Many New FEMA IS Courses

The month of February saw a huge release of new FEMA Independent Study (IS) courses.  Most of these address topics within the public assistance (PA) program, and get into the nitty gritty items that can delay processing of PA paperwork after a federal declaration.  Lots of good info here applicable to public works and highway managers, PA specialists, finance specialists, and emergency managers as a whole. The new courses are listed below.

 

-TR

Disaster Aid Approved for Houses of Worship

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

Emergency Preparedness Solutions, LLC SM

FEMA Public Assistance Thresholds aka Do Your Research

I just received my April edition (number 627) of the Natural Hazards Observer (NHO), a bi-monthly publication of the Natural Hazards Center of the University of Colorado at Boulder. As of my posting of this article, they have not yet posted the April edition on their website, but they are likely to do so shortly.  My desire with this particular post is to encourage a thorough analysis of the topic at hand rather than an extremely narrow perspective as was published in the NHO.

First, I feel a need to mention that The Natural Hazards Observer and I have a tenuous on again, off again relationship. I’ve become rather disenchanted with their articles in the past; occasionally disagreeing completely with authors’ premise and approach (not that everyone is necessarily agreeable to mine). I’ve even written the NHO about the fact that a University center whose goal is to research disasters has presented articles that, to me, come across at times as unprofessional and not well thought out. I’m not really knocking the NHO nor is my intent to pick a fight, rather I’ve been trying to be constructive with them.  Given their foundation, I think their readers expect a more scholarly approach. While there is certainly plenty of good information to find in the NHO, some seems questionable. One of their tag lines is ‘Disaster Research News You Can Use’. I often find that their articles have little to do with research, such as the one I cite below, and are really more of a media regurgitation. There are other, more appropriate forums for that – like blogging – rather than a publication that advertises research.

That said, my particular beef with this edition is the first article, titled ‘All’s Not Fair: Illinois Battles Over Being Too Big To Feel FEMA’s Love’. I encourage you to read the article for yourself and form your own impressions. To sum up the general idea of the article, folks in Illinois are questioning FEMA’s Public Assistance (PA) program thresholds for disaster recovery. Specifically, they take issue with these thresholds being based on per-capita amounts. They argue that larger, more populous, states are discriminated against (their words); and further stating that a larger population doesn’t necessarily equate to a state’s ability to self-fund disaster recovery efforts.

Public Assistance (PA), by the way, is focused on recovering public infrastructure (roads, bridges, public buildings, etc.), whereas Individual Assistance (IA) provides direct assistance to individuals to help cover uninsured losses.

When first reading this, two particular issues stood out to me. 1) They don’t mention the fact that FEMA will also examine a county’s per-capita damages for potential declarations, and 2) High populated states quite frequently receive disaster declarations.

The Texas Department of Public Safety has a great document which summarizes the state and county thresholds for 2014. The NHO article makes no mention of the county threshold, which is where most PA declarations are decreed – for a county or counties, rather than the entire state. While the county threshold is higher, it would generally be easier for a localized disaster to be declared (PA) than the entire state, which is mostly unaffected.

As for state declarations, FEMA provides a great summary by state of major declarations (this is the specific number to look at in this case), emergency declarations, and fire management declarations. By scanning down the list, you’ll see that states like Texas, Florida, California, New York, and Louisiana are among the top contenders for declarations. Other large and more populous states, such as Illinois, are not far behind them. This pretty much blows a hole in the premise that larger, more populated states are ‘discriminated against’. Having been in this business for a while, I know that sometimes you win (the request for a declaration) and sometimes you lose. It makes a significant argument for states to have disaster reserve funds.

All that aside; are there issues of fairness in this traditional per-capita assessment of damages within the disaster declaration process? There may certainly be. The assumption of the current process is that a more populous state has a greater tax base from which to draw funds for disaster relief. This assumption, at a glance, makes sense, but may not be the most fair way of determining if a state warrants assistance.  The most significant arguments against this seem to be 1) A lower relative mean income as compared to other states translates into a lower tax base, and 2) Is the tax base even a fair measure of need/capability for a state?

An interesting read on this is a GAO report from 2012. It seems to me, a guy who is not a FEMA disaster recovery expert – but I’ve been around the block a few times – that there are some issues of fairness and perhaps better ways to assess a state’s true need for Federal assistance. A fair discussion of this topic, however, requires having a 360 degree perspective of all the issues involved. Perhaps it’s a good topic for a research journal?