The Pew Charitable Trusts on Feb. 11, 2021, submitted comments in response to the Federal Emergency Management Agency’s (FEMA’s) proposal to change how it determines whether states qualify for certain types of federal disaster recovery funds. Pew’s letter acknowledged that certain criteria FEMA uses to inform its recommendations regarding major disaster declarations—which trigger federal assistance to communities—are outdated and have contributed to an increase in such declarations in recent decades.
However, Pew noted that one of the agency’s suggested adjustments, incorporating states’ Total Taxable Resources, is an imprecise measure of state fiscal capacity, and the letter recommended that FEMA consider more nuanced measures. Further, Pew’s comments pointed out that the proposal risks simply shifting disaster costs from one level of government to the other, rather than contributing to FEMA’s goal of increasing nationwide resilience.
Ultimately, Pew argued that FEMA should delay the rulemaking and convene a stakeholder working group to consider opportunities for enhanced investment in pre-disaster mitigation in addition to strategies to limit the number of presidential disaster declarations. Such a working group could offer insight into how the declaration metrics might be revised to reward states for taking important mitigation actions, such as updating building codes and siting requirements for critical facilities, or improving flood plain management.
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