Independent FEMA Public Assistance resource. Not affiliated with FEMA.Start hereReform trackerContact
Get technical assistance
Home / Laws & Policy / PAPPG Explorer / Appendix J
PAPPG v5.0 · Appendix J · pages 312–316

Cost-Effective Hazard Mitigation Measures

FEMA’s list of mitigation measures it treats as cost-effective without a separate benefit-cost analysis, as long as they cost no more than the eligible repair. Use it to build stronger when repairing culverts, bridges, roads, utilities, power systems and buildings. Each section lists the pre-approved measures in plain language, with the PAPPG pages.

5 topicsUp to 100% of the repair costNo separate benefit-cost analysisEHP rules still apply
Jump to a part of the chapter
Appendix J › VIII. Buildings and Structures

What mitigation can we add when repairing a damaged building?

Mitigation for buildings and structures
pp. 315–316
Short answer
Roof upgrades (hurricane clips, fully adhered coverings, hip framing), stronger doors, windows, impact glass and shutters, elevation or floodproofing, underpinned footings, stronger siding and vents, interior and furnishing bracing, permeable pavement, wildfire defensible space and non-combustible materials, and tornado or hurricane safe rooms built within the damaged facility’s footprint.
What FEMA requires
  • Anchor small support buildings at risk of uplift or rollover.
  • Elevate, wet floodproof or dry floodproof buildings, including flood barriers and nature-based measures such as rain gardens, bioswales and wetlands.
  • Underpin footings undercut by scour; use stronger siding with stronger attachments; replace vents with water-resistant vents.
  • Brace non-structural components (interior walls, partitions, parapets, veneer, light fixtures, drop ceilings, soffits) and secure replaced furnishings.
  • Outside the wildland-urban interface (where building code policy already requires them), create defensible space and use non-combustible materials for facilities with wildfire risk.
  • Roofs: compatible, corrosion-resistant clips and connectors; strengthen corners, soffits, overhangs and openings; fully adhered low-slope coverings (no loose-laid membranes or ballast); hip framing in place of gable ends; upgraded gutters and downspouts.
  • Doors and windows: better weather stripping; wind-resistant doors, frames and hardware; stronger windows; impact-resistant glass; shutters for critical facilities, debris-exposed lower floors, high-value-content buildings, or buildings near likely debris sources.
  • Replace impervious paving with permeable pavement, including aggregate and geotextile layers.
  • Safe rooms must be within the footprint of the facility being repaired and meet FEMA P-361.
<table class="pt-table"><thead><tr><th>Building element</th><th>Pre-approved measures</th></tr></thead><tbody><tr><td>Whole building</td><td>Anchor small support buildings; elevate, wet or dry floodproof; underpin scoured footings</td></tr><tr><td>Walls and openings</td><td>Stronger siding, water-resistant vents, wind-resistant doors and hardware, stronger windows, impact-resistant glass, upgraded weather stripping</td></tr><tr><td>Shutters</td><td>Critical facilities, lower floors exposed to debris, buildings with high-value contents, or buildings near likely debris sources</td></tr><tr><td>Roofs</td><td>Hurricane clips and connectors, stronger corner and overhang zones and openings, fully adhered low-slope coverings, hip framing in place of gable ends, better gutters and downspouts</td></tr><tr><td>Interiors</td><td>Brace walls, parapets, ceilings and light fixtures; secure furnishings</td></tr><tr><td>Site</td><td>Permeable pavement; defensible space and non-combustible materials (outside the wildland-urban interface)</td></tr><tr><td>Safe rooms</td><td>New or prefabricated tornado or hurricane safe room within the damaged facility’s footprint, meeting FEMA P-361</td></tr></tbody></table>
Documentation

Designs and specifications for the building measures; for safe rooms, designs meeting FEMA P-361 criteria within the footprint of the damaged facility.

Watch out · Govstar advice
FEMA won’t fund mitigation with loose-laid roof membranes or loose ballast stones, which become projectiles in high winds. Specify a fully adhered system if you want the roof upgrade covered.
PAPPG v5.0 pp. 315–316 · FEMA P-361
Read this in the PAPPG
Appendix J › III–VII MEP Components; Pipes; Water/Wastewater; Electric Power; Storage Tanks

What mitigation can we add to utilities, pipes, pumps, power systems and building equipment?

Mitigation for mechanical, electrical, plumbing, pipes, water and wastewater, power systems and storage tanks
pp. 314–315
Short answer
Elevating or floodproofing electrical panels, HVAC, generators and fuel tanks; generator hookups and transfer switches; seismic bracing; flexible and restrained pipe joints and shut-off valves; submersible pumps; watertight sewer covers and sealed well heads; stronger power poles, elevated transformers, surge protection and redundant service to critical facilities; and anchored storage tanks.
What FEMA requires
  • Mechanical, electrical, plumbing: seismic bracing for lines, conduit, piping, ductwork and water heaters; anchor roof-mounted equipment through a continuous load path; elevate or dry floodproof vulnerable components such as controls, panels, HVAC and machinery rooms, generators and fuel tanks, or use submersible-rated equipment where wiring can’t be elevated; install switches, circuit isolation, quick connects, camlocks, transfer switches and panels for backup power.
  • Pipes: joint restraints, flexible connections or more ductile pipe; continuous lining or encasement; shut-off valves to isolate damaged underground sections.
  • Water and wastewater: replace inundated pumps with submersible or inline pumps; elevate sewer access covers to the hydraulic grade line or use watertight frames and covers; seal well casings or raise well heads; buttress raw water intakes.
  • Electric power: looped or redundant service to critical facilities (not grid capacity expansion); surge suppressors and lightning arrestors; elevate pad transformers above base flood elevation; support pole transformers with multiple poles; replace poles with higher-rated poles (preferably two classes stronger) with guys and anchors; cross-brace H-frame poles; add guy-wires.
  • Storage tanks: anchor or stiffen base connections; install self-initiating disconnects and shut-off valves.
<table class="pt-table"><thead><tr><th>System</th><th>Pre-approved measures</th></tr></thead><tbody><tr><td>Mechanical, electrical, plumbing</td><td>Seismic bracing; secure roof equipment against wind; elevate or dry floodproof panels, HVAC, generators and fuel tanks; backup power connections, camlocks and transfer switches</td></tr><tr><td>Pipes</td><td>Joint restraints, flexible connections, more ductile pipe; continuous lining or encasement; shut-off valves on underground pipes</td></tr><tr><td>Water and wastewater</td><td>Submersible or inline pumps; elevated or watertight sewer access covers; sealed or raised well heads; buttressed raw water intakes</td></tr><tr><td>Electric power</td><td>Looped service or redundancy to critical facilities; surge suppressors and lightning arrestors; elevated pad transformers; multi-pole transformer support; higher-rated poles with guys and anchors; H-frame cross-bracing; added guy-wires</td></tr><tr><td>Storage tanks</td><td>Anchor or stiffen base connections; self-initiating disconnects and shut-off valves</td></tr></tbody></table>
Documentation

Equipment specifications, elevation or floodproofing designs, pole class ratings, and drawings for bracing, anchoring or redundant service.

Watch out · Govstar advice
Generator hookups (camlocks and transfer switches) are inexpensive and pay off in the next outage. Add them to any damaged critical facility’s electrical repair scope.
PAPPG v5.0 pp. 314–315
Read this in the PAPPG
Appendix J › II. Transportation Facilities; IX. Signage

What mitigation can we add when repairing bridges, roads, pier ramps and signs?

Mitigation for bridges, roads, railways, pier ramps and signage
pp. 313, 316
Short answer
For bridges: low-water crossings where traffic is light, restraint cables, uplift tie-downs and abutment protection. For pier ramps: open or floating decking with tie-downs. For roads and railways: stabilized shoulders and embankments and geotextile drainage blankets. For signs: stronger panels, supports and fasteners.
What FEMA requires
  • Bridges: replace with low-water crossings where traffic counts are low; install cables to keep bridges on piers or abutments in floods or earthquakes; install girder and deck uplift tie-downs; install longitudinal peaked stone toe protection with planting upstream of a failed abutment, or similar solutions such as engineered logjams, log vanes or bendway weirs.
  • Marine pier ramps: if attached to decking, install open or floating decking with uplift-resistant tie-downs and fasteners.
  • Roads and railways: where shoulders are prone to overflow, stabilize shoulders and embankments with geotextile fabric (erosion control blankets or turf reinforcement mats) and revetments.
  • Roads: use geotextile drainage blankets between the pavement section and subbase.
  • Signs: replace panels and supports with a stronger system, including multiple posts and stronger panels and fasteners.
<table class="pt-table"><thead><tr><th>Facility</th><th>Pre-approved measures</th></tr></thead><tbody><tr><td>Bridges</td><td>Low-water crossings where traffic is low; restraint cables; girder and deck uplift tie-downs; stone toe protection with planting, engineered logjams or log vanes at failed abutments</td></tr><tr><td>Marine pier ramps</td><td>Open or floating decking with uplift-resistant tie-downs</td></tr><tr><td>Roads and railways</td><td>Stabilize shoulders and embankments with erosion control blankets, turf reinforcement mats and revetments</td></tr><tr><td>Roads</td><td>Geotextile drainage blankets between pavement and subbase</td></tr><tr><td>Signs</td><td>Stronger panels and supports, multiple posts, stronger fasteners</td></tr></tbody></table>
Documentation

Traffic counts for low-water crossing proposals, bridge and roadway designs, and specifications for the strengthened components.

Watch out · Govstar advice
Federal-aid roads and bridges usually fall under FHWA’s Emergency Relief program, not FEMA PA, so confirm the facility is FEMA-eligible before planning mitigation on it.
PAPPG v5.0 pp. 313, 316
Read this in the PAPPG
Appendix J › I. Drainage Structures

What mitigation can we add when repairing culverts and drainage structures?

Mitigation for drainage structures and culverts
pp. 312–313
Short answer
Larger or multiple culverts, headwalls and other entrance and exit structures, erosion protection (including vegetated solutions), realignment, extended discharges, debris barriers and relief culverts. A hydrologic and hydraulic study is required in flood hazard areas, where floodplains, listed species or fish habitat could be affected, or for Clean Water Act compliance.
What FEMA requires
  • PA and EHP staff decide whether a hydrologic and hydraulic study is needed. You must submit one when the facility is in a special flood hazard area; there may be adverse floodplain impacts; there may be impacts to listed species, critical habitat or essential fish habitat; or it’s needed to show Clean Water Act compliance.
  • Replacement structures must be considered as part of the total drainage system, using existing local drainage criteria for sizing.
  • Erosion control can include headwalls, wingwalls, flared aprons, energy dissipators, gabions, rip rap, concrete, crushed rock, sheet piling, geotextile fabric (for roads paved before the event), and vegetated measures such as live fascines, vegetated geogrids, live crib walls, brush mattresses and root wads.
  • Culverts may be realigned or relocated, have discharges extended beyond the embankment toe, and get debris barriers, fins or barrier risers. A relief culvert can provide an alternate flow path.
<table class="pt-table"><thead><tr><th>Measure</th><th>Examples</th></tr></thead><tbody><tr><td>Larger or multiple structures</td><td>Upsize using local drainage criteria, considering the whole drainage system</td></tr><tr><td>Entrance and exit structures</td><td>Headwalls, wingwalls, flared aprons, energy dissipators</td></tr><tr><td>Bank and erosion protection</td><td>Gabions, rip rap, concrete, sheet piling, geotextile, vegetated or bioengineered solutions, bioswales and rain gardens</td></tr><tr><td>Culvert alignment</td><td>Realign or relocate to match water flow</td></tr><tr><td>Discharge extension</td><td>Extend the outlet past the toe of the embankment</td></tr><tr><td>Debris control</td><td>Debris barriers, fins or barrier risers</td></tr><tr><td>Relief culvert</td><td>A second culvert above the main flow line or upstream</td></tr></tbody></table>
Documentation

A hydrologic and hydraulic (H&H) study when required; local drainage criteria used for sizing; and designs for entrance and exit structures, erosion protection or realignment.

Watch out · Govstar advice
Upsizing a culvert without an H&H study can push flooding downstream and fail EHP review. Order the study early when the site is in a flood zone or near sensitive habitat, because it controls the culvert size.
PAPPG v5.0 pp. 312–313
Read this in the PAPPG
Appendix J › Introduction

Which mitigation measures does FEMA treat as cost-effective without a separate analysis?

Cost-effective PA hazard mitigation measures (100 percent rule)
p. 312
Short answer
The measures listed in Appendix J are treated as cost-effective if they cost no more than 100 percent of the eligible repair cost, measured before insurance reductions. They still must meet the hazard mitigation rules in Chapter 8 and EHP requirements. If a code or standard already requires the measure, it is part of the repair and needs no cost-effectiveness review at all.
What FEMA requires
  • Measures in Appendix J are cost-effective if they do not exceed 100 percent of the eligible repair cost, before any insurance reductions.
  • They must meet all eligibility requirements in the Hazard Mitigation section of Chapter 8.
  • Where codes or standards require the measure, it is completed as part of the PA repair project with no additional cost-effectiveness evaluation. Resilience beyond the code requirement is PA mitigation.
  • All measures must comply with EHP laws, regulations and executive orders.
Documentation

The eligible repair cost (before insurance reductions), the mitigation measure’s cost, a description showing it matches a measure in Appendix J, and EHP compliance information.

Watch out · Govstar advice
Check codes and standards first. A measure the code requires is funded as part of the repair, which is simpler than treating it as mitigation; only resilience beyond what the code requires counts as 406 mitigation.
PAPPG v5.0 p. 312 · 44 CFR 206.226(d)
Read this in the PAPPG
Govstar summarizes FEMA’s Public Assistance Program and Policy Guide, version 5.0 Amended, for disasters declared on or after January 6, 2025. “Watch out” notes are Govstar practitioner advice, not FEMA policy. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.