
I. TITLE:  	
      
      Hazard Mitigation Assistance for Wind Retrofit Projects for Existing Residential Buildings

II.	DATE OF ISSUANCE: XXX XX, 2012

 III.       POLICY STATEMENT
      
		This policy will ensure that grantees receiving funding under PDM and HMGP for wind retrofits of one- and two-family residential buildings utilize building techniques that conform to the design criteria in the Wind Retrofit Guide for Residential Buildings (FEMA P-804) published December 2010.    

 IV.       PURPOSE:   
      
      The purpose of this policy is to require comprehensive design solutions for wind retrofit projects on existing one- and two-family residences in coastal areas that are funded under the HMGP and PDM grants programs.  These mitigation activities will be required to be implemented in conformance with the criteria in the Wind Retrofit Guide for Residential Buildings (FEMA P-804).
      
V.	SCOPE AND EXTERNAL AUDIENCE:
      
      This policy applies to PDM projects for which the application period opens on or after the date of this policy, and to HMGP projects for which funding is made available pursuant to a major disaster declared on or after the date of this policy.  

 V.  AUTHORITY:
      
      Sections 203 (PDM) and 404 (HMGP) of the Stafford Act, 42 U.S.C. 5133 and 5170(c); 44 C.F.R. Part 206, Subpart N (HMGP).

VII.		OBJECTIVES
      
      The objective of this policy is to ensure that wind retrofit projects on one- and two-family residences funded under HMGP or PDM are designed and constructed to stronger design standards.
      
VIII.	DEFINITIONS, ABBREVIATIONS, AND FORMATTING
		
		BCA				Benefit Cost Analysis
		CFR				Code of Federal Regulations
		FEMA				Federal Emergency Management Agency
		HMA				Hazard Mitigation Assistance
		HMGP				Hazard Mitigation Grant Program
		PDM				Pre-Disaster Mitigation program
		Stafford Act		Robert T. Stafford Disaster Relief and Emergency Assistance Act

IX.		POLICY DETAILS
      
      The Stafford Act authorizes FEMA to provide funding for the purpose of reducing or eliminating risks to life and property from hazards and their effects.  Mitigation grant program regulations and guidance that implement these authorities identify various types of hazard mitigation projects or activities that meet this purpose and may be eligible for funding.  These projects represent a range of activities that protect structures, the contents within those structures and/or the lives of their occupants.  Therefore, wind retrofit projects for the hazard mitigation purpose of structural and building envelope protection against wind hazards for existing residential buildings are eligible activities under PDM and HMGP.  

      Thousands of existing homes in hurricane-prone regions are vulnerable to the effects of high-wind events because they are not designed to the same level of wind resistance required by today's codes and standards. High-wind natural hazards affecting hurricane-prone regions include hurricanes, tropical storms, typhoons, nor'easters, and tornadoes. The retrofits outlined in this policy are specific to protecting existing houses up to hurricane force winds.  
 
      In response to this identified need, FEMA published FEMA P-804, Wind Retrofit Guide for Residential Buildings, in December 2010 to offer a unified technical and programmatic hazard mitigation solution to existing residential wind retrofit projects.   The benefits of FEMA P-804 include: (1) technical assistance and public education on building techniques for the rebuilding and recovery process to reduce the potential for future losses from wind-related damage; (2) promotion of the most appropriate and cost-effective building materials and practices to encourage future construction of disaster-resistant buildings; and, (3) programmatic guidance on developing and implementing residential wind retrofit projects that can be used when applying for funding through PDM and HMGP.

      Specific eligibility criteria for residential wind retrofit projects for existing buildings are listed below. 

      A.       Eligible Activities and Mitigation Packages
           Wind retrofit project activities for existing residential one- and two-family dwellings (not including manufactured housing) that mitigate risk from wind-related damage are eligible for PDM and HMGP funding consideration.  See 44 C.F.R. § 206.434(d)(2)(iii) (for HMGP projects).  Project subapplications for funding residential wind retrofit projects for existing buildings located in areas of known hurricane or typhoon risk must be consistent with the criteria contained in FEMA P-804, Wind Retrofit Guide for Residential Buildings.  
      
           Residential wind retrofit Mitigation Packages for existing buildings do not include structure elevation or mitigation reconstruction. HMA project subapplications that incorporate multiple hazard mitigation measures such as structure elevation or mitigation reconstruction should modify their scope of work to reflect all hazard mitigation measures being requested.  
      
           Residential wind retrofit projects for existing buildings must comply with the Mitigation Packages (Basic Mitigation Package, Intermediate Mitigation Package, and Advanced Mitigation Package) described in FEMA P-804 (Chapter 4).  Each successive package contains retrofits that cumulatively increase the level of protection for wind-related damages to the buildings. The general elements for each package are identified below:
         
               Basic Mitigation Package
               1.                      Option 1: Improvements with roof covering replacement; or  
               2.                      Option 2: Improvements without roof covering replacement
               3.                      Additional Required Retrofits for both Options 1 & 2:  
                   a.                         Strengthening vents and soffits 
                   b.                         Strengthening overhangs at gable end walls
                   c.                         Protecting openings per the Intermediate Packages, if located in the windborne debris region
               Intermediate Mitigation Package
            1.                      Protecting windows and entry doors from windborne debris
            2.                      Protecting garage doors from wind pressure and garage door glazing from wind borne debris
            3.                      Bracing gable end walls 
            4.                      Strengthening connections of attached structures 
               Advanced Mitigation Package
            1.                      Developing a continuous load path 
            2.                      Protecting windows, entry doors, and garage doors from windborne debris and wind pressure.
           For homes with configurations for which the prescriptive Mitigation Packages provided in FEMA P-804 are not feasible, a design professional should be consulted to develop an engineered solution in place of the prescriptive solution.  

      B.       Building Evaluation and Evaluation Criteria
           Existing homes included in a wind retrofit project subapplication should have a building evaluation conducted. The purpose of the evaluation is to determine whether the home is a viable candidate for any of the wind retrofit Mitigation Packages.  The evaluation must be consistent with the minimum evaluation criteria as identified in FEMA P-804 (Chapter 3 and Appendix B) as well as be consistent with any State or local wind mitigation program requirements.  Acceptable evaluators may include building science professionals such as registered architects and engineers, building officials, and evaluators that are certified through State or locally recognized wind retrofit programs (such as the Institute for Business and Home Safety FORTIFIED for Existing Homes program). 
      
      C.       Eligible Costs
           Allowable mitigation costs for FEMA wind retrofit projects are for project components, such as design and building costs, directly related to and necessary for providing increased hazard protection from wind and wind-driven rain intrusion during a high-wind event. FEMA will only reimburse costs that are consistent with the Mitigation Packages provided in FEMA P-804.  For homes with configurations for which the prescriptive Mitigation Packages are not feasible, costs associated with engineered solutions are eligible.  In general, FEMA may allow hazard mitigation funding consideration for all necessary code-required mitigation-related project components. However, in the case of wind retrofits, pre-existing conditions of code non-compliance that local or State officials are obligated to remedy are not eligible for PDM or HMGP funding. 
      
      D.       Ineligible Costs
           Ineligible costs include, but are not limited to:
                                                1.             Project activities and components not consistent with the Mitigation Packages described in FEMA P-804.
                                                2.             Construction products not certified to the appropriate standard (i.e. uncertified products).
                                                3.             Costs related to functionality or outfitting such as furniture, interior or exterior decorative elements and fixtures, floor treatments, electrical and plumbing utilities, and other finishing materials that do not enhance the structural performance of the home.
                                                4.             Costs associated with the repair of gross negligence by a homeowner, previous homeowner, or bank.  This includes, but is not limited to, negligence, lack of maintenance and subsequent damage, termite infestation, and damage where there was a lack of termite inspections and termites were a known hazard.

      E.       Cost-Effectiveness
           PDM and HMGP wind retrofit projects for existing residential buildings requesting funding must demonstrate their cost-effectiveness through an acceptable Benefit Cost Analysis (BCA). FEMA P-804 (Appendix C) discusses using the Hurricane Wind Module for Determining Cost Effectiveness of Retrofit Projects.   In addition, aggregating benefit and cost values is allowed for multiple structures if they are all vulnerable to damage as a result of similar hazard conditions. The PDM applicant and/or subapplicant or the HMGP grantee and/or applicant must use a FEMA-approved methodology to determine cost-effectiveness. FEMA's BCA software may be obtained by visiting www.fema.gov/government/grant/bca.shtm.  
      
      F.       Other general requirements 
           In addition, existing residential wind retrofit projects must adhere to all other PDM or HMGP statutes, regulations, and requirements that apply to this funding category, including: Sections 203 and 404 of the Stafford Act, Hazard Mitigation Grant Program (44 CFR Subpart N), Mitigation Planning (44 CFR Part 201), Floodplain Management and Protection of Wetlands (44 CFR Part 9), Environmental Considerations (44 CFR Part 10), Uniform Administrative Requirements (44 CFR Part 13), Floodplain Management (44 CFR Part 60), and other applicable federal environmental, historic preservation, and grants management requirements, as well as applicable program guidance.
      
           This policy represents FEMA's interpretation of a statutory or regulatory requirement and/or sets forth standard operating procedures.  The policy itself does not impose legally enforceable rights and obligations but sets forth a standard operating procedure or agency practice that FEMA employees follow to be consistent, fair, and equitable in the implementation of the Agency's authorities.
           
X.	ROLES AND RESPONSIBILITIES
	
      Roles and responsibilities herein for all Federal, grantee/applicant and subgrantee/subapplicant participants are consistent with those outlined in 44 C.F.R. Parts 13 and 206 subpart N (for HMGP Projects), and the HMA Unified Guidance.

XI.	MONITORING AND EVALUATION
      
      An awarded grant's performance will be monitored in accordance with the financial and performance reporting requirements outlined in 44 C.F.R Parts 13 and 206 subpart N (for HMGP Projects), and the HMA Unified Guidance.  In addition, all awarded grants must comply with the administrative and audit requirements of 44 C.F.R Parts 13 and 206 subpart N (for HMGP Projects), as well as the terms and conditions of the grant award agreement.
 
XII.	RESPONSIBLE OFFICE:
      
      Federal Emergency Management Agency, Flood Insurance and Mitigation Administration (Risk Reduction Division, Grants Policy Branch)

XIII.	SUPERSESSION  
	
      This policy does not supersede any other policy on this subject.

XIV. REVIEW DATE:  
      
      This policy will be reviewed three (3) years from the date of issuance.



                                 _________________________
                                 David L. Miller
                                 Associate Administrator
                                 Flood Insurance and Mitigation Administration
                                 Federal Emergency Management Agency
