Earlier this year, FEMA expanded their Public Assistance program to include houses of worship.  As the FEMA news release linked here states, the Stafford Act allows FEMA to provide Public Assistance (PA) to certain private not for profit organizations to repair or replace facilities damaged or destroyed by a major disaster.  In a move that seems to underscore FEMA’s change in policy, the President signed a bill into law a few days ago making this policy decision permanent.  Both the policy and the bill back-dated impacts to include Hurricane Harvey.

This is a decision that I’m honestly torn on.  On one hand, houses of worship serve as community centers, shelters, and points of distribution in many communities.  Some (but not all) provide critical services for their communities during disasters.  Aside from the spiritual aspect, these are organizations that communities turn to in time of need.  In fact, there exist a number of faith-based organizations that support disaster response and recovery that do incredible work.  Faith-based organizations are a critical partner in communities, and across the nation and the world.  On the other hand, I’m not certain about the government’s responsibility to fund the rebuilding of houses of worship – most especially if they do not serve the purpose of an approved shelter, point of distribution, or other sanctioned disaster-related activity in a community’s disaster plan.

FEMA’s PA guidelines can be very stringent.  The reason for this is to ensure responsible expenditure of taxpayer dollars in helping communities to recover from disaster.  In work as a state employee and as a consultant I’ve sat in meetings with FEMA in the aftermath of disasters working to ensure that eligible applicants were submitting the appropriate paperwork for eligible projects and receiving everything afforded to them under FEMA policy and the Stafford Act.  This process is bureaucratic and, at times, contentious.   The burden of proof is on the applicant to prove that they are, in fact, eligible to receive recovery assistance, and each category of projects has very specific guidelines.

Given this, to ensure fair application of tax payer dollars, I expect to see guidelines in FEMA’s PA guidebook update that require certain conditions to be met for houses of worship to be eligible to receive PA assistance after a disaster.  These would include:

• Being part of the community’s emergency operations plan for key activities such as sheltering, points of distribution, etc.
  • As with any facility identified for these key activities, I believe they should embrace practices of resilience. That includes having their own emergency operations and business continuity plans as well as a documented history of proactive disaster mitigation projects for their properties (these don’t have to be complex or expensive.  Generators, sump pumps, and preventative landscaping are reasonably simple and high impact)
• Practices of non-discrimination, especially during times of disaster, to include providing for people of all faiths
• The PA policy itself should not discriminate against any particular religion

I’m interested in hearing your thoughts on this topic.

© 2018 Timothy Riecker, CEDP

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