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Local Mitigation Strategy Tips, Hints and Tricks

Does the LMS document the planning process, including how it was prepared (with a narrative description, meeting minutes, sign-in sheets, or another method)?

To meet FEMA requirements, the LMS must show physical documentation of how the plan was prepared, including specified dates, a description of all activities that contributed to the plan’s development, and who was involved. Most planning committees choose to include a narrative description of the process and accompany this with meeting minutes, sign-in sheets, and/or public notices.

When updating, be sure to include the above information for ALL steps taken during the past five years. Include proof of meetings during the most recent five years via narrative descriptions, sign in sheets, and/or meeting minutes. We specifically look for proof of at least one meeting each year and proof that all jurisdictions were participating throughout the process.

Does the LMS list the jurisdiction(s) participating in the plan that are seeking approval?

List the participating jurisdictions (e.g. cities, counties, school boards, hospitals, airport authorities) seeking approval and clarify what is required of the participating jurisdictions. At a minimum, each is expected to take part in the planning process and to have a mitigation action concerning hazards that could affect its jurisdiction. Be sure that the jurisdictions listed remain consistent in all parts of the plans. 

Common delays to the LMS approval process are when:
1) a jurisdiction is listed but does not appear throughout the majority of LMS documentation OR
2) a jurisdiction is not initially listed but appears in other parts of the LMS.
Update your plan by reviewing the list of participating jurisdictions to ensure accuracy and change the roles within jurisdictions as needed.  You may have new members who wish to become participating jurisdictions. These could include: newly incorporated areas, school boards, utility providers, or healthcare networks. If any incorporated areas in your planning area are not participating in the LMS, provide an explanation of why. Also, be sure to mention any jurisdictions which no longer participate in the LMS. Keep in mind that any jurisdictions that cease participation in the LMS process will no longer be eligible for federal hazard mitigation assistance.

Does the plan identify who represented each jurisdiction? (At a minimum, it must identify the jurisdiction represented and the person’s position or title and agency within the jurisdiction.)

Document who represented each jurisdiction. The plan must identify each person’s position or title (e.g.  Director), their agency represented (e.g. Sheriff’s Office), and the corresponding jurisdiction (e.g. Charlotte County).  Be sure that all jurisdictions have some form of representation. It is also recommended to include the name and contact information of each individual. This will provide a starting point for future planning committees and avoid confusion should anyone from the state or local level attempt to contact them. 

Be sure to update your entire list of contacts and their corresponding information, while ensuring that all jurisdictions are represented.

Does the LMS document an opportunity for neighboring communities, local, and regional agencies involved in hazard mitigation activities, agencies that have the authority to regulate development, as well as other interested parties to be involved in the planning process?

Stakeholders that were either given an opportunity to be involved or who took part in the process must be identified by their title/position and agency/organization represented. One possible way of documenting this is to include a general email list, showing the various stakeholders that are invited to participate in the process. Additionally, some committees choose to provide a “task force” list that includes the primary contacts from various stakeholders. This list will likely be composed of those who are most involved and need to be updated more regularly. As with requirement P2 (A1), you may find it helpful to include the names and contact information. This information can also be provided in a narrative format.

When sending out invitations during a plan update, begin with the list of stakeholders from the previous planning process and decide if any changes are needed. The stakeholders will likely include nearby communities and agencies involved in local hazard mitigation and/or development activities. Including more local agencies, state agencies, and other interested parties such as power companies is a way to continuously improve your plan. In the update, describe any changes to the way stakeholders were invited to be involved in the process. Remember that this is to prove stakeholders were invited, not that they participated in the process.

Does the plan identify how the stakeholders were invited to participate in the process?

It must be noted in the plan how invitations were sent to stakeholders. Possible forms of invitations include emails, postings on social media or the county website, ads in the local newspaper, and fliers at the town hall or library. Documentation of these invitations is encouraged.

Another method to show that stakeholders were invited is by providing a template of a flier or email that announces the planning meetings. This will reduce the amount of documentation in your LMS plan and provide an outline for future planning committees.

As you update your plan, evaluate past methods used and determine the most efficient and effective method for inviting new stakeholders to participate in the present process. Be sure to specify in the plan how you contacted them and if desired, show documentation (e.g. screenshot of the county website, scanned image of a newspaper or flier, copy of an email). Again, this requirement focuses on proving how jurisdictions were invited to be a part of the LMS process.

Does the LMS document how the public was involved in the planning process during the drafting stage?

There must be an opportunity for the public to participate in the planning process and an effort to incorporate their feedback into the update. To verify this, documentation must be provided that verifies public was invited to be involved in the planning process. Please note that although it is encouraged to include public commentary on the LMS after completion, this alone will not satisfy the FEMA requirement. It needs to be shown that citizens were invited to be involved during the development of the plan. To verify this, you may include documentation of invitations, sign-in sheets from open meetings, a website that allows user reviews/ comments on the plan, surveys that were completed by the public, and/or a booth hosted at a popular community event.

As you update your plan, show how the public was invited to participate in the most recent planning process, and provide documentation of these invitations. When possible, incorporate public feedback into the plan, and make sure it is apparent to the reviewer.

Please note that even if no community feedback is received, it is required to state how it could be incorporated into the LMS.

Does the LMS describe the review and incorporation of existing plans, studies, reports and technical information?

To meet this requirement, examine existing plans, studies, and reports that can potentially be incorporated into the LMS plan and then show how they are incorporated. A common method to accomplish this second part is to provide citations or reference under tables, diagrams, and maps that are incorporated into your plan from other sources. It is always a benefit to include the source of these images so that the State of Florida’s Planning Unit, FEMA, and future planning committees will know where you obtained the information. Please note that it is not required to have a bibliography. A short citation under each image is sufficient.

As you update your plan, review the most recent list of plans and reports that were incorporated into the LMS to ensure that none are outdated or irrelevant. Evaluate new plans, studies, and reports as well, especially concerning recent development in the jurisdictions. Update the list of reviewed sources as necessary and show how any further material was utilized within the LMS since the last update.

Does the Plan include a general description of all natural hazards that can affect each jurisdiction?

Include a description of all natural hazards for which you plan to mitigate. Technological hazards may be listed as well, but only natural hazards will be evaluated. Please note that if there are no plans to mitigate a particular hazard, it is recommended to omit it with an explanation (see the next section, R2 (B2)).

Providing a clear description, or definition, for each hazard gives clear guidelines to state and federal planners as they review this portion of your plan. For example, should you identify “hail” in your definition of a thunderstorm, reviewers will evaluate how this aspect of thunderstorms is addressed throughout the entire risk assessment. This is usually a dictionary or NOAA definition of the hazard.

While updating, be sure to review your listed hazards and determine if they are still an appropriate list for your LMS; add and omit as needed. Additionally, change the descriptions as desired to reflect what this hazard looks like in your jurisdictions, as well as to reflect updated definitions by NOAA.

Does the Plan provide rationale for the omission of any natural hazards that are commonly recognized to affect the jurisdiction(s) in the planning area?

Should a natural hazard that is commonly recognized to affect the jurisdiction(s) not be listed, an explanation will need to be provided. “Commonly recognized” is usually defined in terms of the State of Florida’s mitigation plan. Not including a hazard that the state recognizes as a common hazard will elicit a need to explain its omission. If using your HIRA from your CEMP please keep in mind that any hazards identified must be fully profiled in the LMS. Sometimes it’s not practical to mitigate every hazard identified in your CEMP. A common way to meet FEMA requirements, while utilizing a single HIRA, is to add a statement which identifies specifically which hazards are being profiled in the LMS. This is important because every identified hazard must have a full profile and potential project attached to it. Omission of “commonly recognized” hazards will be sufficient if a rational reason is included with the omission. It is not recommended, nor expected for your community to mitigate every hazard. Rather, the goal of the HIRA is to evaluate which hazards have the biggest impacts and pose the greatest threat to your community. From this evaluation the most significant hazards will warrant the attention of the LMS committee.

As you update your LMS, review and revise this section to reflect any changes to your omitted hazard list. Be sure to identify hazards which may be impossible or impractical to mitigate. This can include removing duplicate mitigation efforts such as mitigating the effects of storm surge and Tsunami, when the magnitude of these may be quite similar.

Does the Plan include a description of the location for all natural hazards that can affect each jurisdiction?

A description or depiction of the entire location that could be affected by a hazard is a required component of the LMS plan. For wide-ranging hazards, such as severe thunderstorms and hurricanes, the location of occurrence can be the entire planning area and should be stated as such. For a less expansive hazard, such as flooding, the specific locations that can be affected need to be highlighted on a map or described in narrative format. Should you decide to provide a narrative, it should be detailed enough that someone reading it could examine their own map and delineate the areas to which you are referring.
Update your LMS plan by examining the location descriptions and/or maps.

Update them to reflect new developments in the area that will have an effect on the location of the hazard. For example, if there has been a new dam placed in your jurisdiction, this may change the area that can be potentially flooded by a river. As new relevant data and maps appear in other county plans, it is recommended to incorporate these into the LMS plan and note from where you acquired them. This will also help you meet requirement P7 (A4).

Does the Plan include a description of the extent for all natural hazards that can affect each jurisdiction?

The potential strength or magnitude of the hazard should be evaluated in the form of a scientifically recognized scale. It is not necessary to provide predictions for the greatest possible disaster. Rather, it is recommended to show the extent of the greatest disaster for which will be mitigated. Here are examples of scales commonly used for extent:


Unit of Measurement

Tropical Storms/Hurricanes

Saffir-Simpson scale




Acres burned


Palmer Drought Severity Index OR
U.S. Drought Monitor Scale

Extreme Heat

Minimum number of days at expected temperature

Winter Storms/ Freezes

Minimum number of days at expected temperature


Cubic feet or tons of missing sand


Depth and Width


Depth of Water


Density (strikes/second/cubic kilometer)






Acre-Feet Inundation

If the extent is described using a past event in the jurisdiction (ex. “The Fire of 2005”), this past event’s extent must be identified. For the example of fire, it could be described in terms of acres damaged and possibly how many homes, business, critical facilities, etc. were at risk. You may wish to include both the worst possible case, as well as the most common case. For example, your community may be capable of being hit by a category 5 hurricane but most likely it will be a category 2.

While updating your LMS plan, evaluate the severity of hazard events in the past five years. If any recent occurrences had a magnitude greater than the upper bound previously planned for, you may wish to consider raising the extent of the hazard for which you will mitigate. If a natural hazard has consistently been significantly below the extent planned for, and there are no plans to mitigate against a hazard of the extent listed, it may be beneficial to lower the listed extent.

Does the Plan include information on previous occurrences of hazard events for each jurisdiction?

Previous occurrences must be included from the last 5 years to ensure the LMS is up to date.  All occurrences must be listed. However, if there have been too many occurrences to feasibly list (e.g. wildfires or lightning) it is acceptable to state the total number of occurrences and list the largest or most significant cases (specifying date and details). If there have been no previous occurrences in the past five years, it must be explicitly stated for any profiled hazard.

This requirement may also be addressed in the plan’s risk assessment introduction by stating that all profiled threats have included all past occurrences for the last 5 years or state which years the table covers. It is also beneficial to include significant occurrences outside the 5-year limit.

For an LMS update, include previous occurrences within the last 5 years. For hazards with extensive occurrences such as thunderstorms, provide a holistic number of occurrences and spotlight significant occurrences. Be sure to include dates of the events. Additional narratives of the occurrences will often assist in meeting requirement R7.  You may wish to keep only the significant events from previous updates.

Does the Plan include information on the probability of future hazard events for each jurisdiction?

The probability of future occurrences for each identified hazard must be included in the plan. The probability of (re)occurrence can be defined in several ways, including: terms of general descriptors (e.g. low, medium, high), historical frequencies, statistical probabilities (e.g. 1% chance of occurrence in any given year), and/or hazard probability maps. A single definition may be used to fulfill this requirement. If general descriptors are used, they must be defined in the plan with the use of more specific terminology (e.g. reoccurrence frequency rate per year, percentage rate of reoccurrence per year).

For a LMS update, double check your probability figures to reflect any changes in frequency within the past five years or updates in scientific data. It is possible that you may not have any changes as many hazards rely upon statistical models or historical frequencies.

Is there a description of each hazard’s impacts on each jurisdiction (what happens to structures, infrastructure, people, environment, etc.)?

See R5 for an explanation of this element.

Is there a description of each identified hazard’s overall vulnerability  (structures, systems, populations or other community assets defined by the community that are identified as being susceptible to damage and loss from hazard events) for each jurisdiction?

FEMA defines vulnerability as “a measure of the degree in which a jurisdiction, structure, service, or geological area is susceptible to physical injury, harm, damage, or economic loss by the impacts of a particular hazard event or disaster”. In order to meet FEMA requirements, the LMS must explain why the hazards cause problems and why they impact an area of the jurisdiction. It cannot simply be stated that there could be a problem, where that problem could occur, or who will be affected. Asking “why this hazard is a problem for our planning area?” or “Why will this effect X amount of people?” will help you stay on track by creating problem statements which can lead to possible mitigation actions. All hazards previously listed in the HIRA should be examined for vulnerability.

Essentially, the vulnerability assessment should summarize why the planning area should mitigate the identified hazards. Vulnerability should go beyond a simple explanation of what could happen but discuss items specific to the planning area which could be adversely affected.

To update this section in your LMS consider new or previously overlooked problem areas and investigate what is causing these problems. Update previous hazards vulnerability to reflect any changes that have already been completed or are in progress. You can use this analysis to determine future mitigation projects. These assessments should be based on any changes since the last plan as well as expected future changes.

Does the Plan describe the type (residential, commercial, institutional, etc.) and number of FEMA repetitive loss properties within each jurisdiction?

The plan must describe the types (residential, commercial, institutional, etc.) and estimate the numbers of repetitive loss properties located in identified flood hazard areas. This can be done in a number of ways including a sentence describing the type and number of properties in each jurisdiction as well as a chart such as the one below. Remember that we need the type and the number in each jurisdiction, even if the number is zero.






City of USA





Town of America





State Village





Further, the use of flood insurance claim and disaster assistance information is subject to The Privacy Act of 1974, as amended, which prohibits public release of the names of policy holders or recipients of financial assistance and the amount of the claim payment or assistance. If a plan includes the names of policy holders or recipients of financial assistance and the amount of the claim payment or assistance, the plan cannot be approved until this Privacy Act covered information is removed from the plan.

Does the Plan include goals to reduce/avoid long-term vulnerabilities to the identified hazards?

General hazard mitigation goals must be included in the plan. As defined by FEMA, goals are broad policy statements that explain what is to be achieved through the LMS.

For an LMS update, goals do not necessarily have to change, but they must be consistent with the hazards identified in the plan, other plans, and the State Hazard Mitigation Plan. While not required, additional objectives outlining how goals are to be met can be beneficial to include. The update should also reflect that the goals have been recently reviewed.

“Does the plan document each jurisdiction’s existing authorities, policies, programs and resources, and its ability to expand on and improve these existing policies and programs?”

A summary of all existing authorities, policies, programs and resources available to accomplish hazard mitigation must be included in the plan. This includes all jurisdictions within the LMS. This requirement calls for the listing of all resources that can be used to accomplish hazard mitigation, it does not ask for how these resources achieve this. The plan must also include a description of how these policies can be expanded upon to include mitigation information in the future.

For an LMS update, there may or may not be significant changes required to ensure compliance. That depends more on the landscape of the participating jurisdictions. It is crucial to remember that this is a living document and must therefore be receptive to changes within all jurisdictions over this period of time. This includes changes to additional plans, funding sources, budget changes, building codes, and local ordinances. Be sure the most recent version of the document is being cited and delete older versions. If all plans are more than 5 years old, the plan should state that these are the most recent versions. Ensure the process for improving these plans is accurate.

A common issue we see during the plan review is the identification of various policies and programs but very little discussion of resources and ability to expand on these items. Another common mistake planners make is simply listing plans where the LMS can be incorporated and thinking that it will cover this requirement (S9).  Keep in mind that this does not have to be monetary resources but could be the ability to regulate future development, or the ability to incorporate stricter NFIP standards into new housing projects. We also have the ability to expand upon our existing outreach programs to provide tips to homeowners to mitigate their individual properties. This requirement should encourage the LMS working group to think creatively to identify the local resources available and discuss ways in which their capabilities can be maximized and expanded upon.

Does the plan address whether or not each jurisdiction participates in the National Flood Insurance Program (NFIP) and how they will continue to comply?

Each jurisdiction must detail their participation in the NFIP and describe their floodplain management program for continued compliance. FEMA explicitly states that a simple statement of “The community will continue to comply with NFIP”, or various similar statements, will not meet this requirement. Any jurisdiction that is not participating in the NFIP must state why they do not.
For an LMS update, the most important portion to focus on is that the previously listed actions taken by the participating jurisdictions are still current and that any new actions are included in the plan. While it is not required, it can also be beneficial to include specific details of how the participating jurisdictions are meeting NFIP requirements.

Per requirement §201.6(c)(3)(ii), the plan must discuss the jurisdiction's participation within the NFIP as well as their continued compliance with the NFIP's requirements. This can be addressed in your plan by providing a list of the jurisdictions participating in the CRS (Community Rating System) as well as a list of municipalities that participate in NFIP but not CRS (as applicable). This section also addresses, analyzes and prioritizes actions taken (or to be taken) in order to ensure continued NFIP compliance. For example, simple bullet points or a paragraph addressing how new construction and/or improvements through Special Flood Hazard Areas (SFHAs) will be regulated, if any flood insurance studies or mapping updates are to occur, continued provision of information to the public, preparation of and/or continuous update(s) of floodplain mapping, etc. (as applicable).

As a reminder, simply stating "the communities will continue to comply with NFIP requirements" is not sufficient.

Does the Plan identify and analyze a comprehensive range (different alternatives) of specific mitigation actions and projects to reduce the impacts from hazards?

The key focus of this requirement is the range of mitigation actions and projects being undertaken, or proposed, in the plan. Each hazard must have at least one project to mitigate the effects of that hazard. Ideally, each hazard will have multiple different actions analyzed before any specific action (or actions) is identified and placed in the final project list. Alternative actions are required in grant applications therefore including them in the plan will make that step easier. One project can mitigate multiple hazards. If a single project is used for multiple hazards, ensure this is stated.

Including actions and projects that do not necessarily fall under the category of mitigation will not invalidate the plan itself, but will not be considered to fulfill this requirement. Outreach and public education projects are encouraged. Further, projects that are routinely implemented or are being locally funded should be listed as opposed to this list being a “grant wish list”.

For an LMS update, analyze different mitigation actions for each hazard that is profiled in your plan. From that list, identify which actions and/or projects are feasible for your area and include those in your final project list. Remember that project lists should be constantly updated throughout the five-year process.

Does the Plan identify mitigation actions for every hazard posing a threat to each participating jurisdiction?

For this requirement, the plan must provide specific mitigation projects or actions for each distinct jurisdiction. One project can mitigate multiple jurisdictions. If a single project is used for multiple jurisdictions, ensure this is stated.

For an LMS update, ensure that listed mitigation projects or actions are up to date with the participating jurisdictions included in the plan. Updates should ensure that actions or projects used to meet this requirement are still in effect within (or across) specific jurisdictions and edit or remove initiatives that are no longer accurate or relevant. Remember that project lists should be constantly updated throughout the five-year process.

Do the identified mitigation actions and projects have an emphasis on new and existing buildings and infrastructure?

Mitigation projects and actions should focus on retrofitting existing structures to lessen their impact during a future event as well as constructing new structures that will lessen the communities’ impact. This should be a dual approach as opposed to focusing on just new infrastructure or only existing buildings.

For an LMS update, confirming that proposed or enacted projects or actions are up to date is a significant consideration for this requirement. Take the time to inventory the types of projects being proposed to ensure both new infrastructure and existing structure retrofits are being proposed.

Does the Plan explain how the mitigation actions and projects will be prioritized (including cost benefit review)?

Selected mitigation actions/projects need to be prioritized according to one or more criteria. The only required criteria is a cost-to-benefit review. This does not need to be a full cost-to-benefit analysis as is standard with a grant application. It could be as simple as providing an estimated cost of the project (e.g. $10,000-$15,000) and stating the estimated number of people it would benefit (e.g. 8,000-10,000).

When updating your plan, be sure that the list of prioritized projects is up-to-date (to account for deleted, completed, and new projects) and re-analyze the criteria for prioritization as needed.

Does the Plan identify the position, office, department, or agency responsible for implementing and administering the action/project, potential funding sources and expected timeframes for completion?

The plan must list who is responsible for each project. This can be a single person or an entire agency, but it must be specified. Remember that the jurisdiction benefited is not the same as the agency responsible.

Potential funding sources need to be identified. This can be done by listing sources for individual projects or by providing a general list that encompasses all projects. Try to make your list of funding sources as realistic and achievable as possible to give an accurate image of the financial circumstances.  Furthermore, it is beneficial to show all sources of local funding in your LMS to show that there is support coming from the communities for these projects as well as the state/national grant funding to which you may be applying. Try to remember that this is not just an “grant wish list”. You should include projects completed at the local level as well as those which may require federal grant assistance.

Estimated timeframes for completion must be provided for each project. This does not mean that there needs to be a date by when the project will be completed. Rather, it should be an estimate of how long the project will take from when it begins (e.g. 2 weeks, 2 years). If you would like to include information on the status of project (e.g. began May 2015, will begin upon receiving funding), please include this as a separate bullet or column in addition to the timeframe.

When updating the plan, ensure that the responsible parties, funding sources, and timeframes are still relevant. This information should reflect all deleted, completed, and new projects. Review how this information is presented and consider using a concise table.

Does the LMS identify the local planning mechanisms where hazard mitigation information and/or actions may be incorporated?

Identify other plans in the community into which the information or objectives of the LMS can be incorporated. Please note that this is a different requirement than P7 (A4), which requires a review of currently existing documents and plans that can be incorporated into the LMS plan. If information and knowledge was obtained from these other planning mechanisms within the LMS and information from the LMS could also be incorporated back into these plans, you may find that they fit both requirements. However, it should be clearly stated in the LMS plan which ones were utilized for requirement P7 (A4) and which ones were utilized for S9-11 (C6). This list may be the same as listed in S2 (C1).

Local planning mechanisms that have been listed in LMS plans in the past include:

  • County or Municipal Comprehensive Plans
  • Local Emergency Management Plans
  • Floodplain Ordinances
  • Land Development Codes and/or Regulations
  • Building Codes
  • Transportation Plans

When updating the LMS plan, re-examine the list of these local planning mechanisms to make sure that none have become outdated; adjust as needed. Continue adding to the list with any new ideas, especially considering if there have been any new plans created for the community. This should be an outline of where you could integrate the LMS in other planning mechanisms.

Does the plan describe each community’s process to integrate the data, information, and hazard mitigation goals and actions into other planning mechanisms?

In addition to listing local planning mechanisms in which information from the LMS plan can be used, the procedure for how the information will be incorporated needs to be outlined. Rather than describing the process for each local planning mechanism individually, it is sufficient for this requirement to provide an overview of the local planning committee’s process of analyzing potential outlets for the information and objectives of the LMS plan.

In order to update the plan, evaluate the description of the implementation process to ensure it is still accurate. If you have provided a master list of local planning mechanisms into your LMS to meet requirement S9 (C6) and if you have made any changes to it, be sure to update any individual descriptions of how information can be incorporated into these plans.   

The updated plan must explain how the jurisdiction(s) incorporated the mitigation plan, when appropriate, into other planning mechanisms as a demonstration of progress in local hazard mitigation efforts.

The LMS plan should show progress in how information and/or objectives have been successfully integrated into local planning mechanisms in the past. If information provided by the LMS plan has been used in other documents, it is recommended to state in which objectives, policies, codes, etc. this information can specifically be found. If the local planning mechanisms support the goals and objectives of the LMS, describe how exactly they do so.

As you update, continue to provide examples of how information from the LMS plan has been utilized in other community plans and how the objectives have been supported by other planning mechanisms since the last update. You may find it helpful to refer to your plans listed for requirements S9 (Part 1 of C6) and S10 (Part 2 of C6) to see if any progress has been made toward these projections.

Was the plan revised to reflect changes in development?

This section is only a part of an LMS update. There needs to be a descriptive paragraph explaining any changes or new development in each jurisdiction. In each paragraph explain how your vulnerability is affected with these developments whether positive or negative. The LMS can discuss population changes, landscape changes, new developments, etc.

During an update, take the time to review how your community has changed since the last update. This can include changes in population, demographics, land use, policies, etc. describe these changes and how they have affected your vulnerability to hazards overall. You may also discuss how specific development or implemented mitigation actions have increased or decreased your vulnerability to specific hazards.

Was the plan revised to reflect progress in local mitigation efforts? (Were projects completed, deleted or deferred and why if they were deleted or deferred?)

At this point the LMS lists any projects that have been completed, deleted, deferred, or new since the last update. If a project has been deleted since the last LMS this section must address why the jurisdiction has done this. Also, if a project has been deferred the LMS must explain why this happened. Projects that have been completed since the last LMS should also be listed in this section.

To update this section, make sure that projects are current. If a project from the last LMS was deleted or deferred there must be an explanation as to why in order to be approved. A “status” column on the project list is a simple way to document this; alternatively, separately labeled listed may be created.

Was the plan revised to reflect changes in priorities since the plan was previously approved?

The plan must describe if and how any priorities have changed since the plan was previously approved. This is focusing on ensuring the goals and objectives of the plan have been updated. The best way to document this requirement is to state when goals and objectives were reviewed during the planning process. This can be done either in the planning process narrative or through meeting minutes and summaries.

To update this section, make sure that projects are current. If a project from the last LMS was deleted or deferred there must be an explanation as to why in order to be approved. A “status” column on the project list is a simple way to document this; alternatively, separately labeled listed may be created.
To update this section, make sure the goals and objectives have been reviewed at the beginning of the update process. Ensure any goals with dates are updated or removed. Document the review of your goals and objectives in the plan.

This tip will focus on the continuous monitoring, evaluation, and updating of the LMS throughout the five year update process (M4-6). The LMS update process does not end after the LMS is approved and pick back up six months before its next expiration date; it is a continuous cycle that is always ongoing. 

The LMS is a living document that guides action over time.  As conditions change and new information becomes available, or as actions progress over the life of the plan, plan adjustments may be necessary to maintain its relevance.  Approval of the LMS marks the time to establish a schedule and method for keeping the plan current over the next five years.  One of the most important steps in updating your plan is to refine the community’s mitigation strategy, particularly in light of experiences gained from the implementation of the previous plan. 

To continue to be an effective representation of the county’s overall strategy for reducing risk to natural hazards, the updated local mitigation plan must reflect current conditions and progress in mitigation efforts.  This involves establishing a meeting plan with your LMS Working Group and continuously engaging with local jurisdictions in revising the plan with any major changes (including to the local hazard assessment as well as with changes in personnel), tracking the status of projects and mitigation actions (as well as adding new ones and deleting old ones), and evaluating the effectiveness of the plan at achieving its intended goals and objectives (and making any changes as necessary). The annual 27P-22 update (due to us January 29th, 2016) is a great way to conduct these activities on a predetermined annual basis.

Be sure the there is a clear responsible party, timeline, and procedure listed for how the plan will be monitored, evaluated, and updated throughout the life of the plan. These efforts serve as the basis of the next plan update. 

Does the plan identify how, when, and by whom the plan will be monitored (how will implementation be tracked) over time?

Monitoring the plan means tracking the implementation of the plan over time. The plan must include a statement or section detailing how/when/by whom it will be monitored during the 5-year cycle. It is required to state how the plan will be monitored. Simply stating that ‘The plan will be monitored during the 5-year cycle’ is not sufficient. It must state when monitoring will occur;  including who is responsible for monitoring the plan. This requirement’s purpose is to make sure the plan is functioning as it was written.

For an LMS update, ensure that all the detailed information is up to date. This primarily relates to the listing of by whom the plan is monitored but should also apply to the description of how the plan is monitored. It may need to be reconsidered as the 5-year cycle progresses. At minimum, monitoring can occur during the annual update as stipulated in F.A.C. 27P-22.004. Review the monitoring process as stated in the plan and revise as necessary to match current procedures.

Does the plan identify how, when, and by whom the plan will be evaluated (assessing the effectiveness of the plan at achieving state purpose and goals) over time?

Evaluating the plan means assessing the effectiveness of the plan at achieving its stated purpose and goals. The plan must include a statement or section detailing how/when/by whom it will be evaluated during the 5-year cycle. It is required to state how the plan is reaching the goals and objectives it aims to achieve. Simply stating that ‘The plan will be evaluated during the 5-year cycle’ is not sufficient. It also must state when evaluation will occur, meaning scheduled times or stating a certain frequency with which the plan will be evaluated. Including who is responsible for evaluating the plan is also required. This requirement’s purpose is to determine whether the plan is beneficial to the public or not.

For an LMS update, ensuring that all the detailed information is up to date should be the initial point of consideration.  This primarily relates to the listing of who evaluates the plan but should also apply to the description of how the plan is evaluated, it may need to be reconsidered as the 5-year cycle progresses. At minimum, evaluating can occur during the annual update as stipulated in F.A.C. 27P-22.004. Review the evaluation process as stated in the plan and revise as necessary to match current procedures.

Does the plan identify how, when, and by whom the plan will be updated during the 5-year cycle?

The plan must include a statement or section detailing how/when/by whom it will be updated during the 5-year cycle.  A description of how the plan will be updated is required. There must also be a schedule, or set frequency, when update sessions will occur. It is also required to include the board/committee responsible, or the name and title of any individual, who is responsible for updating the plan. This section can refer to the 5-year update only, or it may include intermittent updates if applicable.

For an LMS update, ensuring that all the detailed information is up to date should be the initial point of consideration. This primarily relates to the listing of who will update the plan but should also apply to the description of how the plan is updated, it may need to be reconsidered as the 5-year cycle progresses. At minimum, updating can occur during the annual update as stipulated in F.A.C 27P-22.004. Review the update process as stated in the plan and revise as necessary to match current procedures.

Is there discussion of how the community(ies) will continue public participation in the plan maintenance process?

The plan must detail how community participation will be continued. Public outreach and opportunities for the public to provide feedback on the plan are necessary steps and must be described. Examples to encourage participation can include; presentations on the plan and its progress to community groups (schools, clubs, churches, etc.), questionnaires or surveys to measure understanding of the plan, public meetings, and use of web-based outreach (social media posts or websites available to the public).

For an LMS update, stating how the community is involved in and will be incorporated in the process of writing and updating the plan is the key focus. Stating that past examples were sufficient is an option, but only so long as those past examples ensured actual community participation. If past measures have failed to garner any response from the public this must be addressed and include a discourse on what new measures may be taken.

Does the Plan include documentation that the plan has been formally adopted by the governing body of the jurisdiction requesting approval?

In order to meet this requirement, the LMS plan must provide documentation that proves official adoption of the plan. After obtaining APA (Approved Pending Adoption) status from FDEM, at least one jurisdiction must adopt the plan prior to the plan expiration date. All other jurisdictions will have one year to adopt the plan to remain eligible for HMA guidance.  Proof of this usually comes in the form of a resolution. If you are unable to provide this, possible alternatives are:

  • A clerk or city attorney providing a written confirmation that “the action” meets the community’s legal requirements for adoption.
  • The highest elected official or their designee providing written confirmation of the adoption by providing an explanation and their signature.
  • Certified meeting minutes included that highlight the adoption of the LMS plan by the jurisdiction.

When you submit an updated plan to FDEM and receive an APA status, then you must have the plan re-adopted by the community. Even if the LMS plan has been adopted by the community in the past, the most recent plan needs to be accepted through the standard adoption process for the local jurisdictions. Please note that although the State of Florida’s Planning Unit sends out consistent notifications to the local jurisdictions of their deadlines to renew the LMS plan, jurisdictions with longer adoption processes will find it beneficial to start the process earlier.

For multi-jurisdictional plans, has each jurisdiction requesting approval of the plan documented formal plan adoption?

Proof of adoption must be provided for each jurisdiction that is adopting the LMS plan. This includes every jurisdiction (e.g. counties, cities, school boards, hospitals) that has been listed under requirement P2 (A1). After receiving an APA status from FEMA, at least one of the jurisdictions must adopt prior to plan expiration. After this, all other participating jurisdictions must adopt the plan within the first year in order to remain eligible for HMA funding. It is recommended that all participating jurisdictions adopt the plan prior to the initial expiration, although this is not always practical.

When updating the LMS plan, all jurisdictions listed in P2 (A1) must re-adopt the plan as part of their standard adoption processes. Be sure to provide documentation of this most recent adoption for each jurisdiction. The plan is not considered complete until all jurisdictions have adopted, documentation is included in the plan, and a final plan and review tool have been submitted to FEMA.

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Melissa Schloss
(850) 815-4504

February 27, 2017 16:44

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