared Nation

Strategic Goal 2, “Lead Whole of Community in Climate Resilience,” includes three sub-goals:

  • Sub-goal 1: Increase climate literacy among the emergency management community;
  • Sub-goal 2: Build a climate resilient nation; and
  • Sub-goal 3: Empower risk-informed decision making.

First Trump Administration (2017-2021)

2018-2022 FEMA Strategic Plan

On March 15, 2018, FEMA released the 2018-2022 FEMA Strategic Plan. The Plan outlines three strategic goals:

  • Strategic Goal 1: Build a Culture of Preparedness
  • Strategic Goal 2: Ready the Nation for Catastrophic Disasters
  • Strategic Goal 3: Reduce the Complexity of FEMA

The words “climate” and “climate change” are not mentioned in this document.


Obama Administration (2009-2017)

2014-2018 FEMA Strategic Plan

On July 31, 2014, FEMA released the 2014-2018 FEMA Strategic Plan. This Plan outlines five strategic priorities:

  • Strategic Priority 1: Be survivor-centric in mission and program delivery;
  • Strategic Priority 2: Become an expeditionary organization;
  • Strategic Priority 3: Posture and build capability for catastrophic disasters;
  • Strategic Priority 4. Enable disaster risk reduction nationally; and
  • Strategic Priority 5. Strengthen FEMA’s organizational foundation.

In support of Strategic Priority 4, FEMA established two objectives related to climate change:

  • Objective 4.1: Provide credible and actionable data and tools to support risk-informed decision-making. FEMA committed to modernizing risk-assessment tools and flood risk maps to better assess future risks, including those influenced by climate change.
  • Objective 4.3: Enhance the effectiveness, financial stability, and affordability of the National Flood Insurance Program. FEMA committed to strengthen the National Flood Insurance Program (“NFIP”) by, among other changes, that flood insurance rates accurately reflect the real risk of flooding.
2011-2014 FEMA Strategic Plan

On May 31, 2011, FEMA released the 2011-2014 FEMA Strategic Plan. As part of this plan, FEMA launched its Strategic Foresight Initiative, which assessed factors that would likely affect emergency management. FEMA’s 2011-2014 Strategic Plan identifies climate change as one of “nine drivers of change that will likely affect emergency management.”

Hazard Mitigation Grant Program

The Stafford Disaster Relief and Emergency Assistance Act of 1988 (the “Stafford Act”) makes the Federal Emergency Management Agency (“FEMA”) responsible for administering and coordinating the federal government’s response to disasters.

The Stafford Act (codified at 42 U.S.C. 5170) allows the President to declare that a condition of “Major Disaster” exists if a natural catastrophe, fire, flood, or explosion in the United States causes severe damage. If a Major Disaster has been declared, FEMA may provide several different types of discretionary assistance. FEMA’s Hazard Mitigation Grant Program (“HMGP”) grants funds to State, local, Tribal, and territorial governments to “plan for and implement mitigation measures” for future natural disasters “during the reconstruction process following a disaster.” Under HMGP, FEMA “may contribute up to 75% of the cost of hazard mitigation measures which the President has determined are cost-effective and which substantially reduce the risk of future damage, hardship, loss, or suffering in any area affected by a major disaster.”  (42 U.S.C. 5170c(a))

On August 15, 2024, FEMA published a final rule (89 Fed. Reg. 66241, Aug 15, 2024) extending the HMGP application period. Before this rule, applicants had 12 months after the declaration of a Major Disaster to submit all local HMGP applications to the FEMA Regional Administrator. Applicants could apply for additional extensions, capped at 180 days.

The August rulemaking extended the “base” application period for hazard mitigation grants from 12 months to 15 months following a Major Disaster, and allows Regional FEMA Administrators to grant extensions of up to 8 months. This extension is designed to “increase[] flexibility for applicants by allowing more opportunities for them to develop and improve their grant applications to address the effects of climate change and other unmet mitigation needs.”

Biden Administration (2021-2025)

Hazard Mitigation Grant Program Application Period Extension - Regulation

On August 15, 2024, FEMA published a final rule (89 Fed. Reg. 66241, Aug 15, 2024) extending the HMGP application period. Before this rule, applicants had 12 months after the declaration of a Major Disaster to submit all local HMGP applications to the FEMA Regional Administrator. Applicants could apply for additional extensions, capped at 180 days.

The August rulemaking extended the “base” application period for hazard mitigation grants from 12 months to 15 months following a Major Disaster, and allows Regional FEMA Administrators to grant extensions of up to 8 months. This extension is designed to “increase[] flexibility for applicants by allowing more opportunities for them to develop and improve their grant applications to address the effects of climate change and other unmet mitigation needs.”

Hazard Mitigation Assistance - Regulatory Guidance

On July 30, 2024, FEMA published its 2024 Hazard Mitigation Assistance Program and Policy Guide (“2024 HMA Guide”). The 2024 HMA Guide continued to align FEMA’s guidance with the Biden administration’s climate adaptation, mitigation, and resilience policies.

Hazard Mitigation Assistance - Regulatory Guidance

On March 23, 2023, FEMA published its 2023 Hazard Mitigation Assistance Program and Policy Guide (“2023 HMA Guide”). The 2023 HMA Guide updated and replaced the 2015 HMA Guide, and aligned multiple elements of FEMA’s guidance with the Biden administration’s climate adaptation, mitigation, and resilience policies. The 2023 HMA Guide was effective from March 22, 2023, to July 29, 2024, and was replaced by the 2024 HMA Guide.


First Trump Administration (2017-2021)

N/A


Obama Administration (2009-2017)

Hazard Mitigation Assistance - Regulatory Guidance

On February 27, 2015, FEMA published its Fiscal Year 2015 (FY15) Hazard Mitigation Assistance (HMA) Guidance (“2015 HMA Guide”). The 2015 HMA Guide provided guidance for applications to the HMGP program, and was intended to represent FEMA’s policy position concerning the program. The 2015 HMA Guide outlined extensive climate change and climate resilience considerations that FEMA would incorporate in its administration of the HMGP and review of HMGP applications.

Building Resilient Infrastructure and Communities

FEMA administers the Building Resilient Infrastructure and Communities (“BRIC”) Grant Program, and may set aside 6 percent of estimated disaster expenses for each major disaster to fund the program. The BRIC Grant Program makes funds available to States, territories, and federally recognized Tribes that have had a Major Disaster declaration in the preceding 7 years to fund disaster mitigation programs. Funding is generally subject to a federal cost share of up to 75 percent, and up to 90 percent for small and impoverished communities.

In 2022 the Community Disaster Resilience Zones Act of 2022 (Pub. L. 117-255) amended the Stafford Disaster Relief and Emergency Assistance Act of 1988 (the “Stafford Act”). The amendments added a new section, Section 206 (42 U.S.C. 5136) which requires FEMA to (1) build a public natural hazard assessment program that shows natural hazard risk at the census tract level, and (2) designate “community disaster resilience zones” at the census tract level based on these risk ratings.

On May 26, 2023, FEMA published a notice and request for information related to updates to the National Risk Index and the BRIC Grant Program. (88 Fed. Reg. 34171, May 26, 2023). FEMA’s notice described changes to the National Risk Index, a public natural hazard risk product that could be used to designate community disaster resilience zones. However, FEMA’s notice noted that, as of May 2023, the National Risk Index does not account for future conditions or anticipated impacts due to climate change. Among other questions, FEMA RFI solicited community input on ways to incorporate climate change-related information into the National Risk Index. On December 3, 2024, FEMA published responses to the comments received in response to this RFI. (89 Fed. Reg. 95801, Dec. 3, 2024)

Biden Administration (2021-2025)

Community Disaster Resilience Zones and the National Risk Index - Notice and RFI

On May 26, 2023, FEMA published a notice and request for information related to updates to the National Risk Index and the BRIC Grant Program. (88 Fed. Reg. 34171, May 26, 2023). FEMA’s notice described changes to the National Risk Index, a public natural hazard risk product that could be used to designate community disaster resilience zones. However, FEMA’s notice noted that, as of May 2023, the National Risk Index does not account for future conditions or anticipated impacts due to climate change. Among other questions, FEMA RFI solicited community input on ways to incorporate climate change-related information into the National Risk Index. On December 3, 2024, FEMA published responses to the comments received in response to this RFI. (89 Fed. Reg. 95801, Dec. 3, 2024)

Community Disaster Resilience Zones Act of 2022

On December 20, 2022 the Community Disaster Resilience Zones Act of 2022 (Pub. L. 117-255) amended the Stafford Disaster Relief and Emergency Assistance Act of 1988 (the “Stafford Act”). The amendments added a new section, Section 206 (42 U.S.C. 5136) which requires FEMA to (1) build a public natural hazard assessment program that shows natural hazard risk at the census tract level, and (2) designate “community disaster resilience zones” at the census tract level based on these risk ratings. Among other things, Section 206 allows FEMA to approve a 90% federal cost share for BRIC grants that fund disaster mitigation in a community disaster resilience zone (up from a normal baseline of 75%).

BRIC Grant Program - Policy Guidance

On February 25, 2022, the Federal Emergency Management Agency issued updated guidance (87 Fed. Reg. 10805, Feb. 25, 2022) for the BRIC Grant Program. The policy statement describes a new hazard mitigation grant program to assist States, territories, Tribes, and local governments with mitigating the impacts of natural hazards, including those associated with or amplified by climate change. The program is meant to “promote[] a national culture of preparedness through encouraging investments to protect communities and infrastructure by increasing pre-disaster hazard mitigation and strengthening national resilience.”


Trump Administration (2017-2021)

BRIC Grant Program - Policy Guidance

On August 10, 2020, FEMA issued policy guidance designed to support applications to the BRIC Grant Program (85 Fed. Reg. 20291, Aug. 10, 2020).

Disaster Recovery Reform Act of 2018

On October 5, 2018, the Disaster Recovery Reform Act of 2018 (“DRRA”) (Pub. L. 115-254) amended the Stafford Act and modified a variety of FEMA’s programs and responsibilities. Section 1234 of the DRRA (42 U.S.C. § 5133(i)) authorizes FEMA to set aside 6 percent of estimated disaster expenses for each major disaster to fund a new grant program, called Building Resilient Infrastructure and Communities (“BRIC”). The BRIC Grant Program is meant to “promote[] a national culture of preparedness through encouraging investments to protect communities and infrastructure program,” and replaced the pre-existing Pre-Disaster Mitigation (PDM) program under the Stafford Act. The BRIC Grant Program makes funds available to States, territories, and federally recognized Tribes that have had a Major Disaster declaration in the preceding 7 years to fund disaster mitigation programs. Funding is generally subject to a federal cost share of up to 75 percent, and up to 90 percent for small and impoverished communities.

National Flood Insurance Program

The National Flood Insurance Act of 1968 (“NFIA”), as amended, directs FEMA to set terms and conditions for flood insurance issued under the National Flood Insurance Plan (“NFIP”). (42 U.S.C. 4001 et seq., as amended). Today, FEMA administers the NFIP, underwrites NFIP policies, and oversees the more than 50 private insurance companies that offer flood insurance under the NFIP. The NFIP helps communities avoid and mitigate flood risk through the adoption of floodplain management ordinances and helps policyholders transfer flood risk to the federal government.

On July 11, 2024, FEMA published a notice and request for information exploring changes to its Community Rating System (“CRS”) (89 Fed. Reg. 56889, July 11, 2024). The CRS was established in 1990 as a voluntary program that recognized communities engaged in floodplain management standards above the NFIP’s minimum standards, and offered flood insurance premium discounts to reflect the reduced flood risk resulting from the community's higher floodplain management standards or programs. This RFI builds on an earlier notice and request for information published on August 23, 2021 (86 Fed. Reg. 47128, Aug. 23, 2021) that began evaluation of the CRS standards.

Biden Administration (2021-2025)

Request for Information - National Flood Insurance Program's Community Rating System Redesign Effort

On July 11, 2024, FEMA published a notice and request for information exploring changes to its Community Rating System (“CRS”) (89 Fed. Reg. 56889, July 11, 2024). The CRS was established in 1990 as a voluntary program that recognized communities engaged in floodplain management standards above the NFIP’s minimum standards, and offered flood insurance premium discounts to reflect the reduced flood risk resulting from the community's higher floodplain management standards or programs. This RFI builds on an earlier notice and request for information published on August 23, 2021 (86 Fed. Reg. 47128, Aug. 23, 2021) that began evaluation of the CRS standards.

Proposed Regulation - National Flood Insurance Program: Standard Flood Insurance Policy, Homeowner Flood Form

On February 6, 2024, in recognition of the increased flooding and flood risk caused by climate change, FEMA proposed updates to the “Standard Flood Insurance Policy” issued under the NFIP (89 Fed. Reg. 8282, Feb. 6, 2024).

FEMA establishes the terms and conditions of NFIP policies through a "Standard Flood Insurance Policy," which is adopted in regulation. The current Standard Flood Insurance Policy was adopted in 2000 (65 Fed. Reg. 60758, Oct. 10, 2000). In the February 6, 2024 rulemaking, FEMA proposed a new policy form, the "Homeowner Flood Form," and a set of accompanying policy endorsements.

Many of the changes proposed by FEMA are designed to modernize NFIP policies to make them more readable by policyholders, agents, and claims adjusters, and to increase public awareness of the program. These changes are, in part, intended to increase climate resilience by increasing the number of homes covered by flood insurance. However, some elements of the proposed rulemaking also encourage physical adaptation. Significantly, FEMA’s proposed rulemaking would encourage policyholders to rebuild flood-damaged properties to a more resilient standard. In particular, FEMA has proposed to “shift the default loss settlement from actual cash value to replacement cost value,” and allow homeowners to recoup costs for “flood damage resistant materials.” In addition, FEMA’s proposed rulemaking would allow policyholders who are rebuilding after a flood to recoup some of the expenses associated with moving at-risk machinery and equipment out of flood-prone zones.

Request for Information - National Flood Insurance Program's Floodplain Management Standards for Land Management and Use

On October 12, 2021, FEMA published a notice of request for information on how to best revise the NFIP floodplain management standards to increase climate resiliency. (86 Fed. Reg. 56713, Oct. 12, 2021). NFIP’s floodplain management standards are designed to reduce future flood risk, but they have not been updated since 1976. FEMA’s RFI seeks to align the standards with modern understanding of flood risks and flood risk reduction approaches.

Policy Guidance - National Flood Insurance Manual

On October 1, 2021, the Federal Emergency Management Agency published an update to its Flood Insurance Manual, titled Risk Rating 2.0: Equity in Action, which updates its National Flood Insurance Program (NFIP) to account for increasing flood trends. This is the first update to its NFIP rating methodology since the 1970s, and it follows a 2017 Department of Homeland Security report which found significant inadequacies in FEMA’s previous methodology. The manual explains that “FEMA’s new rating methodology leverages catastrophe modeling, geospatial technology, and NFIP mapping data to estimate risk and determine the cost of flood insurance for each individual building.” FEMA released a report in April 2021 that documents the Risk Rating 2.0 methodology and data sources.


First Trump Administration (2017-2021)

N/A

Federal Flood Risk Management Standard

FEMA administers the Federal Flood Risk Management Standard (“FFRMS”), a flood standard that has been the subject of conflicting Executive Orders between Presidents Obama, Trump, and Biden. The FFRMS requires federal agencies to prepare for and protect federally funded buildings and projects from flood risks.

On July 11, 2024, FEMA issued final regulations implementing the FFRMS (89 C.F.R. 56929, July 11, 2024), alongside updated Policy Guidance for Federal Flood Risk Management Standards

Biden Administration (2021-2025)

Updates to Floodplain Management and Protection of Wetlands Regulations To Implement the Federal Flood Risk Management Standard

On July 11, 2024, FEMA issued final regulations implementing the FFRMS (89 C.F.R. 56929). These regulations require that the FFRMS’s flood resilience standard be applied to federally funded projects, and provide a flexible framework to implement the FFRMS. Under these regulations, agencies could establish a project’s compliance with the FFRMS through four approaches:

  • Climate Informed Science Approach (CISA): The elevation and flood hazard area that result from using the best-available, actionable hydrologic and hydraulic data and methods that integrate current and future changes in flooding based on climate science;
  • Freeboard Value Approach (FVA): The elevation and flood hazard area that result from adding an additional 2 feet to the base flood elevation for non-critical actions and by adding an additional 3 feet to the base flood elevation for critical actions;
  • 500-year floodplain: The area subject to flooding by the 0.2% -annual-chance flood; or
  • Additional approaches: The elevation and flood hazard area that result from using any other method identified in an update to the FFRMS.
  • Alongside this regulation, on July 11, 2024, FEMA finalized its updated Policy Guidance for Federal Flood Risk Management Standards (FFRMS). This policy provides detail on FEMA’s interpretation of the Floodplain Management Regulations contained in 44 C.F.R. Part 9, and outlines steps for implementing the FFRMS consistent with applicable regulations, on applicability, processes, resources, and responsibilities.
Executive Order on Climate-Related Financial Risk

On May 20, 2021, President Biden signed Executive Order 14030 (Climate-Related Financial Risk). Among other directives, Executive Order 14030 re-established the FFRMS, which had been eliminated by President Trump’s Executive Order 13807.


First Trump Administration (2017-2021)

Executive Order Rescinding Federal Flood Risk Management Standard

On August 15, 2017, President Trump signed Executive Order 13807 (Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure Projects). Executive Order 13807 revoked President Obama’s Executive Order 13690, and eliminated the FFRMS.


Obama Administration (2009-2017)

Executive Order Establishing a Federal Flood Risk Management Standard

On January 30, 2015, President Obama signed Executive Order 13690 (Establishing a Federal Flood Risk Management Standard and a Process for Further Soliciting and Considering Stakeholder Input), which established the FFRMS to improve the resilience of communities and Federal assets against the impacts of flooding. Alongside establishing the FFRMS, Executive Order 13690 created a process for input from the public and other stakeholders.