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Grant Management for High Hazard Potential Dam Awards

Accepting Funds

Using Funding

Risk Prioritization

State Administrative Plan

Scope of Work

Environmental & Historic Preservation

Failure to Complete

After the recipients of the High Hazard Potential Dam Grant (HHPD) have been announced, then the process of grant management begins. Learn about the steps, timelines and responsibilities.

Accepting the Award

After FEMA announces the selections, applicants have 60 days to accept award.

The period of performance (PoP) is determined in the NOFO. Extensions to the initial PoP identified in the award will be considered through formal, written requests to FEMA and must contain specific and compelling justifications as to why an extension is required. 

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There is a 90-day limit for the required amendment and SOW change after the date the award is accepted. Please refer to the NOFO for this deadline and details on other applicant deadlines.

Using the Grant Funds

The awarded HHPD funds must result in a completed HHPD Grant Program project, which may include technical, planning, and design, activities toward the repair, removal of rehabilitation of a high hazard potential dam.

Any modification to a dam must improve the safety of the dam. If the project is phased due to financial reasons, sequencing of the work must not compromise the integrity of the dam.

A grant under this program should not exceed the lesser of:

  • 12.5 percent of the total amount of funds made available; or
  • $7.5 million

Additional Funding

HHPD funding is limited and is based on a formula established in statute.  No additional funds will be awarded after all recipients have accepted their awards. 

The recipient may work with the FEMA Program Office to scale back the project. Any costs to complete a project that are above the federal share are the responsibility of the grant recipient or subrecipient.

State Administrative Plan

At a minimum, the State Administrative Plan describes the state capabilities to comply with all federal grant regulations, manage and monitor subrecipients, and manage project schedule and reporting. The State Administrative Plan must include the items listed below.

  • Designation of the State Administrative Agency (SAA) responsible for program administration.
  • Identification of the state official responsible for all matters related to the High Hazard Potential Dam Rehabilitation Grant Program.
  • Timely submission of HHPD quarterly performance progress reports on approved projects.
  • Determination of staffing requirements and sources of staff necessary for administration of the program.
  • If applicable, the establishment of procedures as a Pass-Through Entity:
    • Identify, select, and notify potential subrecipients of the availability of the program.
    • Ensure that potential subrecipients are provided information on the application process, program eligibility, including the requirement for a FEMA-approved mitigation plan that includes all dam risks, and key deadlines.
    • Determine subrecipient eligibility, including the requirement for a FEMA-approved mitigation plan.
    • Submit revisions or amendments for FEMA review and approval. See Section F.2, Pass-Through Requirements.
    • Conduct environmental and floodplain management reviews.
    • Establish priorities for selection of projects.
    • Process requests for advances of funds and reimbursement.
    • Monitor and evaluate the progress and completion of the selected projects.
    • Review and approve cost overruns.
    • Process appeals.
    • Provide technical assistance as required to subrecipient(s) including coordination with State Hazard Mitigation Officer regarding the eligibility requirement to have a FEMA-approved mitigation plan that includes all dam risks and complies with the Disaster Mitigation Act of 2000 (Public Law 106–390; 114 Stat. 1552).  For more information on the Mitigation Plan Requirements, see current NOFO for specific criteria.
    • Comply with the administrative and audit requirements of 2 CFR parts 200 and 3002.

Defining the Scope of Work Package

The required Scope of Work Package must describe how funds will be used to advance priorities and performance goals. Goals and objectives must be clearly defined. The process for selecting subrecipients must also be described.

After funds are received, the Scope of Work Package in the award must be amended to:

  • Include a detailed scope of work, cost estimate, and timelines and milestones for implementing the HHPD grant for each subrecipient.
  • Clearly identify how the SAA proposes to meet the performance metrics identified in the NOFO.

Environmental and Historic Preservation (EHP)

Screening Form

Grant recipients are responsible for completing the Environmental and Historic Preservation (EHP) Screening Form (FEMA Form 024-0-1) for all HHPD projects that physically affect the environment (such as coring or trenching for site analysis).

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Contact the FEMA Grant Program EHP staff if you're unsure if you're required to submit the screening form.

At a minimum, the following information is required on the HHPD Grant Program EHP Screening Form:

  • Clear description of the project
  • Project location – address or latitude/longitude
  • Labeled, ground-level photos of the project area
  • Aerial photo(s)
  • Construction date(s) for any buildings/structures (including dam structures) involved in the project
  • Extent (length, width, depth) of all ground disturbance
  • Other pertinent EHP info (e.g., environmental studies/surveys, permits in-hand, etc.)

Conducting a Review

An EHP review is an analysis of project information to determine whether a project may have the potential to impact environmental or historic/cultural resources. Complex projects may require more information and/or time for EHP review.

EHP Review Requirements

  • All projects funded with federal grant dollars must comply with EHP laws, regulations, and Executive Orders.
  • FEMA may be required to consult with state/territory or federal environmental agencies to determine impacts on environmental or historic/cultural/resources.
  • EHP review must be completed by FEMA before initiating any work on any FEMA- funded project, even if a previous award/year/program/project has an approved EHP review.
  • EHP review is required for the entire project (including cost share items) prior to starting the project.
  • EHP review is to ensure compliance with EHP laws – not to deny projects
  • Some projects may need to be modified to meet FEMA’s EHP responsibilities
  • Costs of EHP review (e.g., archeological surveys, reports, etc.) are paid by the grant recipient and can be part of grant expenditures.
  • EHP reviews are conducted by FEMA EHP staff and may require additional coordination and information-sharing between FEMA and the grant recipient.
  • Projects that include consultation with other resource agencies may require longer review times to complete.

Failing to Complete the Project

The HHPD Grant Award may be terminated in whole or in part by FEMA or the pass-through entity if the subrecipient fails to comply with the terms and conditions of the award, for cause, with consent of the non-federal entity when all parties agree with the termination conditions, or by the non-federal entity upon sending to FEMA or the pass-through entity written notification of the termination including the reason for the termination.

If a project is terminated because a subrecipient fails to complete the project or fails to proceed in an appropriate manner, the subrecipient may appeal the decision.

  • The subrecipient must send information for reconsideration to FEMA Headquarters within the time specified in the notification from FEMA.
  • A FEMA decision will uphold or overturn a decision regarding an award based on information provided by the pass-through entity and subrecipient, and application, award, and subaward management records collected by FEMA.
  • FEMA will reconsider determinations of noncompliance, additional award conditions, or its decision to terminate a federal award.