Watch the Swift Current Webinar

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But we'll go ahead and get started. Good morning everyone. Thank you for joining. This is the fiscal year 24 briefing on FEMA's Flood Mitigation Assistance Swift Current Program. Today we're going to walk through what it is who can apply, what it pays for, how the process works here in Oklahoma. And then just an important note. Everything you hear today is based off of the fiscal year.

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Swift Current... No... sorry. Fiscal Year 24 Swift Current NOFO. Particularly amendment four, which was from April. You are more than welcome to put any questions in chat. And then we will either answer at the end or if we run out of time, we will, email response responses to any questions anybody may have. So a quick brief on how we'll start our how we'll spend our time.

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We'll start with an overview of the program itself and then get into what, projects and costs actually qualify for this program. Then we'll get we'll get into what goes into each sub-application, walkthrough timeline, talk about the cost, share management costs, spend some time on procurement and conflicts of interest, and then close with steps on how to reach out to OEM for help.

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So let's start with the basics. What Swift Current? How it's funded. Who it's for. It's worth pausing on this because FMA is a general resilience grant. It's not an infrastructure grant program. This exists for one specific reason. It's reducing flood risks and cutting down a future flood insurance claims. So it's very important to note that all of your programs and all of the noted communities and, apologies noted properties have to be NFIP insured.

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So the whole point of Swift Current is speed. After a disaster, it gets funding out the door quickly so communities can elevate, buy out or rebuild flood damaged homes. Only for properties that are already insured through the NFIP, which is the National Flood Insurance Program. Oklahoma is the applicant, not any individual communities. So communities identify the properties, put the sub-application together, and then submit to OEM who will submit it to FEMA on your behalf.

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This round covers residential mitigation projects. Plus a small amount of scoping work, but most projects will be for residential mitigation and projects cannot start construction until it is approved and awarded. In discussing the money, Oklahoma has $10 million set aside for this cycle, and it's noncompetitive, so you're only fighting with other Oklahomans, and $10 million is plenty for those communities identified as eligible under this program.

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It's about putting together eligible, well-documented products... projects, funding ties to flood disasters declared between June 1st of 24 to May 31st of 2025. Once awarded, communities get about 36 months to complete the work. There are two deadlines to keep important. OEM's application deadline is due October 16th and then we will submit to FEMA on October 30th.

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So Swift Current is unique for predominantly three reasons. First, it's time round. Oklahoma's deadline to FEMA is October 30th and the funding itself expires by the end of December, so there is no room for any delays. Second, it's property focused. So this is about specific homes that qualify as repetitive loss, severe repetitive loss or substantially damaged properties. And third, it only exists because of a disaster.

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It opened up once a flood event crossed a certain paid claims threshold.

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Eligibility comes down to three main categories. Each one carries a different federal share, so it's important to know which ones qualify for your community. A severe repetitive loss or SRL property has to have four or more claims over $5,000 each, adding up to more than $20,000 or two claims that individually exceed the home's values. And those get a 100% federal share.

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Repetitive loss or RL properties have two flood events for repair costs. Each hit at least a quarter of the home's market value, and those getting 90% federal share. And substantially damaged or SD properties are those that are damaged past a certain threshold after the disaster declaration, and they get 75% federal share. One requirement applies across the board, and that's a every property has to carry NFIP and NFIP flood policy.

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Three parties make this all work, each with very distinct roles. OEM, we are the state applicant. We administer the program, provide technical assistance. Local and tribes are the ones on the ground. You work with the home owners, build the actual sub-applications, line up any local match funding, and manage the project once it's underway. And homeowners themselves have the, sorry, have the option to voluntarily opt in.

00:05:56:09 - 00:06:09:07

Because nobody is required to participate. And if their home is being elevated, they need to keep flood insurance on it for as long as they own it. Next, I will pass to Aubry to discuss eligibility.

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Thanks, Chylar. So now we're going to shift to what this money can actually be spent on the eligible applicants, the project types and the costs tied to each one. So a big question is always who can apply in the first place? Since those of you participating on the call have been specifically reached out to, we've already done our due diligence and know that you are eligible to apply.

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So cities and counties are the eligible sub-applicants. Individual homeowners cannot apply directly to FEMA. If someone wants their home elevated or bought out, their city or county has to sponsor the application on their behalf. And participation is always voluntary on the homeowner's side, and there are a few prerequisites to keep in mind. The applicant has to participate in the NFIP.

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The community needs an approved hazard mitigation plan already on file, just like all other FEMA grants, mitigation grants. And every property in the project need flood insurance that was in effect for June 1st, 2024. OEM and the Oklahoma Water Resources or OWRB, can help you confirm which category a given property falls into SRL, RL, or SD, substantially damaged, so lean on them early rather than guessing.

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Additionally, projects must be proven cost effective through FEMA approved benefit cost analysis methodology. There are four, predominant project types under this program acquisition means buying the property and either tearing down or relocating the structure, with the land permanently restricted as open space going forward. That's a really important point there. Elevation means raising the first floor above the base flood elevation, typically on piers, piles, or stone wall with flood events.

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Reconstruction applies when a home can't be elevated, so instead it's rebuilt to current code and at a higher elevation. And dry flood proofing is the fourth option, but it's only available for historic structures across all four. The homeowner has to keep the NFIP coverage on the property for as long as the structure stands. Now we're going to talk about the eligible scoping applications.

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So Oklahoma can use up to 1% of it set aside for scoping. So 100,000 this cycle for things like gathering property data, prioritizing which homes to pursue and developing project scopes. As long as that scoping work leads directly into an eligible mitigation project. So what it can't be used for are things like hazard mitigation planning, general capacity building, standalone drainage or infrastructure work, or any property that doesn't meet the repetitive loss, substantial repetitive loss, or substantial damage criteria.

00:09:01:09 - 00:09:29:14

So for eligible costs, for acquisition and demolition or relocation projects, eligible costs include buying the property at Fair Market value, demolishing or relocating the structure, legal and administrative work to close the sale and record the open space deed restriction. Appraisals and title work relocation support required under the Uniform Relocation Act for tenants, and a limited relocation benefit for owner occupants. For elevation projects,

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eligible costs include the actual lifting and raising foundation work, utility reconnection, access and egress permits and fees, including new elevation certificates and some limited costs to temporarily house owner occupants during construction.

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Eligible costs for mitigation, reconstruction, include demolition and site work, foundation work, the actual construction, utility and permit costs, and again, a limited relocation benefit for displaced owner-occupants. There are also some hard limits worth flagging. The new structure cannot be more than 10% larger than the original structure. The federal share for construction is capped at 220,000, and everything has to meet the current building code and floodplain standards.

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The cost share gets more interesting once you're combining properties into one project, which is allowable. So say you have a severe, repetitive loss home at $300,000 in total cost. The federal share there is $100,000. So $300,000 is coming from FEMA. Now pair that with a repetitive loss home also 300,000. But because it's repetitive loss it's at a 90% federal share.

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So $270,000 from FEMA. If you're submitting both of these applications together in the same, part or both of these properties together in the same portfolio, that $600,000 in total cost and $570,000 in federal share, which averages out to 95% federal cost share overall. A few rules to keep in mind. You can mix property types with different cost shares in one sub application, but you cannot mix project types, so you can't combine elevations and acquisitions in the same package.

00:11:21:09 - 00:11:45:14

And ultimately it's on both OEM and the sub-applicant to make sure the right cost shared gets applied to each property. Now I'll pass it to Kelly to dive into the details of sub-application requirements. Thanks, Aubrey. Chylar, you can go ahead to the next slide. So, you know, for the Swift Current sub-application,

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so, these are applications that are completed in FEMA Go. It will be a format that folks are familiar with if you've submitted on FMA or even BRIC in the past, you know, as it states on the slide here, you've got your sort of standard, you know, detailed scope of work, cost estimates, projects schedule with your milestones, demonstrating you can meet a 36 month period of performance.

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Benefit cost analyzes are also required for Swift Current, as well as environmental and historic preservation documentation and then documented NFIP benefits. Which is something we can we can sort of chat through later. For individual flood mitigation projects, there are some additional requirements from a paperwork and a, you know, level of detail perspective that aren't sort of standardized throughout the FEMA GO sub-application template.

00:12:44:15 - 00:13:08:11

So you do need to make sure for these individual flood mitigation projects that you have a list of participating properties, voluntary participation forms for each resident. I think, Chylar and Ari have both hit on the fact that, you know, the Swift Current program and all residential mitigation work is voluntary. That has to be verified at multiple times throughout the process for each resident.

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And the first step is getting that into the application. You also want to submit things like property appraiser information to document homeownership, NFIP flood insurance policy declaration pages. You know, if a property owner has NFIP flood insurance, they will know that this is, in addition to, you know, and we'll talk through this as well, proposed elevation or flood proofing heights.

00:13:34:11 - 00:14:03:01

So the level of protection that's going to be provided through these mitigation options, as well as substantial damage documentation, if, one of your properties meets that threshold as well. Thank you for moving to the next slide. So let's talk a little bit about the scope of work. We wanted to provide some examples in this, presentation of like the type of information and the level of detail that FEMA is looking for here.

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So in an individual flood mitigation, project scope of work, especially one that bundles multiple properties together, you want to make sure you're really clear about the location of the properties. So that means addresses. That means, you know, lat long coordinates for GPS entries. You really want to include a good description of existing conditions and historic losses, including the current first floor elevation of the property is compared to the FEMA flood insurance rate maps, or other best available flood data.

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For example, if the local community has a stormwater master plan that shows that, you know, the 100 year flood event, is, you know, maybe has a different, maybe has a different boundary than what the is in the FEMA firms. You also want to mention any engineering methods expected to complete the work, as well as the sub-applicant’s management approach for the project.

00:15:03:13 - 00:15:25:07

This is really important if you are including multiple properties, to sort of talk about how as a sub-applicant, you're going to manage implementing multiple properties at once. So for the next two slides, I'm not going to read these, but you know, this will be made available to you all after the fact. We wanted to include some very high level sample scopes of work.

00:15:25:07 - 00:15:54:08

So you can sort of see how this information is worked into a scope document for sub-applications. The thing I want to highlight here for acquisition demolition okay. Can you go back? Thank you. The thing I want to highlight here for acquisition, demolition and, I believe Aubrey touched on this is this first sentence in the second paragraph that the land will be converted to open space and deed restricted as set forth in FEMA program requirements, as described in 44 CFR.

00:15:54:12 - 00:16:20:01

That is a key sentence that FEMA is going to want to see in the sub application. So if you're applying for acquisition demolition, please make sure that A) you review what those restrictions and requirements are and B) that this statement is in the sub-application. Next slide please. This next scope of work sample is for an elevation project.

00:16:20:01 - 00:16:52:04

And again it just gives an example of demonstrating, you know, what the future first floor elevation is going to be. And demonstrating it's above the current base flood elevation as demonstrated in your firm or through best available data that you as a community may have on hand. Next slide please. Thank you. As we mentioned before, all projects require a benefit cost analysis where the benefit cost ratio has to be above one.

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So you're demonstrating that the total benefits compared to your total costs are, you know, cost effective there. For residential mitigation projects, FEMA does have pre-calculated benefits, which I absolutely recommend that, you use to demonstrate cost effectiveness because it is very streamlined, is the easiest way to document a positive BCR for these types of projects.

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However, please don't conflate these pre-calculated benefits with a project cost cap. Project costs for elevations and acquisitions can be higher than these values. You can, you just have to document your benefit cost analysis in a different way. Which is something that, OEM and their team is able to provide technical assistance on if needed. Next slide please.

00:17:57:03 - 00:18:22:11

Let's talk really quickly about THP for individual flood mitigation projects. You know, from an EHP perspective, you really want to make sure with your sub-application, you're including photographs of all four sides of the structure that you have really nice high resolution maps demonstrating the project boundaries, including, you know, GPS coordinates and the potential area of ground disturbance.

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You also want to make sure that, original construction dates are included, in order to verify potential impacts on historic structures and that you're also including any sort of, like, letters or assumptions on the impacts to threatened or endangered species, as well as an assumption on the potential of lead based paint asbestos or, radon presence.

00:18:46:03 - 00:19:31:07

For older structures, there is a requirement to have documented coordination with the state Historic preservation officer, which actually OEM has to complete the coordination with SHPO. Upon receipt of your sub-application. So, you know, we just ask that you sort of prepare submissions for OEM to send. And OEM can, initiate that correspondence and then for acquisition, demolition in particular it's actually required that, there's coordination with Oklahoma DOT to ensure that that property is not identified for future use for highway or, you know, transportation uses in the future.

00:19:31:08 - 00:20:04:12

OEM will also need to complete that correspondence, but then we will need, information from you all from the sub-applications in order to do that. So I just want to make a note there. And then lastly, we've gone over some of this, but you know, again, for the purpose of providing sort of a checklist there is additional paperwork that's required for, individual flood mitigation projects that's a little different than your typical, HMA project for property owners.

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No matter what type of, residential mitigation project you're undertaking, there needs to be a notice of voluntary interest, which will also share template forms for that. And there also needs to be a current NFIP flood insurance declaration page. If available, there is other documentation we would like to see in an application, including a declaration and release form that demonstrates that the property owners are, U.S. citizens or legal aliens.

00:20:36:15 - 00:21:22:07

And, we also want to make sure that, you know, any sort of like, flood claim history, insurance estimates or substantial damage determinations are also included in the sub-application to, you know, reduce RFIs moving forward. And then from the sub-applicant side, if you are considering, acquisitions and haven't had a chance to look at this documentation already, I highly suggest you take a look at the model statement of assurances for property acquisition projects and FEMA's model Deed restriction language, because FEMA will actually want to see in your application that, you know, the sub-applicant or the community is aware of the deed restriction language that has to occur on acquisitions

00:21:22:07 - 00:21:48:13

in order to keep them open. Keep them as open space in perpetuity. And again, we can provide all of this, for reference as well. So just a couple tips and tricks. If you are thinking about, applying for Swift Currents. First is verify property status and and please confirm that each property is eligible. This is something that OEM can help you do.

00:21:48:14 - 00:22:20:09

But a property must be a severe repetitive loss, repetitive loss or substantially damaged property and have an active NFIP flood insurance policy. You also want to confirm the match source. Think about your match. So it's common for elevations and mitigation reconstruction projects for sub-applicants to offset local match to the homeowners. That's something you'll want to talk to your homeowners about beforehand as they are thinking about participating in the program.

00:22:20:10 - 00:22:53:00

And then you also want to think about your match source for, acquisition projects as well. You know, I... as always, when working with property owners, you know, communication and coordination is really, really important. Participation throughout the program is voluntary. And these award timelines, they could be long. Even though the purpose of Swift Current is to really, you know, really speed up funding to, property owners post award.

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You know, there's still federal review requirements and, the award and application process with OEM. So setting those expectations upfront that this isn't an immediate offer for mitigation is going to be important. Next. And I think this is in the case that you have properties that are like potentially interested or you have a lot of interest and maybe there's limitations such as match availability and everything you can actually submit a priority and a secondary list in your sub-application in case there are dropouts from your priority list.

00:23:37:04 - 00:24:01:05

You just cannot add in properties after FEMA's, review process occurs. So you got to get all of your properties, whether they are a priority or, you know, just thinking about participating, you got to get those in in the initial application. And then we already talked about alternate BCA methodologies, so I won't speak more to that. But hopefully that was helpful.

00:24:01:05 - 00:24:14:03

And Chylar, I'll turn it back to you on the timeline.

00:24:14:05 - 00:24:48:03

I was muted I apologize. Thank you Kelly. Next we'll get into the timeline and how applications actually move through the system. FMA is a FEMA program, but communities submit to OEM and OEM submits to FEMA. You do not submit directly to FEMA. That's why our internal deadline matters just as much, if not more, than FEMA's final deadline, because that's the one that relates to y’all. We have to have time to review what comes in and ask for corrections and put together the state's full submission.

00:24:48:04 - 00:25:11:08

So here's the sequence. First, you have to confirm... your confirmed participation in the NFIP and your homeowner interest. Once you do that, you'll reach out to us here at OEM and put in a NOI in EMGrants, to let us know kind of what your project is looking like, what it's going to be, the scope, that sort of thing.

00:25:11:09 - 00:25:37:12

This is important. It allows us to have visibility on what's kind of expected to come in and allows us to flag pretty early on whether a project looks like a good fit or like it would fit better in another program. From there, the community builds out the scope of work cost estimates and BCAs, all lining up into one another as well.

00:25:37:13 - 00:26:08:15

And then the sub-application is due to OEM in FEMA Go not in EMGrants. The NOI is due in FEMA.. in EMGrants. The sub-application is due in FEMA Go by October 16th. From there, OEM will review. It will ask for any updates, anything that needs to be completed or finished or corrected. And then we will submit the state package to FEMA by October 30th.

00:26:09:00 - 00:26:33:03

So one thing I'd underline is start now. Don't wait until the last few weeks to pull anything together. Don't wait until the last few days because you need plenty of time to put everything together nice and make it ready for FEMA review. Otherwise we will not be sending it forward. And super short list of do's and don'ts that will save a ton of time.

00:26:33:04 - 00:27:06:12

I recommend keeping your file and property naming consistent and FEMA go confirming NFIP status in RL SRL or substantial damage support upfront. Make sure you're scope, budget, schedule, BCA and project type all match one another, tying your design directly to documented flood risk thinking through match funding, procurement, environmental review needs before you submit and regardless of this funding cycle, continue to do outreach with your SR, SRL and RL properties.

00:27:06:13 - 00:27:31:02

If this funding opportunity does not end up working for your community, there will be future opportunities that might. We recommend keeping up with that communication with your property owners. A few important don'ts. Don't submit property data that isn't backed up. Don't leave out ownership or flood history documents. Don't start any work before your project is approved and awarded.

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Don't write a vague scope of work that doesn't match your budget or timeline, and don't propose general infrastructure or planning work that isn't eligible under this program.

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All right, now the fun stuff. Let's shift into a few compliance topics that often get overlooked during the application phase, but matter a lot after award. This includes management costs, procurement, conflicts of interest all affect whether costs actually get reimbursed at the end. A project can be strong on paper but still run into delayed payments, disallowed costs or even repayment demands.

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If procurement isn't handled properly or a conflict of interest was caught. It's time to think about this now. Before you hire a consultant or issue a solicitation. Definitely not after. On management costs, sub recipients can budget up to 5% of the total sub application. Federal and Nonfederal combined for management costs and not money is reimbursed at 100%. Federal share.

00:28:36:15 - 00:29:01:13

It needs its own line item in the scope of work and cost estimate, with its own narrative. The period of performance is 36 months from the award date. Extensions are possible, but not guaranteed. You won't need to request one at least 90 days before your deadline, and extension does not come without federal funding or sorry... an extension does not come with extra federal funding.

00:29:01:14 - 00:29:24:10

All pre award costs are things like BCA, environmental data and design work needed to complete the application can be eligible. FEMA approves them and they need their own line item and even count toward your local match. What's not allowed is starting actual implementation before the award comes through.

00:29:24:12 - 00:29:59:13

For procurement, every purchase under this award has to follow federal procurement rules. Following two CFR 200.317 through 327, it's important that if any state or local rules are stricter, you must follow those instead. Local governments and nonprofits use their own procurement procedures, but this procedures have to meet the federal standards. So states and tribes follow their own policies with the same requirement to meet domestic preference rules and include the required contract language.

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We at OEM expect full and open competition with documented reasoning behind your procurement method, contract type, contractor selection, and pricing. You need a written procurement policy on file before you ever solicit a solid or ever issue a solicitation, and every contract needs the required federal clauses. Infrastructure projects also need to address the BABA, which is Build America by America requirements.

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Watch out for any for practices that will get flagged giving noncompetitive contracts to a consultant already on retainer, specifying one brand with no equivalent, piling on unnecessary experience or bonding requirements. Cost plus percentage of cost contracts which are prohibited, prohibited, and splitting purchases just to dodge a competition threshold. The bottom line is, OEM won't process reimbursement until your procurement policy, your documented process, your rationale in the selection, and your signed contracts are all submitted to us.

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Get this ready before you need it.

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Conflicts of interest A rule worth remembering on its own is a consultant who helps write your grant application, project plans or budget cannot then bid on the contract to build that same project that covers pre award work like grant writing, post award work like grant management. On the personal side, you will need written personal conflict of interest standards in place before you award any contract.

00:31:45:01 - 00:32:15:04

Nobody with a real or apparent conflict, financial interest for themselves, family, a business partner or their employer can take part in selecting, awarding or managing that contract. And your standards need to spell out what happens if somebody violates them. On the organizational side, the firm that wrote your application generally can't win the construction contract, and former employees who worked on the application are also barred.

00:32:15:05 - 00:32:45:00

The one exception is if you do a competitive if you competitively procure a single contract that covers both writing the application and the work from the start. The key takeaway settle your procurement approach before you bring on a consultant and if a conflict of interest surfaces later, this cost get disallowed, the community has to pay the federal money back.

00:32:45:01 - 00:33:05:10

And that's all we've got for today. We've got mine and JJ's contact as well as our group email. I always recommend using our group email for any questions. It reaches our entire team, which means you'll most likely get a more timely response. But if you need anything specifically for me or JJ, our contact information is there.

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We're really here to help, especially with program guidance, sub-application support, benefit cost analysis and documentation support, and environmental and historic preservation guidance. And we're happy to help genuinely wherever we can. So please do not hesitate to reach out to us. Thanks for joining.