How to Write an RFP for a Hazard Mitigation Plan Update

FEMA gives a local hazard mitigation plan five years from the approval date in its letter. Let it lapse, and your jurisdiction can’t get FEMA mitigation project grants until a new plan is approved (44 CFR 201.6). Most updates are bought in a hurry, so most RFPs pay for a thicker document instead of a sharper strategy.

A hazard mitigation plan update is the five-year revision of a local plan that profiles natural hazards, assesses who and what is vulnerable, and sets prioritized actions with owners and funding sources. You need one before the current plan expires. The RFP succeeds when it defines done as a FEMA-approvable plan with an action list ready to fund.

The rules moved in 2025. FEMA reissued its Policy Guide (effective April 11) and Handbook (June), and the $1 billion BRIC round that closed July 23, 2026 stopped paying for planning.

What this work should deliver

The outcome is a plan FEMA approves on the first review, adopted by every participating jurisdiction, with actions specific enough to become grant applications.

Who this is for: counties, cities, towns and special districts updating a local plan under 44 CFR 201.6; regional planning agencies running a multi-jurisdictional plan; and tribal governments updating under 44 CFR 201.7. It is the wrong vehicle for an emergency operations plan or a stand-alone climate adaptation plan, though a good update feeds both. Our climate resilience planning hub covers that adjacent work.

FEMA’s requirements cover natural hazards, and the plan must justify leaving out any commonly recognized one. Human-caused hazards are optional and cost money; Huntingdon County, Pennsylvania added annexes for them in its 2024 RFP. Include them only if someone will use them.

An update is a different job from a first plan. Element E of the Policy Guide asks how development in hazard-prone areas changed vulnerability, the status of every action in the previous plan, and how the old plan reached other plans and programs. Action status is where updates stall; if nobody tracked the last plan’s actions, budget staff time to reconstruct them first.

Multi-jurisdictional plans carry a trap. FEMA dates approval from the first adoption it receives, every participant inherits that expiration date, and a town adopting more than a year after ‘Approvable Pending Adoption’ status must first confirm its information is current (Policy Guide, section 6.4.2). Late adopters lose part of their five years. In Maryland, our county risk profiles set FEMA’s risk scores beside each county’s mitigation grants, a quick check on your hazard ranking.

Rules and standards to cite

Name the regulation and the current policy by date, and tell bidders which edition governs.

• Regulation. 44 CFR 201.6 sets the required contents (planning process, risk assessment, mitigation strategy, maintenance, adoption) and a public comment opportunity during drafting. Tribes follow 44 CFR 201.7 and the Tribal Mitigation Plan Review Guide (December 2017), listed on FEMA’s regulations and guidance page.
• Policy. The Policy Guide (FP-206-21-0002) is FEMA’s official interpretation, and its Appendix A Plan Review Tool is the checklist reviewers apply. It superseded the edition released in April 2022, which took effect April 19, 2023.
• State standards. Element H covers state additions. Pennsylvania’s planning Standard Operating Guide governed Huntingdon’s RFP, and New York’s 2022 planning standards govern Erie County’s. Maryland plans pass through the Maryland Department of Emergency Management before FEMA, as Worcester County’s 2025 RFP spells out.
• Optional elements. Element G, on high hazard potential dams, matters only for FEMA’s dam rehabilitation grants. In the Community Rating System, the 2025 CRS Coordinator’s Manual credits a plan built on its 10-step process with up to 382 points under Activity 510; our flood risk management primer explains the program.
• Baseline data. FEMA’s National Risk Index covers 18 natural hazards by county and census tract (version 1.20, December 2025). It is a starting point, not a substitute for local loss records.

The change that matters most is the one templates miss. The edition in force from April 2023 required that probability of future hazard events include the effects of future conditions, including climate change (element B1-e); the 2025 edition deleted that sentence and every other mention of climate. The regulation still requires the probability of future events, and nothing stops you from asking for more.

Buyers are splitting. Worcester County’s October 2025 RFP asks bidders to assess the long-term effects of changing weather patterns on each hazard, which matters on a coast facing sea-level rise, while Erie County’s March 2026 RFP cites the superseded 2023 editions. Pick a position and write it down.

Sample scope of work

Adapt the bracketed items. The tasks follow the Policy Guide’s elements, so reviewers can map each deliverable to the Plan Review Tool.

1. Roles and schedule. FEMA’s Handbook is blunt that consultants facilitate and communities decide. Put that in the contract.

The Consultant shall facilitate the planning process and prepare plan content. The [County] and each participating jurisdiction shall decide all risk findings, goals, actions and priorities. Within 30 days of notice to proceed, the Consultant shall deliver a work plan and schedule that reserves at least six months for state and FEMA review.

2. Prior plan review. This is the Element E work that weak updates skip.

The Consultant shall document the status of every mitigation action in the current plan for each participating jurisdiction (completed, in progress, carried forward or dropped, with the reason), describe changes in development in hazard-prone areas since the last approval, and describe how the current plan was integrated into other plans and programs.

3. Engagement. The regulation requires a chance for public comment during drafting and before approval. Specify how many meetings, where, and in which languages; our guide to stakeholder engagement plans covers the design.

The Consultant shall prepare and carry out a public engagement strategy with at least [four] public meetings in [locations], an online comment period on the full draft plan, and materials in [English and Spanish]. The Consultant shall log every comment received and document how the plan responded to it.

4. Risk assessment. Say which hazards deserve depth and which can stay at the FEMA minimum. The method overlaps with a climate risk assessment; our hub on the topic collects data sources.

The Consultant shall profile each hazard’s location, extent, previous occurrences (including every federal and state disaster declaration since the last update) and probability of future events, using FEMA’s National Risk Index, [state] data and local records. For [riverine flooding, coastal flooding and extreme heat], the Consultant shall estimate how conditions projected for [2050] change probability and extent, naming the data source and scenario. The Consultant shall deliver exposure and loss analyses as editable GIS layers and spreadsheets.

5. Capabilities and mitigation strategy. Element C5-b requires funding sources more specific than ‘federal’ or ‘state.’ Make the consultant do that work.

The Consultant shall inventory each jurisdiction’s authorities, plans, codes, staff and funding, then facilitate goals and a range of mitigation actions that include at least one action per participating jurisdiction for each hazard. Each action shall name the responsible department, a funding program by name, a planning-level cost range, a defined timeframe and a priority score that weighs benefits against costs.

6. Maintenance and integration.

The Consultant shall prepare a maintenance schedule stating who will monitor, evaluate and update the plan and when, and shall identify, for each jurisdiction, the land use plan, capital improvement program and ordinance updates that will carry the plan’s findings.

7. Review, approval and adoption.

The Consultant shall submit the draft with a completed Local Mitigation Plan Review Tool citing page numbers for every element, make all revisions the State or FEMA requires at no added cost until FEMA issues ‘Approvable Pending Adoption’ status, and support each jurisdiction’s adoption with a draft resolution and briefing materials.

Deliverables to require

• Work plan and schedule, with state and FEMA review time shown separately.
• Engagement record: materials, attendance, a comment log and the plan’s response to each comment.
• Status table for every action in the previous plan, by jurisdiction.
• Hazard profiles and a vulnerability summary for each participant, with counts of NFIP repetitive-loss and severe repetitive-loss properties by type and no policyholder names or claim amounts; the Policy Guide won’t approve a plan that exposes them.
• Editable GIS layers, exposure and loss spreadsheets, and map files, which the Handbook tells buyers to write into the contract.
• Capability assessment tables for each jurisdiction.
• Mitigation action table with owner, named funding program, cost range, timeframe and priority.
• Jurisdiction annexes for multi-jurisdictional plans.
• Maintenance schedule and a list of the plans each jurisdiction will update with the findings.
• Completed Plan Review Tool with page references, plus a CRS 10-step crosswalk if you participate in the Community Rating System.
• Draft adoption resolution and a short briefing deck for each governing body.
• Final plan in editable Word and accessible PDF, with FEMA’s ‘Approvable Pending Adoption’ letter as the finish line. Worcester County holds its final payment until state and FEMA approval; copy that clause.

How to evaluate proposals

Published weights vary. Huntingdon County gave cost 10% and gave 5% to resources and consultant location; Worcester County gave price 30%. Location measures proximity, which says nothing about plan quality; score understanding of your hazards instead.

When federal money pays for the contract, the procurement standards at 2 CFR 200.317 through 200.327 apply. 2 CFR 200.320 requires the RFP to identify every evaluation factor and its relative importance, and to award to the proposal most advantageous with price and other factors considered. Qualifications-based selection without price is limited to architectural and engineering services, so confirm with your grants office before using it.

Two parts of 2 CFR 200.319 surprise buyers. A firm that drafted your specifications or statement of work must be excluded from competing, which can catch the consultant who wrote the scope in your grant subapplication. The section also lists excessive bonding among practices that restrict competition, so strip construction boilerplate such as performance bonds out of a planning RFP.

Interview the person who will run your meetings, and ask for FEMA’s review comments on a plan they took through approval.

Timeline

Work backward from expiration. Anne Arundel County’s current plan runs from September 8, 2025 through September 7, 2030, according to the county’s plan page; on FEMA’s schedule, the county’s next scope and funding request should be moving by 2028. Huntingdon County released its RFP on February 20, 2024 and required ‘Approvable Pending Adoption’ status by July 5, 2025, about 16 months later.

Budget and cost drivers

FEMA’s grant records give the best national benchmark. Of 1,162 local plan updates approved or funded for fiscal years 2020 through 2025 in OpenFEMA’s HMA subapplications data, the median total cost was $53,300, the middle half ran from $32,268 to $120,000, and the top tenth exceeded about $220,000. Those totals include the local match, which often counts staff time. Anne Arundel County’s fiscal 2022 BRIC subapplication for a plan update totaled $97,222 in the same data.

Recent awards sit inside that range. Fayette County, Georgia awarded its 2025 update for $24,000 in December 2024. Routt County, Colorado received four proposals and awarded $69,965 in March 2025, backed by a $70,433 BRIC grant at a 75% federal share, with $10,433 of the local share met through participants’ in-kind hours. Huntingdon County capped its 2024 multi-jurisdictional update, which added a dam analysis and two annexes, at $100,000 from a fiscal 2019 HMGP grant.

Federal money is narrower than it was. FEMA’s HMA guide generally pays up to 75% of eligible costs and lets HMGP recipients spend up to 7% of their ceiling on planning, yet the BRIC round FEMA opened on March 25, 2026 removed planning funding. GAO reports FEMA announced the end of BRIC in April 2025 and its restart in March 2026, and the program page lists that round as closed. Our resilience funding hub tracks other sources.

What moves the price:

• Participants. Each jurisdiction needs its own risk variations, actions, annex and adoption. Erie County’s update covers 45 partners.
• Analysis depth. The Handbook notes hazard profiles may not need detailed event databases or complex geospatial analysis. If you specify a Level 2 Hazus analysis, confirm you have the local building inventory it runs on.
• Optional scope. Future-conditions analysis, human-caused hazards, a dam element and a CRS crosswalk each add hours.
• Engagement. Meeting count, travel between towns, and translation.
• Your data. A current GIS building inventory and a tracked action list cut consultant hours; missing ones add them.
• Review rounds. Ask how many rounds of state and FEMA revisions a fixed price assumes.

Red flags in proposals

• Hazard profiles that could describe any county, or text still carrying another client’s place names.
• A finish line of ‘draft submitted to the state,’ with revisions billed as extra work.
• A vulnerability section that lists assets and stops. The Policy Guide says a list of assets without context is not sufficient.
• Action tables with ‘federal’ or ‘grants’ as the funding source, or with preparedness purchases counted as mitigation, which Element C4-b won’t credit.
• One public meeting at the end, or an online survey as the only engagement.
• No named plan for getting every jurisdiction to adopt.
• Staff hours weighted toward principals and document production, light on analysis and facilitation.

How we’d approach it

We would scope the action table first and the document second, since the actions are what a community funds. In our work with the Resilience Authority of Annapolis and Anne Arundel County on the Annapolis Maritime Resilience Initiative, 18 months of engagement with bilingual materials produced 38 resident-identified sites of concern, and 10 advanced to preliminary concept design, the level of detail an action needs before it becomes an application. Through Council Fire Labs we also built Resilient & Ready with the Resilience Authority to rank projects and match them to funding, the job Element C5 asks an action plan to document.