By Ed Somers
December 12, 2005

On November 2, the Department of Homeland Security (DHS) released new funding guidelines for first responder grants that place a greater emphasis on risk and need in the allocation of funding. A greater focus on risk was a major recommendation of the 9/11 Commission, which just recently issued a report card highly critical of Washington. However, the new focus on risk approved by Congress does not go as far as the Commission had recommended.

As previously reported, funding for first responder block grants was cut by Congress from $1.1 billion to $550 million, and funding for high-threat urban areas was cut from $860 million to $765 million. A major reason for these cuts were complaints from Congress that states have failed to spend previously approved federal homeland security funding.

The FY 2006 Homeland Security Grant Program Guidance and Application Kit ties together core DHS Preparedness Directorate Office of Grants and Training (OG&T, formerly the Office of State and Local Government Coordination and Preparedness) grant programs into a unified application process. The five programs included in the FY 2006 HSGP are:

• State Homeland Security Program (SHSP) – $550 million.

• Urban Areas Security Initiative (UASI) – $765 million.

• Law Enforcement Terrorism Prevention Program (LETPP) – $400 million.

• Metropolitan Medical Response System (MMRS) – $30 million.

• Citizen Corps Program (CCP) – $20 million.

All of this funding continues to flow through the states, and with the exception of the Citizen Corps Program, 80 percent is to be passed-through to local governments within 60 days of receipt. Also, the funding continues to be exempt from the Cash Management Improvement Act which means that cities can draw down funding up to 120 days prior to expenditure.

Total national personnel costs are capped at 15 percent. Overtime is capped at 25 percent of a grant and allowed under the UASI program for Yellow Alert levels or higher, and under the law enforcement program at Orange Alert levels or higher or Yellow for border security activities. Overtime is also allowed for critical infrastructure protection and investigation and intelligence sharing. In addition, a new provision allows for funding to be used for the hiring of state or local intelligence analysts.

Funding for SHSP, UASI, and LETPP in FY 2006 is being allocated based on risk and need. To request FY 2006 HSGP funds, states will submit grant applications for evaluation in a peer-review process. Funding then will be allocated to states based, in part, on demonstrated risk and need.

Each state and territory will receive a base allocation under SHSP and LETPP according to the USA PATRIOT Act formula (0.75 percent for states). The remainder of funds will be allocated based on: 1) an analysis of risk at the state and urban area levels, and 2) the effectiveness of state and urban area grant proposals in reducing their identified needs.

Risk will be assessed at the federal level using two risk calculations: 1) asset-based terrorist risk; and 2) geographically-based terrorist risk. These risk calculations are summed to produce a total terrorism risk score.

Need will be evaluated through a competitive review process. States will identify needs via the Program and Capability Review and develop Initiatives to address these needs. States and urban areas will submit an investment justification showing how funding will be used to support initiatives. Applications will be evaluated based on the effectiveness of the plan to address identified priorities and thereby reduce overall risk.

As U.S.MAYOR went to press, the list of eligible UASI areas had not been released. However, according to DHS officials, there will be a number of key changes to the program this year.

Unlike past years, UASI areas will not be provided a specific funding level at the start of the application process. Instead, areas chosen by DHS to apply for UASI funding will be judged based on their risk level and needs. After this, DHS will compare the UASI applications and risk factors, and then allocate funding.

There may also be some changes to the boundaries of urban areas.

The application kit was released on December 2. States will have 90 days to submit grant applications, which are due March 2, 2006. DHS will evaluate applications and act on awards no later than May 31, 2006.

The application kit and a useful PowerPoint overview compiled by DHS are available at usmayors.org. In addition, once information is released on the UASI grants that also will be posted on the web.