Local Hazard Mitigation Plans

Lead

Varies: typically involves city or county emergency services, fire department/district, or planning/community development department. Any office/agency designated by the local jurisdiction may lead.

Required Consultation, Review, and Approval 

• Consultation: N/A
• Review: Cal OES (Cities, Counties, and special districts)
• Approval: FEMA

Applicable Statutes and Rules

• Stafford Act: Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. §§ 5121-5208) 

• Code of Federal Regulations (CFR) Title 44, Sections 201.6 and 206 

• Federal Disaster Mitigation Act of 2000 (amended the Stafford Act) 

• Gov. Code, §§ 65302.6 and 8685.9 

Required Components

• The Stafford Act and FEMA Regulations at CFR Title 44, Section 201.6 specify requirements for LHMPs (See the Local Mitigation Planning Policy Guide for FEMA’s interpretation of these statutes and minimum requirements). 

• The LHMP must be updated every five years to continue FEMA funding eligibility, and communities must identify a schedule for reviewing the plan and incorporating updates in between five-year updates. (44 C.F.R. § 201.6 (c)(4).) 

• Required LHMP components with opportunities for alignment with other plans include:  

  • Documentation of the plan preparation and process,  

  • Natural hazard risk and vulnerability assessments,  

  • Mitigation strategies with prioritized projects,  

  • Community outreach and engagement,  

  • Incorporation of existing plans, studies, and reports,  

  • An assessment of the community’s existing mitigation capabilities,  

  • A plan maintenance and updating process, and  

  • Revisions that reflect changes in local development. 

• Local Mitigation Planning Policy Guide

• Local Mitigation Planning Handbook

• Local Hazard Mitigation Plans and CEQA Review Technical Advisory

• Develop climate adaptation strategies and actions that complement other hazard mitigation strategies when appropriate.

  • In coastal areas, the mitigation strategy section can consider all coastal hazards impacting the community. For example, coastal flood strategies can be designed to mitigate sea level rise as well as severe storm flooding and tsunamis. Mitigation could also include installation of tide gauges or other data collection measures to monitor sea level rise long-term. 

• Communicate with the State Hazard Mitigation Officer or Cal OES Hazard Mitigation Section early and often and stay up to date on State and Federal hazard mitigation resources. FEMA and Cal OES regularly provide funding, guidance, technical assistance, new resources, and training.  

• Allow ​​sufficient time for plan review by Cal OES and FEMA Region 9, and approval and adoption by your local government body. FEMA and Cal OES both recommend at least six months of lead-time to account for necessary review and approvals.  

• Conduct community engagement throughout the entire process of developing, implementing, or updating an LHMP.  

• The adoption of an LHMP could constitute a California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.) project if the document’s approval is determined to be a discretionary action that could result in a direct or reasonably foreseeable indirect physical change on the environment. Lead agencies may have to perform environmental review of subsequent revisions or updates to the LHMP as well. (See the State’s Technical Advisory on Local Hazard Mitigation Plans and CEQA Review). 

• BENEFITS OF ALIGNING A CEDS AND LHMP Businesses, new buildings and infrastructure, and economic investments are directed to safer, lower risk areas and are developed to be resilient to hazards,  Businesses and critical infrastructure and facilities are resilient to hazards and function throughout an emergency or are able to quickly continue operation afterward,  Economies and local and regional partners collectively diversify economic activities based on shared goals and actions, and are therefore more resilient.  Investment in the region improves due to overall reduction in area risks, and  Natural resources are managed to bolster resilience and support economic activity.  Comprehensive Economic Development Strategy and Hazard Mitigation Plan Alignment Resource Guide, Federal Emergency Management Agency and Economic Development Agency

  Consider reviewing the LHMP annually and after each disaster event to ensure the LHMP still reflects the needs of the community.  

• Consider aligning the LHMP and other resilience planning efforts with a Community Economic Development Strategy (CEDS). This could involve clarifying the geographies each plan covers; aligning planning activities, goals, and update cycles; combining planning teams, partnerships and public engagement when addressing shared topics; and aligning the LHMP risk and vulnerability information with the CEDS Strengths, Weaknesses, Opportunities and Threats (SWOT) analysis. For more guidance on aligning LHMPs and CEDS, see the Comprehensive Economic Development Strategy and Hazard Mitigation Plan Alignment Resource Guide. 

• Consider applying for a FEMA Hazard Mitigation Grant Program under the category “Planning Related Activities” or Building Resilient Infrastructure and Communities Grant Program under the category “Capability and Capacity Building Activities,” which includes hazard mitigation planning and planning related activities. Proposals to integrate other plans into an LHMP or the LHMP into other plans may be eligible under either program; FEMA usually does not fund proposals for other plans unless there is an LHMP integration component. 

(See Adaptation Pathways and Plan Alignment for an introductory overview of the Adaptation Pathways planning approach).

• An LHMP may be more appropriate for describing near-term strategies in detail than other local planning documents like the general plan or LCP. In their LHMP, jurisdictions should identify criteria for prioritizing actions, expected costs of each action, who is responsible for administering each action, and potential funding sources and expected time frames for completion of each action. LHMPs used to meet the safety element requirements of SB 379 (2015) must include feasible implementation measures (Gov. Code, § 65302, subd. (g)(4)(C)). LHMP’s may also be considered nimbler and more responsive to changing conditions than some plans due to FEMA requirements for annual reviews and regular updates (See the Local Mitigation Planning Policy Guide and Planning Handbook). 

• LHMP’s can identify low/no regrets actions that set the groundwork for future actions and build capacity. These could include conducting climate adaptation-related studies and information gathering, developing funding strategies, updating and integrating multiple plans, and other actions that the jurisdiction aims to make progress on by the next 5-year LHMP update. Findings from these tasks could inform future updates to the LHMP and other plans, as well as mid-term and long-term strategies. That said, LHMPs do not need to be completely overhauled every 5-years. Jurisdictions can choose to only address key areas that may have changed based on their circumstances.  

• A detailed approach to near-term strategies should always be balanced with longer term strategies and future climate risk, whether directly in the LHMP itself, or in alignment with other plans with long-term planning horizons. The LHMP mitigation strategy can identify a range of actions both near and long term. While they typically have a 5 or 10-year planning horizon, there is nothing precluding an LHMP from identifying longer-term needs and actions; jurisdictions should consider this approach. Regardless, near-term climate-adaptive mitigation strategies and measures that have long-term consequences, such as capital improvement projects, should be carefully considered and aligned with longer-term climate risks and adaptation goals. 

• A responsive pathways approach in an LHMP could involve planning thresholds and ongoing monitoring strategies. When evaluating alternatives in the mitigation strategy section, consider linking near-term climate adaptation measures in the LHMP with pre-determined threshold events or conditions, such as an established level, frequency or intensity of storms or coastal flooding over a given time period. When thresholds are passed, they could trigger subsequent actions or the initiation, implementation, or update of other plans. Future updates to the LHMP and other plans can also serve as a key threshold, where every time a plan is updated, the various strategy pathways are re-evaluated, compared against current conditions and new information, and more closely integrated with other plans. 

• Review FEMA LHMP guidance to understand the risk assessment process. Risk assessments must include the following, among other things: 

  1. Information on previous occurrences of hazard events and on the probability of future hazard events, and an overall summary of each hazard and its impact on the community (44 C.F.R. § 201.6(c)(1)-(2)). 

  2. A review of FEMA National Flood Insurance Program insured structures that have been repetitively damaged by floods (44 C.F.R. § 201.6(c)(2)(ii)). 

  3. The risk assessment section should assess each jurisdiction’s risks where they vary from the risks facing the entire planning area, and include a description of the type, location and extent of all natural hazards that can affect each jurisdiction (44 C.F.R. § 201.6(c)(2)(i)). 

• Combine hazard mitigation capability assessments and climate change adaptive capacity assessments when appropriate. Both capability assessments and adaptive capacity assessments evaluate authorities, policies, programs, staff, funding, and other resources available to accomplish mitigation both within the lead agency and across the community.  

• Address climate risk and resilience in each hazard profile and/or as a standalone section or appendix in the LHMP risk assessment. The LHMP risk assessment must include the probability of future events, including the effects of climate change and other future conditions on the type, location and range of anticipated intensities of identified hazards. Jurisdictions must also describe how climate change will affect impacts from hazards facing the community (Local Mitigation Planning Policy Guide).  

• The risk, vulnerability, and capability assessments of an LHMP describe weaknesses, threats, strengths, and opportunities of a community or region that can also be addressed in the SWOT analysis required of CEDs and inform the development trajectories outlined in local area plans. Moreover, identifying high-risk areas can help inform where to prioritize future economic development and avoid conflicts between local economic development and hazard mitigation goals, priorities, and policies. For additional tips on aligning LHMP assessments with CEDS SWOT analyses, see Comprehensive Economic Development Strategy and Hazard Mitigation Plan Alignment Resource Guide. 

Wildfire

• Use data sources consistent with those listed in the Fire Hazard Planning Technical Advisory to align the LHMP risk assessment with the wildfire and climate change vulnerability assessment requirements of the Safety Element.

Flood-After-Fire

• Assess post-fire effects of flooding, debris flows, and mud flows. Utilize risk assessment tools that consider current flood and debris flow hazards, as well as risk under modeled future climate conditions. Consider flood effects as a cascading or compounding hazard following wildfire, where previous occurrences may not be an accurate assessment of future risk.  

• Incorporate geospatial data on critical infrastructure and drinking water supplies into risk assessments. This incorporation allows for strategies to address the possibility that burn scars occur within or upstream from water supplies.

Coastal Hazards

• Align the LHMP risk assessment and the climate change vulnerability assessment requirements of the safety element (Gov. Code, § 65302), which require similar types of information. When assessing sea level rise risk and other coastal hazards, complement historic data and current FEMA flood data with those listed in the State of California sea level Rise Guidance to evaluate storm-related coastal flooding, sea level rise and shoreline change, and both current and future impacts. FEMA flood maps do not include forward-looking projections of sea level rise or other climate change impacts, so complementing these data with sources recommended by OPC will provide more accurate risk assessment results for future conditions.  

• Incorporate the most recently updated LHMP into the Safety Element. Assembly Bill (AB) 2140 (Gov. Code §§ 65302.6 and 8685.9) allows jurisdictions to be eligible to apply for state funding to cover the local match (6.25%) of FEMA Public Assistance (PA) costs for recovery activities after hazard events, if the local jurisdiction incorporates their LHMP into the Safety Element of their General Plan.

• Synchronize LHMP and Housing Element updates with Safety Element updates, when possible, to leverage the process and reduce redundancy across all three efforts, especially when communities have an LHMP update due proximal to their next Housing Element update. Recently updated LHMPs can be used as a resource for a subsequent Safety Element review or update.

Wildfire

• CAL FIRE provides review and direct support for the development and submittal of Community Wildfire Protection Plans (CWPPs).

• Update CWPP’s every five years to match the LHMP update timeline and maintain best available information on wildfire risk and resilience. Aligning these timelines will also allow jurisdictions to maintain eligibility for both National Fire Plan funds and FEMA Hazard Mitigation Assistance grants. 

• Use a FEMA mitigation planning grant to develop or update significant portions of a CWPP while updating the LHMP. 

• For jurisdictions in the Coastal Zone, when developing or updating a Local Coastal Program leverage the wildfire information included in the LHMP to meet the wildfire planning requirements of the Coastal Act (Public Resources Code § 30253).

• Multiple integration pathways are possible between a CWPP and LHMP and/or other plans. Possible pathways to integrate the plans include but are not limited to:

  • Incorporate the entire CWPP. Communities can develop a standalone CWPP and include the plan as either a separate volume or chapter in the LHMP. 
  • Use sections of the CWPP. The CWPP maps and Risk Assessment may become the basis for the Wildfire Hazard Profile in an LHMP. The CWPP Priorities and Action Plan could be incorporated into the goals, strategies, and actions of the LHMP. 
  • Develop a single, unified plan that meets both plans’ requirements. Chart a project course that meets CWPP and LHMP planning process and content requirements.
  • Maintain separate, but aligned, plans between jurisdictions. Jurisdictions with different but overlapping boundaries may find it most useful to maintain separate plans that leverage the same information, resources, and processes when appropriate.

​​​​​​Flood-After-Fire

• Utilize post-fire assessments by the California State Watershed Emergency Recovery Teams (WERTs) to identify types and locations of threats to life-safety and property, gauge burn intensity, and develop preliminary emergency protection measures. Identify opportunities where these strategies can be modified based on these assessments and recommendations.

Coastal Hazards

• Look for inconsistencies between LCP policies and local hazard mitigation plan actions (e.g., building height limits versus elevation requirements; armoring restrictions versus shoreline armoring). Including sea level rise hazard avoidance strategies from an LCP certification or update, such as relocation of critical facilities, in the LHMP narrative can make them eligible for FEMA project implementation funding. This information can also be added as an addendum/annex to the LHMP, if the LHMP was recently updated. 

• While developing or updating an LHMP to incorporate sea level rise adaptation strategies, link to flood and natural infrastructure resilience strategies in the LCP and general plan. 

• Where transportation infrastructure functions as part of emergency evacuation routes, local governments can coordinate with transportation asset managers and emergency response planners to ensure consistency between LHMPs, LCPs, emergency operations plans, transportation and mobility plans, and general plan evacuation planning requirements (Gov. Code, §§ 65302 and 65302.15). This could involve developing contingency plans and alternative routes to utilize when infrastructure is inoperable due to coastal flooding and/or erosion.

• Meet FEMA eligibility requirements by identifying all jurisdictions and entities involved in the planning process. To meet minimum eligibility requirements, LHMPs must outline each jurisdictions’ representative, and additional entities must include local and regional agencies involved in hazard mitigation, agencies that have the authority to regulate development, neighboring communities, representatives of business, academia, and other private organizations, and representatives of nonprofit organizations, including community-based organizations, that work directly with and/or provide support to underserved communities and socially vulnerable populations, among others.

• To foster ongoing alignment and support implementation for economic and hazard resilience, include community economic developers in the alignment team or local/regional task forces developed for the purpose of resilience planning. 

• Consider carefully whether your alignment (planning) team or advisory groups should include any of the entities from each of these entity types, as applicable to your jurisdiction. Develop a plan to determine how and when to engage different entities to achieve the most equitable and accurate results.