Comment Submitted by Malissa Potter, South Carolina Emergency Management

The South Carolina Emergency Management Division fully supports the proposed change to the submission requirements for state mitigation plans. Extending the required plan update cycle from three years to five years is cost beneficial, aligns the state with local mitigation plan update requirements, and provides states with additional time and funds to implement proposed mitigation actions. The update process of a state mitigation plan is quite lengthy and expensive. States pay hundreds of thousands of dollars to update their plan every three years. A significant cost savings would result from this proposed change. With the elimination of all pre-disaster federal mitigation funds, a three year update cycle would pose a financial burden on states as there is little other funding available for this activity. In addition, the update process is extremely arduous and takes a great deal of time and personnel. Under current requirements, a plan update takes the entire three years allotted to be completed. By extending the cycle to a five year period, states could spend more time and funds implementing the proposed mitigation actions listed in the plan. A five year cycle will solve many of the issues the states face as they attempt to reduce the loss of life and property from natural hazard events.