Why tribal nations need a hazard mitigation plan

The eligibility gate

Under 44 CFR 201.7, a federally recognized tribal government must have a FEMA-approved or approvable-pending-adoption hazard mitigation plan in order to receive funding under the Hazard Mitigation Grant Program (HMGP), the Building Resilient Infrastructure and Communities (BRIC) program, or the Flood Mitigation Assistance (FMA) program. That is not optional guidance. It is a regulatory prerequisite.

The plan must be developed, adopted by the tribal governing body, submitted to FEMA, and approved. Once approved, it is valid for five years. If it expires without an update, eligibility lapses until a new plan is approved.

Where things stand

FEMA publishes plan status data through the Hazard Mitigation Plan Status page and the OpenFEMA dataset. The numbers tell a clear story: the majority of the 574 federally recognized tribal governments in the United States do not have a current FEMA-approved mitigation plan. Many have never had one. The coverage gap in Indian Country is far wider than in state and local government, where 77.7% of the population lives in a community with a current plan.

That is not because tribal nations face fewer hazards. It is because most tribes lack the staff, the planning budget, and the consultant capacity to develop and maintain the plan on the five-year cycle FEMA requires.

What is at stake

After a presidential or tribal disaster declaration, HMGP funding becomes available to help the affected community reduce future risk. But that money can only flow to an applicant with an approved plan. A tribe without a plan can receive emergency assistance under FEMA Public Assistance Categories A and B, but it cannot access the mitigation dollars that would prevent the same damage from happening again.

The BRIC program works on an annual competitive cycle, separate from declarations. Tribes can apply directly to FEMA as applicants. But again, the plan is a condition of eligibility. A tribe that wants to compete for BRIC funding starts by having an approved plan in place before the notice of funding opportunity opens.

Who pays for the plan

In most cases, the tribal nation does not fund the plan from general revenue. FEMA's Hazard Mitigation Assistance programs provide grant funding specifically for plan development and updates. Tribes can apply directly to FEMA as applicants or through a state as sub-applicants. The federal cost share is typically 75%, with the tribal match often met through in-kind contributions such as staff time, data, and meeting space.

What the plan requires

The requirements are laid out in 44 CFR 201.7 and in FEMA's Tribal Mitigation Plan Review Guide. A compliant plan includes a planning process open to the tribal community, a risk assessment covering the hazards the tribe faces, a mitigation strategy with specific actions, and a maintenance process for keeping the plan current over its five-year life. Tribal plans must also address how the tribe will continue to involve the public, including tribal members and neighboring jurisdictions.

The full requirements are covered in our tribal mitigation plan requirements guide.

How we help

Okla Risk Advisors develops and updates tribal hazard mitigation plans under NAICS 541620. The firm's principal holds FEMA IS-318.b (Mitigation Planning for Local and Tribal Communities) and IS-328.a (Plan Review for Local Mitigation Plans), along with 43 additional FEMA Independent Study courses across the mitigation, Public Assistance, incident management, and recovery curricula. An office inside the Choctaw Nation reservation and a graduate degree in Indigenous Peoples Law ground the work in familiarity with tribal governance and the federal trust relationship.