FEMA used the total annual Project Amounts for affected FEMA programs as a basis to estimate the increased costs due to the elevation and floodproofing requirements of the FVA.  The programs affected are IA, PA, HMA, GPD, and FEMA facilities.  FEMA data for PA and HMA include data fields that identify projects located in the 1 percent annual chance floodplain.  Over the 10-year period FEMA examined, 38 percent of PA projects were located within the 1 percent annual chance floodplain.  FEMA was not able to obtain floodplain location for IA projects.  As the data is not available for IA, FEMA used the 38 percent of PA projects as a proxy for the number of projects located in the floodplain for IA.  FEMA used the PA data as a proxy for IA because FEMA believes that these two data sets have similar characteristics: PA and IA are both disaster assistance grant programs that are provided in areas with declared disasters, so these grants are generally given in the same areas.  FEMA requests comments from the public regarding these assumptions.  Historical data show that GPD and FEMA facilities have not funded projects that would be subject to the FFRMS elevation requirements.  This is because GPD projects are not typically substantial improvement and new construction.  Permanent FEMA facilities would generally not be built in the floodplain by policy.  FEMA will continue to go through this process to determine whether the facility is in the new FFRMS floodplain.  FEMA facilities may be affected by the horizontal expansion of the floodplain, which would require FEMA to follow FFRMS regulations for future facilities.  This rule proposes a 3-foot freeboard requirement on projects that are considered critical actions.  FEMA estimated the percentage of projects considered critical by using a keyword search on project descriptions in the data provided by FEMA programs.  As stated previously, FEMA estimates that only 5 percent of PA projects and 2.2 percent of HMA projects listed meet the criteria to be considered critical actions.  IA is awarded to individuals and households after a disaster and does not cover activities that are considered critical actions.
      FEMA uses an NFIP report to estimate the cost of the proposed elevation requirements.  The report provides estimates for the cost of elevating structures as a percentage of total construction cost.  The data consist of only residential structures in coastal zones, which have different characteristics to the properties in the FFRMS floodplain.  FEMA does not have cost data for elevation of non-residential structures, so FEMA uses these estimates for both residential and non-residential projects.  FEMA requests comments from the public regarding elevation costs for non-residential structures and structures outside of coastal zones.
      The NFIP report provides cost estimates when freeboard is included in the design of a housing construction project.  Historical FEMA project data includes grants for both new construction and substantial improvements to residential and non-residential structures.  However, FEMA is unable to distinguish between new construction and substantial improvement projects.  New construction is less costly to elevate than existing structures, so this analysis may understate the cost of the proposed elevation requirements for projects of substantial improvement or to address substantial damage.  FEMA requests comments from the public regarding the cost and the number or percentage of projects that qualify as substantial improvement.
      Because it is likely that a large number of projects affected by this rule will be substantial improvement projects, FEMA has provided a rough comparison between these projects' elevation costs and those of new construction.  A 2006 FEMA report compiled the following data on home elevation costs during retrofits (adjusted for inflation here using the US Census Bureau's Construction Price Index).  The costs range from $54,615 to $132,233, with the degree of elevation varying between studies (see Table 10).
Table 10.  Cost of elevation per house (2015$)
Year
                                        2015 elevation cost per house (nominal)
                                        2015 elevation cost per house (2015USD)
                                                                Elevation raise
1990
                                                                        $30,000
                                                                        $61,229
                                                                  From 2-6 feet
1992
                                                                        $33,500
                                                                        $66,531
                                                                   Up to 3 feet
1995
                                                                        $48,000
                                                                        $84,802
                                                                        Unknown
1998
                                                                        $61,000
                                                                       $100,139
                                                                        Unknown
1999
                                                                        $66,000
                                                                       $102,989
                                                                        Unknown
1999
                                                                        $35,000
                                                                        $54,615
                                                                        Unknown
1999
                                                                        $54,000
                                                                        $84,264
                                                                         4 feet
1999
                                                                        $50,000
                                                                        $78,022
                                                                   4.2-8.2 feet
2000
                                                                        $88,000
                                                                       $132,233
                                                                       5-6 feet
2001
                                                                        $57,000
                                                                        $83,122
                                                                        Unknown

                                                                        Minimum
                                                                        $54,615

                                                                        Maximum
                                                                       $132,233

                                                                         Median
                                                                        $83,693

                                                                        Average
                                                                        $84,795

      For new construction, as noted earlier in this RIA, FEMA estimates the increased costs for elevation are 0.3% (low estimate, BFE+2) to 6.8% (high estimate, BFE+3) of total construction costs.  The National Association of Home Builders (NAHB) estimates that the average new single family home in 2015 cost $289,415 for construction and averaged 2,802 ft[2], or $103/ft[2].  Multiplying that figure by the average home size from 2015 Census data (a more complete survey), 2,687 ft[2], suggests an average construction cost of $277,537.  Applying the 0.3-6.8% range suggests an elevation cost of $833-18,873.
      Thus, a comparison of the lowest estimate of substantial improvement elevation costs ($54,615) and the highest new construction elevation cost ($18,873) suggests that elevation in substantial improvement projects is significantly more expensive than new construction elevation.  However, because these studies do not present the costs as a percentage of the construction costs, FEMA is unable to use them to scale the costs to FEMA projects.  Moreover, the available NAHB data is from 2015, while the existing home data is from prior to 2008, presenting possible comparison issues.  Together with the fact that many FEMA grants involving substantial rehabilitation of non-residential structures will elect to floodproof rather than elevate, we do not use these cost estimates to elevate existing buildings in the final estimates of the rule's costs.
      Under this proposed rule, non-residential projects may also elect to floodproof rather than elevate.  FEMA anticipates that larger structures may choose to floodproof, where elevation is not feasible.  Non-residential structures with basements could dry floodproof to the freeboard level, but the basement could not be a habitable space.  Basements may be dry floodproofed using the same techniques as spaces above grade, including the creation of continuous impermeable walls, creating flood resistance in core interior areas, adding sealants on openings, installing flood shields for openings in exterior walls, and installing backflow valves and internal drainage systems.  FEMA data does not provide enough information to easily determine if there is a basement present or not.  Therefore FEMA cannot estimate the additional costs for adding freeboard to buildings with basements.  In addition to the construction cost of meeting the proposed freeboard requirements, additional opportunity costs would be incurred for structures where the basement is below the freeboard elevation.  For these projects, basements would no longer be allowed to be used as habitable space, and structural requirements for elevating to the freeboard level may require that the basement be filled in.  FEMA seeks comments on the assumptions made on basements.
      FEMA undertook the following steps in this analysis to estimate the number and associated cost of projects that would be subject to the proposed freeboard requirements:
      1) FEMA determined the historical number of projects in each program that were located in the 1 percent annual chance floodplain and multiplied the Project Amounts for these by the estimated percentage increase in construction costs due to freeboard elevations.
      2) FEMA examined a sample of 24 counties in California, Florida, Georgia, North Carolina, South Carolina, and Washington to determine the estimated expansion of the floodplain due to the freeboard requirements.  As shown previously in Table 7, based on this data FEMA estimates that the 2-foot freeboard requirement would expand the floodplain area by an average of 16.8 percent, while the 3-foot freeboard requirement would expand it by an average of 24.7 percent.
      3) FEMA multiplied the expansion percentage from Table 7 by the number of projects located in the 1 percent annual chance floodplain to estimate the additional number of projects that would be located within the expanded FFRMS floodplain.
      4) As projects in the expanded FFRMS floodplain move further from the BFE and closer to the 2-foot freeboard value, the amount of elevation required to reach 2 feet of freeboard elevation is lower.  Therefore, FEMA adjusted costs to account for this.  Because data is not available on the number of projects located at an intermediate elevation, FEMA decided the best methodology to use was to assume that (1/2) of projects would need to be elevated to 1 foot and (1/2) would need to be elevated 2 feet.  FEMA believes this is a reasonable assumption where good data is not available.  FEMA seeks public comments on this methodology.
      5) FEMA subtracted out elevation costs already part of the baseline because of existing State or local freeboard requirements.  To do so, FEMA estimated the percentage of projects that are subject to existing freeboard requirements by using the percentage of the U.S. population in areas with such existing requirements shown in Table 8.  This percentage was multiplied by the cost of elevating to determine the cost that would be incurred in the absence of this rule due to these existing requirements, which was subtracted from the total costs.
      6) FEMA determined the percentage of projects that are considered critical actions by conducting a keyword search for projects that involved, for instance, hospitals, fire stations, police stations, jails, emergency operations centers, hazmat storage, treatment plants, and nursing homes, and dividing this number by the total number of PA projects to obtain a percentage.  Steps 1-5 were repeated for critical actions.  However, because critical actions require 3 feet of freeboard, in Step 4, it was assumed that (1/3) of projects would need to be elevated to 1 foot, (1/3) to 2 feet, and (1/3) to 3 feet.
9.5.1 Individual Assistance
      IA Grants are provided to individuals to cover expenses incurred because of a disaster.  Most IA grants do not fund new construction or substantial improvements.  Rather, most assistance is for food, clothing, medical expenses, etc.  The only IA actions subject to the proposed rule are PHC, sales of MHUs, and replacement of private residential bridges.  These forms of IA do not have a cost share.  PHCs are funded 100 percent by FEMA.  An MHU, after use as temporary housing following a disaster, must be brought up to standards at the expense of the IA grant recipient who ultimately purchases the MHU.
      Over the last 10 years, IA has not funded grants for any residential bridge replacement projects, so residential bridges are not included in the cost estimates.  However, residential bridge replacement projects may be approved in the future.
      According to historical IA approvals over the period from 2006-2015, IA funded 50 PHCs and 114 MHU sales, averaging 5 PHCs and 11 MHUs per year.  FEMA subject matter experts estimate that the cost per PHC during this time period was $500,000.  The average MHU over the same time period sold for $31,966.  An MHU sold to a disaster survivor is not eligible for Federal funds to cover elevation costs, so the entire cost would be borne by the IA recipient who ultimately purchases the MHU.  Due to the relatively low costs of MHUs, the percentages of construction costs applied to estimate the cost of adding freeboard may underestimate the actual cost of elevating MHUs on the low end.  However FEMA does not have sufficient data to narrow this cost range.  FEMA requests comments on these MHU assumptions.
      IA data does not designate projects that are located in the floodplain, so FEMA is using the percentage of PA projects as a proxy to estimate the number of IA projects in the 1 percent annual chance floodplain.  Applying the 38 percent of projects located in the floodplain would result in an average of 1.9 PHCs (5 x 0.38) and 4.18 (11 x 0.38) MHUs located in the floodplain each year.  Because of the nature of the IA program, no IA projects meet the definition of a critical action.  Using the data in Table 9, FEMA estimates that a 2-foot freeboard requirement leads to a 16.8 percent increase in the area of the floodplain.  Applying the 16.8 percent increase to the number of projects located in the 1 percent annual chance floodplain leads to an average of 0.32 (0.168 x 1.9) PHCs and 0.70 (0.168 x 4.18) MHUs in the expanded FFRMS floodplain per year.
Table 11.  Percentage and Number of IA Projects Located in the FFRMS-FVA Floodplain Annually

                                                                    Percent (%)
                                                                           No.
                                                         Average Project Amount
PHC Projects
                                                                            100
                                                                              5
                                                                       $500,000
MHU Sales
                                                                            100
                                                                             11
                                                                        $31,966
PHCs in the 1 percent annual chance floodplain
                                                                             38
                                                                            1.9

MHUs in the 1 percent annual chance floodplain
                                                                             38
                                                                           4.18

PHCs between the 1 percent annual chance floodplain and 2-foot freeboard
                                                                          16.8*
                                                                           0.32

MHUs between the 1 percent annual chance floodplain and 2-foot freeboard
                                                                          16.8*
                                                                            0.7

  *16.8 percent is the estimated percent increase in the size of the expanded floodplain.
      To account for the costs of elevation requirements for IA projects, FEMA used a multi-step process to estimate the range of costs for elevating structures.  FEMA used elevation cost data from a FEMA study on the NFIP's Building Standards, shown in Table 7.  In this process, FEMA also accounts for existing freeboard requirements, shown in Table 9.
      Permanent Housing Construction
      1. Cost of elevating projects in the 1 percent annual chance floodplain
      PHC projects that are located within the 1 percent annual chance floodplain, would be required to elevate an additional 2 feet under the proposed rule.  FEMA calculates the cost of elevating these projects as follows:
      Project Amount x number of projects in the 1 percent annual chance floodplain x percentage cost of elevating 2 feet
      $500,000 project amount per PHC x 1.9 projects x 0.3% cost of elevating 2 feet = $2,850 (Low Estimate)
      $500,000 project amount per PHC x 1.9 projects x 4.8% cost of elevating 2 feet = $45,600 (High Estimate)
      2. Cost of elevating projects between 1 percent annual chance floodplain and 2-foot freeboard elevation
      In addition to projects located in the 1 percent annual chance floodplain, additional projects that are located outside of the 1 percent annual chance floodplain, but are below the 2-foot freeboard elevation must also be elevated.  These projects would require elevations of different levels, depending on the elevation of the ground that they are located on.  Some would need to be elevated 1 foot (if they are currently at an elevation that is 1 foot above the 1 percent annual chance floodplain).  Some would need to be elevated 2 feet (if they are currently at an elevation that is just at the 1 percent annual chance floodplain).  Others would require a smaller amount elevation to intermediate levels (e.g., 6 inches for a structure already elevated 1.5 feet above the 1 percent annual chance floodplain).  FEMA estimates the cost of elevating these projects by assuming half of the projects would need to be elevated by 1 foot, and the other half of projects would need to be elevated by 2 feet.
FEMA calculates the cost of elevating projects between 1 percent annual chance floodplain and 2-foot freeboard elevation as follows:
      (1/2)(Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 2 feet) + (1/2)(Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 1-foot)
      (1/2)($500,000 project amount per PHC x 0.32 projects x 0.2% cost of elevating 1 foot) + (1/2)($500,000 project amount per PHC x 0.32 projects x 0.3% cost of elevating 2 feet) = $400 (Low Estimate)
      (1/2)($500,000 project amount per PHC x 0.32 projects x 3.9% cost of elevating 1 foot) + (1/2)($500,000 project amount per PHC x 0.32 projects x 4.8% cost of elevating 2 feet) = $6,960 (High Estimate)
      3. Less costs that would be incurred in the absence of this rule due to existing freeboard requirements.
      There are areas that have existing freeboard requirements.  FEMA has accounted for existing freeboard requirements by subtracting the cost of building to the existing requirements.  If there are fixed costs to substantial improvement elevation projects and if structures are already at the locally required level, then this methodology may understate the cost, since in the absence of this rule, no further elevation (and thus no fixed costs) would be required.  FEMA does not have data to account for these factors and requests comments from the public on estimating these effects.
      FEMA has multiplied the cost of the existing freeboard requirements by the percentage of the population that lives in those areas (see Table 12) and then subtracted these costs from the total costs estimated in the steps 1 and 2 above.
      FEMA subtracts costs that would be incurred in the absence of this rule due to existing freeboard requirements.  First, FEMA accounts for PHC projects that are located within the 1 percent annual chance floodplain that have 1-foot existing freeboard requirements.  FEMA calculates these costs as follows:
      Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot
      $500,000 project amount per PHC x 1.9 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 0.2%  cost of elevating 1 foot = $863 (Low Estimate)
      $500,000 project amount per PHC x 1.9 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 3.9% cost of elevating 1 foot = $16,836 (High Estimate)
      Next, FEMA accounts for PHC projects that are located within the 1 percent annual chance floodplain that have 2-foot existing freeboard requirements.
      Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of elevating 2 feet
      $500,000 project amount per PHC x 1.9 projects x 16.55% population living in areas with 2-foot freeboard requirement x 0.3% cost of elevating 2 feet= $472 (Low Estimate)
      $500,000 project amount per PHC x 1.9 projects x 16.55% population living in areas with 2-foot freeboard requirement x 4.8% cost of elevating 2 feet= $7,547 (High Estimate)
Finally, FEMA accounts for PHC projects that are located between the 1 percent annual chance floodplain and 2-foot freeboard elevation.  To account for this, FEMA multiplied the cost of elevating these projects by the population living in areas with an existing 2-foot freeboard requirement so this can be subtracted from the cost.
(Project Amount x number of projects located between the 1 percent annual chance flood level and the 2 foot freeboard level x percentage cost of elevating 1 foot x percentage of population living in areas with existing 1-foot freeboard requirement) + (Project Amount x number of projects located between the 1 percent annual chance flood level and the 2-foot freeboard level x percentage cost of elevating 2 feet x percentage of the population living in areas with at least 2-foot existing freeboard requirement)
      ($500,000 project amount per PHC x 0.32 projects x 0.2% cost of elevating 1 foot x 45.44% population living in areas with existing 1-foot freeboard requirement) + ($500,000 project amount per PHC x 0.32 projects x 0.3% cost of elevating 2 feet x 16.55% population living in areas with at least 2-foot existing freeboard requirement) = $225 (Low Estimate)
      ($500,000 project amount per PHC x 0.32 projects x 3.9% cost of elevating 1 foot x 45.44% population living in areas with existing 1-foot freeboard requirement) + ($500,000 project amount per PHC x 0.32 projects x 4.8% cost of elevating 2 feet x 16.55% population living in areas with at least 2-foot existing freeboard requirement) = $4,106 (High Estimate)
      Total baseline cost for PHC to be subtracted due to existing freeboard requirements
      $863 + $472 + $225 = $1,560 (Low Estimate)
      $16,836 + $7,547 + $4,106 = $28,489 (High Estimate)
      4. Total cost for PHC
      FEMA calculated the total cost for PHC by adding the cost of elevating projects in the 1 percent annual chance floodplain to the cost of elevating projects between the 1 percent annual chance floodplain and the 2-foot freeboard elevation.  FEMA subtracted the baseline costs due to existing freeboard requirements to determine the total cost for PHC.
Table 12.  Total Annual Cost for IA PHC

                                                                   Low Estimate
                                                                  High Estimate
      Cost of elevation from 1 percent annual chance floodplain
                                                                         $2,850
                                                                        $45,600
      Cost of elevation between 1 percent annual chance floodplain and 2-foot freeboard
                                                                           $400
                                                                         $6,960
      Existing requirements (Cost already to be incurred)
                                                                        -$1,560
                                                                       -$28,489
      Total Cost
                                                                         $1,690
                                                                        $24,071
      Mobile Housing Unit Sales
      The cost of this rule for MHUs was estimated using the same process as for PHCs.
      1. Cost of elevating projects that are located within the 1 percent annual chance floodplain
      Project amount x number of projects in the 1 percent annual chance floodplain x percentage cost of elevating 2 feet.
      $31,966 project amount per MHU x 4.18 projects x 0.3% cost of elevating 2 feet = $401 (Low Estimate)
      $31,966 project amount per MHU x 4.18 projects x 4.8% cost of elevating 2 feet = $6,414 (High Estimate)
      2. Cost of elevating projects between the 1 percent annual chance floodplain and the 2-foot freeboard elevation
      (1/2) (Project amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 2 feet) + (1/2) ( Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 1 foot)
      (1/2) ($31,966 project amount per MHU x 0.7 projects x 0.2% cost of elevating 1 foot) + (1/2) ($31,966 x 0.7 projects x 0.3% cost of elevating 2 feet) = $56 (Low Estimate)
      (1/2) ($31,966 project amount per MHU x 0.7 projects x 3.9% cost of elevating 1 foot) + (1/2) ($31,966 x 0.7 projects x 4.8% cost of elevating 2 feet) = $973 (High Estimate)
      3. Less costs that would be incurred in the absence of this rule due to existing freeboard requirements
      Project amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot
      $31,966 project amount per MHU x 4.18 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 0.2% cost of elevating 1 foot = $121 (Low Estimate)
      $31,966 project amount per MHU x 4.18 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 3.9% cost of elevating 1 foot = $2,368 (High Estimate)
      Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of elevating 2 feet
      $31,966 project amount per MHU x 4.18 projects x 16.55% population living in areas with 2-foot freeboard requirement x 0.3% cost of elevating 2 feet = $66 (Low Estimate)
      $31,966 project amount per MHU x 4.18 projects x 16.55% population living in areas with 2-foot freeboard requirement x 4.8% cost of elevating 2 feet = $1,061 (High Estimate)
      (Project Amount x number of projects located between the 1 percent annual chance flood level and the 2 foot freeboard level x percentage cost of elevating 1 foot x percentage of population living in areas with existing 1-foot freeboard requirement) + (Project Amount x number of projects located between the 1 percent annual chance flood level and the 2-foot freeboard level x percentage cost of elevating 2 feet x percentage of the population living in areas with at least 2-foot existing freeboard requirement)
      ($31,966 project amount per MHU x 0.7 projects x 0.2% cost of elevating 1 foot x 45.44% population living in areas with existing 1-foot freeboard requirement) + ($31,966 x 0.7 projects x 0.3% cost of elevating 2 feet x 16.55% the population living in areas with at least 2-foot existing freeboard requirement) = $31 (Low Estimate)
      ($31,966 project amount per MHU x 0.7 projects x 3.9% cost of elevating 1 foot x 45.44% population living in areas with existing 1-foot freeboard requirement) + ($31,966 x 0.7 projects x 4.8% cost of elevating 2 feet x 16.55% the population living in areas with at least 2-foot existing freeboard requirement) = $574 (High Estimate)
      Total baseline cost for MHU to be subtracted due to existing freeboard requirements
      $121 + $66 + $31 = $219 (Low Estimate)
      $2,368 + $1,061 + $574 = $4,004 (High Estimate)
      4. Total cost for MHU
      FEMA calculated the cost for MHU by adding the cost of elevating projects in the 1 percent annual chance floodplain to the cost of elevating projects between the 1 percent annual chance floodplain and the 2-foot freeboard elevation.  FEMA subtracted the baseline costs due to existing freeboard requirements to determine the total cost for MHU.
Table 13.  Total Annual Cost for IA MHU Sales

                                                                   Low Estimate
                                                                  High Estimate
      Cost of elevation from 1 percent annual chance floodplain
                                                                           $401
                                                                         $6,414
      Cost of elevation between 1 percent annual chance floodplain and 2-foot freeboard
                                                                            $56
                                                                           $973
      Existing requirements (cost already to be incurred)
                                                                          -$219
                                                                        -$4,004
      Total Cost
                                                                           $238
                                                                         $3,383
      PHCs are fully funded by FEMA, so the costs to FEMA are estimated to range between $1,690 and $24,071 per year.  MHU elevation must be paid fully by purchasers, so the non-FEMA costs are estimated to range between $238 and $3,383 per year.
9.5.2 Public Assistance
      PA Grants are provided to public and private non-profit entities that have suffered damage to property as a result of a declared disaster.  PA projects that fall under the proposed rule are new construction, substantial improvement, or repair of substantial damage to a structure or facility.  Of the PA Category E (Public Buildings) and Category C (Roads and Bridges) projects over the past 10 years, 438 Category E and 71 Category C projects would be subject to the proposed rule.
      Category E Projects (Public Buildings)
      FEMA used data from PA grant approvals from 2006-2015.  According to these data, over the 10[ ]year period, out of a population of 20,341 individual Category E grant recipients, 438 projects meet FFRMS inclusion criteria (new construction or substantial improvement), averaging 44 projects per year.  The average Project Amount for these projects was $7,925,401.  PA data identify projects located in the 1 percent annual chance floodplain.  Of the 438 projects that meet FFRMS inclusion criteria, there were 165 Category E Federally Funded Projects located in the floodplain, 38 percent of applicable projects.  Therefore, FEMA estimates that an average of 16.38 Category E projects per year that would be subject to the proposed rule are located in the 1 percent annual chance floodplain.  PA grants data show that approximately 5 percent of included PA projects during the 10-year time period meet the criteria to be considered critical actions.  Applying the 5 percent to the estimated 16.38 Category E projects per year, FEMA estimates that 0.82 (5 percent x 16.38) Category E projects annually would be considered critical actions; the remaining 95 percent, or 15.56 projects would be considered non-critical actions.
      Using the data in Table 10, FEMA estimates that a 2-foot freeboard requirement leads to a 16.8 percent increase in the area of the floodplain.  Applying the 16.8 percent increase to the number of non-critical projects located in the 1 percent annual chance floodplain leads to an average of 2.61 (16.8 percent x 15.56 projects) non-critical projects that would be in the expanded FFRMS floodplain per year.  FEMA applies the floodplain expansion percentage of 24.7 percent to the 0.82 critical actions per year located in the 1 percent annual chance floodplain to estimate an additional 0.20 critical actions in the expanded 3-foot freeboard elevation.
Table 14.  Percentage and Number of PA Category E Projects Located in the FFRMS-FVA Floodplain Annually

                                                                    Percent (%)
                                                                            No.
                                                         Average Project Amount
Number of Projects in 1 percent annual chance floodplain
                                                                           38.0
                                                                          16.38
                                                                     $7,925,401
Non-Critical Actions
                                                                           95.0
                                                                          15.56

Non-Critical Action between 1 percent annual chance floodplain and 2 foot freeboard
                                                                           16.8
                                                                           2.61

Critical Actions
                                                                            5.0
                                                                           0.82

Critical Actions between 1 percent annual chance floodplain and 3-foot freeboard
                                                                          24.7*
                                                                           0.20

* 16.8% and 24.7% are the estimated percent increases in the size of the expanded floodplain.
      To account for the costs of elevation requirements for PA projects, FEMA used a multi-step process to estimate the range of costs for elevating structures.  FEMA used elevation cost data from a FEMA study on the NFIP's Building Standards, shown in Table 7.  In this process FEMA also accounts for existing freeboard requirements, shown in Table 9.
   1. Cost of elevating Projects in the 1 percent annual chance floodplain
      PA projects located in the 1 percent annual chance floodplain would be required to elevate an additional 2 feet (if non-critical), under the proposed rule.  FEMA calculates the cost of elevating these projects as follows:
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage cost of elevating 2 feet
      $7,925,401 PA project amount x 15.56 projects x 0.3% cost of elevating 2 feet = $369,958 (Low Estimate)
      $7,925,401 PA project amount x 15.56 projects x 4.8% cost of elevating 2 feet = $5,919,323 (High Estimate)
      In addition to projects located in the 1 percent annual chance floodplain, additional projects that are located outside of the floodplain, but are below the 2-foot freeboard elevation, would also need to be elevated.  These projects would require elevations of different levels, depending on the structure's current elevation.  Some would need to be elevated 1 foot (if they are located on ground 1 foot above the BFE).  Some would need to be elevated 2 feet (if they are located on ground that is just at the BFE).  Others would require elevation to intermediate levels (e.g., 6 inches, 1 (1/2) feet, etc.).  FEMA estimates the cost of elevating these projects by assuming half of the projects would need to be elevated 1 foot, and the other half or projects would need to be elevated 2 feet.
   2. Cost of elevating projects between 1 percent annual chance floodplain and 2-foot freeboard elevation
      (1/2)(Average Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 2 feet) + (1/2)(Average Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 1 foot)
      (1/2)($7,925,401 PA project amount x 2.61 projects x 0.2% cost of elevating 1 foot) + (1/2)($7,925,400.68 PA project amount x 2.61 projects x 0.3% cost of elevating 2 feet) = $51,713 (Low Estimate)
      (1/2)($7,925,401 PA project amount x 2.61 projects x 3.9% cost of elevating 1 foot) + (1/2)($7,925,400.68 PA project amount x 2.61 projects x 4.8% cost of elevating 2 feet) = $899,810 (High Estimate)
   3. Less costs that would be incurred in the absence of this rule due to existing freeboard requirements.
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot
      $7,925,401 PA project amounts x 15.56 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 0.2% cost of elevating 1 foot = $112,072 (Low Estimate)
$7,925,401 PA project amounts x 15.56 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 3.9% cost of elevating 1 foot =$2,185,413 (High Estimate)
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of elevating 2 feet
      $7,925,401 PA project amounts x 15.56 projects x 16.55% population living in areas with 2-foot freeboard requirement x 0.3% cost of elevating 2 feet = $61,228 (Low Estimate)
      $7,925,401 PA project amounts x 15.56 projects x 16.55% population living in areas with 2-foot freeboard requirement x 4.8% cost of elevating 2 feet = $979,648 (High Estimate)
      (Average Project Amount x number of projects located between the 1 percent annual chance flood level and the 2 foot freeboard level x percentage cost of elevating 1 foot x percentage of population living in areas with existing 1-foot freeboard requirement) + (Average Project Amount x number of projects located between the 1 percent annual chance flood level and the 2-foot freeboard level x percentage cost of elevating 2 feet x percentage of the population living in areas with at least 2-foot existing freeboard requirement)
      ($7,925,401 PA project amounts x 2.61 projects x 45.44% cost of elevating 1 foot x 0.2% population living in areas with existing 1-foot freeboard requirement) + ($7,925,401 PA project amounts x 2.61 projects x 16.55% population living in areas with at least 2-foot existing freeboard requirement x 0.3% cost of elevating 2 feet) = $29,068 (Low Estimate)
      ($7,925,401 PA project amounts x 2.61 projects x 45.44% population living in areas with existing 1-foot freeboard requirement x 3.9% cost of elevating 1 foot) + ($7,925,401 PA project amounts x 2.61 projects x 16.55% population living in areas with at least 2-foot existing freeboard requirement x 4.8% cost of elevating 2 feet) = $530,900 (High Estimate)
      Total baseline cost for non-critical actions to be subtracted due to existing freeboard requirements
      $112,072 + $61,228 + $29,068 = $202,368 (Low Estimate)
      $2,185,413 + $979,648 + $530,900 = $3,695,963 (High Estimate)
   4. Total cost for PA non-critical actions
      FEMA calculated the cost for non-critical actions by adding the cost of elevating projects in the 1 percent annual chance floodplain to the cost of elevating projects between the 1 percent annual chance floodplain and the 2-foot freeboard elevation.  FEMA subtracted the baseline costs due to existing freeboard requirements to determine the total cost for non-critical actions.
Table 15.  Total Annual Cost for PA Category E Non-Critical Actions

                                                                   Low Estimate
                                                                  High Estimate
Elevation from 1 percent annual chance floodplain
                                                                       $369,958
                                                                     $5,919,323
Elevation between 1 percent annual chance floodplain and 2-foot freeboard
                                                                        $51,713
                                                                       $899,810
Existing requirements (cost already to be incurred)
                                                                      -$202,368
                                                                    -$3,695,963
Total Cost
                                                                       $219,301
                                                                     $3,123,171
   5. FEMA used a similar process to determine the costs of elevating critical actions.  The first step was to determine the costs of elevating projects located in the 1 percent annual chance floodplain an additional 3 feet.  Cost for critical actions in the 1 percent annual chance floodplain:
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage cost of elevating 3 feet
      $7,925,401 PA project amounts x 0.82 critical actions x 0.7% cost of elevating 3 feet = $45,492 (Low Estimate)
      $7,925,401 PA project amounts x 0.82 critical actions x 6.8% cost of elevating 3 feet = $441,920 (High Estimate)
   6. Cost of elevating critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation
      The costs associated with elevating critical actions that are located between the 1 percent annual chance floodplain and the 3-foot freeboard elevation was determined using cost estimates for 1 foot, 2 feet, and 3 feet of elevation to account for different elevation requirements due to the ground elevation above the 1 percent annual chance flood level.  FEMA estimates the cost by assuming that one-third of the projects would need to be elevated by 1 foot, 2 foot, and 3 foot, respectively.
      FEMA calculates the cost for critical actions between the 1 percent annual chance floodplain and the 3-foot freeboard elevation as follows:
      (1/3) (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of elevating 3 feet) + (1/3) (Average Project Amount x number of projects between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of elevating 2 feet) + (1/3) (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of elevating 1 foot)
      (1/3) ($7,925,401 PA project amounts x 0.2 critical actions x 0.7% cost of elevating 3 feet) + (1/3) ($7,925,401 x 0.2 critical actions x 0.3% cost of elevating 2 feet) + (1/3) ($7,925,401 PA project amounts x 0.2 critical actions x 0.2% cost of elevating 1 foot) = $6,340 (Low Estimate)
      (1/3) ($7,925,401 PA project amounts x 0.2 critical actions x 6.8% cost of elevating 3 feet) + (1/3) ($7,925,401 x 0.2 critical actions x 4.8% cost of elevating 2 feet) + (1/3) ($7,925,401 PA project amounts x 0.2 critical actions x 3.9 % cost of elevating 1 foot) = $81,896 (High Estimate)
   7.          Less costs for critical actions that would be incurred in the absence of this rule due to existing freeboard requirements
      As with non-critical actions, some projects would be located in areas with existing freeboard requirements.  FEMA uses a similar process to estimate the costs that would be incurred in the absence of this rule due to State and county regulations, but with the addition of a 3-foot freeboard requirement.
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot freeboard requirement x percentage cost of elevating 1 foot
$7,925,401 PA project amounts x 0.82 critical actions x 45.44% population living in areas with 1-foot freeboard requirement x 0.2% cost of elevating 1 foot = $5,906 (Low Estimate)
      $7,925,401 PA project amounts x 0.82 critical actions x 45.44% population living in areas with 1-foot freeboard requirement x 3.9% cost of elevating 1 foot = $115,170 (High Estimate)
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of elevating 2 feet
      $7,925,401 PA project amounts x 0.82 critical actions x 15.12% population living in areas with 2-foot freeboard requirement x 0.3% cost of elevating 2 feet = $2,948 (Low Estimate)
      $7,925,401 PA project amounts x 0.82 critical actions x 15.12% population living in areas with 2-foot freeboard requirement x 4.8% cost of elevating 2 feet = $47,166 (High Estimate)
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 3-foot freeboard requirement x percentage cost of elevating 3 feet
      $7,925,401 PA project amounts x 0.82 critical actions x 1.43% population living in areas with 3-foot freeboard requirement x 0.7% cost of elevating 3 feet = $651 (Low Estimate)
      $7,925,401 PA project amounts x 0.82 critical actions x 1.43% population living in areas with 3-foot freeboard requirement x 6.8% cost of elevating 3 feet = $6,319 (High Estimate)
      (Average Project Amount x number of critical actions between the 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot) + (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 2-foot existing freeboard requirement x percentage cost of elevating 2 feet) + (Average Project Amount x number of critical actions between the 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 3-foot existing freeboard requirement x percentage cost of elevating 3 feet)
      ($7,925,401 PA project amounts x 0.2 critical actions x 45.44% population in areas with 1-foot existing freeboard requirement x 0.2% cost of elevating 1 foot) + ($7,925,401 PA project amounts x 0.2 critical actions x 15.12% population in areas with 2-foot existing freeboard requirement x 0.3% cost of elevating 2 feet) + ($7,925,401 PA project amounts x 0.2 critical actions x 1.43% population in areas with 3-foot existing freeboard requirement x 0.7% cost of elevating 3 feet) = $2,318 (Low Estimate)
      ($7,925,401 PA project amounts x 0.2 critical actions x 45.44% population in areas with 1-foot existing freeboard requirement x 3.9% cost of elevating 1 foot) + ($7,925,401 PA project amounts x 0.2 critical actions x 15.12% population in areas with 2-foot existing freeboard requirement x 4.8% cost of elevating 2 feet) + ($7,925,401 PA project amounts x 0.2 critical actions x 1.43% population in areas with 3-foot existing freeboard requirement x 6.8% cost of elevating 3 feet) = $41,135 (High Estimate)
      Total baseline cost for PA critical actions to be subtracted due to existing freeboard requirements
      $5,906 + $2,948 + $651 + $2,318 = $11,823 (Low Estimate)
      $115,170 + $47,166 + $6,319 + $41,135 = $209,790 (High Estimate)
   8.          Total cost for PA critical actions
      FEMA calculated the cost for critical actions by adding the cost of elevating the projects in the 1 percent annual chance floodplain to the cost of elevating projects between the 1 percent annual chance floodplain and the 3-foot freeboard elevation and then subtracting the baseline costs due to existing freeboard requirements.
Table 16.  Total Annual Cost for PA Category E Critical Actions

                                                                   Low Estimate
                                                                  High Estimate
Elevation from 1 percent annual chance floodplain
                                                                        $45,492
                                                                       $441,920
Elevation between 1 percent annual chance floodplain and 3-foot freeboard
                                                                         $6,340
                                                                        $81,896
Existing requirements(Cost already to be incurred)
                                                                      - $11,823
                                                                      -$209,790
Total Cost
                                                                       $40,009
                                                                      $314,026
   9. Total cost for all projects (non-critical and critical)
Table 17.  Total Annual Cost for All PA Category E Projects

                                                                   Low Estimate
                                                                  High Estimate
Non-Critical Actions
                                                                      $219,301
                                                                    $3,123,171
Critical Actions
                                                                       $40,009
                                                                      $314,026
Total Cost
                                                                      $259,311
                                                                    $3,437,197
      Category C Projects (Roads and Bridges)
      PA Category C grants may be used to repair or replace publicly-owned bridges.  FEMA's PA program provides grant funding to eligible applicants for repair and replacement of non-Federal aid roads and bridges following a declared major disaster or emergency.  This assistance can include emergency work needed to restore citizen access to homes and communities as well as permanent repair or replacement of damaged infrastructure.  Restoration of a damaged bridge may include upgrades necessary to meet current codes and standards, which includes Federal, State and local repair or replacement standards.  In addition, mitigation measures to reduce risk of future damage can be incorporated into road and bridge repair or new construction.  PA Category C grants do not overlap with any assistance provided by the Department of Transportation.
      To estimate the number of bridge replacements in the floodplain, FEMA conducted a search of project descriptions using the term "bridge" with the assumption that projects with the term bridge would be in the floodplain.   FEMA estimates that over the past 10 years, PA has funded the replacement of 71 bridges in the floodplain, averaging 7.1 bridge replacements per year.  The project amount for bridge replacement has averaged $3,180,571 per grant, and also has an average 75 percent cost share.  Bridges inside the floodplain would be vital for escape routes and access in emergencies.  FEMA considered all 71 bridges included in its analysis to be critical actions.
      The costs of making bridges resilient to flooding involves more than elevation since bridges could affect the flow of water underneath them, and possibly be overtopped during a flood event.  The cost estimation formula used for building projects is not appropriate for bridge projects.  Currently, FEMA does not have accurate data on the cost of additional elevation and floodproofing of bridges.  FEMA therefore relied on California's Department of Transportation Comparative Bridge Costs Table.  The table provides a range of cost per square foot estimates for a variety of bridge structure types.  It also lists factors that should be taken into account when determining a price within the cost range.  FEMA believes that the cost of affected Category C projects currently skew towards the higher end of the cost range because these projects are located in a floodplain and include long spans, high structure heights, environmental constraints, wet conditions (cofferdams required), and pile footing (large diameter piling).  According to this table, factors that would improve flood resiliency of bridges, such as changing the substructure construction or structure with more than two construction stages, would push the construction costs from 25 to 150 percent over the higher level of the bridge construction cost range.  FEMA does not have the data to confirm if all 71 bridges have been located in the floodplain.  For any bridges not in the floodplain, but would be under the proposed rule, the bridge replacement cost may increase greater than the 25 to 150 percent estimate.  These projects costs may have been towards the lower end of the range.  Using the bridge cost table previously discussed, in these cases construction costs could increase from the lower end to the higher end of construction costs, or between 56 to 186 percent.
      Assuming that the resiliency standards would increase construction costs between 25 and 150 percent, and using the PA annual average cost of bridge grants of $3,180,571, FEMA estimates that the costs of this proposed rule for Category C bridge projects would range from $5,645,515 ($3,180,571 x 7.1 bridges x 25%) on the low end to $33,873,084 ($3,180,571 x 7.1 bridges x 150%) on the high end.  These grants have a cost share of 75 percent funded by FEMA and the remaining 25 percent funded by the applicant.  FEMA requests public comments regarding available cost data for bridge flood resiliency costs, and the assumptions made in this analysis.
      FEMA was unable to estimate the cost of the rule for road projects.  Improving flood resiliency of roads is highly project-specific, and there are numerous options for making roads resilient.  Damage to roads during flood events can be caused by erosion and scour, inundation by floodwater, or debris blockage, and can be worsened by issues such as misaligned culverts, insufficient culvert capacity, embankment erosion, road and shoulder damage, and obstructions that reduce culvert capacity.  A sampling of mitigation actions that can improve the resiliency of a road to flooding include installing low water crossings, increasing culvert size, installing a relief culvert, adding rip rap to a road embankment to provide slope protection, installing structures such as aprons and baffle structures that dissipate the energy of floodwater, realigning culverts, and installing road shoulder subsurface drains.  FEMA does not have the data to accurately estimate the number of road projects which would be considered a substantial improvement or new construction.  FEMA seeks comment on how it might estimate the effect of the proposed rule on the costs of these projects.
      Other PA Categories
      PA Category A (Debris Removal) and Category B (Emergency Protective Measures) are not under the scope of the FFRMS.  Those categories are for emergency work authorized under sections 403 and 502 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, (as amended 42 U.S.C. 5170b and 5192).  Section 8 of Executive Order 11988 specifically exempts assistance provided under those sections from application of the Order.  Category H (Fire Management) is not under the scope of the FFRMS because Fire Management Assistance (section 420) is excluded from the 8-step review by 44 CFR 9.5(c)(6).
      Category D (Water Control Facilities), Category F (Utilities), and Category G (Parks, Recreational Areas, and Other Facilities) may fund projects that would be subject to the FFRMS.  These grants are not used for construction, improvement, or repair of buildings; therefore, the percentage cost of elevating to the freeboard level would not be an appropriate way to measure costs associated with these categories.  However, these projects would still need to be designed to meet resiliency standards in order to withstand flood levels at the appropriate elevation, and are subject to the 8-step process if they are located within the 1 percent annual chance floodplain or the expanded FFRMS floodplain.  In the sections below FEMA discusses each of these PA Categories in more detail.
      PA Category D (Water Control Facilities)
      Category D covers water control facilities, such as those that were built for channel alignment, recreation, navigation, land reclamation, maintenance of fish and wildlife habitat, interior drainage, irrigation, and erosion prevention.  Many projects under this category will not meet the definition of Federally Funded Projects because projects under this category often involve minor repairs to existing structures that do not rise to the level of substantial improvement.
      It is not possible to develop cost estimates of the effects of this rule on Category D projects because the manner in which the applicants meet the resiliency standards will be fact-specific and dependent upon the nature of the design and purpose of the specific water control system.  Further, such projects often involve funding from other Federal agencies which means that FEMA will need to coordinate with those agencies to determine the appropriate FFRMS approach to apply.  FEMA requests comments from the public on the type and cost of resiliency measures for water control facilities.
      PA Category F (Utilities)
      PA Category F allows for the repair or restoration of utilities, including:  water treatment plants and delivery systems; power generation and distribution facilities, including natural gas systems, wind turbines, generators, substations, and power lines; sewage collection and treatment plants; and communications.  The vast majority of PA Category F projects involve repairing power lines and associated equipment damaged in storms, primarily from wind or debris striking power lines.  These projects, when located in the 1 percent annual chance floodplain or the expanded FFRMS FVA floodplain would be required to undergo the 8-step process and take appropriate mitigation measures.
      Based on historical data from 2006-2015, PA Category F grants have been used in repairs to sewage treatment plants, water treatment plants, and power plants.  These grants have also been used to repair and replace non-structural equipment such as pumps, generators, transformers, and fences.  Equipment that is susceptible to water damage, particularly electrical equipment, would need to be protected to the freeboard level.  PA projects already require this equipment to be protected above the 1 percent annual chance flood level, but additional elevation of equipment may be required for applicable projects in the FFRMS floodplain.  Because of significant differences in the type and scope of these projects, FEMA is not able to develop cost estimates that adequately account for the highly specific nature of individual projects.  FEMA seeks comments from the public on the costs of resiliency measures for Category F projects.  FEMA requests comments on the costs to Category F projects.
      PA Category G (Parks, Recreational Areas, and Other Facilities)
      PA Category G may include playground and picnic equipment, swimming pools, golf courses, tennis courts, piers, some beaches, and supporting facilities.  Based on a review of historical Category G data, FEMA did not have projects where flood mitigation would be feasible.  These projects would be subject to the 8-step process, but limited measures are available to mitigate flood risk.  Due to the limited feasibility of mitigation measures for these types of projects, FEMA is unable to make cost estimates for Category G projects.  FEMA requests comments from the public on the costs associated with Category G projects.
      Total Cost to PA program
      The total cost to the PA program is estimated to be between $5.9 million and $37.3 million per year.  With the 75 percent cost share, the cost to FEMA would be between $4.4 million and $28.0 million, while the cost to grant recipients would be between $1.5 million and $9.3 million.
Table 18.  Total Annual Cost to PA Program

                                                                   Low Estimate
                                                                  High Estimate
PA Category E
                                                                       $259,311
                                                                     $3,437,197
PA Category C
                                                                     $5,645,515
                                                                    $33,873,084
Total Estimated Costs
                                                                     $5,904,826
                                                                    $37,310,281
PA Category D
                                                                   Unquantified
                                                                   Unquantified
PA Category F
                                                                   Unquantified
                                                                   Unquantified
PA Category G
                                                                   Unquantified
                                                                   Unquantified
9.5.3 Hazard Mitigation Assistance
      The purpose of HMA is to help communities implement hazard mitigation measures following a Presidential major disaster declaration.  Hazard mitigation is any action taken to reduce or eliminate long-term risk to people and property from natural hazards.  These grants are distributed to individual homeowners, businesses, and private non-profits who must apply through States, territories, or federally-recognized Tribes.
      FEMA used data from HMA grant approvals from 2005-2014.  According to this data, over the 10-year period, HMA funded 628 elevation and 44 floodproofing projects.  HMA projects may include a single structure, or multiple structures.  FEMA data does not have the individual cost per structure, so FEMA is estimating costs based on total project costs.  HMA has funded an average of 67 projects per year, with 63 of these for elevation and 4 for floodproofing.  The remaining projects include property acquisition and retrofitting structures, which fall outside of the scope of the proposed rule because they would not meet the definition of FEMA Federally Funded Projects as defined by the proposed rule.  The average HMA grant for elevation of structures was approximately $1.3 million, while the average amount for floodproofing was approximately $630,000.  Because FEMA examined elevation and floodproofing projects, all HMA grants used in this analysis were located in  the 1 percent annual chance floodplain, so all HMA elevation and floodproofing projects are assumed to be in the 1 percent annual chance floodplain for this analysis.
      Of the 63 elevation projects funded each year, 2.2 percent of projects per year would be considered critical actions.  Applying the percentage of critical actions to the number of annual projects, 61.61 projects (63 x 97.8%) would be considered non-critical, and 1.39 (63 x 2.2%) would be considered critical.  Due to the horizontal expansion of the FFRMS floodplain, FEMA expects an additional 10.35 (61.61 x 16.8%) non-critical projects to require elevation and an additional 0.34 (1.39 x 24.7%) critical projects to require elevation.
Table 19.  Percentage and Number of HMA Projects Located in the FFRMS-FVA Floodplain Annually

                                                                    Percent (%)
                                                                            No.
                                                         Average Project Amount
Projects in the 1 percent annual Chance Floodplain
                                                                            100
                                                                             67

Elevation Projects
                                                                             94
                                                                             63
                                                                     $1,268,474
Floodproofing Projects
                                                                              6
                                                                              4
                                                                       $627,330
Elevation Non-Critical Actions in 1 percent annual chance floodplain
                                                                           97.8
                                                                          61.61

Floodproofing Non-Critical Actions in 1 percent annual chance floodplain
                                                                           97.8
                                                                           3.91

Elevation of Non-Critical Actions in Expanded Floodplain
                                                                          16.8*
                                                                          10.35

Floodproofing of Non-Critical Actions in Expanded Floodplain
                                                                          16.8*
                                                                           0.67

Elevation Critical Actions
                                                                            2.2
                                                                           1.39

Floodproofing Critical Actions
                                                                            2.2
                                                                           0.09

Elevation Critical Actions between 1 percent annual chance floodplain and 3-foot freeboard
                                                                          24.7*
                                                                           0.34

Floodproofing Critical Actions between 1 percent annual chance floodplain and 3-foot freeboard
                                                                          24.7*
                                                                           0.03

*16.8% and 24.7% are the estimated percent increases in the size of the expanded floodplain.

      Elevation of Structures
      FEMA uses the same multi-step process and methodology as PA to estimate HMA costs.
   1.          Cost of elevating Projects in the 1 percent annual chance floodplain
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage cost of elevating 2 feet
      $1,268,474 HMA project amount x 61.61 projects x 0.3% cost of elevating 2 feet = $234,452 (Low Estimate)
      $1,268,474 HMA project amount x 61.61 projects x 4.8% cost of elevating 2 feet = $3,751,232 (High Estimate)
   2. Cost of elevating projects between 1 percent annual chance floodplain and 2-foot freeboard elevation
      (1/2) (Average Project Amount x number of projects between 1 percent annual chance floodplain and 1-foot freeboard elevation x percentage cost of elevating 2 feet) + (1/2) (Average Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of elevating 1 foot)
      (1/2) ($1,268,474 HMA project amount x 10.35 projects x 0.2% cost of elevating 1 foot) + (1/2) ($1,268,474 x 10.35 projects x 0.3% cost of elevating 2 feet) = $32,822 (Low Estimate)
      (1/2) ($1,268,474 HMA project amount x 10.35 projects x 3.9% cost of elevating 1 foot) + (1/2) ($1,268,474 x 10.35 projects x 4.8% cost of elevating 2 feet) = $571,099 (High Estimate)
   3. Less costs that would be incurred in the absence of this rule due to existing freeboard requirements
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot
      $1,268,474 HMA project amount x 61.61 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 0.2% cost of elevating 1 foot = $71,023 (Low Estimate)
      $1,268,474 HMA project amount x 61.61 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 3.9% cost of elevating 1 foot = $1,384,955 (High Estimate)
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of elevating 2 feet
      $1,268,474 HMA project amount x 61.61 projects x 16.55% population living in areas with 2-foot freeboard requirement x 0.3% cost of elevating 2 feet = $38,802 (Low Estimate)
      $1,268,474 HMA project amount x 61.61 projects x 16.55% population living in areas with 2-foot freeboard requirement x 4.8% cost of elevating 2 feet = $620,829 (High Estimate)
      (Average Project Amount x number of projects between the 1 percent annual chance flood elevation and 2-foot freeboard elevation x percentage of population in areas with 1-foot existing freeboard requirements x percentage cost of elevating 1 foot) + (Average Project Amount x number of projects between the 1 percent annual chance flood elevation and the 2-foot freeboard elevation x percentage of population in areas with at least a 2-foot existing freeboard elevation x percentage cost of elevating 2 feet)
      ($1,268,474 HMA project amount x 10.35 projects x 45.44% population in areas with 1-foot existing freeboard requirements x 0.2% cost of elevating 1 foot) + ($1,268,474 HMA project amount x 10.35 projects x 16.55% population in areas with at least a 2-foot existing freeboard elevation x 0.3% cost of elevating 2 feet) = $18,450 (Low Estimate)
      ($1,268,474 HMA project amount x 10.35 projects x 45.44% population in areas with 1-foot existing freeboard requirements x 3.9% cost of elevating 1 foot) + ($1,268,474 HMA project amount x 10.35 projects x 16.55% population in areas with at least a 2-foot existing freeboard elevation x 4.8% cost of elevating 2 feet) = $336,956 (High Estimate
      Total baseline cost for non-critical actions to be subtracted due to existing freeboard requirements:
      $71,023 + $38,802 + $18,450 = $128,275 (Low Estimate)
      $1,384,955 + $620,829 + $336,956 = $2,342,740 (High Estimate)
   4. Total cost for HMA non-critical actions
Table 20.  Total Annual Cost for HMA Elevation Non-Critical Actions

                                                                   Low Estimate
                                                                  High Estimate
Elevation from 1 percent annual chance floodplain
                                                                       $234,452
                                                                     $3,751,232
Elevation between 1 percent annual chance floodplain and 2-foot freeboard
                                                                        $32,822
                                                                       $571,099
Existing requirements (Cost already to be incurred)
                                                                      -$128,275
                                                                    -$2,342,740
Total Cost
                                                                       $138,999
                                                                     $1,979,591
   5. Cost for critical actions in the 1 percent annual chance floodplain
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage cost of elevating 3 feet
      $1,268,474 HMA project amount x 1.39 critical actions x 0.7% cost of elevating 3 feet = $12,342 (Low Estimate)
      $1,268,474 HMA project amount x 1.39 critical actions x 6.8% cost of elevating 3 feet = $119,896 (High Estimate)
   6. Cost for critical actions between the 1 percent annual chance floodplain and the 3-foot freeboard elevation
      (1/3) (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of elevating 3 feet) + (1/3) (Average Project Amount x number of projects between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of elevating 2 feet) + (1/3) (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of elevating 1 foot)
      (1/3) ($1,268,474 HMA project amount x 0.34 critical actions x 0.7% cost of elevating 3 feet) + (1/3) ($1,268,474 HMA project amount x 0.34 critical actions x 0.3% cost of elevating 2 feet) + (1/3) ($1,268,474 HMA project amount x 0.34 critical actions x 0.2% cost of elevating 1 foot) = $1,725 (Low Estimate)
      (1/3) ($1,268,474 HMA project amount x 0.34 critical actions x 6.8% cost of elevating 3 feet) + (1/3) ($1,268,474 HMA project amount x 0.34 critical actions x 4.8% cost of elevating 2 feet) + (1/3) ($1,268,474 HMA project amount x 0.34 critical actions x 3.9% cost of elevating 1 foot) = $22,283 (High Estimate)
   7. Less costs for critical actions that would be incurred in the absence of this rule due to existing freeboard requirements
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot freeboard requirement x percentage cost of elevating 1 foot
      $1,268,474 HMA project amount x 1.39 critical actions x 45.44% population living in areas with 1-foot freeboard requirement x 0.2% cost of elevating 1 foot = $1,602 (Low Estimate)
      $1,268,474 HMA project amount x 1.39 critical actions x 45.44% population living in areas with 1-foot freeboard requirement x 3.9% cost of elevating 1 foot = $31,246 (High Estimate)
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of elevating 2 feet
      $1,268,474 HMA project amount x 1.39 critical actions x 15.12% population living in areas with 2-foot freeboard requirement x 0.3% cost of elevating 2 feet = $800 (Low Estimate)
      $1,268,474 HMA project amount x 1.39 critical actions x 15.12% population living in areas with 2-foot freeboard requirement x 4.8% cost of elevating 2 feet = $12,796 (High Estimate)
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 3-foot freeboard requirement x percentage cost of elevating 3 feet
      $1,268,474 HMA project amount x 1.39 critical actions x 1.43% population living in areas with 3-foot freeboard requirement x 0.7% cost of elevating 3 feet = $176 (Low Estimate)
      $1,268,474 HMA project amount x 1.39 critical actions x 1.43% population living in areas with 3-foot freeboard requirement x 6.8% cost of elevating 3 feet = $1,715 (High Estimate)
      (Average Project Amount x number of critical actions between the 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot) + (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 2-foot existing freeboard requirement x percentage cost of elevating 2 feet) + (Average Project Amount x number of critical actions between the 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 3-foot existing freeboard requirement x percentage cost of elevating 3 feet)
      ($1,268,474 HMA project amount x 0.34 critical actions x 45.44% population in areas with 1-foot existing freeboard requirement x 0.2% cost of elevating 1 foot) + ($1,268,474 HMA project amount x 0.34 critical actions x 15.12% population in areas with 2-foot existing freeboard requirement x 0.3% cost of elevating 2 feet) + ($1,268,474 HMA project amount x 0.34 critical actions x 1.43% population in areas with 3-foot existing freeboard requirement x 0.7% cost of elevating 3 feet) = $631 (Low Estimate)
      ($1,268,474 HMA project amount x 0.34 critical actions x 45.44% population in areas with 1-foot existing freeboard requirement x 3.9% cost of elevating 1 foot) + ($1,268,474 HMA project amount x 0.34 critical actions x 15.12% population in areas with 2-foot existing freeboard requirement x 4.8% cost of elevating 2 feet) + ($1,268,474 HMA project amount x 0.34 critical actions x 1.43% population in areas with 3-foot existing freeboard requirement x 6.8% cost of elevating 3 feet) = $11,192 (High Estimate)
   8. Total baseline cost for critical actions to be subtracted due to existing freeboard requirements
      $1,602 + $800 + $176 + $631 = $3,209 (Low Estimate)
      $31,246 + $12,796 + $1,715 + $11,192 = $56,950 (High Estimate)
   9. Total cost for HMA critical actions
      FEMA calculated the cost for critical actions by adding the cost of elevating the projects in the 1 percent annual chance floodplain to the cost of elevating projects between the 1 percent annual chance floodplain and the 3-foot freeboard elevation.
Table 21.  Total Annual Cost for HMA Critical Elevation Actions

                                                                   Low Estimate
                                                                  High Estimate
Elevation from 1 percent annual chance floodplain
                                                                        $12,342
                                                                       $119,896
Elevation between 1 percent annual chance floodplain and 3-foot freeboard
                                                                         $1,725
                                                                        $22,283
Cost avoidance from existing requirements
                                                                        -$3,209
                                                                       -$56,950
Total Cost
                                                                        $10,858
                                                                        $85,229
   10.      Total cost for all HMA elevation projects (non-critical and critical)
Table 22.  Total Annual Cost for All HMA Elevation Projects

                                                                   Low Estimate
                                                                  High Estimate
Non-Critical Actions
                                                                       $138,999
                                                                     $1,979,591
Critical Actions
                                                                        $10,858
                                                                        $85,229
Total Cost
                                                                      $149,857
                                                                    $2,064,820
      Floodproofing of Structures
      To estimate the cost for floodproofing structures, FEMA used the same process as for elevating structures.  However, because the average grant amount for floodproofing projects was approximately half of the average grant amount (including the Federal cost share) for elevation projects, FEMA reduced the estimated cost by 50 percent.
      Of the approximately 4 HMA floodproofing projects funded each year, FEMA estimates that a total of 0.09 (4 x 2.20 percent) projects per year are considered critical actions; the remaining 3.91 are non-critical.  Due to the horizontal expansion of the FFRMS floodplain, FEMA expects an additional 0.67 (4 x 16.8 percent) non-critical actions and 0.03 (0.09 x 24.7 percent) critical actions to require floodproofing.
   1.          Cost of floodproofing projects in the 1 percent annual chance floodplain
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage cost of floodproofing 2 feet
      $627,330 HMA project amount x 3.91 projects x 0.15% cost of floodproofing 2 feet = $3,681 (Low Estimate)
      $627,330 HMA project amount x 3.91 projects x 2.4% cost of floodproofing 2 feet = $58,899 (High Estimate)
   2. Cost of floodproofing projects between 1 percent annual chance floodplain and 2-foot freeboard elevation
      (1/2) (Average Project Amount HMA project amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of floodproofing 2 feet) + (1/2) (Average Project Amount x number of projects between 1 percent annual chance floodplain and 2-foot freeboard elevation x percentage cost of floodproofing 1 foot)
      (1/2) ($627,330 HMA project amount x 0.67 projects x 0.10% cost of floodproofing 1 foot) + (1/2) ($627,330 HMA project amount x 0.67 projects x 0.15% cost of floodproofing 2 feet) = $527 (Low Estimate)
      (1/2) ($627,330 HMA project amount x 0.67 projects x 1.95% cost of floodproofing 1 foot) + (1/2) ($627,330 HMA project amount x 0.67 projects x 2.40% cost of floodproofing 2 feet) = $9,169 (High Estimate)
   3. Costs that would be incurred in the absence of this proposed rule due to existing freeboard requirements
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot
$627,330 HMA project amount x 3.91 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 0.10% cost of elevating 1 foot = $1,115 (Low Estimate)
$627,330 HMA project amount x 3.91 projects x 45.44% population living in areas with 1-foot existing freeboard requirement x 1.95% cost of elevating 1 foot = $21,745 (High Estimate)
      Average Project Amount x number of projects in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of floodproofing 2 feet
      $627,330 HMA project amount x 3.91 projects x 16.55% population living in areas with 2-foot freeboard requirement x 0.15% cost of floodproofing 2 feet = $609 (Low Estimate)
      $627,330 HMA project amount x 3.91 projects x 16.55% population living in areas with 2-foot freeboard requirement x 2.40% cost of floodproofing 2 feet = $9,748 (High Estimate)
      (Average Project Amount x number of projects between the 1 percent annual chance flood elevation and 2-foot freeboard elevation x percentage of population in areas with 1-foot existing freeboard requirements x percentage cost of elevating 1 foot) + (Average Project Amount x number of projects between the 1 percent annual chance flood elevation and the 2-foot freeboard elevation x percentage of population in areas with at least a 2-foot existing freeboard elevation x percentage cost of elevating 2 feet)
      ($627,330 HMA project amount x 0.67 projects x 45.44% population in areas with 1-foot existing freeboard requirements x 0.10% cost of elevating 1 foot) + ($627,330 HMA project amount x 0.67 projects x 16.55% population in areas with at least a 2-foot existing freeboard elevation x 0.15% cost of elevating 2 feet) = $296 (Low Estimate)
      ($627,330 HMA project amount x 0.67 projects x 45.44% population in areas with 1-foot existing freeboard requirements x 1.95% cost of elevating 1 foot) + ($627,330 HMA project amount x 0.67 projects x 16.55% population in areas with at least a 2-foot existing freeboard elevation x 2.40% cost of elevating 2 feet) = $5,410 (Low Estimate)
      Total baseline cost for non-critical actions to be subtracted due to existing freeboard requirements
      $1,115 + $609 + $296 = $2,021 (Low Estimate)
      $21,745 + $9,748 + $5,410 = $36,903 (High Estimate)
Table 23.  Total Annual Cost for HMA Floodproofing Non-Critical Actions

                                                                   Low Estimate
                                                                  High Estimate
Elevation from 1 percent annual chance floodplain
                                                                         $3,681
                                                                        $58,899
Elevation between 1 percent annual chance floodplain and 2-foot freeboard
                                                                           $527
                                                                         $9,169
Existing requirements
                                                                        -$2,021
                                                                       -$36,903
Total Cost
                                                                         $2,188
                                                                        $31,165
   4. Cost for critical actions in the 1 percent annual chance floodplain
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage cost of floodproofing 3 feet
      $627,330 HMA project amount x 0.09 critical actions x 0.35% cost of floodproofing 3 feet = $193 (Low Estimate)
      $627,330 HMA project amount x 0.09 critical actions x 3.40% cost of floodproofing 3 feet = $1,877 (High Estimate)
   5. Cost for critical actions between the 1 percent annual chance floodplain and the 3-foot freeboard elevation
      (1/3) (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of floodproofing 3 feet) + (1/3) (Average Project Amount x number of projects between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of floodproofing 2 feet) + (1/3) (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage cost of floodproofing 1-foot)
      (1/3) ($627,330 HMA project amount x 0.03 critical actions x 0.35% cost of floodproofing 3 feet) + (1/3) ($627,330 HMA project amount x 0.03 critical actions x 0.15% cost of floodproofing 2 feet) + (1/3) ($627,330 HMA project amount x 0.03 critical actions x 0.10% cost of floodproofing 1 foot) = $37 (Low Estimate)
      (1/3) ($627,330 HMA project amount x 0.03 critical actions x 3.4% cost of floodproofing 3 feet) + (1/3) ($627,330 HMA project amount x 0.03 critical actions x 2.40% cost of floodproofing 2 feet) + (1/3) ($627,330 HMA project amount x 0.03 critical actions x 1.95% cost of floodproofing 1 foot) = $475 (High Estimate)
   6. Less costs for critical actions that would be incurred in the absence of this rule due to existing freeboard requirements
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 1-foot freeboard requirement x percentage cost of floodproofing 1 foot
      $627,330 HMA project amount x 0.09 critical actions x 45.44% population living in areas with 1-foot freeboard requirement x 0.10% cost of floodproofing 1 foot = $25 (Low Estimate)
      $627,330 HMA project amount x 0.09 critical actions x 45.44% population living in areas with 1-foot freeboard requirement x 1.95% cost of floodproofing 1 foot = $489 (High Estimate)
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 2-foot freeboard requirement x percentage cost of floodproofing 2 feet
      $627,330 HMA project amount x 0.09 critical actions x 15.12% population living in areas with 2-foot freeboard requirement x 0.15% cost of floodproofing 2 feet = $13 (Low Estimate)
      $627,330 HMA project amount x 0.09 critical actions x 15.12% population living in areas with 2-foot freeboard requirement x 2.40% cost of floodproofing 2 feet = $200 (High Estimate)
      Average Project Amount x number of critical actions in the 1 percent annual chance floodplain x percentage of the population living in areas with 3-foot freeboard requirement x percentage cost of floodproofing 3 feet
      $627,330 HMA project amount x 0.09 critical actions x 1.43% population living in areas with 3-foot freeboard requirement x 0.35% cost of floodproofing 3 feet = $3 (Low Estimate)
      $627,330 HMA project amount x 0.09 critical actions x 1.43% population living in areas with 3-foot freeboard requirement x 3.40% cost of floodproofing 3 feet = $27 (High Estimate)
      (Average Project Amount x number of critical actions between the 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 1-foot existing freeboard requirement x percentage cost of elevating 1 foot) + (Average Project Amount x number of critical actions between 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 2-foot existing freeboard requirement x percentage cost of elevating 2 feet) + (Average Project Amount x number of critical actions between the 1 percent annual chance floodplain and 3-foot freeboard elevation x percentage of population in areas with 3-foot existing freeboard requirement x percentage cost of elevating 3 feet)
      ($627,330 HMA project amount x 0.03 critical actions x 45.44% population in areas with 1-foot existing freeboard requirement x 0.10% cost of elevating 1 foot) + ($627,330 HMA project amount x 0.03 critical actions x 15.12% population in areas with 2-foot existing freeboard requirement x 0.15% cost of elevating 2 feet) + ($627,330 HMA project amount x 0.03 critical actions x 1.43% population in areas with 3-foot existing freeboard requirement x 0.35% cost of elevating 3 feet) = $13
      ($627,330 HMA project amount x 0.03 critical actions x 45.44% population in areas with 1-foot existing freeboard requirement x 1.95% cost of elevating 1 foot) + ($627,330 HMA project amount x 0.03 critical actions x 15.12% population in areas with 2-foot existing freeboard requirement x 2.40% cost of elevating 2 feet) + ($627,330 HMA project amount x 0.03 critical actions x 1.43% population in areas with 3-foot existing freeboard requirement x 3.40% cost of elevating 3 feet) = $239
      Total baseline costs for HMA critical actions projects due to existing freeboard requirements
      $25 + $13 + $3 + $13 = $54 (Low Estimate)
      $489 + $200 + $27 + $239 = $955 (High Estimate)
Table 24.  Total Annual Cost for HMA Critical Floodproofing Actions

                                                                   Low Estimate
                                                                  High Estimate
Elevation from 1 percent annual chance floodplain
                                                                           $193
                                                                         $1,877
Elevation between 1 percent annual chance floodplain and 3-foot freeboard
                                                                            $37
                                                                           $475
Existing requirements
                                                                           -$54
                                                                          -$955
Total Cost
                                                                           $176
                                                                         $1,397
   7.  Total cost for all floodproofing projects (non-critical and critical)
Table 25.  Total Annual Cost for All HMA Floodproofing Projects

                                                                   Low Estimate
                                                                  High Estimate
Non-Critical Actions
                                                                         $2,188
                                                                        $31,165
Critical Actions
                                                                           $176
                                                                         $1,397
Total Cost
                                                                        $2,364
                                                                       $32,562
      FEMA estimates the total cost of this rule for the HMA program to be between $150,000 and $2.1 million per year.  With the 75 percent cost share, the cost to FEMA would be between $114,000 and $1.6 million, while the cost to grant recipients would be between $38,000 and $525,000.
Table 26.  Total Annual Cost to HMA Program

                                                                   Low Estimate
                                                                  High Estimate
HMA Elevation
                                                                       $149,857
                                                                     $2,064,820
HMA Floodproofing
                                                                         $2,364
                                                                        $32,562
Total
                                                                       $152,221
                                                                     $2,097,382
      Other HMA Projects
      HMA grants may also be used for other types of projects, including: property acquisition, mitigation reconstruction, generators, and safe rooms.  Additional minor mitigation measures would have to be taken for these projects if located in the expanded FFRMS FVA floodplain.  While there would be costs associated with these projects, FEMA is unable to provide an estimate because of the highly individualized nature of these designs and purposes of these projects.  FEMA requests public comments on the methodology for determining the FFRMS costs for these types of HMA projects.
9.5.4 Other FEMA Programs Potentially Affected
      The FFRMS rule could potentially affect FEMA's GPD, the IPAWS, and FEMA Facilities.  These programs are not routinely involved in actions that are covered by this rule, but may have projects in the future that require adherence to the FFRMS.
GPD
      FEMA's GPD is responsible for managing several preparedness grant programs.  These have included the Homeland Security Grant Program, Port Security Grant Program, Assistance to Firefighters Grant Program, Emergency Operations Center Grant Program, and various others.  GPD programs do not typically fund new construction or substantial improvement projects, with the notable exception of communications towers.  Preparedness grants managed under GPD have previously funded new construction of Fire Stations and Emergency Operations Centers, but funding has not been allocated for Emergency Operations Centers in recent years.  Fire Station construction is no longer eligible under the Assistance to Firefighters Grant Program.
      The primary effect of the proposed rule on GPD would be on the construction of communications towers.  These must be made resilient to floods which could require them to meet higher freeboard elevation standards.  Communication towers which are used for emergency communication may be considered critical actions.
      According to GPD data for the past 10 years (2005-2014), 259 communications towers have been constructed with an average cost of $671,549 per tower.  Mitigation actions to minimize the effects of flooding on communication towers are not generally necessary since communications towers are typically resilient from flooding; however, associated equipment and infrastructure, such as generators or electronic components, must be protected from possible flood damage, which could result in some additional costs.  Overhead utilities are inherently resistant to damage from flooding and buried portions of underground electrical utilities are also generally resistant to flood damage.  Construction of communication towers in areas subject to the FFRMS floodplain may incur minimal costs to ensure flood resiliency.  Subject matter experts from GPD do not believe significant mitigation actions would be required.  FEMA requests comments from the public regarding these assumptions.
IPAWS
      The IPAWS is a modernization and integration of the Nation's alert and warning infrastructure.  IPAWS provides public safety officials with an effective way to alert and warn the public about serious emergencies using the Emergency Alert System, Wireless Emergency Alerts, the National Oceanic and Atmospheric Administration (NOAA) Weather Radio, and other public alerting systems from a single interface.  In order to fully implement IPAWS, communications equipment throughout the country is being modernized to be compatible.  IPAWS may fund some additional infrastructure in the form of communications towers and support equipment.  Most IPAWS funded construction would not be new construction or substantial improvement and therefore would not require elevation or floodproofing, but it is possible that some future IPAWS projects could fall under the requirements of the proposed rule.
FEMA Facilities
      The proposed rule would apply to all FEMA-owned and operated property.  FEMA facilities that would be located within the FFRMS floodplain would be required to comply with this proposed rule, including the proposed elevation requirements.  Temporarily occupied facilities such as Joint Field Offices in disaster areas would be exempt from this proposed rule because they are considered "Emergency Work" under the Stafford Act, even though FEMA, for practical reasons (such as continuity of operations), generally avoids placing such facilities in the floodplain.  When occupying new facilities, FEMA currently goes through the process to determine whether the facility is in the 1 percent annual chance floodplain.  FEMA will continue to go through this process to determine whether the facility is in the new FFRMS floodplain.  Some FEMA facilities that would have been outside the base floodplain may fall within the FFRMS floodplain.  FEMA would be required to complete the 8-step process for any FEMA Federally Funded Project involving such a facility.  However, FEMA does not currently have plans for occupying new facilities.
9.6 Administrative Costs
      Under this proposed rule, FEMA would make a determination of a proposed action's location, i.e., whether it is in the FFRMS floodplain.  This rule would apply to FEMA grant applicants and would not result in an increase of applications; however, there would be additional work for FEMA when making floodplain determinations as part of the 8-step process.  This is a multi-step process carried out as part of the decision-making for projects that have potential impacts to or within the floodplain.  This would be conducted for all relevant actions by FEMA's Office of Environmental Planning and Historic Preservation (OEHP) with assistance from the FIMA's Risk Analysis Division (RAD).  RAD staff are subject matter experts in this area and would only be used in rare cases where the determination is exceptionally difficult.  For OEHP staff to be able to make these determinations, they would be trained in this process by FEMA's Emergency Management Institute.  The required training time is estimated at 8 hours and would be adapted from a current course, Managing Floodplain Development through the NFIP.  OEHP has 112 employees that would be trained in floodplain determination, from FEMA reservists to GS-14 full-time employees.
9.6.1 Training Costs
      OEHP staff would receive initial training; there would not be a recurrent training requirement.  The training costs include instructors from the Emergency Management Institute as well as the hours spent by FEMA employees attending the training.  The instruction cost for off-site courses is $1,500 per student for the 3-day Managing Floodplain Development through the NFIP course.  This course contains the required training for FFRMS floodplain determinations in Units 3, 4, and 10, which total about 8 hours of training time.  FEMA will modify this course to accommodate the training needs.  This new training cost is estimated at $500 per student ($1,500 / 3 days), totaling $56,000 ($500 x 112).  Wage rates of those receiving the training would be included in the cost of this rule, but they are considered opportunity costs only and would not result in additional expenditure by FEMA.  These wage rates have been multiplied by 1.4 estimate the fully-loaded wage rate.  The fully-loaded wage rate is the full cost per hour worked that the employer pays for wages plus the cost for benefits.  The employment breakdown and wage rates of OEHP is listed in Table 27.
Table 27.  FEMA Employees Requiring Training for FFRMS
Grade Level
                                                            Number of Employees
                                                         Fully-Loaded Wage Rate
                                                                     Total Cost
                       (number of Employees x Fully-Loaded Wage Rate x 8 Hours)
GS-5 Step 5
                                                                             44
                                                                         $26.43
                                                                         $9,303
GS-11 Step 5
                                                                              7
                                                                         $48.44
                                                                         $2,713
GS-12 Step 5
                                                                             30
                                                                         $58.07
                                                                        $13,937
GS-13 Step 5
                                                                             19
                                                                         $69.05
                                                                        $10,496
GS-14 Step 5
                                                                             12
                                                                         $81.59
                                                                         $7,833

                                                                          Total
                                                                        $44,281
      The total opportunity cost for initial training is $44,281.  The total initial training cost including instructional costs is $100,281 ($56,000 + $44,281).  These costs would only be incurred in year 1.
      As OEHP staff turns over, new employees would be required to complete the training in FFRMS floodplain determination.  Yearly training costs would depend on the number of employees hired by OEHP.  For the past 3 years, OEHP has hired new staff at a rate of 16 employees per year.  Using the weighted average fully-loaded wage rate for current OEHP staff of $49.42, the annual cost of training is estimated to be $6,326 ($49.42 x 8 hrs. x 16 employees) in wages and $8,000 ($500 x 16) in instructional costs for a total of $14,326 per year.
9.6.2 The FFRMS Floodplain Determination
      FEMA Federally Funded Projects that fall under the scope of the proposed rule would need to be evaluated to see if they are in the FFRMS floodplain.  Since the FFRMS floodplain is not depicted on FIRMs, FEMA Federally Funded Projects would require further evaluation to determine if they are in the FFRMS floodplain or not.  This determination would be made by OEHP staff using one of several methods.  The only change to the process for grantees is on one screen of the online application process, in which the grantee could attach information to support FEMA's review to determine if the application is in compliance with FEMA's regulations implementing the FFRMS.
      For projects that are located within the SFHA, staff would continue to use the 1 percent annual chance flood elevation listed on the FIRM as well as an elevation certificate (that is required for structures built in the SFHA).  This information can also be used to determine the FFRMS elevation required for the structure.  Because projects in the SFHA are already subject to elevation and floodproofing requirements under current floodplain management regulations, there would be no additional cost associated with floodplain determinations for projects within the SFHA.
      Projects that are located near the SFHA, but not in it, may be in the FFRMS floodplain.  Because there are no federally produced maps depicting the boundary of the FFRMS floodplain established by the FVA or CISA, an alternate method would be used to determine whether the project is located in the FFRMS floodplain and the amount of freeboard required.  This process would be done by examining the floodplain maps.  The floodplain determination can generally be made by comparing the ground elevation at the proposed site to the elevation established using the applicable FFRMS approach.  If the ground elevation is less than the FFRMS elevation, then the site is in the FFRMS floodplain.  If the property is not near a mapped base floodplain or there are no maps available for that area, an elevation certificate would need to be obtained to determine if the building's elevation is sufficient to meet all regulatory requirements.  This proposed rule would not change this procedure and only buildings that would be currently required to obtain an elevation certificate would be required to obtain one under the new regulation.  There would be no additional costs to grantees, subgrantees, or beneficiaries.  However, there may be additional costs for FEMA as FEMA may need to consult more than one map or make other changes to the determination process that might slightly lengthen the determination time; the specific method for determining if a project is in the FFRMS floodplain and finding the required elevation would depend on the nearby flood zone.  Only in a rare circumstance, such as a project in a remote area, would FEMA expect the process to significantly differ from the time estimates provided in Table 30.  In these instances, the process would be based on the individual circumstances of the project.
      This rule would apply to FEMA grant applicants and would not result in an increase of applications; however, there would be additional work for FEMA when making floodplain determinations as part of the 8-step process.  FEMA currently evaluates all projects to determine if they are in the 1 percent annual chance floodplain.  Projects already in the 1 percent annual chance floodplain would not require any additional work.  All other FEMA Federally Funded Projects would require extra time to determine if the projects are in the expanded FFRMS floodplain.
      Table 28 lists the amount of time and wage rates for FFRMS determinations by zone as well as the percentage and number of projects that FEMA estimates would be annually subject to determination for each zone.  The number of projects for each zone was calculated by multiplying the percentage of projects near each flood zone type by the 30.44 Federally Funded Projects outside of the 1 percent annual chance floodplain that FEMA funds each year.
Table 28.  Cost of Floodplain determination by nearby flood zone
Nearby Zone
                                                                          Hours
                                                        Fully-Loaded Wage Rate
                                                                  % of Projects
                                                             Number of Projects
                                                                           Cost
A
                                                                           1.67
                                                                         $49.42
                                                                          35.95
                                                                          10.94
                                                                          $903
AE/A1-30
                                                                           1.00
                                                                         $49.42
                                                                          47.13
                                                                          14.35
                                                                          $709
AO
                                                                           0.67
                                                                         $49.42
                                                                           1.70
                                                                           0.52
                                                                           $17
AH
                                                                           0.83
                                                                         $49.42
                                                                           3.85
                                                                           1.17
                                                                           $48
VE
                                                                           0.67
                                                                         $49.42
                                                                           0.66
                                                                           0.20
                                                                            $7

                                                                          Total
                                                                        $1,684
      FEMA estimates that the cost of determining whether projects are located in the FFRMS floodplain is $1,684 per year.
9.7 The FFRMS Implementation Costs
      This proposed rule would entail implementation costs that include publicizing the FFRMS to stakeholders.  FEMA's Office of External Affairs would be responsible for a major portion of the FFRMS implementation process.  FEMA expects to use a team of existing staff members.  This team would include 11 External Affairs Officers, seven officers working for 120 hours and four officers working for 80 hours each, to prepare the implementation process, as well as one Senior Executive Service (SES) employee for 20 hours and one political appointee for 10 hours for the review and approval process.  As FEMA uses current staff, there are opportunity costs associated with their time.  The breakdown of External Affairs wages is presented in Table 29.
Table 29.  External Affairs implementation costs

                                   Employees
                            Fully-Loaded Wage Rate
                                     Hours
                               Phase ONE (2016)
                         Design, Review & Approval
               Phase TWO (2017) Implementation & Evaluation
                                  Total Wages
GS-12 Step 5
                                      3
                                    $58.07
                                    120 ea
                                                                             +
                                                                             +
                                                                       $20,905
GS-13 Step 5
                                      3
                                    $69.05
                                    120 ea
                                                                             +

                                                                       $24,858
GS-14 Step 5
                                      1
                                    $81.59
                                    120 ea
                                                                             +
                                                                             +
                                                                        $9,791
GS-15 Step 5
                                      4
                                    $95.98
                                     80 ea
                                                                             +
                                                                             +
                                                                       $30,714
SES
                                       1
                                    $102.73
                                      20
                                                                             +
                                                                             +
                                                                        $2,055
ES Level V
                                      1
                                    $100.01
                                      10
                                                                             +

                                                                        $1,000

Total
                                                                       $89,325
      The proposed rule would affect four standing External Affairs National and Regional communications roll-outs  - including:  Annual Hurricane Season, Annual Severe Winter Weather, National Preparedness Month, and America's PrepareaThon.  No training for staff or support to roll-out to States is necessary.  FEMA estimates the total implementation costs of this rule to be $89,325 in wages and salaries.
9.8 Qualitative Discussion of Additional Potential Costs
      There are a number of additional unquantifiable costs associated with the proposed rule.  The primary quantifiable costs have been discussed in previous sections of this analysis, but certain costs cannot be quantified at this time.  These are important and should be considered when looking at the impact of the proposed rule.  These may be quantifiable through observation once the rule is implemented.
9.8.1 The 8-step Floodplain Management Decision-Making Process
      This proposed rule would require that structures in the expanded FFRMS floodplain be elevated that were not previously required to do so.  However, in doing so, it also requires these additional projects to undergo the 8-step process.  While step 1 is required of all FEMA Federally Funded Projects, steps 2-8 applies specifically to projects located in the floodplain.  FEMA does not have sufficient data to quantify the cost of the 8-step process because these costs are widely variable, depending on a range of factors.  As a result, FEMA is unable to quantify the costs of applying the 8-step process to projects in the expanded floodplain or any results from that application.  Some of the costs would overlap with the floodplain determination costs listed in Section 9.6.2.  Because FEMA will be making floodplain determinations for these projects, the majority of this cost would fall on FEMA.  FEMA requests comments from the public regarding the cost of applying the 8-step process to additional projects.
9.8.2 Diversion of Projects Out of the Floodplain
      Because this proposed rule places more stringent requirements on building or improving structures in the floodplain and emphasizes considering alternatives to building in the floodplain, the effect of the proposed rule could be to divert some projects out of the floodplain.  It is not possible to state with a reasonable degree of certainty how many structures this would affect, or the costs or benefits associated with diverting these projects out of the floodplain. The costs and benefits and decision to build in the floodplain or outside of the floodplain would be dependent on the specific location or characteristics of a property or project.  For example, if a hospital needs to be rebuilt there might not be a large enough plot of land available outside of the floodplain that is still close enough to the population the hospital services.
      Avoidance of the floodplain is the best way to reduce risk and FEMA's preferred mitigation method.  Avoiding the floodplain allows building owners to avoid the cost of elevation or floodproofing and is the best way to avoid flood damage.  Additionally, fewer structures in the floodplain reduces interference with the natural flood system and helps to reduce the severity of flooding.  FEMA requests comments from the public regarding the diversion of projects out of the floodplain.
9.9 Total Estimated Costs of the Proposed Rule
      The total estimated annual costs of the proposed rule are comprised of elevation and floodproofing costs due to the FVA, and administrative costs of implementing the proposed rule.  Table 30 and Table 31 present the annual costs of the proposed rule (low estimate and high estimate).
Table 30.  Annual FEMA and Non-FEMA costs of the Proposed Rule (Low Estimate, 2015$)

                                   Projects
                                                                     FEMA Admin
                                                                FEMA Grant Cost
                                                           Recipient Cost Share
                                                                     Total Cost
IA MHU
                                                                           4.88
                                                                            N/A
                                                                            N/A
                                                                          $238
                                                                          $238
IA PHC
                                                                           2.22
                                                                            N/A
                                                                        $1,690
                                                                            N/A
                                                                        $1,690
PA Category E
                                                                          19.19
                                                                            N/A
                                                                      $194,483
                                                                       $64,828
                                                                      $259,311
PA Category C (excludes road costs)
                                                                            7.1
                                                                            N/A
$4,234,136
$1,411,379
                                                                    $5,645,515
HMA Elevation
                                                                          73.69
                                                                            N/A
                                                                      $112,393
                                                                       $37,464
                                                                      $149,857
HMA Floodproofing
                                                                            4.7
                                                                            N/A
                                                                        $1,773
                                                                          $591
                                                                        $2,364
FEMA Training (Year 1)
                                                                            N/A
                                                                       $44,281
                                                                            N/A
                                                                            N/A
                                                                       $44,281
FEMA Training (Year 2+)
                                                                            N/A
                                                                       $14,326
                                                                            N/A
                                                                            N/A
                                                                       $14,326
Floodplain Determination
                                                                            127
                                                                        $1,684
                                                                            N/A
                                                                            N/A
                                                                        $1,684
Implementation Costs (Year 1 & 2)
                                                                            N/A
                                                                       $89,326
                                                                            N/A
                                                                            N/A
                                                                       $89,326
Year 1 Costs

                                                                      $135,291
                                                                    $4,544,475
                                                                    $1,514,499
                                                                    $6,208,591
Year 2 Costs

                                                                      $105,336
                                                                    $4,544,475
                                                                    $1,514,499