ANALYSIS (attachment to FEMA determination letter):
Issue 1: The project does not meet the eligibility requirements as stated in 44 CFR 206.434 (b)(4) and (b)(5) (I-V). The HIC does not solve a problem independently, or substantially reduce the risk of future damages. Projects that merely identify or analyze hazards or problems are not eligible.
The HIC does not solve a problem independently as defined in 44 CFR 206.434 (b)(4). The HIC is primarily geared towards public awareness, identifying potential hazards and informing residents on methods of risk reduction. It does not directly implement the mitigation measures it advocates. As with all public awareness campaigns, the HIC relies on the inconstant participation of the general public to implement recommended mitigation measures. In addition, the Hurricane Information Center will contribute to the dissemination of information to the public about methods of preparing for emergencies in the City ofVenice, however, it would not prevent or reduce recurring damages as defined under HMGP 44 CFR 206.434 (b) (5) (I-V).
Issue 2: Although the proposed project is in conformance with the 409 State Hazard Mitigation Plan, it must still meet other eligibility requirements under 44 CFR 206.434 (b)(l).
A State may include educational programs or materials in their State Hazard Mitigation Plan that may have benefits that are not easily quantified or which fall outside the eligibility guidelines for projects funded through the HMGP. These projects may be funded through other sources, including the HMGP 5% initiative. Projects that are considered for HMGP funding must contribute to the development of a long-term comprehensive mitigation program corresponding with the State Hazard Mitigation Plan and meet the eligibility requirements of the HMGP.
Issue 3: The Venice Integrated Neighborhood Emergency System (VINES) component of the proposal is geared towards emergency response, not mitigation.
The HIC would also house an early warning system, VINES, which is geared towards emergency response, not mitigation. It is unclear where the funds to house VINES are being derived from. Within the context of HMGP, mitigation measures are those projects that, over the long term, reduce the risk of repetitive loss and hardship so that the cost of response and recovery will be less in the future. Warning systems are not long-term solutions to the problem of hurricane damage. Projects such as this are more appropriately funded under the 5% initiative of the HMGP.