FEMA Canceled Its Biggest Disaster Prevention Program. 22 States Sued. The Money Is Back.

Americans collectively spent an estimated $1 trillion on disaster recovery and insurance in 2024 — roughly 3% of GDP. That number is growing every year as wildfires, floods, hurricanes, and extreme heat events intensify. The federal government's primary tool for reducing those costs before disasters strike — rather than paying for them afterward — is a FEMA program called Building Resilient Infrastructure and Communities, or BRIC. In April 2025, the Trump administration killed it.

Thirteen months, one federal lawsuit, and two court orders later, BRIC is back. FEMA opened applications on March 26, 2026, making $1 billion available for fiscal years 2024 and 2025 combined. The deadline is July 23. But the program that returned isn't quite the one that was canceled, and the communities that need it most may struggle to compete under its new rules.

How the Program Died and Came Back

BRIC was established by the Disaster Recovery Reform Act of 2018 — bipartisan legislation that President Trump himself signed during his first term. The program's premise was straightforward: spend federal money on resilience projects before disasters hit, reducing the far larger costs of emergency response and recovery afterward. Between fiscal years 2020 and 2023, FEMA obligated approximately $1 billion through BRIC out of roughly $4.6 billion in selected awards. Projects included school safe rooms in tornado-prone states, utility hardening against hurricanes, flood-prone facility relocations, and pump station improvements.

In April 2025, acting FEMA administrator Cameron Hamilton canceled the program, calling it "wasteful and ineffective." No replacement was announced. Billions in pending applications were frozen. States and localities that had spent months developing proposals — many with engineering plans already at 60% or 90% design — were left with sunk costs and no path forward.

Twenty-two Democratic-led states plus Washington, D.C. sued. The plaintiff coalition was geographically and politically diverse by design, including blue states like California and Maryland, swing states like Arizona, Pennsylvania, Wisconsin, and North Carolina, and states where disaster resilience isn't a partisan issue because the hurricanes, tornadoes, and floods don't check voter registration. The Carnegie Endowment for International Peace framed the lawsuit in national security terms: when 3% of GDP goes to disaster costs, resilience isn't an environmental issue. It's an economic survival issue.

U.S. District Judge Richard G. Stearns ruled in December 2025 that the cancellation was unlawful. In March 2026, he issued an additional order directing FEMA to take concrete steps toward restoration. FEMA complied within the required 21-day timeframe, publishing the Notice of Funding Opportunity on March 25 and opening the application portal the following day.

The legal victory was decisive but narrow. The court ordered FEMA to resume the program Congress had authorized. It didn't — and couldn't — order the administration to run it enthusiastically.

$1 Billion, But Not the Same $1 Billion

The revived BRIC program combines two fiscal years of funding into a single application cycle, creating both opportunity and unusual competitive pressure.

The $1 billion breaks down as follows: $757 million in a national competition open to all eligible applicants, with individual project caps of $20 million. $112 million in state and territory allocations, capped at $2 million per applicant. $50 million set aside for Tribal Nations. And $81 million in building code incentive funding for communities that adopt and enforce modern building codes.

The per-applicant ceiling across all categories is 15% of total funding — $150 million — preventing any single state from dominating the allocation. Applications flow through state emergency management agencies, which serve as the official applicants on behalf of local jurisdictions. This means local governments don't apply directly to FEMA; they submit subapplications to their states, which package and prioritize them before forwarding to FEMA.

That intermediary role matters. States typically establish their own pre-application deadlines well before FEMA's July 23 cutoff. If you're a local jurisdiction planning to apply, contact your state hazard mitigation officer now — their internal deadline may be weeks earlier than the federal one.

The Rules Changed While It Was Gone

The revived NOFO includes several significant changes from previous BRIC cycles that reshape who can compete effectively.

Infrastructure takes priority. The new scoring criteria place stronger emphasis on projects that directly improve physical infrastructure resilience — transportation systems, utilities, water infrastructure, and critical facilities. This is a departure from earlier cycles that gave roughly equal weight to community capacity-building, planning, and nature-based solutions.

Design readiness is now decisive. Projects at 90-100% design completion receive maximum scoring points — up to 30 points out of the total. The minimum threshold for eligibility is 30% design. This is a dramatic shift. In previous cycles, communities could apply with conceptual proposals and use BRIC funding to advance design. Now, the scoring system heavily rewards projects that are essentially shovel-ready, penalizing communities that haven't already invested in engineering and design.

Planning grants are gone. Hazard Mitigation Plans are no longer eligible for BRIC funding. Standalone planning activities and general training programs have also been removed from the capability-building category. Communities that relied on BRIC to fund their planning infrastructure will need to find other sources.

First-time applicants get a boost. In a partial acknowledgment that the new rules disadvantage less-experienced communities, FEMA is awarding additional scoring points to jurisdictions that have never received BRIC funding. It's a modest counterweight to the design-readiness requirements that structurally favor well-resourced applicants.

Island territories get cost-share relief. FEMA will waive the non-federal cost share for insular areas — the U.S. Virgin Islands, Guam, American Samoa — on projects with matches under $200,000. Given the catastrophic disaster exposure and limited tax bases of these territories, this provision could be the difference between participation and exclusion.

The Equity Problem the Rules Create

The design-readiness scoring creates a structural advantage for communities that can afford to invest in engineering before they know whether federal funding will materialize. Wealthy suburban counties with dedicated planning departments and engineering firms on retainer can maintain a portfolio of shovel-ready projects. Rural counties, tribal communities, and low-income urban neighborhoods — often the most disaster-vulnerable — typically can't.

This is the tension at the heart of the revived program. The administration canceled BRIC by calling it wasteful. The court forced it back. The new rules optimize for speed and execution efficiency — reasonable goals in isolation. But they also concentrate funding in communities that already have the institutional capacity to compete, potentially leaving the most vulnerable populations behind.

The Carnegie Endowment analysis put it bluntly: BRIC funding has historically been "concentrated in areas with existing technical capacity and financial resources, leaving vulnerable communities underserved." The new design-readiness requirements may amplify that pattern rather than correct it.

States can partially mitigate this by using their allocation funding — the $2 million per state — to support planning and technical assistance for underserved communities. Some states have already announced technical assistance programs for first-time BRIC applicants. But the national competition, where the bulk of the money sits, will reward readiness over need.

Who Should Apply — and How to Win

Despite the compressed timeline and new rules, the combined FY2024-2025 cycle represents the largest single BRIC funding opportunity ever offered. The 120-day application window — generous by federal standards — gives prepared applicants enough time to assemble competitive submissions.

The strongest applications will share several characteristics:

Shovel-ready infrastructure projects. If you have a resilience project at 90% design or higher — a seawall upgrade, utility undergrounding, critical facility relocation, stormwater system improvement — this cycle is built for you. The scoring system rewards projects that can move to construction quickly. Quantify your benefit-cost ratio explicitly and use FEMA's BCA toolkit to demonstrate that every federal dollar invested prevents multiple dollars in future disaster losses.

Alignment with NOFO language. The scoring criteria include specific terminology — "future conditions," "risk reduction," "community lifelines" — that reviewers are trained to look for. Mirror the NOFO's language in your subapplication. This isn't about gaming the system; it's about demonstrating that your project addresses the criteria FEMA will actually evaluate.

State coordination. Your state hazard mitigation office is both gatekeeper and ally. States prioritize subapplications before forwarding them to FEMA, and some states provide technical review and feedback before submission. Engage your state office early, attend their webinars, and ask explicitly about their internal prioritization criteria. Some states rank projects by benefit-cost ratio; others prioritize geographic equity or alignment with state hazard mitigation plans.

Right-sized scope. The $20 million per-project cap is a ceiling, not a target. Smaller, well-defined projects with clear benefit-cost ratios often score higher than ambitious mega-projects with uncertain timelines. If your full resilience plan costs $50 million, identify the $8-12 million component that delivers the most measurable risk reduction and apply for that.

Outreach documentation. Up to 10% of project funding can support outreach activities tied to infrastructure resilience outcomes. If your project involves community notification systems, evacuation route improvements, or public shelter access, document the outreach component as an integral part of the project — not an afterthought.

The Bigger Picture: Resilience as Policy Battleground

BRIC's cancellation and court-ordered revival exposed a fundamental disagreement about whether the federal government should invest in preventing disasters or only in responding to them. The administration's position — that the program was wasteful — implicitly argued for the latter. The court's ruling — that the cancellation violated the law Congress passed — reaffirmed the former.

That disagreement isn't resolved. The administration complied with the court order, but nothing prevents future efforts to restrict the program's scope, reduce its funding, or impose additional conditions that achieve cancellation by other means. The FY2027 budget request, which proposes significant cuts across domestic spending, hasn't specified BRIC's funding level — an ambiguity that could be ominous or merely bureaucratic.

For communities considering whether to invest the time and resources in a BRIC application, the calculus is pragmatic: $1 billion is available right now, applications close July 23, and the program may or may not exist in this form for future cycles. The uncertainty is itself a reason to apply — this may be the window.

The disasters, meanwhile, aren't waiting for policy consensus. FEMA's own data shows that every $1 invested in hazard mitigation saves $6 in future disaster costs. At $1 trillion in annual disaster spending, the math argues for dramatically more prevention investment, not less. Whether the political system catches up to the arithmetic remains an open question. For now, the application portal is open, and tools like Granted can help communities identify their strongest project concepts and build competitive proposals before the July deadline.