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?

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