Attachment A- South Dakota Enhanced Plan Review Tool.pdf

FEMA Region 8 | State of South Dakota Enhanced Hazard Mitigation Plan

State Mitigation Plan Review Tool The State Mitigation Plan Review Tool (Plan Review Tool) demonstrates and documents how the state mitigation plan meets the regulations set forth in 44 CFR Part 201 and offers FEMA mitigation planners an opportunity to provide feedback to the state.

The Regulation Checklist must be completed by FEMA. The FEMA Plan Approver must reference the

State Mitigation Planning Policy Guide when completing the Plan Review Tool. The purpose of the checklist is to identify the location of relevant or applicable content in the plan by element/sub-element and to determine if each requirement has been “Met” or “Not Met.”

The Required Revisions summary at the bottom of each element must clearly explain the revisions that are required for plan approval. Required revisions must be explained for each plan sub-element that is “Not Met.” Sub-elements should be referenced by the appropriate number, where applicable

(e.g., S2-a, S2-b). Requirements for each element and sub-element are described in detail in

Sections 3 and 4 of the State Mitigation Planning Policy Guide.

The HHPD section and FMAG sub-elements only need to be completed if the state is pursuing eligibility for those grant programs.

The Plan Assessment must be completed by FEMA. This assessment provides more comprehensive feedback to the state to acknowledge where the plan exceeds minimum requirements and provides suggestions for improvements. FEMA will describe the strengths that are demonstrated and highlight examples of best practices. FEMA’s suggestions for improvement are not required to be made for plan approval.

For greater clarification of the elements in the regulation checklist, please see Sections 3 and 4 in the State Mitigation Planning Policy Guide. This document defines terms and phrases used within this review tool.

Attachment A

1. Plan and Review Information

Plan Information

State South Dakota

Title and Date of Plan 2024 State of South Dakota Enhanced Hazard Mitigation

Plan

February 12, 2024

Plan Update Version 2024

State Point of Contact Name Jim Poppen

Title Mitigation Branch Chief/State Hazard Mitigation Officer

Agency South Dakota Office of Emergency Management

Address 118 W. Capitol Ave., Pierre, SD 57501

Phone Number 605-773-3231

Email Jim.Poppen@state.sd.us

Meets mitigation planning requirements for HHPD?

Yes

Meets mitigation planning requirements for FMAG?

Yes

Review Information

Date Received by FEMA region February 12, 2024

FEMA Reviewer (Planning) Logan Sand, Community Planning Section

Chief

Rob Pressly, Community Planner

Melissa Ryder, Community Planner

Brooke LaPlaca, Planning Program Analyst

FEMA Reviewer (HMA) Patrick Boas, HMA Specialist

Christy Weiser, HMA Specialist

FEMA Reviewer (Technical Assistance) Katherine Baum, BRIC Technical Assistance

Section Chief

FEMA Reviewer (FM&I) Rob Liska, FM&I Specialist

FEMA Reviewer (Risk MAP) Madeleine Pluss, Management and Program

Analyst

FEMA Reviewer (Engineering) Luis Andrade, General Engineer

FEMA Reviewer (HHPD) Rich Hansen, Grants Management Specialist

FEMA Reviewer (Earthquake Program) Sean McGowan, Earthquake Program Manager

FEMA Reviewer (Building Sciences) Rob MacKay, Civil Engineer

FEMA Reviewer (EHP) Bridget Mehaffey, Environmental Protection

Specialist

Plan Status (Not Approved, Approvable Pending

Adoption, Approved)

Not Approved; 3/14/2024

Approvable Pending Adoption; 4/11/2024

Approved; 4/17/2024

SUMMARY YES NO

STANDARD STATE MITIGATION PLAN

Does the plan meet the standard state mitigation plan requirements? ☒ ☐

ENHANCED STATE MITIGATION PLAN

Does the plan meet the enhanced state mitigation plan requirements? ☒ ☐

2. Standard State Mitigation Plan Regulation Checklist

PLANNING PROCESS

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

S1. Does the plan include a description of the process used to develop the plan? [44 CFR §§ 201.4(b) and 201.4(c)(1)]

S1-a. Does the plan describe the current process used to update the plan, including how the plan was prepared, the schedule or time frame, specific milestones and activities, the agencies and stakeholders who were involved in the process, and if the mitigation planning process was integrated to the maximum extent possible with other state planning efforts?

Section 2 (p2-1 to 2-9)

Met

S2. Does the plan describe how the state coordinated with other agencies and stakeholders? [44 CFR §§ 201.4(b) and 201.4(c)(1)]

S2-a. Does the plan describe how the state coordinated with other state agencies, appropriate federal agencies, and other stakeholders, and how they were involved in the process?

Section 2.2 (p2-

2 to 2-4)

Met

Planning Process Required Revisions:

Click or tap here to enter text.

HAZARD IDENTIFICATION AND RISK ASSESSMENT

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

S3. Does the risk assessment include an overview of the type and location of all natural hazards that can affect the state? [44 CFR §

201.4(c)(2)(i)]

S3-a. Does the plan include a current overview of all natural hazards that can affect the state, including the type, location and previous occurrences?

Section 3.1 (p3-1 to 3-14) and 3.3

(p3-35 to 3-259, esp. Hazard

Description, Location, and Past

Events subsections)

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

S4. Does the risk assessment provide an overview of the probabilities of future hazard events? [44 CFR § 201.4(c)(2)(i)]

S4-a. Does the risk assessment provide an overview of the probability of future hazard events that includes projected changes in the location, range of anticipated intensities, frequency, and/or duration of each natural hazard?

Section 3.3 (p3-35 to 3-259, esp.

Probability of Future Occurrence, Climate Change Considerations, &

Development Trends subsections)

Met

S4-b. Does the probability include considerations of changing future conditions, including climate change (e.g., long-term weather patterns, average temperature, and sea levels) on the type, location and range of anticipated intensities of identified hazards?

Section 3.3 (p3-35 to 3-259, esp.

Climate Change Considerations subsections)

Met

S5. Does the risk assessment address the vulnerability of state assets located in hazard areas and estimate the potential dollar losses to these assets? [44 CFR §§ 201.4(c)(2)(ii) and 201.4(c)(2)(iii)]

S5-a. Does the risk assessment include an overview and analysis of the vulnerability to state assets from the identified hazards as well as a summary of the most vulnerable assets?

Section 3.2 (p3-15 to 3-34); Section

3.3 (p3-35 to 3-259, esp. Vulnerability

Assessment / State Assets, Critical

Facilities, and Infrastructure subsections); Appendix D

Met

S5-b. Does the risk assessment estimate potential dollar losses to state assets located in identified hazard areas?

Section 3.2 (p3-15 to 3-34); Section

3.3 (p3-35 to 3-259, esp. Vulnerability

Assessment / State Assets, Critical

Facilities, and Infrastructure subsections); Appendix D

Met

S6. Does the risk assessment include an overview and analysis of jurisdictions’ vulnerability to the identified hazards and the potential losses? [44 CFR §§ 201.4(c)(2)(ii) and 201.4(c)(2)(iii)]

S6-a. Does the risk assessment provide an overview and analysis of vulnerable jurisdictions based on the state and local government risk assessments?

Section 3.3 (p3-35 to 3-259, esp.

Vulnerability Assessment subsections)

(section and/or page number)

Met /

Not Met

S6-b. Does the risk assessment include an overview and analysis of the potential losses to the identified vulnerable structures based on estimates in the local risk assessments as well as the state risk assessment?

Section 3.3 (p3-35 to 3-259, esp.

Vulnerability Assessment subsections)

Met

S7. Was the risk assessment revised to reflect changes in development? [44 CFR § 201.4(d)]

S7-a. Does the plan provide a summary of recent development and potential or projected development in hazard-prone areas based on state and local government risk assessments?

Section 3.3 (p3-35 to 3-259, esp.

Climate Change Considerations, &

Development Trends subsections)

STATE MITIGATION CAPABILITIES

(section and/or page number)

Met /

Not Met

S8. Does the plan discuss the evaluation of the state’s hazard management policies, programs, capabilities, and funding sources to mitigate the hazards identified in the risk assessment? [44 CFR

§ 201.4(c)(3)(ii)]

S8-a. Does the plan include an evaluation of state laws, regulations, policies and programs related to hazards that improve or impede resilience to future natural hazard events and other future conditions, including the effects of climate change?

Section 4 (p4-1 to 4-68)

S8-b. Does the plan include a general discussion of state funding capabilities for hazard mitigation actions and projects?

Section 5.3 (p5-

23 to 5-37)

S8-c. Does the plan include a summary of obstacles, challenges and proposed solutions related to any state capabilities, including a brief discussion of potential strategies for overcoming any challenges related to implementing and enforcing hazard-resistant building codes statewide, as applicable, and changes since the previous plan approval?

Section 4.2 (p4-

3 to 4-14);

Section 4.4.14

(p 4-47 to 4-48)

Hazard Identification and Risk Assessment Required Revisions:

State Mitigation Capabilities Required Revisions:

MITIGATION STRATEGY

(section and/or page number)

Met /

Not Met

S9. Does the mitigation strategy include goals to reduce long-term vulnerabilities from the identified hazards? [44 CFR §

201.4(c)(3)(i)]

S9-a. Does the plan identify hazard mitigation goals representing what the state seeks to accomplish through mitigation plan implementation using a wide range of funding, including non-FEMA funding?

Section 5.1 (p5-

1 to 5-2)

Met

S9-b. Are the goals consistent with the hazards and vulnerabilities identified in the risk assessment?

Section 3.5 (p3-

267 to 3-275);

Section 5.1 (p5-

1 to 5-2)

Met

S10. Does the plan prioritize mitigation actions to reduce vulnerabilities identified in the risk assessment? [44 CFR §§

201.4(c)(3)(i), 201.4(c)(3)(ii) and 201.4(c)(3)(iii)]

S10-a. Does the plan identify actions based on the current risk assessment to reduce the vulnerability of jurisdictions within the state, as well as the vulnerability of state assets as described in

Elements S5 and S6?

Section 5.2 (p5-

3 to 5-22)

Met

S10-b. Does the plan describe the process used by the state to evaluate and prioritize actions that are cost-effective, environmentally sound, and technically feasible?

Section 5.2.1

(p5-3 to 5-5)

Met

S10-c. Does the plan describe how each action contributes to the hazard mitigation goals?

Section 5.2 (p5-

3 to 5-22)

Met

S10-d. Does the plan describe how local government mitigation strategies link to the state mitigation strategy?

Section 5.2 (p5-

3 to 5-22)

(section and/or page number)

Met /

Not Met

S11. Does the plan identify current and potential sources of funding to implement mitigation actions and activities? [44 CFR §

201.4(c)(3)(iv)]

S11-a. Do mitigation activities include the identification of current and/or potential sources of federal, state, local or private funding for implementation?

Section 5.2.3, “Goal & Action” column (p5-5 to

5-18)

Met

S11-b. Does the plan identify FEMA mitigation funding sources (if applicable), including, but not limited to: HMGP, BRIC, FMA and PA

Mitigation, at a minimum?

Section 5.3 (p5-

23 to 5-37)

S12. Was the plan updated to reflect progress in statewide mitigation efforts and changes in priorities? [44 CFR § 201.4(d)]

S12-a. Does the plan provide a narrative of the status of each mitigation action in the previous plan?

Section 5.2.2

(p5-5); Section

5.2.3, “2024

Status and

Notes” column

(p5-5 to 5-18)

Met

S12-b. Was the prioritization of mitigation actions and activities updated based on the updated analysis of risks, capabilities and progress?

Section 5.2.1 through 5.2.2

(p5-3 to 5-5);

LOCAL PLANNING COORDINATION AND CAPABILITY BUILDING

(section and/or page number)

Met /

Not Met

S13. Does the plan generally describe and analyze the effectiveness of local government mitigation policies, programs, and capabilities? [44 CFR § 201.4(c)(3)(ii)]

S13-a. Does the plan provide a summary of current local government policies, programs and capabilities of jurisdictions to accomplish hazard mitigation?

Section 4.6 thru

4.7 (p4-55 to 4-

68)

Met

S13-b. Does the plan describe the effectiveness of local government mitigation policies, programs and capabilities?

Section 4.6 thru

4.7 (p4-55 to 4-

68)

Met

S14. Does the plan describe the process to support the development of approvable local government mitigation plans? [44

CFR §§ 201.3(c)(5) and 201.4(c)(4)(i)]

S14-a. Does the plan describe how the state supports developing or updating FEMA-approvable mitigation plans?

Section 4.6.3 thru 4.6.4 (p4-

57 to 4-58)

Met

S14-b. Does the plan provide a brief summary of barriers to developing or updating, adopting, and implementing FEMA-approved local government mitigation plans based on an analysis of plan and jurisdiction coverage data and trends across the state and steps to remove barriers to help local governments advance mitigation planning, including how plan and jurisdiction coverage data and trends inform those steps?

Section 4.6.3

(p4-57 to 4-58)

Met

S15. Does the plan describe the criteria for prioritizing funding?

[44 CFR § 201.4(c)(4)(iii)]

S15-a. Does the plan describe criteria for prioritizing jurisdictions to receive planning and project grants under available federal and non-federal programs?

Section 4.6.2

(p4-57)

Mitigation Strategy Required Revisions:

page number)

Met /

Not Met

S16. Does the plan describe the process and time frame to review, coordinate, and link local and tribal mitigation plans with the state mitigation plan? [44 CFR §§ 201.3(c)(6), 201.4(c)(2)(ii), 201.4(c)(3)(iii), and 201.4(c)(4)(ii)]

S16-a. Does the plan describe the state’s process and time frame to review and submit approvable local and tribal mitigation plans to

FEMA?

Section 4.6.4

(p4-58)

Met

S16-b. Does the plan describe the state’s process and time frame to share risk assessment data and mitigation priorities with local governments for their plan updates, as well as integrate local risk assessment and mitigation actions into the state mitigation plan updates?

Section 4.6.3

(p4-57 to 4-58)

Local Planning Coordination and Capability Building Required Revisions:

REVIEW, EVALUATION, AND IMPLEMENTATION

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

S17. Is there a description of the method and schedule for keeping the plan current? [44 CFR §§ 201.4(c)(5)(i) and 201.4(d)]

S17-a. Does the plan describe the agency/office responsible for monitoring, evaluating and updating the plan?

Section 6.1 (p6-

1)

Met

S17-b. Does the plan describe the schedule for monitoring, evaluating, and updating the plan?

Section 6.1 (p6-

1 to 6-2)

Met

S18. Does the plan describe the systems for monitoring implementation and reviewing progress? [44 CFR §§ 201.4(c)(5)(ii) and 201.4(c)(5)(iii)]

S18-a. Does the plan describe the system for tracking the implementation of the mitigation activities and projects identified in the mitigation strategy, including all mitigation activities and not just those funded by FEMA?

Section 6.2 (p6-

2 to 6-3) page number)

Met /

Not Met

S18-b. Does the system include the schedule, the agency/office responsible for coordination, and the role of the agencies/offices identified in the mitigation strategy as responsible for implementation of actions?

Section 6.2 (p6-

2 to 6-3)

Met

S18-c. Does the plan describe a system for reviewing progress on achieving the mitigation strategy’s goals that includes the criteria and process for evaluating progress?

Section 6.2 (p6-

2 to 6-3)

Review, Evaluation, and Implementation Required Revisions:

ADOPTION AND ASSURANCES

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

S19. Did the state provide documentation that the plan has been formally adopted? [44 CFR § 201.4(c)(6)]

S19-a. Did the state provide documentation of formal adoption by the highest elected official or designee prior to FEMA approval?

Click or tap here to enter text.

Met

S20. Did the state provide assurances? [44 CFR § 201.4(c)(7)]

S20-a. Does the plan include assurances that the state will manage and administer FEMA funding in accordance with applicable federal statutes and regulations?

Section 1.5 (p1-

5)

Met

S20-b. Does the plan include assurances that the state will update its plan whenever necessary to reflect changes in state or federal laws and statutes?

Section 1.5 (p1-

5)

Adoption and Assurances Required Revisions:

HIGH HAZARD POTENTIAL DAMS

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

HHPD1. Did Element S2 (planning process) describe how the state dam safety agency, other agencies, and stakeholders participated in the planning process and contributed expertise, data, studies, information, etc. relative to high hazard potential dams?

HHPD1-a. Does the plan describe how the state dam safety agency, other agencies, and stakeholders were involved in the planning process?

Section 2.2.2

(p2-2 to 2-4)

Met

HHPD1-b. Does the plan describe the types of data contributed? Section 4.4.1

(p4-28)

Met

HHPD2. Did Element S6 (risk assessment) address all dam risk for high hazard potential dams in the risk assessment?

HHPD2-a. Does the plan provide a list of high hazard potential dams that have been identified by the state with their names, National

Inventory of Dams identification numbers, locations by jurisdiction, and other relevant information, as well as maps?

Section 3.3.2

(p3-57 to 3-58 and 3-66 to 3-

68); Appendix I

(pI-1)

Met

HHPD2-b. Does the plan summarize statewide vulnerabilities to/from high hazard potential dams from hazards and the potential consequences associated with dam incidents?

Section 3.3.2

(p3-57 to 3-58 and 3-66 to 3-

68); Appendix I

(pI-1)

Met

HHPD2-c. Does the plan document limitations and describe the approach to address deficiencies?

Section 3.3.2

(p3-57 to 3-58 and 3-66 to 3-

68); Appendix I

(pI-1) page number)

Met /

Not Met

HHPD3. Did Element S9 (mitigation goals) include mitigation goals to reduce long-term vulnerabilities from high hazard potential dams?

HHPD3-a. Does the plan address a reduction in vulnerabilities to/from high hazard potential dams from hazards and the potential consequences associated with dam incidents as part of their own goals or with other long-term strategies?

Section 5.1 (p5-

1 to 5-2)

Met

HHPD3-b. Does the plan link the proposed actions to reduce long-term vulnerabilities consistent with the goals?

Section 5.2 (p5-

3 to 5-22)

Met

HHPD4. Did Element S10 (mitigation actions) prioritize mitigation actions and activities to reduce vulnerabilities from high hazard potential dams?

HHPD4-a. Does the plan include actions to reduce vulnerabilities to/from high hazard potential dams?

Table 5-4 (p5-19 to 5-22)

Met

HHPD4-b. Does the plan describe the process to evaluate and prioritize actions related to high hazard potential dams that are cost-effective, environmentally sound and technically feasible?

Section 5.2.1

(p5-3 to 5-5)

Met

HHPD4-c. Does the plan describe how each action to reduce risks related to high hazard potential dams contributes to the goals and describe how strategies are linked to the state mitigation strategy?

Section 5.2.3, “Goal & Action” column (p5-5 to

5-18)

Met

HHPD5. Did Element S11 (funding sources) identify current and potential sources of funding to implement mitigation actions and activities for high hazard potential dams?

HHPD5-a. Does the plan include various funding sources to mitigate vulnerabilities to and from high hazard potential dams from hazards and the potential consequences associated with dam incidents, as well as funding sources to rehabilitate or remove high hazard potential dams?

Section 5.3 (p5-

21 to 5-37)

Met

HHPD6. Did Element S13 (local coordination) generally describe and analyze the effectiveness of local mitigation policies, programs, and capabilities that address high hazard potential dams?

page number)

Met /

Not Met

HHPD6-a. Does the plan provide a summary of the local policies, programs, and capabilities to implement mitigation actions and reduce vulnerabilities from high hazard potential dams from hazards and the potential consequences associated with dam incidents?

Section 4.6 thru

4.7 (p4-55 to 4-

68)

Met

HHPD6-b. Does the plan describe challenges to implementing local mitigation policies, programs and capabilities to reduce vulnerabilities to and from high hazard potential dams and the approach to overcome these challenges?

Section 4.6.3

(p4-57 to 4-58)

Met

HHPD6-c. Does the plan describe opportunities for implementing mitigation actions to reduce risks to and from high hazard potential dams through local capabilities?

Section 4.6.3

(p4-57 to 4-58)

Met

HHPD7. Did Element S15 (prioritizing funding) describe the criteria for prioritizing funding for high hazard potential dams?

HHPD7-a. Does the plan describe the method for funding actions to reduce vulnerabilities to and from high hazard potential dams if these actions were prioritized differently than mitigation actions for other hazards?

Section 5.2.1

(p5-3 to 5-5)

Met

HHPD7-b. Does the plan document limitations and describe the approach to addressing deficiencies?

Section 4.4.1

(p4-28)

HHPD Required Revisions:

FIRE MANAGEMENT ASSISTANCE GRANTS

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

FMAG1. Does the plan address wildfire risks? [44 CFR 201.4(c)(2);

44 CFR § 204.51(d)(2)]

FMAG1-a. Does the risk assessment provide an overview of the location and previous occurrences of wildfire hazards in the state?

Section 3.3.5

(p3-139 to 3-

158) page number)

Met /

Not Met

FMAG1-b. Does the risk assessment provide an overview of the probability of future wildfire events that includes projected changes in the location, intensity, frequency and/or duration of wildfire hazards?

Section 3.3.5

(p3-150)

Met

FMAG1-c. Does the risk assessment address the vulnerability of state assets located in wildfire hazard areas and estimate the potential dollar losses to those assets?

Section 3.3.5

(p3-139 to 3-

158); Appendix

D

Met

FMAG1-d. Does the risk assessment include an overview and analysis of local governments’ vulnerability to wildfires and the potential losses to vulnerable structures?

Section 3.3.5

(p3-151 to 3-

158); Appendix

H

Met

FMAG2. Does the plan’s mitigation strategy contain wildfire-related mitigation initiatives? [44 CFR 201.4(c)(3); 44 CFR § 204.51(d)(2)]

FMAG2-a. Does the mitigation strategy identify mitigation actions and activities to reduce the vulnerability of jurisdictions within the state as well as the vulnerability of state-owned assets as described in Elements S5 and S6?

Table 5-4 (p5-19 to 5-21)

FMAG Required Revisions:

3. Enhanced State Mitigation Plan Regulation Checklist

ENHANCED STATE PREREQUISITES

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

E1. Does the enhanced plan include all elements of the standard state mitigation plan? [44 CFR § 201.5(b)]

E1-a. Does the enhanced plan meet all the required elements of the standard state mitigation plan?

See above Met

E2. Regarding HMA, is the state maintaining the capability to meet application time frames and submitting complete project applications? [44 CFR § 201.5(b)(2)(iii)(A)]

E2-a. Are all applications complete and submitted by the end of each program’s respective application period?

Section 5.4 (p5-

38 to 5-50)

Met

E2-b. Are all applications entered into FEMA’s electronic data systems (i.e., NEMIS, eGrants, and/or FEMA GO)?

Section 5.4 (p5-

38 to 5-50)

Met

E2-c. Is a complete Minimum Criteria Checklist for Project

Subapplicants or equivalent documentation prepared for all subapplications?

Section 5.4 (p5-

38 to 5-50)

Met

E2-d. Are all applications determined to be complete by FEMA within

90 days of submittal or selection for further review, or after the first request for information response?

Section 5.4 (p5-

38 to 5-50)

Met

E3. Regarding HMA, is the state maintaining the capability to prepare and submit accurate environmental reviews and benefit-cost analyses? [44 CFR § 201.5(b)(2)(iii)(B)]

E3-a. Are all applications and amendments determined to be complete by FEMA within 90 days of submittal or selection for further review, or after the first request for information response, including all data requested by FEMA to support cost-effectiveness determinations and EHP compliance reviews?

Section 5.4 (p5-

38 to 5-50)

Met

E4. Regarding HMA, is the state maintaining the capability to submit complete and accurate quarterly progress and financial reports on time? [44 CFR § 201.5(b)(2)(iii)(C)]

E4-a. Are all progress reports complete and submitted on time? Section 5.4 (p5-

38 to 5-50) page number)

Met /

Not Met

E4-b. Are all FFR SF-425s submitted on time? Section 5.4 (p5-

38 to 5-50)

Met

E4-c. Does the state consistently comply with the Financial

Management Standard requirements described in 2 CFR §§

200.300 to 200.309?

Section 5.4 (p5-

38 to 5-50)

Met

E5. Regarding HMA, is the state maintaining the capability to complete HMA projects within established performance periods, including financial reconciliation? [44 CFR § 201.5(b)(2)(iii)(D)]

E5-a. Is all work as part of HMA subawards completed by the end of the period of performance, as described in the HMA Guidance?

Section 5.4 (p5-

38 to 5-50)

Met

E5-b. Have there been no major findings on the last single audit obtained by the state related to HMA programs?

Section 5.4 (p5-

38 to 5-50)

Met

E5-c. Are all grant closeout activities, including financial reconciliation, completed within 120 days from the end of the performance period as outlined in 2 CFR 200.344?

Section 5.4 (p5-

38 to 5-50)

Met

E5-d. Have actual expenditures been documented and are they consistent with SF-424A or SF-424C?

Section 5.4 (p5-

38 to 5-50)

Enhanced State Prerequisites Required Revisions:

INTEGRATED PLANNING

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

E6. Does the plan demonstrate integration, to the extent practicable, with other state and/or regional planning initiatives and FEMA mitigation programs and initiatives? [44 CFR §

201.5(b)(1)]

E6-a. Does the enhanced plan demonstrate integration with other state and/or regional planning initiatives?

Section 4.2 thru

4.4 (p4-3 to 4-

48)

Met

E6-b. Does the enhanced plan demonstrate integration of FEMA mitigation programs and initiatives?

Section 4.5 (p4-

49 to 4-54)

Integrated Planning Required Revisions:

DEMONSTRATING COMMITMENT TO A COMPREHENSIVE STATE MITIGATION PROGRAM

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

E7. Does the state demonstrate commitment to a comprehensive mitigation program? [44 CFR §§ 201.3(c), 201.5(b)(4) and

201.6(d)]

E7-a. Does the state demonstrate commitment to statewide programs, initiatives and plans that advance mitigation and resilience?

Section 4.2 thru

4.4 (p4-3 to 4-

48)

Met

E7-b. Does the state demonstrate a commitment to mitigation training and capability building?

Section 4.3.1 (4-

22 to 4-24)

Met

E7-c. Does the state demonstrate a commitment to its mitigation planning responsibilities by helping local governments update and adopt their plans before they expire?

Section 4.6.2 thru 4.6.4 (p4-

57 to 4-58)

Demonstrating a Commitment to a Comprehensive State Mitigation Program Required Revisions:

EFFECTIVE USE OF EXISTING MITIGATION PROGRAMS TO ACHIEVE MITIGATION GOALS

Requirements Location in Plan

(section and/or page number)

Met /

Not Met

E8. Is the state effectively using existing mitigation programs to achieve mitigation goals? [44 CFR §§ 201.5(a) and 201.5(b)(3)]

E8-a. Does the state demonstrate and document the full and effective use of existing FEMA programs (if funding is available)?

Section 5.4.1 (4-

28 to 4-36)

Met

E8-b. Does the state demonstrate and document the full and effective use of non-FEMA programs?

Section 5.4.1 (4-

28 to 4-36)

Effective Use of Existing Mitigation Programs to Achieve Mitigation Goals Required Revisions:

DOCUMENTATION OF THE STATE’S IMPLEMENTATION CAPABILITY

(section and/or page number)

Met /

Not Met

E9. Does the enhanced plan document capability to implement mitigation actions? [44 CFR §§ 201.5(b)(2)(i), 201.5(b)(2)(ii), and

201.5(b)(2)(iv)]

E9-a. Does the enhanced plan describe the system to rank the mitigation measures according to established eligibility criteria, including a process to prioritize between funding programs, jurisdictions, and proposals that address different or multiple hazards?

Section 5.4.2 thru 5.4.3 (p5-

47 to 5-50)

Met

E9-b. Does the enhanced plan describe how the state will assess the effectiveness of mitigation actions, mitigation the agencies that are involved as well as the timeline, and use the results to inform the mitigation strategy?

Section 5.4.6 thru 5.4.8 (p5-

56 to 5-59)

Documentation of the State’s Implementation Capability Required Revisions:

4. Plan Assessment The Plan Assessment comments can be used to help guide the ongoing maintenance and update of your mitigation plan.

Standard State Mitigation Plan Requirements

PLANNING PROCESS

Strengths

▪ The plan thoroughly describes how multiple agencies, stakeholders, and other interested parties were involved in the overall planning process and ongoing maintenance. Of particular note is the input received from the South Dakota Housing Development Authority regarding vulnerability of unhoused populations. As a new partner, they will be able to further align this and future mitigation plans and activities with the housing and economic development sectors. We are pleased to see the continued strategic coordination and engagement of the SHMT, leveraging of the partnership with the U.S. Army Corps of Engineers Silver Jackets, and the outreach to all nine federally recognized tribes in South Dakota to participate in the plan update.

▪ Section 2.4.1 Ongoing Public Outreach Since Last Plan Update provides insightful information on how the State has engaged the public since the 2019 E-SHMP was approved, including narrative on ongoing public outreach, developing a Story Map for engagement (HMA 101, plan updates, etc.), the Tommy the Turtle campaign, annual OEM booth at the state fair, and NFIP and campaigns. We recommend adding metrics of success for these efforts in the next state plan update to demonstrate the effectiveness of these programs.

▪ Integrating the State’s Drought Mitigation Plan into this E-SHMP is an excellent way to ensure alignment between different State planning mechanisms and bolsters the State’s ability to address long-term issues to drought.

Opportunities for Improvement

▪ Given all that Planning Districts do in developing hazard mitigation plans and other planning mechanisms across South Dakota, elevating their role in the next E-SHMP update to be a member of the SHMT would enable them to contribute their expertise and insight from working with local communities on mitigation plans. While not a formal State office, page 4-40 notes they are considered an extension of state government. We look forward to seeing how the State might continue to expand and leverage their partnership with the Planning Districts to have them more actively participate and inform the next plan update.

▪ Though public outreach was completed through several methods (e.g., a public draft on website, press release, agency social media, and flyer at two state conferences), only five comments were received on the draft plan made available for public review. In the next plan update, consider utilizing additional methods to engage the public and gather comments on the draft plan, like radio announcements or discussing the update at local mitigation plan kick-off meetings, which may yield more feedback from the public.

HAZARD IDENTIFICATION AND RISK ASSESSMENT

Strengths

▪ The vulnerability analysis in the HIRA includes informative context to understand how available data was used in this plan update and what gaps exist specific to state asset vulnerability and potential dollar loss. Data developed in response to these gaps as part of the mitigation strategy will only strengthen the Risk Assessment’s analysis in the next plan update.

▪ Table 3-81 Hazard Risk Summary Table is a great snapshot of an extensive amount of information included in the plan’s risk assessment. This resource will be a useful reference tool to ensure the plan is useful for state staff and local practitioners to understand risk in South

Dakota in an accessible way, especially as it relates to climate change impacts.

▪ The Tornado hazard profile serves as a good example for identifying vulnerable populations and exploring why they might be particularly vulnerable to a hazard. For example, the plan discusses how people with physical disabilities may need more time to take shelter or evacuate. We will look forward to seeing how the State will build this type of vulnerable population discussion into future planning efforts.

Opportunities for Improvement

▪ Table 3-9 Socially Vulnerable Demographics, South Dakota vs U.S provides a brief comparison of the percentage of population with different socially vulnerable characteristics in South Dakota compared to the rest of the country. Expanding on this and adding county-specific socially vulnerable characteristics (rolled up from local hazard mitigation plans, if possible) will provide a localized perspective on socially vulnerable populations in South Dakota.

▪ The wildfire profile notes three types of studies, specific to South Dakota, would facilitate more effective management of wildfire hazards. The mitigation plan would be strengthened if it included a mitigation action to develop these studies, and then information from them integrated into the next E-SHMP update.

▪ The plan does a good job at identifying the gaps in information needed to fully describe the state’s vulnerability to hazards through mitigation actions. The results from the mitigation actions to address these data gaps should be integrated into the next plan update to create a more robust analysis of the vulnerability of state assets and local jurisdictions.

STATE MITIGATION CAPABILITIES

Strengths

▪ This section provides a comprehensive overview of partners, programs, and funding capabilities and identifies implementation challenges as well as suggested improvements. The discussion includes the state’s approach to oversubscribing to all HMGP funding opportunities, the goal to maximize 406 funding post-disaster, the commitment to improving application quality, and the ample assistance provided through providing a portion of the local match for projects. This narrative exemplifies the state’s considerable mitigation capabilities.

▪ Table 5-12 FEMA Public Assistance Section 406 Funding: 2010-2023 (page 5-51) summarizes the use of the 406 PA Mitigation program. The level of detail provided in this table is appreciated as it is easy to understand and digestible. This table also shows the continuous tracking efforts made by the state to ensure success of the program.

▪ Section 5.4.8 Loss Avoidance Case Studies (page 5-58), though not directly tied to the success of the 406 PA Mitigation program, shows that the State is using methods such as Loss Avoidance

Analysis to evaluate the impacts that were prevented by completed mitigation projects.

▪ The plan effectively calls out mitigation capabilities related to historic and environmental review and compliance.

Opportunities for Improvement

▪ Table 5-5 Mitigation Funding Sources in South Dakota (Page 5-25) includes a detailed summary of federal, state, local, and private funding sources that have been, or could be, used to implement mitigation actions. In the next plan update, please add detail to demonstrate how non-FEMA funding has been used for mitigation efforts in the state, if applicable. Other types of non-FEMA funded mitigation projects could ultimately be something the State might consider adding into its online South Dakota Mitigation Project Map – which continues to be a best practice publicly available tool to showcase all the State’s mitigation investment and work!

MITIGATION STRATEGY

Strengths

▪ Table 4-7 Comparison of Current Local Mitigation Actions, 2019 vs. 2024 and Table 4-12 Tribal

Mitigation Actions Identified and Completed in 2024 Plans show local mitigation action progress made since the 2019 plan approval. Table 4-8 Comparison of Most Commonly Identified Local

Mitigation Actions and Related State Mitigation Actions and Table 4-11 State Mitigation Actions

Specific To Tribes demonstrate alignment to the goals and objectives of the E-SHMP and show the integration of information from the local plan “roll ups.”

▪ Identifying mitigation actions by theme (Structure & Infrastructure Projects, Education, Awareness, & Outreach, Data & Studies, Technical Assistance, Planning & Regulations, Natural

Systems Protection, Training & Exercises) in the 2024 E-SHMP will be useful for the State Hazard

Mitigation Team to utilize during the next plan update to ensure a comprehensive range of actions are included when considering mitigation action ideas.

▪ Many mitigation actions identify multiple State agencies responsible for implementation. This demonstrates a whole State approach and commitment to mitigation.

Opportunities for Improvement

▪ For the next plan update, consider merging Table 5-4 Mitigation Actions by Hazards Addressed with Table 5-3 South Dakota 2024 Hazard Mitigation Actions. Having one table would make it easier for plan readers to understand which mitigation actions address which hazard(s).

LOCAL PLANNING COORDINATION AND CAPABILITY BUILDING

▪ 97% of counties in South Dakota are covered by a mitigation plan. South Dakota maintains a very high percentage of participating jurisdictions, demonstrating the commitment to local mitigation planning from local governments, planning districts, and the State OEM team.

▪ Section 3.1.2 Local Hazard Mitigation Plan Roll-Up provides a thorough summary that captures how local plans identify hazards and assess capabilities. This is valuable insight into local communities’ concerns and local mitigation priorities and an excellent method for displaying this information.

▪ Table 3-14 Growth and Development Trends Extracted from Local Plans Updated Since 2017 does a good job of incorporating information from local plans from each county and Tribal Nation specific to land use development changes.

▪ Section 4.6.5 Local Capabilities Overview identifies a number of challenges and capabilities gaps that local communities face to implement mitigation activities, along with solutions the State will provide to address these. In the next plan update, we look forward to seeing the results of the

State’s efforts to address local challenges.

▪ The State went above and beyond planning requirements to document Tribal mitigation plan content and priorities.

Opportunities for Improvement

▪ When discussing the effectiveness of local government mitigation policies, programs, and capabilities, the next plan should address gaps and disparities in serving underserved communities and challenges resulting from the impacts of climate change.

REVIEW, EVALUATION, AND IMPLEMENTATION

▪ Leveraging the quarterly Silver Jackets meetings will help ensure that progress on the plan is being regularly tracked by key stakeholders involved in plan development and implementation.

▪ The plan includes a clear system for measuring progress on achieving the mitigation strategy goals. We look forward to discussing progress achieved on mitigation strategy goals with the

State Hazard Mitigation Officer during our enhanced validation meetings and annual consultations.

ADOPTION AND ASSURANCES

Strengths

▪ FEMA Region 8 values our partnership with the State to advance mitigation in South Dakota and look forward to continued collaboration throughout this plan’s lifecycle.

HIGH HAZARD POTENTIAL DAMS

▪ FEMA Region 8 is pleased to see the State pursue HHPD eligibility. Access to this FEMA funding opportunity can help fund the implementation of actions that reduce risk to State-, local-, and private-owned dams.

▪ Appendix I provides a comprehensive list of high hazard dams as well as summary tables in a spreadsheet format.

Opportunities for Improvement

▪ The next plan would benefit from further analysis of high hazard dams that pose the greatest risk to the state (e.g., poor condition, high population at risk, critical infrastructure, water supply), along with a more detailed description of the data that contributed to this analysis.

FIRE MANAGEMENT ASSISTANCE GRANTS

Strengths

▪ The wildfire profile provided the most detailed vulnerability assessment in the E-SHMP, especially in the Development Trends and Consequence Summary section.

Opportunities for Improvement

▪ Action 2-8 notes that OEM conducts outreach on new HMGP Post-Fire funding opportunities.

Expand on how OEM carries out this outreach and any positive results from it. For example, include how many new communities participate in Firewise or have developed Community

Wildfire Protection Plans over the plan lifecycle.

Enhanced State Mitigation Plan Requirements

ENHANCED STATE PREREQUISITES

Strengths

▪ FEMA Region 8 commends South Dakota’s commitment to maintaining and implementing an enhanced state hazard mitigation planning program.

Opportunities for Improvement

▪ The requirements for analysis of State- and local-owned assets, hazard-specific risk to vulnerable and underserved populations, and impacts from recent and future development are met in this plan update through the inclusion of mitigation actions aimed at filling data gaps in the next five years. The next plan’s Risk Assessment should incorporate the data gathered and analyzed through the implementation of these mitigation actions.

INTEGRATED PLANNING

▪ The program’s integration with a broad range of stakeholders, included those as required by state mitigation planning policy, demonstrates a coordinated approach to planning and implementing the State’s mitigation goals.

▪ The South Dakota Housing Development Authority is a fantastic addition to the State Hazard

Mitigation Team. Having this organization at the table will allow the State to further coordinate with the housing sector on mitigation planning and implementation activities, as well as other regional planning initiatives that include housing considerations like Comprehensive Economic

Development Strategies.

Opportunities for Improvement

▪ As the State implements this plan, identify where the mitigation team could strategically engage key stakeholders from non-governmental organizations serving underserved communities in

South Dakota.

DEMONSTRATING A COMMITMENT TO A COMPREHENSIVE MITIGATION PROGRAM

Strengths

▪ The trainings, technical assistance and touchpoints offered by the State like G318 Local

Mitigation Planning Workshops and direct technical assistance actions in the mitigation strategy show South Dakota is committed to a comprehensive mitigation program.

Opportunities for Improvement

▪ A few key ongoing and impactful opportunities for technical assistance between SD OEM and

FEMA Region 8 were not included in the plan. For example, engaging in joint local mitigation plan reviews enables us to connect on planning policy interpretation and application, and ensure local communities are creating robust hazard mitigation plans. In the next plan, we recommend discussing these opportunities and reporting on the results of these engagements.

EFFECTIVE USE OF EXISTING MITIGATION PROGRAMS TO ACHIEVE MITIGATION GOALS

Strengths

▪ Table 5-9 Summary of Mitigation Projects Conducted by Project Type (page 5-44) shows how the

State has used a variety of funding sources to successfully fund mitigation projects, and also make clear connections between funding and project priorities.

Opportunities for Improvement

▪ As noted in the plan, a constraint for this plan is limited data on assets and recent and future development. To ensure this data is captured for the next E-SHMP, the State should develop a process to capture the information from local mitigation plans (elements B2 and E1 in the Local

Mitigation Planning Policy Guide) over the next five years.

DOCUMENTATION OF THE STATE’S IMPLEMENTATION CAPABILITY

▪ The plan describes an effective system to rank local mitigation measures according to eligibility criteria, including a process to prioritize between funding programs, jurisdictions, and proposals that address different or multiple hazards.

▪ The state’s story map webpage documents all FEMA-funded mitigation projects in the state since

1992. The webpage tracks the location, subapplicant, status, federal share, and the project's funding opportunity. This information is very helpful to demonstrate the state’s mitigation implementation capabilities to external partners and to document implementation for local practitioners. As mentioned in a previous plan assessment comment, this resource continues to be a best practice to showcase the State’s mitigation investments and work. We look forward to watching it grow and evolve in the coming years!

Opportunities for Improvement

▪ The state plan includes criteria to evaluate progress on the mitigation strategy (numbers of actions completed, numbers of actions in-progress, summarizing actions completed by goals as an indication of enhanced resilience, and tracking and highlighting losses avoided). In the next plan update, we recommend enhancing the evaluation of mitigation strategies by discussing other benefits such as non-monetary benefits for underserved communities.