The Role of Local Capacity in Who Receives BRIC Funding

NRDC studied the relationship between local capacity and the ability to apply for the Building Resilient Infrastructure and Communities (BRIC) competitive funds in a previous analysis. We used the Climate and Economic Justice Screening Tool (CEJST), the National Risk Index (NRI), and the Rural Capacity Index (RCI) to evaluate the accessibility of BRIC grants to lower-capacity localities.

In the next phase of this analysis, we shifted our focus from who was able to apply for funding to who may have received the funds.

We closely looked at the list of BRIC's subapplicants to investigate if and how community characteristics (such as local capacity) are linked to receiving funding. BRIC, administered by the Federal Emergency Management Agency (FEMA), is participating in the Justice40 Initiative, which aims to prioritize investments in disadvantaged communities. Ensuring that BRIC's benefits are directed towards communities with the greatest need is essential for addressing inequities in resource allocation.

We used logistic regression for our analysis and compiled a list of subapplications across BRIC grant cycles 2020, 2021, and 2022, along with aggregated data from the three years combined. We then assigned each submitted subapplication to a county based on its title or description. While smaller geographical entities like cities or towns can also apply for BRIC funds, planning and funding decisions typically occur at the county level. This analysis is also at the county scale. We defined a variable based on the status of the submitted subapplications, indicating if a project was identified for further review or if it was rejected/withdrawn. Though "identified for further review" is not a final decision for funding and is not the same thing as receiving an award, it gave us a good understanding of which subapplications are more likely to be funded.

Similar to our previous assessment, we used the RCI, CEJST, and NRI indexes that help identify priority communities for resilience investment. We also included other variables to improve the accuracy of the models:

• Rural Capacity Index: Developed by Headwaters Economics based on 12 variables that serve as a proxy for local capacity, such as population change and voter turnout. This index is displayed as the national rank and higher values show higher capacity. While the Index is designed to highlight the capacity gap faced by rural communities, values are provided for the entire nation.
• Percentage disadvantaged area: The percentage of a county's area that is considered disadvantaged as defined by the Council on Environmental Quality in the CEJST. In this case, a higher value shows a larger area that meets the criteria to be considered disadvantaged. While this variable doesn't directly measure local capacity, it offers a broader picture of the community characteristics/disadvantages that could lead to reduced capacities in accessing federal grants.
• Social vulnerability score: The susceptibility of social groups to the impacts of hazards and is shown as percentiles where higher value means higher social vulnerability. This variable is a component of FEMA's NRI and is based on the Centers for Disease Control and Prevention (CDC)/ Agency for Toxic Substances and Disease Registry (ATSDR) Social Vulnerability Index. While this variable doesn't directly measure local capacity, it offers a broader picture of the community characteristics/vulnerabilities that could lead to reduced capacities in accessing federal grants.
• Population: The total population of a county, based on the 2020 US Census data.
• Total Expected Annual Loss (EAL) rate: The weighted average of the proportion of total economic value (including effects on people, agriculture, and buildings) expected to be lost annually for a community due to natural hazards. This value is a component of FEMA's National Risk Index.
• Number of major disaster declarations: The county's total number of major disaster declarations (excluding COVID-19) over the past 7 years preceding the grant cycle, consistent with BRIC's eligibility requirements.
• Existing BRIC allocation subapplication: A variable showing if there was at least one State/Territory Allocation funding subapplication within the county in the current or previous grant cycles.
• Funding requests for expensive projects: A variable indicating if the requested federal share amount from FEMA falls within the upper 90^th percentile of all federal shares requested during the grant cycle. This way we can account for BRIC's funding availability and its budget cap for that year.
• Per capita federal share amount requested: The amount of funding requested from FEMA per person, to accommodate the varying population sizes of counties.
• Federal cost share percentage: The percentage of federal cost share requested by subapplicants. Typically, BRIC's cost share is 75% federal and 25% nonfederal. Subapplicants may be eligible for an increase in cost share up to 90%.
• Small, impoverished subapplicants: A variable indicating if a subapplicant is small impoverished. Small, impoverished communities have "3000 or fewer individuals identified by the applicant that is economically disadvantaged, with residents having an average per capita annual income not exceeding 80% of the national per capita income." These communities are prioritized by FEMA grant programs and receive an increased federal cost share.

The Rural Capacity Index and the Outcomes of BRIC Grants

When using Headwater Economics' Rural Capacity Index, we found that in FYs 2020 and 2022 subapplications from counties with lower capacities were more likely to be selected for further review (We did not observe any relationship between local capacity and the distribution of BRIC grants in FY 2021). While this relationship was not particularly strong, it resonated with FEMA's increased focus on equity and directing more investment to disadvantaged communities. Also, being categorized as a small, impoverished community raised the chances of the subapplication being selected for further review in all our models. Though the definition of small, impoverished communities overlooks many low-income localities that struggle to compete for funding.

In the BRIC grant cycle of 2020, localities that requested higher federal share amounts and cost shares were less likely to have successful subapplications. Another interesting trend in FY 2020 grant distribution: Requesting funds for expensive projects had a positive relationship with the outcomes of BRIC's funding. This implies that when considerable amounts of funding were requested for mitigation projects, such projects were more likely to be selected for further review by the agency. This was not surprising to observe, as NRDC previously found that in FY 2020, 22 projects accounted for 75% of BRIC funding. Compared to the projects not selected, these projects were more expensive and had higher non-federal cost shares, which could also explain why projects with higher federal cost share requests were less likely to be successful that year.

The Climate and Economic Justice Screening Tool and the Outcomes of BRIC Grants

Next, we replaced RCI with the percentage of a county's area that is considered disadvantaged as defined by the Council on Environmental Quality. Like the trends we observed using RCI, these models showed that for FYs 2020 and 2022, the distribution of BRIC funds aligned with FEMA's equity goals: counties with a higher percentage of their area considered disadvantaged, were more likely to have at least one potentially successful subapplication. Also, regardless of which grant cycle we studied, being categorized as a small, impoverished community increased the likelihood of subapplications advancing to further review.

The National Risk Index and the Outcomes of BRIC Grants

Lastly, we used NRI's social vulnerability score to evaluate the outcomes of BRIC's competitive funds. We noticed a difference this time: In the previous models, we did not observe any relationship between local capacity and the distribution of BRIC's grant in FY 2021. But here, results showed that subapplications from counties with higher social vulnerabilities were more likely to be selected for further review in all three years. This may suggest that based on the social vulnerability score, BRIC grants have been directed to disinvested communities across all grant cycles and subapplicants from socially vulnerable counties may have been prioritized.

Implications

In this analysis, NRDC examined factors associated with the selection of BRIC competitive subapplications. Despite a shift towards a more equitable distribution of funds, we noticed varying trends for certain grant cycles when using different metrics to assess community characteristics. For example, using the Rural Capacity Index highlighted that in FYs 2020 and 2022, subapplications from counties with lower capacities were more likely to be selected for further review but this trend was not observed in FY 2021. Alternatively, when we used NRI's social vulnerability score, subapplications from socially vulnerable counties were more likely to be prioritized for funding across all three years, including FY 2021. This discrepancy highlights the limitations of relying on individual tools and emphasizes the importance of adopting a holistic approach to informed decision-making.

Overall, the findings reflect FEMA's increased focus on distributing grants equitably. While it is encouraging that the agency is taking steps to select more projects from disadvantaged communities, it may not support localities lacking the capacity to apply. FEMA can further advance its progress by simplifying the application processes and enhancing capacity-building and technical assistance support.

Notes:

In this analysis, significance levels are based on standard notations: *p≤.001, **p≤.01, *p≤.05, and +p≤.10. Additionally, not all existing statistically and marginally significant associations between variables have been elucidated in the findings sections. For more information on the analysis, feel free to contact us.

Additional resources:

1. Access to BRIC Funding May Depend on Where You Live

2. The BRIC Wall: Capacity Gaps Put FEMA Grants out of Reach
3. Building Resilience, BRIC by BRIC
4. Building Resilience, BRIC by BRIC: Summer 2022 Update
5. Building Resilience, BRIC by BRIC: Fall 2022 Update
6. Building Resilience, BRIC by BRIC: BRIC's Fourth Year

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