Hurricane Sandy: Frequently Asked Questions—Competitive Resilience NOFA

Hurricane Sandy: Frequently Asked Questions Main Page

Question Response
Where can I find the materials that were presented on January 7th, 21st or 28th about the resilience competition and the Hazard Mitigation Cost Effectiveness requirements? The slides and training guides from these presentations can be found on FTA’s emergency relief website at www.fta.dot.gov/emergencyrelief. Please contact us at FTASandyResilience@dot.gov if you are interested in obtaining a recording of the webinars.
If my agency provides public transportation service, but is not a current FTA recipient, are we permitted to apply to this program? Any provider of public transportation service is eligible to apply. If your agency is not an active recipient of FTA funding, you must apply in coordination with a current recipient that is willing to receive and administer the award on your behalf. If funds are awarded, you would need to be a subrecipient of the award under the administration of the current FTA recipient. For such cases, applicants should simply provide a letter from a current recipient indicating their willingness to pass the award through to you as a subrecipient. If you are unsure of who can serve as a direct recipient of FTA funds, please contact your regional FTA office. In addition to larger transit operators, this could include State departments of transportation.
If an applicant’s responses to the evaluation criteria do not fit within the space provided in the supplemental form, can we submit additional attachments to respond to the criteria? (NEW) In general, responses to the evaluation criteria should be concise enough to fit within the space provided on the supplemental form. Additional files may be submitted if necessary for documentation or backup, however, the supplemental form must still contain a complete summary of your response to the criteria. If additional documents are required (e.g. letters of funding commitment, excerpts from plans or studies, engineering documents), these should be referenced specifically in the response to the relevant evaluation criterion.
If a grantee combines related initiatives together as a single grant application, is it possible for another FTA recipient to manage one of those initiatives? Or does the other agency need to submit a separate application? An agency may submit an application for a project that involves multiple subcomponents, provided that those components are part of a larger overall resilience proposal. If one or more of the subcomponents need to be undertaken by another agency, the applicant may either serve as the grantee for the entire award, and administer a sub-award to the other agency, or if the other agency is an FTA direct recipient (grantee), the applicant may direct the other agency to apply to FTA separately for its part of the project. In this second case, both agencies will be required to enter into an agreement outlining their mutual responsibilities in accomplishing the project and the terms of their coordination.
If an applicant can include sub-grantee projects in a single application, can a discrete amount of funding for the sub-grantee's initiative be flexed to FRA? Or would any project that requires flexing funds need to be an independent application? In accordance with the answer to the previous question, if a portion of funds are awarded for a project component that must be undertaken by an intercity passenger rail operator, those funds may be transferred to FRA for administration. If such a proposal is submitted as a single project, the applicant must clearly identify the portion of the project proposed to be administered by the intercity rail operator.
How can a grantee address project benefits that are not directly related to resilience, such as improvements to safety, asset management (SGR), or operational efficiencies? This purpose of this program is to provide funding for projects that make the regional public transportation system more resilient to future extreme weather events and other disasters. Consistent with the evaluation criteria listed in the Notice of Funding Availability, FTA will evaluate proposed projects based entirely on their resilience benefits and the ability of the project sponsor to carry out the project. To the extent that a project may have other incidental benefits, these may only be described to the extent they relate to the stated evaluation criteria. The overall purpose and complete benefits of the project may also be summarized in the project description.
What level of NEPA work needs to be done prior to applying? FTA does not require that any NEPA work be completed prior to applying. However, applicants should have a reasonable understanding about the NEPA class of action required for the project, as this will allow them to develop an appropriate project timeline. If a project is selected, agencies are advised to consult with FTA prior to grant submittal and indicate in the grant submission if a 4(f) or Section 106 review will be needed.
How should an applicant demonstrate the availability of local matching funds? If an applicant is proposing to use their own funds as local match, the documentation of the availability of such funds in a capital or financial plan is recommended. If local match will be provided by a separate entity, a letter that promises the availability of funds should be submitted. Finally, if an applicant will need to raise funds for a project, such as through the issuance of bonds, a description and timeline for that process should be provided.
May an applicant request funding for resilience elements of a project that is already underway? Yes, an applicant may apply for funding for a project that has previously been funded through FTA’s Emergency Relief Program or other programs, however, the funds must be for elements of the project for which funds are currently not obligated. This includes projects that are in the design or engineering stages for which federal funding has been received or resiliency components of a federally funded recovery project if the applicant can demonstrate it has not received sufficient funding from FTA already to carry out the resiliency components. Note that FTA will not allocate competitive resilience funds in cases where they would displace other Federal funds that have been obligated on existing projects. Projects funded from local or state funds may not be eligible if they did not receive FTA pre-award authority or if they do not comply with Federal requirements.
May an applicant request funding for resilience elements of a project where the entire project is not currently funded? The applicant must demonstrate that they have the financial capacity to complete the resilience project. If a resiliency projects is dependent on another project being implemented, the applicant must demonstrate they have funding committed (whether federal, state or local) to carry out the other project.
What does this mean: “In all instances, FTA retains the authority to award funds in direct alignment with recipient acceptance of and continued compliance with Federal determinations regarding increased standards for floodplain management.” This means that FTA will consider a recipient’s acceptance of a standard base flood elevation of one foot above FEMA’s best available flood hazard information as a minimum requirement for funding under this program. All recipients must indicate how this floodplain management guideline has been considered in project selection and design.
What information is required to document that a project complies with FEMA’s best available information plus one foot? For the ABFE+1/FEMA Best Available+1 requirement, applicants must submit documentation showing that they have identified the appropriate flood hazard area and the best available base flood elevation for the project location, or locations, as applicable. Applicant must also provide an explanation of how a proposed project was designed to make the asset resilient based on this flood hazard information. Applicants should cite the relevant FEMA map source and/or FEMA flood insurance study for the project location.
Are transit projects eligible for FEMA’s Section 40l4 Hazard Mitigation Grant Program (HMGP)? Yes, however each state administers its own HMGP funds and determines how those funds are spent, in accordance with FEMA requirements.
Can HMGP funds be used as local match for Emergency Relief Program resilience awards? No. The only Federal funds that can be used in place of local share for the FTA Emergency Relief Program are funds, which by statute lose their federal identity and can be used as match for other Federal programs, such as Community Development Block Grant funds.
Are grantees required to conduct a cost-benefit analysis of multiple resilience alternatives? No, applicants are not required to conduct a cost-benefit analysis to evaluate multiple alternatives for protecting a given asset, although this may be a useful step in selecting and identifying proposed projects for this competition.
As a part of the evaluation criterion “Protection of Most Vulnerable and Essential Infrastructure”, applicants should explain how and why a particular alternative was identified for this competition. This evaluation may use FTA’s HMCE tool, or may utilize a similar hazard-mitigation focused BCA process.
Can an applicant reduce the cost side of the HMCE analysis by providing additional local share, or sharing the project’s cost with another entity? If so, how should the cost of the project be reflected, as the resulting Federal request, or the total project cost? No, the HMCE analysis should always reflect the total project cost, as the analysis is based on the costs and benefits of the project to society, not to the Federal government. The application should clearly identify both the total project cost and the requested Federal funding amount.
Should travel time costs include both the time an asset is out of service due to a disaster and also the projected time it is out of service for repairs after the disaster? Yes. Applicants should include the customer impact of repair projects together with the customer impact from direct storm damage in the same section of the HMCE analysis. Please show how each estimated interruption is estimated and how the user impacts are calculated for each. If multiple types of customer impacts are included, please provide a separate analysis showing how each was calculated.
According to FTA’s guidance, the value of passenger time may be adjusted for regional differences. Can you please explain further how this number may be adjusted? The standard value of passenger time in the HMCE tool is pre-set at $15.58 per hour. Consistent with FEMA and DOT guidance, this represents one half of the average national wage, as reported by the Bureau of Labor Statistics. The value allows the HMCE tool to evaluate the benefits of avoided service outages or alternative services, as well as the cost of outages associated with project implementation.
Applicants have three options for this value:
  1. Use the standard value in the tool of $15.58 per hour, reflecting 50 percent of the national average wage rate.
  2. Adjust the value to account for regional differences, using regional wage information reported by the Bureau of Labor Statistics.


    Based on an analysis of the September 2013 BLS report “Employer Costs for Employee Compensation – September 2013”, Historical Listings through September 2013, and National Compensation Survey data from 2010-2011 for applicable Census regions and combined statistical areas (CSAs, i.e. adjacent metropolitan areas), comparing regional average wage values to the regional average private industry wages resulted in the following adjustments:

    • Regional:
      1. New England (CT, RI, MA, ME, NH, VT): $18.38 per hour
      2. Mid-Atlantic (NY, NJ, PA): $17.59 per hour
      3. South-Atlantic (MD, DC, DE, VA, NC, etc.): $14.38 per hour
    • Combined Statistical Areas
      1. Boston-Worcester-Manchester (RI, MA, NH) CSA: $18.80 per hour
      2. New York-Newark-Bridgeport Mid-Atlantic (NY-NJ-CT) CSA: $19.40 per hour
      3. Philadelphia-Camden-Vineyard (PA-NJ-DE-MD) CSA: $17.86 per hour
      4. Washington-Baltimore-Northern Virginia (DC-MD-VA-WV) CSA: $18.25 per hour
  3. Adjust the value to account for regional differences as follows: Calculate one half of the average household income for the applicant’s service area, or for all public transportation users in the applicant’s service area, divided by the average household size for the population used.

Regardless of the approach selected, the same value must be used in all proposals submitted by a single applicant. If an applicant intends to use the third option, additional backup documentation is required, including copies of the applicable census tables, the calculations used, and a brief statement of why one of the other two options is not accurate or sufficient for the analysis. Other alternative approaches are not recommended.

For public transportation projects is it legitimate to include benefits to passengers that accrue at all times, rather than just in weather events? For example, if one is building a new bridge that will be storm resilient, but this bridge would shorten the trip for all users, can the “routine” time savings be included as a benefit (along with all costs of course)? No. Please see the response to the question regarding non-resilience benefits. In accordance with the intent of the program, the HMCE analysis is designed to only assess the resilience benefits of a proposed project, which are those that are realized in the event of a natural disaster.
Under what circumstances does the following text from the NOFA apply? “Additional information may be considered on a case-by-case basis, such as if an applicant believes that the information requested above does not adequately measure the proposed benefits of a project.” If an applicant believes the FTA HMCE analysis tool does not capture all of the resilience benefits of a proposed project, the applicant should provide additional information in the qualitative benefits section of the HMCE tool, which is located beneath the projects apparent benefit cost ratio (BCR). Other benefits may also be quantified by an applicant and submitted separately, however, in such a case the applicant must submit a highly detailed explanation of how and why the alternative analysis differs from the HMCE tool. FTA will carefully scrutinize the justification, as well as the procedures and methodology provided together with the results of the HMCE tool.
Can the HMCE tool be used to estimate cost effectiveness for a scenario where a 100 year event causes more damage than a 200 year event? For example, this may occur if a lower flood elevation (e.g. 100-year event) causes bridge-damaging wave forces to hit a bridge for a long duration, whereas a higher flood elevation (e.g. 200-yr. storm) submerges the bridge pillars quickly and protects them from wave damage. How can you account for this in the tool? The HMCE tool is designed to accurately interpolate between two or more events with increasing total damages and increasing recurrence intervals (RIs). So for a scenario where a 100-year event causes more damage than a 200-year event; the HMCE tool would not accurately interpolate between the events and would underestimate the actual project benefits. Therefore, to produce accurate results in the HMCE tool, we recommend the following:
  • If there are only the two known RI events, then input only the 100-year event as a known RI event and omit the 200-year RI event to avoid an undercounting of project benefits and explain your reasoning in the documentation.
  • If there are three more events including the two known RI events, then input all the events as unknown RI events and let the tool estimate the RIs and group the results.
How should an applicant account for the benefits of a project that affect riders of other systems, for example a ferry project that would provide additional service in the event of a disaster? The HMCE analysis for this type of proposal would show its benefits entirely in the value of passenger time. The analysis should describe the number of passengers who would have shortened trips, or who would be able to get to work when their other travel mode is out of service. Note that this type of project could have a positive cost effectiveness ratio even if it does not reduce any direct damages, provided that the social benefits of the project are large relative to the project cost. FTA will carefully evaluate the methodology used to estimate social benefits in cases where the affected infrastructure is owned or operated by a separate entity. As in other parts of the HMCE analysis, information from previous disasters would be valuable in documenting the impact on passengers.
Can we assume that certain assets would experience increased utilization during a 100-year storm event? For example, a secondary terminal could see an increased number of passengers if damage restricts access to a primary terminal. Yes, it can be assumed that certain assets would experience increased utilization during a 100-year storm event; however, data documentation must be provided to support this assumption indicating 1) the historical precedence for the assumption, 2) the estimated level of increased utilization, and 3) the basis for the estimated increase. In general, assumptions based on predicted behavior will require much more stringent documentation than for historic events.
Can we propose mitigations whose sole or primary benefit is preventing disruption, rather than protecting an asset? For example, enhanced drainage in a yard could mitigate nuisance rain storms that previously resulted in service delays, but little to no physical asset damage. Yes, a project that prevents disruptions in the case of a disaster, even if an asset is not damaged, could be eligible. For example, a hurricane might submerge the entrance to a bus depot, thereby affecting service but not damaging the facility.
Regarding nuisance events, please be aware that funding in this program is designed to minimize impacts or prevent damage from infrequent extreme weather events and other disasters, which generally means those with a recurrence interval of 10 years or more. A project that protects assets against exposure to typical weather, but has no benefit in a disaster scenario, is not eligible for resilience funding. However, if a project protects against a disaster, but also provides benefits in typical conditions, the application may present these and other ongoing benefits as reduced operations and maintenance costs over the project’s lifespan.
Can mitigation of chronic climate-related damages be considered a competitive grant objective? For example, preventing repeated exposure to rainwater flooding into sidewalk vent gratings, which gradually diminishes the useful life of assets. No. Resilience projects must be designed to reduce damages and losses from extreme weather events and other disasters, not to protect assets from exposure to typical weather patterns and other environmental factors. If a project protects against a disaster, but also provides benefits in typical conditions, the application may present these and other ongoing benefits as reduced operations and maintenance costs over the project’s lifespan.
Does the HMCE tool treat historic damages and expected damages differently? No. The HMCE tool treats expected damages and historic damages in the same manner to estimate project benefits. However, because expected damages and historic damages are determined differently, there are different rules for their use (described below), and the HMCE tool cannot conduct an analysis based on a combination of expected and historic damages.
  • Historic damages are based on records from actual past disaster events. Since the recurrence intervals (RIs) of historic damage events may be known or unknown, the HMCE tool is capable of conducting analyses of historic damages with events of known RIs, unknown RIs, or a combination unknown and known RIs. (Refer to the HMCE Tool User Guide for additional details.) Historic damages must be documented based on damage reports, insurance claims, or other historic records.
  • Expected damages are based on damages predicted from a theoretical model or engineering analysis. For this reason, expected damages tend to be more difficult to justify than historic damages, and unlike historic damage events, the RIs of expected damage events must be known. The HMCE tool is capable of conducting analyses of expected damages with one or more events of known RIs. (Refer to the HMCE Tool User Guide for additional details.) Expected damages must be documented based on complete theoretical damage models, engineering analysis, or applicable historic damages with similar characteristics.
What should an applicant consider in deciding whether a project is scalable? Applicants should indicate when a resilience project can be undertaken either in multiple phases or multiple independent elements, provided that each phase or element can be completed independently and will serve to make the transportation system more resilient. If funding is not available for an entire project, FTA may consider awarding funds for one or more scalable project phases or elements. Applicants should identify the proposed scope and reduced funding amount for each scalable alternative, and must complete a separate HMCE analysis for each alternative.
How many HMCE analyses are required for scalable projects? Applicants should submit one HMCE analysis for each proposed funding amount, including the total funding request and any reduced alternatives.
May an applicant request funding for repair and recovery costs that include resilience improvements under the competitive resilience NOFA? No. This Competitive Resilience NOFA is for resilience projects only, which may include upgrades or other improvements to existing assets. Recovery project should be funded from the initial Category 1-3 allocations or the pro-rated recovery allocations published by FTA on March 28, 2013 and May 29, 2013. If an agency has repair and recovery costs exceeding the amount that has been allocated to date (less any insurance settlements), they should discuss this with FTA.
Is there a defined time limit on expending resilience funds? Although Section 904(c) of the Disaster Relief Act requires that funds received under the Disaster Relief Act be expended within two years of obligation, OMB issued a waiver of this requirement for grants awarded under FTA’s Emergency Relief Program. In issuing this waiver, OMB stated an expectation that Federal agencies and grantees will work together to ensure that funds obligated under the Disaster Relief Act are expended in a timely manner.
Based on the complexity of projects we expect to be submitted, FTA expects to award funds for major capital projects that will take multiple years to complete. While there is not a defined timeframe in which these funds must be expended, all projects must be undertaken and completed in accordance with the project grant agreement and all identified milestones.
If a project comes in under budget, or does not require the full amount awarded, what happens? Any funds awarded for a competitively selected project must be used for that project, consistent with the scope identified in the project proposal. If a project is completed under budget, any remaining funds must be returned to FTA. If funds cannot be used to complete the project as proposed, FTA should be notified immediately, so that funds can be reallocated through the program.
Where can we find the Rebuild by Design risk criteria referenced in the NOFA? This information can be found at: http://www.rebuildbydesign.org/research/vulnerabilities
If a project is not selected for competitive funding, can it be undertaken using other FTA ER funds? As an alternative to the competitive resilience NOFA, some projects may also be eligible for funding that FTA allocated to certain agencies for locally prioritized resilience projects on May 29, 2013. In general, these local priority resiliency funds were intended for resiliency improvements that are integrated with a repair project, or for stand-alone projects that are not complex and/or need to be completed quickly. Grantees should contact their regional office, which must approve local priority resiliency projects.