[House Hearing, 117 Congress]
[From the U.S. Government Publishing Office]




 
                       FEMA PRIORITIES FOR 2022:
                        STAKEHOLDER PERSPECTIVES

=======================================================================

                                (117-41)

                             REMOTE HEARING

                               BEFORE THE

                            SUBCOMMITTEE ON
    ECONOMIC DEVELOPMENT, PUBLIC BUILDINGS, AND EMERGENCY MANAGEMENT

                                 OF THE

                              COMMITTEE ON
                   TRANSPORTATION AND INFRASTRUCTURE
                        HOUSE OF REPRESENTATIVES

                    ONE HUNDRED SEVENTEENTH CONGRESS

                             SECOND SESSION

                               __________

                           FEBRUARY 16, 2022

                               __________

                       Printed for the use of the
             Committee on Transportation and Infrastructure
             
             
 [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]             
             


     Available online at: https://www.govinfo.gov/committee/house-
     transportation?path=/browsecommittee/chamber/house/committee/
                             transportation
                             
                             
                            ______                       


             U.S. GOVERNMENT PUBLISHING OFFICE 
47-872PDF           WASHINGTON : 2022 
                             
                             


             COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE

  PETER A. DeFAZIO, Oregon, Chair
SAM GRAVES, Missouri                 ELEANOR HOLMES NORTON,
DON YOUNG, Alaska                      District of Columbia
ERIC A. ``RICK'' CRAWFORD, Arkansas  EDDIE BERNICE JOHNSON, Texas
BOB GIBBS, Ohio                      RICK LARSEN, Washington
DANIEL WEBSTER, Florida              GRACE F. NAPOLITANO, California
THOMAS MASSIE, Kentucky              STEVE COHEN, Tennessee
SCOTT PERRY, Pennsylvania            ALBIO SIRES, New Jersey
RODNEY DAVIS, Illinois               JOHN GARAMENDI, California
JOHN KATKO, New York                 HENRY C. ``HANK'' JOHNSON, Jr., 
BRIAN BABIN, Texas                   Georgia
GARRET GRAVES, Louisiana             ANDRE CARSON, Indiana
DAVID ROUZER, North Carolina         DINA TITUS, Nevada
MIKE BOST, Illinois                  SEAN PATRICK MALONEY, New York
RANDY K. WEBER, Sr., Texas           JARED HUFFMAN, California
DOUG LaMALFA, California             JULIA BROWNLEY, California
BRUCE WESTERMAN, Arkansas            FREDERICA S. WILSON, Florida
BRIAN J. MAST, Florida               DONALD M. PAYNE, Jr., New Jersey
MIKE GALLAGHER, Wisconsin            ALAN S. LOWENTHAL, California
BRIAN K. FITZPATRICK, Pennsylvania   MARK DeSAULNIER, California
JENNIFFER GONZALEZ-COLON,            STEPHEN F. LYNCH, Massachusetts
  Puerto Rico                        SALUD O. CARBAJAL, California
TROY BALDERSON, Ohio                 ANTHONY G. BROWN, Maryland
PETE STAUBER, Minnesota              TOM MALINOWSKI, New Jersey
TIM BURCHETT, Tennessee              GREG STANTON, Arizona
DUSTY JOHNSON, South Dakota          COLIN Z. ALLRED, Texas
JEFFERSON VAN DREW, New Jersey       SHARICE DAVIDS, Kansas, Vice Chair
MICHAEL GUEST, Mississippi           JESUS G. ``CHUY'' GARCIA, Illinois
TROY E. NEHLS, Texas                 ANTONIO DELGADO, New York
NANCY MACE, South Carolina           CHRIS PAPPAS, New Hampshire
NICOLE MALLIOTAKIS, New York         CONOR LAMB, Pennsylvania
BETH VAN DUYNE, Texas                SETH MOULTON, Massachusetts
CARLOS A. GIMENEZ, Florida           JAKE AUCHINCLOSS, Massachusetts
MICHELLE STEEL, California           CAROLYN BOURDEAUX, Georgia
                                     KAIALI`I KAHELE, Hawaii
                                     MARILYN STRICKLAND, Washington
                                     NIKEMA WILLIAMS, Georgia
                                     MARIE NEWMAN, Illinois
                                     TROY A. CARTER, Louisiana
                                ------                                

      Subcommittee on Economic Development, Public Buildings, and
                          Emergency Management

     DINA TITUS, Nevada, Chair
DANIEL WEBSTER, Florida              ELEANOR HOLMES NORTON,
THOMAS MASSIE, Kentucky                District of Columbia
JENNIFFER GONZALEZ-COLON,            SHARICE DAVIDS, Kansas
  Puerto Rico                        CHRIS PAPPAS, New Hampshire, Vice 
MICHAEL GUEST, Mississippi           Chair
BETH VAN DUYNE, Texas                GRACE F. NAPOLITANO, California
CARLOS A. GIMENEZ, Florida           JOHN GARAMENDI, California
SAM GRAVES, Missouri (Ex Officio)    TROY A. CARTER, Louisiana
                                     PETER A. DeFAZIO, Oregon (Ex 
                                     Officio)
                                     


                                CONTENTS

                                                                   Page

Summary of Subject Matter........................................     v

                 STATEMENTS OF MEMBERS OF THE COMMITTEE

Hon. Dina Titus, a Representative in Congress from the State of 
  Nevada, and Chair, Subcommittee on Economic Development, Public 
  Buildings, and Emergency Management, opening statement.........     1
    Prepared statement...........................................     3
Hon. Daniel Webster, a Representative in Congress from the State 
  of Florida, and Ranking Member, Subcommittee on Economic 
  Development, Public Buildings, and Emergency Management, 
  opening statement..............................................     4
    Prepared statement...........................................     5
Hon. Peter A. DeFazio, a Representative in Congress from the 
  State of Oregon, and Chair, Committee on Transportation and 
  Infrastructure, opening statement..............................     5
    Prepared statement...........................................     6
Hon. Sam Graves, a Representative in Congress from the State of 
  Missouri, and Ranking Member, Committee on Transportation and 
  Infrastructure, prepared statement.............................    53

                               WITNESSES

Chris P. Currie, Director, Homeland Security and Justice, U.S. 
  Government Accountability Office, oral statement...............     8
    Prepared statement...........................................     9
Erica Bornemann, Director, Vermont Emergency Management, on 
  behalf of the National Emergency Management Association, oral 
  statement......................................................    17
    Prepared statement...........................................    18
Carolyn J. Harshman, MPA, CEM, President, International 
  Association of Emergency Managers, oral statement..............    27
    Prepared statement...........................................    29

                       SUBMISSIONS FOR THE RECORD

Submissions for the Record by Hon. Dina Titus:
    Statement of the American Flood Coalition....................    53
    Statement of June Isaacson Kailes, Disability Policy 
      Consultant.................................................    55
    Statement of the National Association of Home Builders.......    57
    Statement of the Reinsurance Association of America..........    64
    Statement of the Union of Concerned Scientists...............    77
    Statements from 10 Stakeholder Organizations \\......    85

                                APPENDIX

Question from Hon. Eleanor Holmes Norton to Erica Bornemann, 
  Director, Vermont Emergency Management, on behalf of the 
  National Emergency Management Association......................    87

----------
\\ The 10 stakeholder organizations are: Association of State 
Floodplain Managers, Inc., BuildStrong Coalition, International 
Association of Fire Chiefs, National League of Cities, National Low 
Income Housing Coalition, Natural Resources Defense Council, National 
Rural Electric Cooperative Association, The Pew Charitable Trusts, The 
Refuge Resource Group, and SmarterSafer Coalition.




                           February 11, 2022

    SUMMARY OF SUBJECT MATTER

    TO:      LMembers, Subcommittee on Economic Development, 
Public Buildings, and Emergency Management
    FROM:  LStaff, Subcommittee on Economic Development, Public 
Buildings, and Emergency Management
    RE:      LSubcommittee Hearing on ``FEMA Priorities for 
2022: Stakeholder Perspectives.''
_______________________________________________________________________


                                PURPOSE

    The Subcommittee on Economic Development, Public Buildings, 
and Emergency Management will meet on Wednesday, February 16, 
2022, at 2:00 p.m. in 2167 Rayburn House Office Building and 
via Zoom to receive testimony on ``FEMA Priorities for 2022: 
Stakeholder Perspectives.'' At the hearing, Members will 
receive testimony from witnesses who are emergency management 
experts and represent key external Federal Emergency Management 
Agency (FEMA stakeholders to gauge their perspective regarding 
what efforts the agency should prioritize in this year. The 
Subcommittee will hear from the U.S. Government Accountability 
Office (GAO), National Emergency Management Association, and 
International Association of Emergency Managers.

                               BACKGROUND

    When disaster strikes, state, territorial, and Tribal 
governments may request the President declare a major disaster 
or emergency pursuant to the Robert T. Stafford Disaster Relief 
and Emergency Assistance Act (Stafford Act).\1\ If the 
president declares a major disaster or emergency, FEMA is 
authorized to provide response and recovery assistance in the 
form of individual assistance, public assistance, or both 
funded from the Disaster Relief Fund.
---------------------------------------------------------------------------
    \1\ 42 U.S.C. Sec.  5121 et seq.
---------------------------------------------------------------------------
    FEMA also provides assistance through specialized programs 
and grants to assist state, local, Tribal, and territorial 
governments prepare for, mitigate against, and respond to 
disasters. These include the Emergency Management Assistance 
Compact (EMAC) which facilitates mutual aid across 
jurisdictions; \2\ the Urban Search and Rescue (USAR) teams 
which are deployed to support search and rescue options; \3\ 
Emergency Management Performance Grants (EMPG) to support 
preparation and capacity at the state and local levels of 
government; \4\ Building Resilience Infrastructure and 
Communities (BRIC) grant program supporting pre-disaster 
mitigation investments; \5\ and the post-disaster Hazard 
Mitigation Grant Program (HMGP).\6\
---------------------------------------------------------------------------
    \2\ 6 U.S.C. Sec.  761.
    \3\ 6 U.S.C. Sec.  722; 42 U.S.C. Sec.  5165f.
    \4\ 6 U.S.C. Sec.  762.
    \5\ Section 1234, Disaster Recovery Reform Act of 2018, Public Law 
115-254.
    \6\ 42 U.S.C. 5170c
---------------------------------------------------------------------------

PUBLIC ASSISTANCE (PA)

    Pursuant to a declaration under the Stafford Act, FEMA PA 
programs reimburse state, local, Tribal, and territorial 
governments and certain non-profit organizations for the cost 
of emergency protective measures, debris removal, and repair 
and replacement of public infrastructure damaged in a 
disaster.\7\ Due to the increased frequency and intensity of 
natural disasters, fiscal year (FY) 2020 marked the largest 
obligation for PA to date--even when excluding PA obligations 
related to COVID-19.\8\ FEMA's National Advisory Council found 
that applicants consistently report that ``the PA process feels 
disjointed, is overburdensome, and has far too many 
requirements.'' \9\ Some communities with limited resources 
have reported that navigating the PA process is so challenging 
that they opt to forgo the program.\10\
---------------------------------------------------------------------------
    \7\ GAO. (December 2021). Disaster Recovery: Additional Actions 
Needed to Identify and Address Potential Recovery Barriers. GAO-22-
104039
    \8\ CRS. (2021). FEMA's Public Assistance Program: A Primer and 
Considerations for Congress.
    \9\ National Advisory Council. (December 2021). Report to the 
Administrator. https://www.fema.gov/sites/default/files/documents/
fema_nac-2021-report-211216.pdf
    \10\ Id.
---------------------------------------------------------------------------
    PA recipients are responsible for a percentage of recovery 
costs, which is termed the non-federal cost-share.\11\ The 
President has the authority through the Stafford Act to reduce 
or waive the non-federal cost-share. FEMA recommends that the 
federal cost share be increased from 75% to 90% if the 
estimated cost of PA exceeds $151 dollars per capita.\12\ The 
Committee received testimony that suggested that even a reduced 
cost share may still be burdensome for some communities.\13\
---------------------------------------------------------------------------
    \11\ GAO. (December 2021). Disaster Recovery: Additional Actions 
Needed to Identify and Address Potential Recovery Barriers. GAO-22-
104039
    \12\ CRS. (April 1, 2021). FEMA's Public Assistance Program: A 
Primer and Considerations for Congress. https://sgp.fas.org/crs/
homesec/R46749.pdf
    \13\ Subcommittee on Economic Development, Public Buildings, and 
Emergency Management. (October 27, 2021). Hearing: Are FEMA's Programs 
Adequately Designed to Assist Communities Before, During, and After 
Wildfire? Testimony submitted by Casey Hatcher.
---------------------------------------------------------------------------
    PA funds sourced though PA mitigation and the post-disaster 
Hazard Mitigation Grant Program (HMGP) can be used by 
communities to build back more resiliently after a 
disaster.\14\ FEMA funds PA mitigation projects with a minimum 
75 percent federal share.\15\ Proposed PA mitigation projects 
are evaluated by FEMA by considering four factors: risk 
reduction, cost-effectiveness, technical feasibility, and 
compliance with applicable laws and regulations.\16\ Confusion 
surrounds the eligible uses of PA mitigation and HMGP funds for 
the same project.\17\ FEMA's Public Assistance Program and 
Policy Guide states: \18\
---------------------------------------------------------------------------
    \14\ FEMA. (2020). Mitigate Disaster Damage with FEMA Public 
Assistance. https://www.fema.gov/sites/default/files/2020-06/fema-
pa406-mitigation-brochure.pdf
    \15\ Id.
    \16\ Id.
    \17\ National Academies Press. (June 2014). Disaster Recovery 
Funding: Achieving a Resilient Future? & National Advisory Council. 
(December 2021). Report to the Administrator. https://www.fema.gov/
sites/default/files/documents/fema_nac-2021-report-211216.pdf
    https://www.ncbi.nlm.nih.gov/books/NBK316517/
    \18\ FEMA. (June 2020). Public Assistance and Policy Guide: Version 
4. https://www.fema.gov/sites/default/files/documents/fema_pappg-v4-
updated-links_policy_6-1-2020.pdf

          ``The Applicant may use both PA mitigation and HMGP 
        mitigation funds to implement mitigation measures on the same 
        facility, but not for the same work. The Applicant cannot use 
        funds from one of these mitigation programs to meet the non-
        Federal cost share of work funded under the other mitigation 
        program.''
          ``Eligible PA mitigation measures are those the Applicant 
        performs on the damaged portion(s) of the facility. If the 
        Applicant proposes mitigation measures that are distinct and 
        separate from the damaged portion(s) of the facility, FEMA 
        evaluates the proposal and determines eligibility on a case-by 
        case basis considering how the mitigation measure protects the 
        damaged portion(s) of the facility and whether the mitigation 
        measure is reasonable based on the extent of damage.''

    A survey conducted by FEMA's National Advisory Council 
found that PA applicants want to leverage mitigation funds.\19\ 
However, spending on mitigation though the PA program has not 
been consistent with the increase in spending on recovery due 
the increased frequency and intensity of natural disasters.\20\ 
The complexity of the PA mitigation and HMGP guidance has 
created an equity issue since applicants with limited resources 
are often unable to navigate this process.\21\ As a result, 
these applicants cannot build back to be more resilient, which 
increases their vulnerability and likelihood for repetitive 
loss.\22\
---------------------------------------------------------------------------
    \19\ National Advisory Council. (December 2021). Report to the 
Administrator. https://www.fema.gov/sites/default/files/documents/
fema_nac-2021-report-211216.pdf
    \20\ Id.
    \21\ Id.
    \22\ Id.
---------------------------------------------------------------------------

INDIVIDUAL ASSISTANCE (IA)

    FEMA IA programs include the Individuals and Households 
Program (IHP), Mass Care and Emergency Assistance, the Crisis 
Counseling Assistance and Training Program, Disaster 
Unemployment Assistance, Disaster Legal Services, and Disaster 
Case Management.\23\ IHP is the primary FEMA program to assist 
disaster survivors; it covers housing needs such as home 
repair, limited property replacement, and rental 
assistance.\24\ While FEMA's IA programs--authorized by the 
Stafford Act--are not intended to replace insurance or meet the 
full post-disaster needs of survivors, recent declared events 
have been a cause for concern regarding both denial rates for 
IA, as well as suspected fraudulent registrations for FEMA 
assistance.\25\
---------------------------------------------------------------------------
    \23\ FEMA. (May 2021). Individual Assistance Program and Policy 
Guide (IAPPG). https://www.fema.gov/sites/default/files/documents/
fema_iappg-1.1.pdf
    \24\ CRS. (December 5, 2019) FEMA Individual Assistance Programs: 
An Overview (R46014) https://sgp.fas.org/crs/homesec/R46014.pdf.
    \25\ NPR. (July 1, 2021). As Western Wildfires Worsen, FEMA is 
Denying Most People Who Ask for Help. As Climate Change Worsens 
Wildfires, FEMA Denies Most California, Oregon Claims : NPR
---------------------------------------------------------------------------
    In May 2021, Chairs DeFazio and Titus, along with Ranking 
Members Graves (MO) and Webster, sent a letter to the FEMA 
Administrator expressing frustration that the approval rate for 
IHP applications has reached an all-time low.\26\ Following the 
September 2020 wildfires in Oregon, FEMA denied 70 percent of 
IHP assistance requests after it filtered out applications that 
were potentially fraudulent.\27\ Following the 2017 and 2018 
fire seasons in California, 48,856 individuals applied for IHP 
and about only one-fifth received some amount of 
assistance.\28\
---------------------------------------------------------------------------
    \26\ T&I. (May 13, 2021) Letter to FEMA Administrator. https://
transportation.house.gov/news/press-releases/committee-leaders-
question-fema-after-approvals-for-disaster-survivor-aid-program-falls-
to-all-time-low.
    \27\ NPR. (July 1, 2021). As Western Wildfires Worsen, FEMA is 
Denying Most People Who Ask for Help. As Climate Change Worsens 
Wildfires, FEMA Denies Most California, Oregon Claims : NPR
    \28\ University of Pennsylvania Risk Management and Decision 
Processes Center. (April 16, 2020). Wildfires and Recovery: FEMA's 
Individual Assistance Funding Provides Important Support--But Unfunded 
Damages Remain. Wildfires and Recovery: FEMA's Individual Assistance 
funding provides important support--but unfunded damages remain--Risk 
Management and Decision Processes Center (upenn.edu)
---------------------------------------------------------------------------
    The application process for IHP has repeatedly been 
described as overwhelming and confusing by disaster 
survivors.\29\ Applicants must navigate a series of steps 
before FEMA registers a decision on their application. 
Survivors of the December 2021 Kentucky tornadoes have told 
Committee staff that their IA denial letters did not clearly 
state the reason for a denial. Without a reason for denial, 
disaster survivors feel they do not have enough information to 
successfully navigate the appeal process.
---------------------------------------------------------------------------
    \29\ GAO. (October 2019). Wildfire Disasters: FEMA Could Take 
Additional Actions to Address Unique Response and Recovery Challenges.
---------------------------------------------------------------------------
    In December 2021, GAO reported that federal recovery 
programs, including FEMA's IA programs, lack key information 
that would enable officials to identify barriers to access and 
disparate outcomes and establish processes to overcome such 
barriers and disparities.\30\ In 2021, FEMA requested authority 
from the Office of Management and Budget (OMB) to begin asking 
IA applicants for demographic information.\31\ Advocacy groups, 
such as the National Low Income Housing Coalition, have urged 
FEMA to make this data accessible to the public--once it is 
available.\32\
---------------------------------------------------------------------------
    \30\ GAO. (December 2021). Disaster Recovery: Additional Actions 
Needed to Identify and Address Potential Recovery Barriers. GAO-22-
104039.
    \31\ Id.
    \32\ E&E News. (December 3, 2021). FEMA Wants to Track Race of 
Disaster Victims for First Time. https://www.eenews.net/articles/fema-
wants-to-track-race-of-disaster-victims-for-first-time/
---------------------------------------------------------------------------

HAZARD MITIGATION ASSISTANCE (HMA)

    Implementing mitigation measures is a proven way to reduce 
the impact of natural disasters.\33\ To make communities more 
resilient to future hazard events and minimize the financial 
strain of disaster recovery, this Committee has stressed that 
investing in mitigation efforts should be a federal priority, 
and established permanent authorizations for both pre- and 
post-disaster mitigation programs as well as funding them via 
calculations from response and recovery expenses from FEMA's 
Disaster Relief Fund.\34\
---------------------------------------------------------------------------
    \33\ GAO. (February 2021). FEMA Should Take Additional Steps to 
Streamline Hazard Mitigation Grants and Assess Program Effects, GAO-21-
140.
    \34\ Robert T. Stafford Disaster Relief and Emergency Assistance 
Act (Stafford Act, P.L. 93-288, as amended), Sections 203, 404, 404(d).
---------------------------------------------------------------------------
    As with FEMA's PA program, applicants have expressed 
difficulty navigating FEMA's mitigation grants applications, 
particularly small, rural, and disadvantaged communities with 
limited staff and resources. Communities with large tax-bases 
often can afford hiring professional consultants to complete 
successful mitigation grant applications. The Committee has 
received information from small, rural, and disadvantaged 
communities that cannot afford to hire such consultants that 
they do not have the fiscal resources for consultants nor the 
staff with enough bandwidth or expertise to write grant 
applications in addition to their day-to-day emergency 
management responsibilities. FEMA's own summary of stakeholder 
feedback for its Building Resilient Infrastructure Communities 
(BRIC) grants quoted subgrantees that said the BRIC grant was, 
``too hard and not worth the time and effort to apply.'' \35\
---------------------------------------------------------------------------
    \35\ FEMA ((March 2020). Summary of Stakeholder Feedback: Building 
Resilient Infrastructure Communities (BRIC). https://www.fema.gov/
sites/default/files/2020-06/fema_bric-summary-of-stakeholder-feedback-
report.pdf
---------------------------------------------------------------------------
    Removing barriers and simplifying the mitigation assistance 
process will make FEMA's programs more equitable and 
communities more resilient. Unprecedented investments across 
FEMA's HMA suite--$500 million for BRIC and $3.5 billion for 
Flood Mitigation Assistance (FMA) as part of the recently 
enacted Infrastructure Investment and Jobs Act (IIJA, Pub. L. 
117-58), as well as the president's approval of some Hazard 
Mitigation Grant Program (HMGP) assistance for COVID-19 major 
disaster declarations--make reforming the mitigation grant 
process a timely issue.\36\
---------------------------------------------------------------------------
    \36\ CRS.(November 16, 2021). Recent Funding Increases for FEMA 
Mitigation Assistance. https://crsreports.congress.gov/product/pdf/IN/
IN11733
---------------------------------------------------------------------------

WORKFORCE CHALLENGES

    FEMA's workforce is divided into 23 cadres that are 
organized by responsibilities of work.\37\ Each cadre is 
composed of permanent full-time (PFT) workers, Cadre of On-Call 
Response Recovery Employees (CORE), and Reservists.\38\ PFTs 
are full-time workers eligible for career tenure.\39\ CORE 
employees are hired to work for a period of two to four years; 
their positions may be renewed if disaster work is ongoing at 
the end of the term and funding is available from the Disaster 
Relief Fund.\40\ Reservists serve on an on-call basis and 
assist disaster survivors and first responders on the site of 
major disasters.\41\
---------------------------------------------------------------------------
    \37\ https://www.fema.gov/careers/position-types/cadres
    \38\ Id.
    \39\ Id.
    \40\ Id.
    \41\ Id.
---------------------------------------------------------------------------
    FEMA's PFT workforce volume has remained steady over time. 
The volume of CORE and Reservist employees has increased by 
approximately 30 percent since 2018.\42\ However, in January 
2022, a FEMA panel told the GAO that the agency is still 
struggling to adequately address its workload.\43\ Every major 
disaster declaration adds to FEMA's backlog of work; presently, 
the agency is actively managing more than 1,000 incidents.\44\
---------------------------------------------------------------------------
    \42\ Federal News Network. (January 26, 2022). FEMA Suffering 
Staffing Shortages and Natural Disasters Intensify. https://
federalnewsnetwork.com/agency-oversight/2022/01/fema-suffering-
staffing-shortages-as-natural-disasters-intensify/
    \43\ Id.
    \44\ Id.
---------------------------------------------------------------------------
    Workforce challenges impact FEMA's ability to successfully 
fulfill its mission. The GAO has reported that workforce-
related issues has impacted the quality of recovery services in 
Puerto Rico; high turnover rates among employees responsible 
for overseeing PA projects has created unnecessary confusion 
according to municipal and Commonwealth of Puerto Rico agency 
officials.\45\ Low morale and inadequate training within FEMA's 
call centers prevented employees from adequately assisting 
survivors seeking IA following the catastrophic 2017 and 2018 
hurricane seasons.\46\ Most recently, burnout and low morale 
have made it challenging for FEMA's workforce to implement the 
COVID-19 funeral assistance program.\47\
---------------------------------------------------------------------------
    \45\ GAO. (January 2022). FEMA Workforce: Long-Standing Challenges 
and New Challenges Could Affect Mission Success. GAO-22-105631
    \46\ Id.
    \47\ Washington Post. (December 2021). ``My Sincere Condolences.'' 
https://www.washingtonpost.com/nation/2021/12/21/fema-covid-funeral-
assistance/
---------------------------------------------------------------------------
    In January 2022, the GAO identified three factors limiting 
FEMA's workforce readiness: \48\
---------------------------------------------------------------------------
    \48\ GAO. (January 20, 2022). FEMA Workforce: Long Standing and New 
Challenges Could Affect Mission Success. GAO-22-105631.
---------------------------------------------------------------------------
     LStaffing shortages: The 2017 and 2018 disaster 
seasons resulted in the deployment of over 10,000 FEMA 
personnel. A workforce shortage existed when the disaster 
season began and 18 of 23 cadres operated with staffing levels 
that were 25 percent lower than full capacity. Additionally, 
nearly 50 percent of FEMA reservists declined deployments to 
certain disasters citing burnout and poor working conditions in 
the field. GAO expressed concern that FEMA may be unable to 
manage a catastrophic natural disaster because of its workforce 
shortages.\49\
---------------------------------------------------------------------------
    \49\ Id.
---------------------------------------------------------------------------
     LWorkforce Qualifications: FEMA's qualification 
and training processes have not adequately kept pace with need. 
Field leaders have told GAO that new hires do not have the 
training necessary to fulfill their duties during 
deployments.\50\
---------------------------------------------------------------------------
    \50\ Id.
---------------------------------------------------------------------------
     LStaff Development: Reservists make up 35 percent 
of FEMA's workforce during a disaster deployment. Reservists 
have reported that they often receive training to fulfill their 
duties on the job site; they are unable to receive compensation 
for participating in training programs prior to a disaster 
deployment. FEMA hired 3,200 Reservists from June 2017 to May 
2019; these new hires now make up 40 percent of the Reservist 
work force. Lack of adequate training, increased frequency of 
disasters, a workplace culture that contributes to harassment 
and discrimination, and few benefits have negatively impacted 
workplace morale and retention.\51\
---------------------------------------------------------------------------
    \51\ Id.
---------------------------------------------------------------------------

CONCLUSION

    Given the recent intensity and frequency of natural 
disasters, it is critical that FEMA make reforms to improve its 
mitigation and recovery programs. Improvements to FEMA's 
workforce will enable the agency to better assist disaster 
stakeholders and survivors. The GAO has provided numerous 
recommendations to FEMA (see supplementary information) 
regarding reforms that may rectify FEMA's current 
shortcomings--many of which remain outstanding.

                              WITNESS LIST

     LChris Currie, Director, Homeland Security and 
Justice, U.S. Government Accountability Office
     LErica Bornemann, Director, Vermont Emergency 
Management, on behalf of the National Emergency Management 
Association
     LCarolyn Harshman, President, International 
Association of Emergency Managers

SUPPLEMENTARY INFORMATION

    The following are GAO recommendations to FEMA marked as 
`open':

Disaster Recovery: Additional Actions Needed to Identify and 
Address Potential Recovery Barriers. (December 2021) \52\
---------------------------------------------------------------------------
    \52\ GAO. (December 2021). Disaster Recovery: Additional Actions 
Needed to Identify and Address Potential Recovery Barriers. GAO-22-
104039
---------------------------------------------------------------------------
     LThe FEMA Administrator should, in coordination 
with the SBA Associate Administrator of the Office of Disaster 
Assistance and the HUD Assistant Secretary for Community 
Planning and Development, develop, with input from key recovery 
partners, and implement an interagency plan to help ensure the 
availability and use of quality information that includes (1) 
information requirements, (2) data sources and methods, and (3) 
strategies for overcoming information challenges--to support 
federal agencies involved in disaster recovery in identifying 
access barriers and disparate outcomes.
     LThe FEMA Administrator should coordinate with the 
SBA Associate Administrator of the Office of Disaster 
Assistance and the HUD Assistant Secretary for Community 
Planning and Development to design and establish routine 
processes to be used within and across federal disaster 
recovery programs to address identified access parries and 
disparate outcomes on an ongoing basis.

COVID-19: Additional Actions Needed to Improve Accountability 
and Program Effectiveness of Federal Response. (October 2021) 
\53\
---------------------------------------------------------------------------
    \53\ GAO. (October 2021). COVID-19: Additional Actions Needed to 
Improve Accountability and Program Effectiveness of Federal Response. 
GAO-22-105051
---------------------------------------------------------------------------
     LThe FEMA Administrator should improve the 
consistency of the agency's interpretation and application of 
the COVID-19 Public Assistance policy within and across regions 
by further clarifying and communicating eligibility 
requirements nationwide. See the FEMA's Disaster Relief Fund 
and Assistance to state, local, Tribal, and territorial 
Governments enclosure.
     LThe FEMA Administrator should require the 
agency's Public Assistance Program employees in the regions and 
at its Consolidated Resource Centers to attend training on 
changes to COVID-19 Public Assistance policy to help ensure it 
is interpreted and applied consistently nationwide. See the 
FEMA's Disaster Relief Fund and Assistance to state, local, 
Tribal, and territorial Governments enclosure.
     LThe FEMA Administrator should direct the Head of 
Contracting Activity to establish a formal process to (1) 
collect contracting lessons learned from COVID-19 and future 
emergency response efforts; and (2) ensure contracting lessons 
learned are shared with the Continuous Improvement Program for 
inclusion in FEMA's formal lessons learned process to inform 
FEMA's contracting efforts in response to ongoing and future 
emergencies.

Puerto Rico Recovery: FEMA Made Progress in Improving Projects 
but Should Identify and Assess Risks to the Recovery. (May 
2021) \54\
---------------------------------------------------------------------------
    \54\ GAO. (May 2021). Puerto Rico Recovery: FEMA Made Progress in 
Improving Projects but Should Identify and Assess Risks to the 
Recovery. GAO-21-264
---------------------------------------------------------------------------
     LThe FEMA Administrator should, in coordination 
with the Government of Puerto Rico and relevant federal 
agencies, identify and assess the risks to the remainder of 
Puerto Rico's recovery, including internal and external 
factors, such as Puerto Rico's capacity to carry out projects.
     LThe FEMA Administrator should, in coordination 
with the Government of Puerto Rico and relevant federal 
agencies, identify potential actions to manage the risks to the 
remainder of Puerto Rico's recovery and continuously monitor 
risks.

COVID-19: Sustained Federal Action is Crucial as Pandemic 
Enters Its Second Year. (March 2021) \55\
---------------------------------------------------------------------------
    \55\ GAO. (March 2021). COVID-19: Sustained Federal Action is 
Crucial as Pandemic Enters Its Second Year. GAO-21-387
---------------------------------------------------------------------------
     LThe FEMA Administrator should adhere to the 
agency's protocols listed in its updated 2019 Tribal 
Consultation Policy by obtaining Tribal input via the four 
phases of the Tribal consultation process when developing new 
policies and procedures related to COVID-19 assistance.
     LThe FEMA Administrator should provide timely and 
consistent technical assistance to support tribal governments' 
efforts to request and receive Public Assistance as direct 
recipients, including providing additional personnel, if 
necessary, to ensure that Tribal nations are able to 
effectively respond to COVID-19.

Disaster Resilience: FEMA Should Take Additional Steps to 
Streamline Hazard Grants and Assess Programs Effects. (February 
2021) \56\
---------------------------------------------------------------------------
    \56\ GAO. (February 2021). Disaster Resilience: FEMA Should Take 
Additional Steps to Streamline Hazard Grants and Assess Programs 
Effects. GAO-21-140
---------------------------------------------------------------------------
     LThe FEMA Administrator should establish a plan 
with time frames to develop pre-calculated benefits for 
additional project types, where appropriate.
     LThe FEMA Administrator should establish a plan 
with time frames to assess PA, HMGP, FMA, and BRIC hazard 
mitigation grant processes to identify and implement steps to 
reduce the complexity of and time required for grant 
applications, including steps to facilitate the use of funding 
from more than one FEMA mitigation grant program on a project.
     LThe FEMA Administrator should create a 
centralized inventory of hazard mitigation resources on the 
FEMA website.
     LThe FEMA Administrator should develop a plan for 
conducting future loss avoidance studies to ensure they can 
include more hazard types.
     LThe FEMA Administrator should ensure that as new 
methods and metrics to assess the effectiveness of hazard 
mitigation are developed, FEMA officials consider opportunities 
to adopt common methods and metrics across all of its hazard 
mitigation programs.
     LThe FEMA Administrator should publicly share pre-
calculated benefits studies and state developed records of 
effectiveness, such as by posting them to its website.
     LThe FEMA Administrator should assess the need for 
an agency-wide consolidated standard operating procedures 
document for the HMGP that provides detailed information on the 
roles and responsibilities, requirements, and key tasks and 
milestones for monitoring and closing out program projects.

2018 Pacific Island Disasters: Federal Actions Helped 
Facilitate the Response, But FEMA Needs to Address Long-Term 
Recovery Challenges. (February 2021) \57\
---------------------------------------------------------------------------
    \57\ GAO. (February 2021). 2018 Pacific Island Disasters: Federal 
Actions Helped Facilitate the Response, But FEMA Needs to Address Long-
Term Recovery Challenges. GAO-21-91
---------------------------------------------------------------------------
     LThe FEMA Administrator should consider the unique 
challenges of recovery missions for large-scale disaster in 
U.S. insular and other remote areas to establish appropriate 
timeliness goals for the pre-award phase of the Public 
Assistance program specific to these types of disasters.
     LThe FEMA Administrator should use data relating 
to the timeliness of completing various steps of the pre-award 
phase of the Public Assistance program to help identify and 
address any inefficiencies occurring during this phase of the 
program.
     LThe FEMA Administrator should develop guidance to 
streamline the process to assist direct housing applicants with 
proof of residency and proof of ownership requirements in those 
locations, such as in insular areas, where the nature of 
housing may otherwise result in processing delays due to the 
volume of required waivers or modifications to these 
requirements.
     LThe FEMA Administrator should incorporate lessons 
learned from earlier Permanent Housing Construction missions 
and address long-standing issues, such as the lack of 
architecture and engineering services in its existing 
contracts, in guidance that outlines necessary steps to better 
plan for and implement the Permanent Housing Construction 
program in insular and other remote areas.

Disaster Housing: Improved Cost Data and Guidance Would Aid 
FEMA Activation Decisions. (December 2020) \58\
---------------------------------------------------------------------------
    \58\ GAO. (December 2020). Disaster Housing: Improved Cost Data and 
Guidance Would Aid FEMA Activation Decisions. GAO-21-116
---------------------------------------------------------------------------
     LThe FEMA Administrator should identify and make 
changes to the applicable data system to capture cost data, 
including administrative costs for each of its housing 
assistance programs that will allow the agency to analyze the 
full cost of providing assistance under each program.
     LThe FEMA Administrator should specify the 
information needed to compare the projected costs of each 
direct housing program in its guidance for assessing which 
programs to activate.

Disaster Assistance: Additional Actions Needed to Strengthen 
FEMA's Individuals and Households Program. (September 2020) 
\59\
---------------------------------------------------------------------------
    \59\ GAO. (September 2020). Disaster Assistance: Additional Actions 
Needed to Strengthen FEMA's Individuals and Households Program. GAO-20-
503
---------------------------------------------------------------------------
     LThe FEMA Administrator should improve the 
completeness and consistency of its communication of the 
requirement to apply for an SBA disaster loan prior to being 
considered for SBA-dependent other needs assistance.
     LThe FEMA Administrator should assess the extent 
to which its process for determining an applicant's eligibility 
for SBA-dependent other needs assistance limits or prevents 
survivors' access to IHP assistance, and work with SBA to 
identify options to simplify and streamline the disaster 
assistance application process for survivors.
     LThe FEMA Administrator should improve the IHP 
award determination letters by using federal guidance and best 
practices for communicating with the public to ensure that 
applicants understand that an ``ineligible'' determination does 
not mean they cannot continue to pursue assistance.
     LThe FEMA Administrator should identify and 
implement strategies to provide additional information to 
applicants about how FEMA determined their eligibility for 
assistance and the amount of assistance to award.
     LThe FEMA Administrator should identify and 
implement strategies to provide readily accessible information 
and resources, such as guidance and training, about the 
Individuals and Households Program to state, local, Tribal, and 
territorial officials.
     LThe FEMA Administrator should correct and refine 
the methodology used to survey survivor experiences with the 
IHP by (1) weighting the survey data to reflect the 
stratification of its survey design, (2) adjusting the base 
sampling weights for survey nonresponse within each stratum, 
and (3) calculating the sampling error for the survey data 
after adjusting the base sampling weights for nonresponse.
     LThe FEMA Administrator should complete the 
following key process improvement activities as part of its 
effort to redesign the Individual Assistance Program: (1) 
engage with additional program customers and stakeholders to 
obtain a more comprehensive understanding of their needs; (2) 
assess performance gaps between current processes and customer 
and stakeholder needs, and develop measurable and achievable 
improvement goals to address any identified performance gaps; 
and (3) prioritize the processes that need improvement based on 
documented selection criteria.
     LThe FEMA Administrator should establish time 
frames for finalizing the Individual Assistance Division's 
draft strategic plan and developing implementation plans that 
integrate its IHP improvement efforts.
     LThe FEMA Administrator should use desirable 
characteristics of employee engagement--including performance 
feedback, career development, communication, and attention to 
work-life balance--while completing planned activities for 
improving morale among call center staff.
     LThe FEMA Administrator should use desirable 
characteristics of employee engagement--including performance 
feedback, career development, communication, and attention to 
work-life balance--when assessing NPSC staff satisfaction 
scores and identifying additional steps to strengthen employee 
morale.
     LThe FEMA Administrator should assess the 
effectiveness of the IHP training and support for NPSC staff 
during surge events and implement any necessary changes.
     LThe FEMA Administrator should identify and 
implement strategies to help ensure staff deployed to Disaster 
Recovery Centers (DRC) have the needed skills and capabilities 
to provide support and consistent service to survivors.

Disaster Assistance: FEMA Should Take Additional Actions to 
Strengthen Fraud Risk Management for Public Assistance 
Emergency Work Grants. (September 2020) \60\
---------------------------------------------------------------------------
    \60\ GAO. (September 2020). Disaster Assistance: FEMA Should Take 
Additional Actions to Strengthen Fraud Risk Management for Public 
Assistance Emergency Work Grants. GAO-20-604
---------------------------------------------------------------------------
     LThe FEMA Administrator should plan and conduct 
regular fraud risk assessments of PA emergency work grants to 
determine a fraud risk profile that aligns with leading 
practices as provided in the Fraud Risk Framework. 
Specifically, this process should include (1) identifying 
inherent fraud risks to PA grant funds, (2) assessing the 
likelihood and impact of inherent fraud risks, (3) determining 
fraud risk tolerance, (4) examining the suitability of existing 
fraud controls, and (5) documenting the fraud risk profile.
     LThe FEMA Administrator should designate one 
entity as the lead entity with responsibility for providing 
oversight of agency-wide efforts to manage fraud risks to PA 
emergency work grants, including managing the fraud risk 
assessment process, consistent with leading practices.
     LThe FEMA Administrator should update key training 
and guidance documents for the PA grant program to include 
information on where and how to report suspected fraud, and 
direct PA recipients to include such information in key 
training and guidance documents they provide to subrecipients.
     LThe FEMA Administrator should update key 
resources, such as training and guidance documents, FEMA makes 
available to PA applicants to ensure these resources 
consistently communicate information on the highest fraud risks 
to PA emergency work grant funds and applicants' 
responsibilities for managing those risks. The highest fraud 
risks may include risks related to procurement and debris 
removal, and other risks FEMA identifies through fraud risk 
assessments.
     LThe FEMA Administrator should implement program-
specific antifraud training for PA staff who work directly with 
PA applicants; this training should include information on the 
highest fraud risks to PA emergency work grants. The highest 
fraud risks may include risks related to procurement and debris 
removal, and other risks FEMA identifies through fraud risk 
assessments.

FEMA Disaster Workforce: Actions Needed to Address Deployment 
and Staff Development Challenges. (May 2020) \61\
---------------------------------------------------------------------------
    \61\ GAO. (May 2020). FEMA Disaster Workforce: Actions Needed to 
Address Deployment and Staff Development Challenges. GAO-20-360
---------------------------------------------------------------------------
     LThe FEMA Administrator should develop a plan--
with time frames and milestones and input from field 
leadership--to address identified challenges that have hindered 
FEMA's ability to provide reliable and complete information to 
field leaders and managers about staff knowledge, skills, and 
abilities.
     LThe FEMA Administrator should develop mechanisms, 
including collecting relevant data, to assess how effectively 
FEMA's disaster workforce was deployed to meet mission needs in 
the field.
     LThe FEMA Administrator should create a staff 
development program for FEMA's disaster workforce that, at a 
minimum, addresses access to training, delivery of on-the-job 
training and mentoring, use of performance evaluations, and 
consistent developmental opportunities regardless of deployment 
status.

Disaster Assistance: FEMA Action Needed to Better Support 
Individuals Who Are Older or Have Disabilities. (May 2019) \62\
---------------------------------------------------------------------------
    \62\ GAO. (May 2019). Disaster Assistance: FEMA Action Needed to 
Better Support Individuals Who Are Older or Have Disabilities. GAO-19-
318
---------------------------------------------------------------------------
     LThe FEMA Administrator should communicate to 
Regional Administrators and Regional Disability Integration 
Specialists a written plan for implementing its new disability 
integration staffing approach, consistent with the objectives 
established for disability integration. Such a plan should 
include an implementation timeline and details on staff 
responsibilities, which regions could use to evaluate staff 
performance.
     LThe FEMA Administrator should develop a plan for 
delivering training to FEMA staff that promotes competency in 
disability awareness. The plan should include milestones and 
performance measures, and outline how performance will be 
monitored.
     LThe FEMA Administrator should develop and 
publicize guidance for partners working to assist individuals 
who are older or have disabilities for requesting data and 
working with FEMA staff throughout the data sharing process to 
obtain Individual Assistance data, as appropriate.

Disaster Contracting: Actions Needed to Improve the Use of Post 
Disaster Contracts to Support Response and Recovery. (April 
2019) \63\
---------------------------------------------------------------------------
    \63\ GAO. (April 2019). Disaster Contracting: Actions Needed to 
Improve the Use of Post Disaster Contracts to Support Response and 
Recovery. GAO-19-281
---------------------------------------------------------------------------
     LThe FEMA Administrator should take the lead to 
work together with the Coast Guard and the U.S. Army Corps of 
Engineers to revise the mission assignment policy and related 
guidance to better incorporate consideration of contracting 
needs, such as demobilization, and to ensure clear 
communication of coordination responsibilities related to 
contracting.
     LThe FEMA Administrator should assess its 
workforce needs--including staffing levels, mission needs, and 
skill gaps--for contracting staff, to include regional offices 
and DART; and develop a plan, including timelines, to address 
any gaps.

Disaster Recovery: Additional Actions Would Improve Data 
Quality and Timeliness of FEMA's Public Assistance Appeals 
Processing. (December 2017) \64\
---------------------------------------------------------------------------
    \64\ GAO. (December 2017). Disaster Recovery: Additional Actions 
Would Improve Data Quality and Timeliness of FEMA's Public Assistance 
Appeals Processing. GAO-18-143
---------------------------------------------------------------------------
     LThe Assistant Administrator for Recovery should 
develop a detailed workforce plan that documents steps for 
hiring, training, and retaining key appeals staff. The plan 
should also address staff transitions resulting from 
deployments to disasters.

Federal Disaster Assistance: Improved Criteria Needed to Assess 
a Jurisdiction's Capability to Respond and Recovery on Its Own. 
(September 2012) \65\
---------------------------------------------------------------------------
    \65\ GAO. (September 2012). Federal Disaster Assistance: Improved 
Criteria Needed to Assess a Jurisdiction's Capability to Respond and 
Recovery on Its Own. GAO-12-838
---------------------------------------------------------------------------
     LTo increase the efficiency and effectiveness of 
the process for disaster declarations, the FEMA Administrator 
should develop and implement a methodology that provides a more 
comprehensive assessment of a jurisdiction's capability to 
respond to and recover from a disaster without federal 
assistance. This should include one or more measures of a 
jurisdiction's fiscal capacity, such as TTR, and consideration 
of the jurisdiction's response and recovery capabilities. If 
FEMA continues to use the PA per capita indicator to assist in 
identifying a jurisdiction's capabilities to respond to and 
recover from a disaster, it should adjust the indicator to 
accurately reflect the annual changes in the U.S. economy since 
1986, when the current indicator was first adopted for use. In 
addition, implementing the adjustment by raising the indicator 
in steps over several years would give jurisdictions more time 
to plan for and adjust to the change.


           FEMA PRIORITIES FOR 2022: STAKEHOLDER PERSPECTIVES

                              ----------                              


                      WEDNESDAY, FEBRUARY 16, 2022

                  House of Representatives,
      Subcommittee on Economic Development, Public 
               Buildings, and Emergency Management,
            Committee on Transportation and Infrastructure,
                                                    Washington, DC.
    The subcommittee met, pursuant to call, at 2:02 p.m., in 
room 2167 Rayburn House Office Building and via Zoom, Hon. Dina 
Titus (Chair of the subcommittee) presiding.
    Members present remotely: Ms. Titus, Mr. DeFazio, Ms. 
Norton, Ms. Davids of Kansas, Mr. Pappas, Mrs. Napolitano, Mr. 
Garamendi, Mr. Carter of Louisiana, Mr. Webster of Florida, Mr. 
Massie, Miss Gonzalez-Colon, Mr. Guest, Mr. Gimenez, Mr. Graves 
of Louisiana, and Mr. LaMalfa.
    Ms. Titus. Well, good morning. The subcommittee will come 
to order. Thank you all for tuning in, either being in 
Washington or virtually.
    I ask unanimous consent that the chair be authorized to 
declare a recess at any time during today's hearing.
    Without objection, so ordered.
    I also ask unanimous consent that the Members who are not 
on the subcommittee, but want to sit in, be permitted to do 
that at today's hearing, and also ask questions.
    Without objection, so ordered.
    As a reminder, please keep your microphones muted unless 
speaking. Should I hear any inadvertent background noise, I 
will request that the Member please mute their microphone.
    To insert a document into the record, please have your 
staff email it to [email protected].
    Before I begin, I would like to just take a moment of 
personal privilege to tell you all that Aaron Davis is leaving 
our committee. I hate to hear that, because he has been a great 
member of this team, and certainly an asset to me and all of 
us, providing excellent information. Aaron has been 3 years on 
the Transportation and Infrastructure Committee. He spent 4\1/
2\ years at FEMA, and brought that experience with him to the 
committee. And he served 11 years in different personal House 
offices.
    He is moving to become the vice president of Federal 
relations at the International Code Council, and they are lucky 
to have him. He certainly has a lot of background in this area. 
I think we will still be seeing Aaron, but now he will be 
sitting across the table from us, instead of behind the podium.
    So, Aaron, we wish you all the best, and we thank you for 
all that you have done for this committee, and we look forward 
to interacting and working with you in your new role.
    I will now start with my own statement, and then we will go 
to Mr. Webster, the ranking member, for his.
    Welcome today, our witnesses. This is a very important 
hearing, because we are going to be discussing what should be 
the priorities of FEMA, moving into 2022.
    When we think about FEMA, we typically think about floods, 
or hurricanes, or wildfires, or those kinds of immediate 
disasters that are usually limited to a specific area. But what 
we have learned with the national disaster declaration during 
COVID-19 is that unexpected events of all kinds can impact any 
community at any time.
    Now, during this declaration, which is ongoing, people in 
Nevada--and I am sure in all of your States--have really relied 
on FEMA to provide certain services that perhaps they haven't 
in the past, like setting up community vaccination centers.
    In addition to the pandemic, we know that climate change 
and severe weather events, which have combined with high-risk 
areas having more intense development to really make 
emergencies more serious, have changed the emergency management 
landscape as a result.
    And Government and insurance data show that these disasters 
are more expensive and have a greater impact than ever before.
    And that is what we need to talk about, as we look at 
FEMA's plans for the next year. We need to see how FEMA can 
adapt to this new reality in dealing with certain kinds of 
disasters, and with those that are unexpected, and how they can 
keep our communities and the survivors as a priority as they 
move forward.
    The demand for Public Assistance has never been greater. It 
is used to help repair public infrastructure after a disaster. 
That has just increased at rocket speed, as the intensity of 
natural disasters have also increased. And presently, FEMA has 
the longest queue for Public Assistance to date as a result of 
these disasters. You only have to look at Puerto Rico, if you 
don't believe me, because they are still trying to get Public 
Assistance for the people who were affected by the weather 
conditions in those areas, as well as in the Virgin Islands.
    Reimbursements are critical from FEMA to these communities 
to get back on their feet. But one of the things that we have 
heard over the years in the time I have chaired this committee 
is there is just too much redtape, too many burdensome 
requirements, people don't know where to apply, it is 
contradictory information. So, that has got to be a priority, 
that we clean up that redtape and simplify the Public 
Assistance program to better assist our communities.
    The second thing that I know we want to talk about that 
should be a priority is the workforce. Two things are happening 
at the same time: it is difficult to find people to work, and 
yet the disasters are increasing. So, how do we find additional 
team members to work with the men and women who have done such 
a good job, and worked so hard in these, kind of, trying times, 
in order to expand the workforce there?
    We need more diversity. We need more longevity of the 
members. We need to be able to attract a well-qualified 
workforce to FEMA. And so, that has got to be a priority.
    I have got legislation that is bipartisan, which will be 
introduced, designed to help FEMA meet these needs to recruit 
and retain qualified reservists. We need to provide protection 
for these folks, we need to provide training, and we need to 
provide benefits if we want to have a team who can meet the new 
demands.
    A third issue that seems to run throughout the priorities 
that FEMA should be looking at for the new year is the notion 
of building resilience. When you build back, you need to build 
back better. And so, I am proud to have championed some 
efforts, along with the chairman of this committee, Mr. 
DeFazio, in the Resilient AMERICA package, so that we could 
provide some of this assistance.
    We also sent a letter to FEMA talking about the inequitable 
distribution of benefits that need to be considered.
    So, I look forward to working with FEMA on these efforts 
during 2022. This committee stands ready to do what Congress 
can to assist FEMA's efforts. We want to hear how FEMA is 
trying to meet the 50 open recommendations that have come from 
the GAO that address some of these shortcomings all across the 
program.
    And I am anxious to hear from Mr. Currie how GAO believes 
that FEMA can prioritize these 50 open issues.
    And I also want to hear from the emergency management folks 
at the National Emergency Management Association and the 
International Association of Emergency Managers. They are on 
the front lines, and they can tell us, from their standpoint, 
how they think things can be improved, how they are working 
well, and how we need to make some adjustments.
    So, we will look forward to the hearing. We thank the 
witnesses for being here.
    [Ms. Titus' prepared statement follows:]

                                 
  Prepared Statement of Hon. Dina Titus, a Representative in Congress 
     from the State of Nevada, and Chair, Subcommittee on Economic 
        Development, Public Buildings, and Emergency Management
    I'd like to welcome everyone to today's hearing and thank our 
witnesses for joining us to discuss their perspectives regarding what 
FEMA should prioritize in 2022.
    While Southern Nevada does not experience many major disasters that 
require FEMA intervention, the nationwide major disaster declaration 
for COVID-19 reminded us that unexpected events can impact any 
community at any time. During this major disaster declaration--which is 
still an open event--Nevadans have relied on FEMA's programs, such as 
vaccine sites, to provide lifesaving services.
    Climate change and associated severe weather, as well as 
development in high-risk areas have changed the emergency management 
landscape. Disasters are more expensive and have a greater impact than 
ever before, supported by government and insurance industry data.
    Today we are going to discuss how FEMA can adapt to this new 
reality and ensure disaster survivors and their communities remain the 
priority.
    The demand for Public Assistance, which is used to repair public 
infrastructure after a disaster, has skyrocketed with the increased 
frequency and intensity of natural disasters.
    Presently, FEMA has the largest queue for Public Assistance 
worksheets to date, a result of the national scale of the pandemic 
declarations, as well as expanded eligibility for pandemic-related 
countermeasures.
    Reimbursements provided by FEMA's Public Assistance program are 
critical for communities trying to get back on their feet post-
disaster. However, we hear time and time again from stakeholders that 
this program is plagued by red tape and burdensome requirements. This 
year, it must be an agency priority to simplify the Public Assistance 
program so that it can better assist communities.
    There is no place where the consequences of FEMA's complex Public 
Assistance program are more evident than Puerto Rico and the U.S. 
Virgin Islands. Individuals in these communities are still waiting for 
the restoration of full access to basic public infrastructure such as 
reliable electricity, health care facilities, schools, and roads 
following Hurricanes Irma and Maria nearly five years ago. And I remain 
committed to supporting the recovery process in Puerto Rico and the 
U.S. Virgin Islands until the last public worksheet has been completed.
    When considering how to improve FEMA's programs, focus must be 
placed upon its workforce. I am proud that FEMA's workforce has 
consistently risen to the challenge--they have been confronted with 
unprecedented disaster damage, a pandemic, and expanding 
responsibilities.
    I expect to soon introduce bipartisan legislation designed to 
ensure FEMA has the tools needed to recruit and retain qualified 
workers for its cadre of disaster reservists. I believe that providing 
FEMA's workforce with access to appropriate protections, training, and 
benefits will increase the agency's capabilities and result in better 
outcomes for disaster survivors and their communities.
    A consistent thread connecting FEMA's challenges is the increasing 
severity and cost of disasters. Mitigation projects must be used to 
reduce the impact of such incidents and build resilience. That is why I 
am proud to have championed expanded mitigation efforts as Chair of 
this Subcommittee, including our bipartisan Resilient AMERICA package. 
We've also sent a letter to FEMA regarding the inequitable distribution 
of mitigation grant dollars.
    I look forward to continuing these efforts in 2022.
    FEMA has achieved many noteworthy accomplishments--but there is 
still much work to be done. The Government Accountability Office has 
more than 50 open recommendations to FEMA, which address shortcomings 
across all of FEMA's programs.
    I look forward to hearing from Mr. Currie regarding how the GAO 
believes FEMA should prioritize addressing outstanding recommendations. 
I also look forward to hearing how state and local emergency managers 
represented by the National Emergency Management Association and 
International Association of Emergency Managers have been impacted by 
FEMA's programs.
    I once again thank our witnesses for joining us today to share 
their perspective and expertise. We are grateful for your testimony and 
look forward to our discussion.

    Ms. Titus. And I would now turn to Mr. Webster, the ranking 
member, for his opening statement.
    [Pause.]
    Voice. Say it again.
    Ms. Titus. We can't hear you, Mr. Webster.
    Mr. Webster of Florida. How is that?
    Ms. Titus. OK.
    Mr. Webster of Florida. OK, great. Thank you so much. I 
just want to say FEMA has a mission critical to our Nation, but 
also critical to the State of Florida, my home State.
    FEMA leads the Federal Government's response to disasters, 
natural and man-made. When FEMA's processes are complicated and 
riddled with too much redtape, it slows the preparation for the 
recovery from disasters, and it discourages investment in 
mitigation.
    Over the years, the committee has passed legislation 
intended to cut redtape, but these laws are rarely implemented, 
and so, they are intended to be done, but they just don't get 
done.
    The Government Accountability Office has issued dozens of 
reports and many recommendations still open across a host of 
areas, including recovery, mitigation, and Individual 
Assistance. What seems to be the common theme throughout all of 
the reports is how confusing and complicated FEMA's process can 
be.
    It is more critical than ever, with the number of the 
disasters we are seeing, for the process to be streamlined. We 
need to get assistance out the door quickly to allow 
communities and families to rebuild faster and easily build in 
mitigation so next time there will be less damage.
    That is why I am pleased to cosponsor bipartisan 
legislation, the SPEED Recovery Act, introduced by Ranking 
Member Sam Graves, which will streamline the process for about 
95 percent of the disasters that are happening.
    I look forward to hearing from GAO and the stakeholders 
here today and those submitting written testimony for the 
record.
    [Mr. Webster's prepared statement follows:]

                                 
Prepared Statement of Hon. Daniel Webster, a Representative in Congress 
from the State of Florida, and Ranking Member, Subcommittee on Economic 
        Development, Public Buildings, and Emergency Management
    FEMA has a mission critical to our Nation and my home state of 
Florida. FEMA leads the federal government's response to disasters--
natural and man-made.
    When FEMA's processes are complicated and riddled with too much red 
tape, it slows preparation for and recovery from disasters, and it 
discourages investment in mitigation. Over the years, this Committee 
has passed legislation intended to cut red tape, but these laws are 
either rarely implemented as intended, or FEMA finds more red tape to 
put back into the process.
    The Government Accountability Office has issued dozens of reports 
with many recommendations still open across a host of areas including 
recovery, mitigation, and individual assistance. What seems to be a 
common theme throughout many of these reports is how confusing and 
complicated FEMA's process can be.
    It is more critical than ever, with the number of disasters we are 
seeing, for the process to be streamlined and sped up. We need to get 
assistance out the door quickly to allow communities and families to 
rebuild faster and easily build in mitigation so next time there will 
be less damage.
    That is why I am pleased to be a cosponsor of the bipartisan 
legislation, the SPEED Recovery Act, introduced by Ranking Member Sam 
Graves, which will streamline the process for 95 percent of disaster 
projects.
    I look forward to hearing from the GAO and stakeholders here today 
and those submitting written testimony for the record.

    Mr. Webster of Florida. Thank you, Chair, and I yield back.
    Ms. Titus. Thank you, Mr. Webster. We now turn to the 
chairman of the Transportation and Infrastructure Committee, 
Mr. DeFazio, for his opening statement.
    Mr. DeFazio. Thank you, Madam Chair, and I certainly also 
want to congratulate Aaron on his new position. That 
organization is incredibly lucky to have him coming on board, 
with his extraordinary breadth and depth of experience. He did 
start many years ago in my personal office on the Hill, and 
then, as you noted, moved on to many, many other important 
positions.
    And it has been great to have him on the committee, 
especially since I think he is the only person who can master 
all of the acronyms of FEMA. I don't think there is another 
agency of the Federal Government that has as many acronyms for 
as many programs, and I find it incredibly confusing, as I 
think many others do, but he can always explain it.
    So, again, congratulations.
    We put, obviously, extraordinary burdens on FEMA recently 
with COVID, the border, and then we are having more and more 
extreme natural disasters, both wildfire and weather events 
that are exacerbated by climate change. We have to help the 
Agency streamline, so that it can, with more facility, deal 
with this extraordinary burden that they have. We recognize 
that their budgets are stretched, and we also have to meet our 
obligations there.
    I was particularly interested in the National Emergency 
Management Association's thoughts, a paper on what we would do 
with wildfire response and recovery, particularly an incredible 
concern here, in the Western U.S., as we are now headed into 
the 20-some-odd year of what is called a megadrought, the worst 
in recorded history if this winter continues the way it is 
going. And their comments about the FMAG, DRRA, HMGP, and WUI 
are very well taken, and I hope they will amplify on those a 
little bit today as they testify.
    The other area of major concern beyond all of the 
outstanding issues with GAO are things that relate to personal 
assistance and the confusion there. We have to simplify these 
processes. And we also have to better integrate with other 
agencies that can be involved, including HUD or other 
disciplines.
    We still have people from the fires in Oregon who do not 
have long-term housing. And I am concerned that they may soon 
have to be paying substantial rent for temporary quarters. And 
that is a subject of a letter recently sent.
    The chair and the ranking member mentioned legislation that 
is pending. I am going to have to get off this, probably pretty 
quickly, because I have to go to a chairs meeting, and I am 
going to raise the issue of when we are going to bring those 
bipartisan bills to the floor, as opposed to post offices and 
other things that we have been doing lately. Particularly the 
Resilient AMERICA package, I believe, would move expeditiously 
through the House, and I am looking forward to that in the not 
too distant future.
    [Mr. DeFazio's prepared statement follows:]

                                 
   Prepared Statement of Hon. Peter A. DeFazio, a Representative in 
      Congress from the State of Oregon, and Chair, Committee on 
                   Transportation and Infrastructure
    Thank you, Chair Titus, and thank you to our witnesses for being 
with us today.
    Today's witnesses will provide stakeholder perspectives on FEMA's 
successes and shortcomings.
    As natural disasters become more costly and have greater impact 
upon communities across the nation, it is critical that FEMA programs 
are as effective and efficient as possible. We've heard time and again 
that the quality of FEMA interactions significantly impacts disaster 
survivors' recovery.
    In 2020, wildfires forced Oregonians to understand the importance 
of FEMA's programs more than ever. The Labor Day fires damaged more 
than 5,000 structures across the state and tens of thousands of 
Oregonians were forced to evacuate.
    A year and a half later, the recovery process for this disaster 
continues. Just last week, the Seattle Times reported that some 
survivors who lost their homes are still struggling to secure long-term 
housing solutions.
    I continue to follow the progress of survivors and am committed to 
helping Oregonians throughout this long recovery process. The entire 
Oregon congressional delegation recently joined together to send a 
letter to FEMA Administrator Criswell regarding FEMA's direct housing 
mission and the possibility of rental charges being assessed on 
survivors during a six-month extension, which the agency just approved 
at the request of the state.
    A series of unprecedented hazard events, including the record cost 
of the 2017 and 2018 disaster seasons and nationwide major disaster 
declarations for COVID-19, have stretched FEMA to its limit. The 
agency's oversubscription has made it difficult for FEMA's workforce to 
adequately support disaster survivors.
    I hope today's discussion will help us consider ways that FEMA 
might adapt its programs to ensure quality assistance to survivors in 
this new reality, which is fueled by climate change and compounded by a 
pandemic.
    Disasters do not discriminate. Therefore, it is critical that FEMA 
programs are designed to benefit the needs of every single disaster 
survivor.
    The GAO has highlighted concerns with FEMA's ability to administer 
its programs equitably. I am pleased that this Administration has made 
equity a priority and that FEMA is in the process of seeking innovative 
ways to restructure its programs. I fully support these efforts and am 
open to considering statutory changes that may be needed to achieve 
this goal.
    The increasing frequency, intensity, and cost of natural disasters 
makes us ask--what can we do to protect communities before disaster 
strikes? The answer is to invest in mitigation efforts.
    Time and again we've discussed mitigation as a commonsense, cost-
effective way to save lives and property. That's why I strongly support 
finding ways to expand funding for mitigation projects.
    I am proud to have introduced the Resilient AMERICA package along 
with Chair Titus and Ranking Members Graves and Webster last year. We 
successfully advanced this bill out of committee, and I look forward to 
the opportunity to debate it on the House Floor. The improvements to 
hazard mitigation assistance programs that this legislation provides 
will help individuals and communities make needed investments in 
mitigation efforts.
    However, mitigation cannot be effective unless it is fairly 
distributed across all communities. Stakeholder feedback has me 
concerned that FEMA's mitigation assistance programs are only reaching 
the largest and best-resourced communities. The complexity of the 
application processes makes it near impossible for small, 
disadvantaged, and rural communities to successfully access these 
funds.
    I sent a letter with Chair Titus, Ranking Member Webster, and 
Ranking Member Graves to FEMA this week to detail my concern and 
request an update on the agency's actions to address inequity in the 
mitigation grant application process. This concern has been echoed by 
the witnesses' written testimony.
    Once again, thank you to our witnesses for joining us today. I look 
forward to hearing your testimony and learning from your experience.

    Mr. DeFazio. So, with that, Madam Chair, I would yield back 
the balance of my time.
    Ms. Titus. Thank you, Mr. Chairman.
    I don't believe that Mr. Graves is with us, so, we will go 
right to our witnesses.
    Thank you all for joining us this morning, and welcome to 
our subcommittee. Our witnesses are Mr. Chris Currie, Director 
of Homeland Security and Justice with the U.S. GAO; Ms. Erica 
Bornemann, director of Vermont Emergency Management, and also 
is testifying on behalf of the National Emergency Management 
Association; and Ms. Carolyn Harshman, who is the president of 
the International Association of Emergency Managers.
    We thank you for being here today, and we look forward to 
your testimony.
    Without objection, our witnesses' full statements will be 
included in the record.
    Since your written word will now be part of the record, we 
would kindly request that you limit your testimony to 5 
minutes.
    So, we will begin with you, Mr. Currie. Please proceed.

 TESTIMONY OF CHRIS P. CURRIE, DIRECTOR, HOMELAND SECURITY AND 
     JUSTICE, U.S. GOVERNMENT ACCOUNTABILITY OFFICE; ERICA 
BORNEMANN, DIRECTOR, VERMONT EMERGENCY MANAGEMENT, ON BEHALF OF 
 THE NATIONAL EMERGENCY MANAGEMENT ASSOCIATION; AND CAROLYN J. 
  HARSHMAN, MPA, CEM, PRESIDENT, INTERNATIONAL ASSOCIATION OF 
                       EMERGENCY MANAGERS

    Mr. Currie. Thank you, Chairwoman Titus, Chairman DeFazio, 
and Ranking Member Webster, for the chance to be here today to 
talk about GAO's work on FEMA priorities.
    First, I think it is important to recognize the pressures 
and the challenges that FEMA has on it. In recent years, the 
Agency has led the pandemic response, responded to year after 
year of record-setting hurricanes and wildfires, and also been 
asked to help with other national issues such as border 
security. At GAO, even though we audit and evaluate FEMA, we 
also have respect for the hard-working staff and the mission. 
There is not a more dedicated group of Federal employees, and 
also I have found FEMA leadership to be very committed to self-
evaluation and improvement.
    Having said that, I see four key challenges that FEMA will 
have to tackle in the years ahead.
    First, as was mentioned in the opening statements, is the 
workforce managing its own people. The FEMA workforce is worn 
down by a disaster season that really never ends anymore. Also, 
the Agency's staffing, training, and hiring processes were 
designed for a mission that has changed.
    We have found that FEMA has long faced challenges in 
deploying staff with the right qualifications and skills to 
meet disaster needs.
    We have also found that FEMA struggles to train, coach, and 
develop its disaster workforce, especially when they are 
deployed in the field. For example, reservists, who make up 
almost 40 percent of the workforce, face barriers to getting 
the training and other developmental opportunities they need 
when they are not deployed, including not having paid time and 
technology to get training when they are not in the field.
    We have made recommendations to fix some of these problems, 
but I think broader workforce reform, involving Congress and 
this committee, is needed to be able to hire, train, and retain 
the staff FEMA needs to meet a growing mission.
    The second major challenge area is simplifying disaster 
relief and removing barriers for disaster survivors. We have 
found that survivors face a number of challenges in 
understanding and obtaining FEMA Individual Assistance. We 
recently made 14 recommendations in 1 report alone to improve 
the Individual Assistance program, including that FEMA overhaul 
and improve how it communicates award decisions or denials with 
survivors. We found that confusion doesn't just lead to 
frustration; it also led to some survivors not pursuing 
assistance when they may have been eligible to get it.
    The third area of challenge is streamlining and simplifying 
complex, lengthy recovery grants and programs for State, local, 
Tribal, and Territorial governments. In our work, States, 
Tribes, and other localities tell us over and over again that 
recovery programs are, at best, overly complicated, and at 
worst, actually a disincentive sometimes to recovery.
    According to FEMA, the Agency had almost 1,000 open 
disasters or emergency declarations going back years, including 
Hurricane Katrina in 2005. While most think of FEMA staff as 
immediately responding to a disaster, the truth is that much of 
FEMA's workforce manages thousands of grants and recovery 
projects from prior disasters. Streamlining recovery programs 
to be more efficient would help cut down on FEMA's workload, 
and going back to the staffing issues I talked about, help the 
staff focus on the most pressing matters.
    Also, coordination between FEMA, as Chairman DeFazio said, 
and other Federal recovery programs like HUD and SBA and 
others, would further cut down on the burden and frustration 
that States and communities face.
    Further compounding the challenges related to complexity, 
concerns are also being raised now about the extent to which 
disaster assistance programs are helping those most in need, 
and how they impact vulnerable populations, as well.
    The last and fourth key priority area is building 
resilience. This is an area that FEMA has made tremendous 
progress on in recent years, partly due to Congress' actions, 
too, to create new programs. Mitigation and building resilience 
is one of the few solutions that we have to adapt to extreme 
weather and severe infrastructure damage. Additional 
predisaster mitigation grants like the BRIC program, the 
Building Resilient Infrastructure and Communities program, will 
help to address these issues, but FEMA needs to continue to 
focus on ensuring these grants encourage mitigation.
    We just reported last year that State and local officials 
told us that mitigation grant programs were still too lengthy 
and complicated, making them even more difficult to use 
effectively than some other grant programs.
    This completes my statement. I look forward to discussing 
how we can address these challenges, and to your questions.
    [Mr. Currie's prepared statement follows:]

                                 
Prepared Statement of Chris P. Currie, Director, Homeland Security and 
             Justice, U.S. Government Accountability Office
 FEMA: Opportunities to Help Address Mission and Management Challenges
    Chair Titus, Ranking Member Webster, and Members of the 
Subcommittee:
    Thank you for the opportunity to discuss our work on challenges 
facing the Federal Emergency Management Agency (FEMA).
    FEMA leads our nation's efforts to prepare for, protect against, 
respond to, recover from, and mitigate against the risk of disasters. 
The historic 2017 and 2018 disaster seasons pushed FEMA well beyond its 
routine disaster response posture. In 2017, hurricanes Harvey, Irma, 
and Maria, and the severe wildfires in California, collectively 
affected 47 million people--nearly 15 percent of the nation's 
population. In 2018, hurricanes Florence and Matthew and another severe 
California wildfire season again necessitated a major federal response. 
Furthermore, Hawaii, the Commonwealth of the Northern Mariana Islands, 
and Guam experienced an unprecedented number of disasters in 2018--
including typhoons, earthquakes, mudslides, and volcanic eruptions. In 
2020, FEMA responded to 230 presidentially declared emergencies and 
major disasters--an all-time high--including a record-breaking 
hurricane season in the Atlantic Ocean, and the most active fire year 
on record for the West Coast. In 2021, there were 20 weather and 
climate-related disaster events with losses exceeding $1 billion each 
in the United States, according to the National Oceanic and Atmospheric 
Administration.
    In addition to its responsibilities responding to the rising number 
of disasters and other emergencies, FEMA has been tasked with new 
responsibilities. FEMA has played a key role in the federal response to 
the COVID-19 pandemic. For example, it established mass vaccination 
sites and provided funeral assistance to families, the scope of which 
is unprecedented for the agency. According to FEMA data, as of August 
30, 2021, the agency's call center had received and was processing 
264,544 applications, and FEMA had awarded more than $1 billion for 
funeral assistance. Prior to the COVID-19 pandemic, FEMA had processed 
approximately 6,000 cases of funeral assistance over the past decade. 
It has also assisted in the Afghan refugee resettlement efforts and at 
the southwest border.
    While we recognize the difficult job FEMA has been tasked with, in 
recent years, we have reported on various mission and management 
challenges the agency faces. For instance, FEMA management has had to 
redeploy response personnel from one disaster to the next, and the 
agency has reported facing staffing shortfalls in response to some 
disasters. In addition, a large influx of new employees has added to 
the challenges of providing timely, program-specific training. FEMA 
hazard mitigation programs and disaster recovery programs sometimes 
have complex and lengthy processes and mechanisms that have affected 
access to, as well as the speed and delivery of assistance. Some 
programs also lack information that would allow them to examine 
patterns and indicators to identify access barriers and differing 
outcomes for different groups of survivors.
    My statement today discusses our prior work and recommendations 
related to FEMA's challenges in four key areas: (1) workforce 
management; (2) long-term disaster recovery efforts; (3) potential 
barriers to disaster assistance and disparate recovery outcomes; and 
(4) future disaster resilience and mitigation. Successfully addressing 
these challenges is important because the rising number and costs of 
disasters and the increasing reliance on the federal government for 
disaster assistance will likely continue as the climate changes.\1\
---------------------------------------------------------------------------
    \1\ GAO, Climate Change: Information on Potential Economic Effects 
Could Help Guide Federal Efforts to Reduce Fiscal Exposure, GAO-17-720 
(Washington, D.C.: Sept. 28, 2017).
---------------------------------------------------------------------------
    My statement today is based on products we developed and issued 
from January 2015 to December 2021. To perform our prior work, we 
reviewed and analyzed federal law, a non-generalizable sample of post-
disaster contracts, agency guidance, and other agency documentation. We 
also analyzed data on FEMA's workforce, disaster assistance programs, 
and flood mapping efforts, among others. We interviewed officials from 
FEMA and other selected federal agencies; and state, territory, local, 
and nonprofit officials impacted by disasters. We conducted some of 
these interviews as part of visits to locations affected by hurricanes 
in 2017 and 2018, where we also met with disaster survivors. 
Additionally, we conducted 17 focus groups with FEMA staff. More 
detailed information on the scope and methodology of our prior work can 
be found in each of the issued reports cited throughout this statement.
    We conducted the work on which this statement is based in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives.
                          Workforce Management
    FEMA has faced longstanding challenges related to its workforce, 
which have affected its ability to achieve its mission. In recent 
years, we have reported on these challenges--(1) staffing shortages; 
(2) workforce qualifications; and (3) staff development--and their 
impact. We have also made recommendations to address various aspects of 
these challenges.
    Staffing shortages. Several large-scale disasters and concurrent 
emergencies have created an unprecedented demand for FEMA's workforce. 
In May 2020, we reported that during the 2017 and 2018 disaster 
seasons, FEMA deployed 14,684 and 10,328 personnel, respectively, at 
the peak of each of these seasons and reported staffing shortages.\2\ 
FEMA faced shortages across over half of its cadres--groups organized 
by operational or programmatic functions--during the 2017 and 2018 
disaster seasons. For instance, according to FEMA's deployment data, 18 
of 23 cadres operated with 25 percent or fewer staff available to 
deploy when Hurricane Maria made landfall in Puerto Rico. In addition, 
many staff members who were available to deploy declined when requested 
to do so, in part due to the austere conditions and burnout, FEMA 
officials told us. For example, 48 percent of FEMA staff declined a 
deployment to Puerto Rico in 2017 after Hurricane Maria, and 40 percent 
declined a deployment to California in response to the November 
California wildfires in 2018.
---------------------------------------------------------------------------
    \2\ GAO, FEMA Disaster Workforce: Actions Needed to Address 
Deployment and Staff Development Challenges, GAO-20-360 (Washington, 
D.C.: May 4, 2020).
---------------------------------------------------------------------------
    In light of the aforementioned issues, we are continuing to monitor 
FEMA's ability to deploy personnel to catastrophic disasters or 
concurrent disasters. We recently initiated work related to FEMA's 
recruitment, hiring, and retention.
    Workforce qualifications. In addition to staffing shortages, we 
found that FEMA faced challenges identifying and deploying staff with 
the right qualifications and skills at the right time to best meet 
disaster needs. We reported challenges with the reliability of 
information from FEMA's qualification and deployment processes and 
systems. According to FEMA managers and staff in the field, an 
employee's recorded qualification status was not a reliable indicator 
of staff's ability to perform their positions in the field. For 
example, at the height of FEMA workforce deployments in October 2017, 
54 percent of staff were serving in a capacity in which they did not 
hold the title of qualified--according to FEMA's qualification system 
standards--a past challenge we also identified in 2015.\3\
---------------------------------------------------------------------------
    \3\ GAO, 2017 Hurricanes and Wildfires: Initial Observations on the 
Federal Response and Key Recovery Challenges, GAO-18-472 (Washington, 
D.C.: Sept. 4, 2018).
---------------------------------------------------------------------------
    In 2020, we recommended that FEMA develop a plan to address 
identified challenges that have hindered FEMA's ability to provide 
reliable and complete information to field leaders and managers about 
staff abilities. FEMA concurred and reported progress in developing 
qualification plans for cadre personnel to better inform field leaders 
about staff knowledge, skills, and abilities, among other actions, as 
of December 2021. We are conducting follow-up to assess the extent to 
which FEMA is taking a comprehensive approach and developing a plan 
that considers cross-cutting solutions to the complex and interrelated 
challenges we identified in our report.
    Staff development. Our previous work found shortcomings in FEMA's 
ability to ensure staff development--training courses, on-the-job 
learning, coaching, and mentoring--for the skills and abilities needed 
in the field. We found that at the start of their deployment during the 
2017 and 2018 disaster seasons, 36 percent of FEMA's incident 
management workforce did not have an official assigned to coach and 
evaluate their task performance--the primary mechanism the agency 
depends on for coaching. Furthermore, when such officials were 
assigned, they often lacked time to coach staff. For example, officials 
at one of the joint field offices we visited said mission needs always 
come first and coaching and evaluating responsibilities are frequently 
not a priority. Supervisors in the field also often inconsistently 
completed performance evaluations for deployed staff.
    Additionally, reservists--who often comprise the greatest 
proportion of FEMA staff in the field during a disaster and made up 35 
percent of FEMA's workforce as of August 2021--faced barriers to 
accessing developmental opportunities when not deployed, including lack 
of paid time and technology needed to access training. Effective and 
consistent staff development is particularly important because FEMA has 
hired a large number of reservists over the past few years. The 
challenges associated with underqualified staff underscore the need for 
a comprehensive staff development program that would equip all staff to 
meet mission needs in the field.
    We recommended that FEMA create a staff development program that 
addresses access to training, use of performance evaluations, and 
consistent developmental opportunities regardless of FEMA employees' 
deployment status. FEMA concurred with our recommendation and, as of 
December 2021, has taken steps to improve staff development efforts, 
including steps to allow training to be more accessible to staff, 
implementing assessments for coaching, and establishing a process for 
providing annual performance appraisals for reservists. We are 
monitoring FEMA's actions to assess the extent to which they constitute 
an integrated and cohesive program for workforce development.
    We have reported examples of how these workforce challenges affect 
FEMA's operations and those FEMA serves, including that (1) shortages 
in contracting staff exacerbated challenges for recovery efforts, and 
(2) low morale and high attrition rate affected service delivery.
    Shortages in contracting staff exacerbated challenges for recovery 
efforts. In 2019, we found that during the 2017 hurricanes and 
California wildfires, FEMA experienced shortages in their workforce of 
contracting staff, which exacerbated challenges for disaster response 
and recovery.\4\ For example, eight of FEMA's 10 regional offices had 
only one permanent full-time contracting official.\5\ Regional offices 
are responsible for managing post-disaster contracts that can last for 
years, even if regional procurement staff were not involved in the 
initial award of those contracts.
---------------------------------------------------------------------------
    \4\ GAO, 2017 Disaster Contracting: Actions Needed to Improve the 
Use of Post-Disaster Contracts to Support Response and Recovery, GAO-
19-281 (Washington, D.C.: April 24, 2019).
    \5\ FEMA's 10 regional offices cover all the U.S. states and 
territories.
---------------------------------------------------------------------------
    We also found that FEMA had not assessed its contracting workforce 
needs since 2014 and recommended it assess its workforce needs--
including staffing levels, mission needs, and skill gaps--and develop a 
plan to address any gaps. FEMA concurred with our recommendation and 
officials told us they planned on hiring additional contracting staff 
and conducting competency modeling for its contracting staff, as well 
as a workforce analysis to identify skill gaps. As of May 2021, these 
actions were still in progress.
    Low morale and high attrition rates affected service delivery. In 
May 2020, participants in our focus groups and field managers we 
interviewed cited operational challenges that hindered the cadre's 
ability to support mission needs, including low morale.\6\ Furthermore, 
in September 2020, we reported on FEMA's call center workforce's 
struggles with low morale and their challenges in using program 
guidance to assist survivors.\7\ For example, call center staff worked 
without adequate training, in part due to high disaster activity in 
2017 and 2018. In addition, the training FEMA provided did not 
effectively support staff in applying guidance to answer survivors' 
questions and process cases encountered in their work, according to 
National Processing Service Center staff. These limitations resulted in 
missed opportunities to help survivors quickly.
---------------------------------------------------------------------------
    \6\ GAO-20-360.
    \7\ GAO, Disaster Assistance: Additional Actions Needed to 
Strengthen FEMA's Individuals and Households Program, GAO-20-503 
(Washington, D.C.: Sep. 30, 2020).
---------------------------------------------------------------------------
    Additionally, in 2016, we found that the FEMA's Cadre-of-On-Call 
Response Employee (CORE) Incident Management Assistance Teams (IMAT)--
rapid-response teams of FEMA employees that deploy to disaster sites 
with little to no notice and remain there for unspecified amounts of 
time, depending on mission needs--had experienced high attrition since 
its implementation in fiscal year 2013.\8\ According to IMAT officials 
from nine of 10 regions and one of three national IMATs, key reasons 
cited for the attrition in the initial years of implementing the 
program were the relatively low pay and lack of upward mobility for 
CORE IMAT team members. This high attrition can be costly because of 
the investment required to hire and train new staff.
---------------------------------------------------------------------------
    \8\ GAO, Disaster Response: FEMA Has Made Progress Implementing Key 
Programs, but Opportunities for Improvement Exist, GAO-16-87 
(Washington, D.C.: Feb. 05, 2016).
---------------------------------------------------------------------------
    In 2020, we recommended, among other things, that FEMA use 
desirable characteristics of employee engagement while completing 
planned activities for improving morale among call center staff, 
assessing staff satisfaction scores, and identifying additional steps 
to strengthen employee morale.\9\ FEMA concurred and is taking steps to 
address our recommendation. In 2016, we also recommended FEMA develop a 
process for systematically gathering attrition data and a workforce 
strategy for retaining IMAT staff.\10\ FEMA concurred with the 
recommendation and implemented it with a series of actions, such as an 
assessment of attrition in the IMAT workforce and policy changes 
informed by the assessment, which they completed in June 2021.
---------------------------------------------------------------------------
    \9\ GAO-20-503.
    \10\ GAO-16-87.
---------------------------------------------------------------------------
                      Long-Term Disaster Recovery
    The federal government has dozens of programs that provide recovery 
assistance in the wake of a disaster to eligible state, local, tribal, 
and territorial governments; businesses; and individuals and 
communities. We have reported on the extent to which FEMA provides 
recovery assistance after disasters through its Public Assistance and 
Individual Assistance programs, among other initiatives. During our 
work relating to disasters that affected the Pacific and Caribbean 
regions and California in 2017 and 2018, we found that these recovery 
programs can be complex and slow to provide assistance.
Challenges Facing FEMA's Public Assistance Program
    FEMA's Public Assistance program reimburses state, local, tribal, 
and territorial governments and certain types of nonprofit 
organizations for the cost of disaster-related debris removal, 
emergency protective measures to protect life and property, and 
permanent work to repair or replace damaged or destroyed 
infrastructure. According to FEMA's January 2022 Disaster Relief Fund 
report, total projected obligations for the Public Assistance programs 
from August 1, 2017 through fiscal year 2022 are approximately $112 
billion.\11\
---------------------------------------------------------------------------
    \11\ DHS, FEMA, Disaster Relief Fund: Monthly Report as of December 
31, 2021. (Jan. 7, 2022).
---------------------------------------------------------------------------
    DHS's Fiscal Year 2019-2021 Annual Performance Report states that 
the speed at which FEMA obligates funding for Public Assistance 
projects is a priority for advancing the recovery process. However, 
this report also states that in fiscal year 2019, FEMA awarded only 28 
percent of Public Assistance projects within FEMA's target time frames. 
In February 2021, we found that FEMA met its goal of awarding Public 
Assistance funds within 189 days of a disaster for only 14 percent of 
Public Assistance projects in the Pacific region (70 of 492 
projects).\12\ On average, it took 13 months for FEMA to award funding 
for these projects. Similarly, we reported in November 2019 and May 
2021 on slow time frames for awarding Public Assistance funding in 
Puerto Rico and the U.S. Virgin Islands.\13\ In February 2021, we 
recommended that FEMA analyze Public Assistance program data to 
identify causes of funding delays and take actions to address those 
delays.\14\ FEMA concurred and is working to address this 
recommendation.
---------------------------------------------------------------------------
    \12\ GAO, 2018 Pacific Island Disasters: Federal Actions Helped 
Facilitate the Response, but FEMA Needs to Address Long-Term Recovery 
Challenges, GAO-21-91 (Washington, D.C.: Feb. 3, 2021).
    \13\ GAO, U.S. Virgin Islands Recovery: Additional Actions Could 
Strengthen FEMA's Key Disaster Recovery Efforts, GAO-20-54 (Washington, 
D.C.: Nov. 19, 2019); GAO, Puerto Rico Recovery: FEMA Made Progress in 
Approving Projects, But Should Identify and Assess Risks to the 
Recovery, GAO-21-264 (Washington, D.C.: May 19, 2021).
    \14\ GAO-21-91.
---------------------------------------------------------------------------
    We have reported on several additional factors that may have 
contributed to FEMA's slowness in awarding Public Assistance funding:
    Reimbursement model. Most Public Assistance projects utilize a 
reimbursement model in which award recipients--state or territorial 
governments where the President has declared a major disaster--must 
provide upfront funding for projects and later seek reimbursement from 
FEMA. We found that this model delayed recovery in some locations. 
Specifically, we reported in November 2019 that, due to the U.S. Virgin 
Islands' fiscal situation and inability to provide upfront funding for 
all Public Assistance projects, the territory had to prioritize certain 
projects over others.\15\ Similarly, we reported in May 2021 that 
Puerto Rico's fiscal situation made it difficult for Public Assistance 
award recipients to provide upfront project funding, and consequently, 
construction for many approved projects had not started. For example, 
we found that as of January 2021--over 3 years since hurricanes Irma 
and Maria struck the island--Puerto Rico had expended less than $158 
million (or less than 1 percent) of the $17.5 billion that FEMA 
obligated to reimburse award recipients for permanent work Public 
Assistance projects.\16\
---------------------------------------------------------------------------
    \15\ GAO-20-54.
    \16\ GAO-21-264.
---------------------------------------------------------------------------
    In May 2021, we recommended that FEMA coordinate with the 
Government of Puerto Rico and relevant federal agencies to identify and 
assess risks--and potential actions to manage those risks--to the 
remainder of Puerto Rico's disaster recovery, including factors such as 
Puerto Rico's capacity to carry out Public Assistance projects. FEMA 
agreed with this recommendation and has started a formal risk 
assessment process. In addition, officials in the U.S. Virgin Islands 
told us that pursuing projects under the Public Assistance alternative 
procedures program may help to address issues with the reimbursement 
model by providing more flexibility regarding when and how projects are 
funded. These alternative procedures are discussed below.
    Fixed-cost estimates. FEMA developed alternative procedures in 
which FEMA provides funding for Public Assistance projects based on a 
fixed-cost estimate, which may help alleviate the challenges associated 
with the reimbursement model. FEMA intended to expedite the provision 
of assistance with these alternative procedures. However, in 2019, 
2020, and 2021, we reported that Public Assistance applicants in the 
Pacific and Caribbean regions found the process of developing fixed-
cost estimates to be difficult and lengthy, and this estimation process 
delayed disaster recovery.\17\ We have made recommendations to help 
FEMA improve the use of fixed-cost estimates, and identify and address 
related inefficiencies. FEMA concurred and has taken actions to address 
these recommendations.
---------------------------------------------------------------------------
    \17\ GAO-20-54; GAO-21-91; and GAO, Puerto Rico Disaster Recovery: 
FEMA Actions Needed to Strengthen Project Cost Estimation and Awareness 
of Program Guidance, GAO-20-221 (Washington, D.C.: Feb. 5, 2020).
---------------------------------------------------------------------------
    Wildfire debris removal. We also found in October 2019 that the 
unique challenge of removing wildfire debris led to confusion over soil 
excavation standards and led to over-excavation of some homeowners' 
lots, lengthening the recovery process.\18\ To address this and other 
wildfire-related challenges, we recommended that FEMA comprehensively 
assess operations to identify any additional updates to its management 
controls--such as policies, procedures, or training--that could enhance 
future response and recovery from large-scale and severe wildfires. 
FEMA is taking steps to address this recommendation, including by 
developing analyses to update disaster assessment efforts and working 
to update guidance.
---------------------------------------------------------------------------
    \18\ GAO, Wildfire Disasters: FEMA Could Take Additional Actions to 
Address Unique Response and Recovery Challenges, GAO-20-5 (Washington, 
D.C.: Oct. 9, 2019).
---------------------------------------------------------------------------
Challenges Facing FEMA's Individual Assistance Program
    FEMA's Individual Assistance program provides financial assistance 
and, if necessary, direct assistance to eligible individuals and 
households who, as a direct result of a major disaster or emergency, 
have necessary expenses and serious needs, and are unable to meet such 
expenses or needs through other means. According to FEMA's January 2022 
Disaster Relief Fund report, total projected obligations for Individual 
Assistance programs from August 1, 2017 through fiscal year 2022 are 
approximately $5 billion.\19\
---------------------------------------------------------------------------
    \19\ DHS, FEMA, Disaster Relief Fund: Monthly Report as of December 
31, 2021. (Jan. 7, 2022).
---------------------------------------------------------------------------
    Individuals and Households Program (IHP). In September 2020, we 
reported that survivors faced numerous challenges obtaining aid and 
understanding the IHP--one of FEMA's Individual Assistance programs 
that provides housing and other needs assistance to individuals 
affected by a major disaster or emergency.\20\ We found FEMA, state, 
territory, and local officials said that disaster survivors did not 
understand and were frustrated by the requirement that certain 
survivors first be denied a Small Business Administration (SBA) 
disaster loan before receiving certain types of IHP assistance. FEMA 
did not fully explain the requirement to survivors and its process for 
the requirement may have prevented many survivors from being considered 
for certain types of assistance, including low-income applicants who 
are less likely to qualify for an SBA loan. For instance, we identified 
tens of thousands of potentially low-income IHP applicants who were 
referred to the SBA but did not submit a loan application. As a result, 
FEMA could not consider these applicants for personal property 
assistance--for millions of dollars in verified losses--under its 
current process.
---------------------------------------------------------------------------
    \20\ GAO-20-503.
---------------------------------------------------------------------------
    We also found that opportunities exist to improve survivors' 
understanding of FEMA's eligibility and award determinations for the 
IHP; for example, clarifying that an ineligible determination is not 
always final but may mean FEMA needs more information to decide the 
award. In addition, we reported that state and local officials 
generally had trouble understanding the IHP. For example, these 
officials said that FEMA did not provide sufficient training, support, 
and guidance that was needed in order for them to be able to 
effectively work with FEMA to facilitate IHP assistance.
    To address these and other challenges relating to the IHP, we made 
14 recommendations, including identifying ways to simplify the IHP 
application process and providing more information to survivors about 
their award, among others. FEMA agreed with our recommendations and is 
working to address them. For example, as of October 2021, FEMA 
officials told us that they are pursuing a regulatory change to alter 
the requirement that disaster survivors apply to SBA and be denied 
before seeking assistance from FEMA for some types of IHP assistance. 
Additionally, as of fall 2021, FEMA was planning revisions to its 
communications to survivors and published guidance for state and local 
officials, among other steps in progress.
    Permanent housing in remote areas. We have also identified 
challenges relating to FEMA's Permanent Housing Construction program--
another Individual Assistance program. Specifically, in February 2021, 
we reported that 2 years after typhoons struck the Commonwealth of the 
Northern Mariana Islands, FEMA had completed 60 percent (73 out of 121) 
of home repairs, and only completed about 11 percent (20 out of 182) of 
new construction for survivors enrolled in the Permanent Housing 
Construction program (93 of 303 houses).\21\ These delays were due, in 
part, to a lack of expertise within FEMA relating to soliciting and 
awarding construction contracts and construction errors made by 
contracted entities.
---------------------------------------------------------------------------
    \21\ GAO-21-91.
---------------------------------------------------------------------------
    We found that these housing assistance challenges were consistent 
with lessons learned from prior FEMA missions in other remote areas of 
the United States. To address these challenges, we recommended that 
FEMA incorporate lessons learned from earlier Permanent Housing 
Construction missions and address long-standing issues in guidance that 
outlines necessary steps to better plan for and implement the program 
in remote areas. FEMA concurred and is planning to implement this 
recommendation in a Direct Housing Guide it is developing.
   Potential Barriers and Disparate Outcomes with Disaster Recovery 
                               Assistance
    As we highlighted above, disaster recovery is a complex process 
with many factors that affect individual and community outcomes, 
including in various socioeconomic and demographic groups. While 
federal disaster recovery programs are not typically targeted toward 
only low-income or vulnerable populations, our recent work and 
recommendations have identified areas that could help these 
populations. Specifically, we have reported on FEMA's efforts to (1) 
identify and address potential access barriers to disaster recovery 
programs; (2) prioritize flood map investments for vulnerable 
populations; and (3) provide assistance to individuals who are older or 
who have disabilities.
    Identifying and addressing potential access barriers and disparate 
outcomes. In December 2021, we reported on six federal disaster 
recovery programs with historically large obligations and found the 
programs have taken some actions that could help officials identify and 
address social and institutional barriers.\22\ However, these recovery 
programs generally lacked quality information that would allow them to 
identify potential access barriers and disparate recovery outcomes. 
Additionally, FEMA and federal partners administering disaster recovery 
programs have not established processes to address any potential 
barriers and disparate outcomes they identify on an ongoing basis. 
However, FEMA and other federal agencies with large recovery programs 
can and should work together to devise workable approaches to identify 
and address barriers to accessing federal recovery programs and 
disparate outcomes.
---------------------------------------------------------------------------
    \22\ GAO, Disaster Recovery: Additional Actions Needed to Identify 
and Address Potential Recovery Barriers, GAO-22-104039 (Washington, 
D.C.: Dec. 15, 2021).
---------------------------------------------------------------------------
    We recommended that FEMA, along with federal partners, (1) develop 
and implement an interagency plan to help ensure the availability and 
use of quality information; and (2) design and establish routine 
processes to be used within and across federal disaster recovery 
programs to identify and address potential barriers and disparate 
outcomes on an ongoing basis. FEMA agreed with both of the 
recommendations and is planning to take actions to address them by the 
end of 2022.
    Prioritizing flood map investments for vulnerable populations. In 
October 2021, we reported that the FEMA flood mapping investments for 
fiscal years 2012 through 2020 were lower for communities with higher 
levels of social vulnerability and underserved populations, other 
factors being equal.\23\ More specifically, we found communities with 
relatively higher levels of social vulnerability and underserved 
populations had (1) more unmapped miles or paper maps in fiscal year 
2012; (2) a smaller increase in the percentage of mapped miles that met 
FEMA's quality standard metric; and (3) longer cycle times between the 
stages of FEMA's mapping process.
---------------------------------------------------------------------------
    \23\ GAO, FEMA Flood Maps: Better Planning and Analysis Needed to 
Address Current and Future Flood Hazards. GAO-22-104079, (Washington, 
D.C.: Oct. 25, 2021). Social vulnerability is broadly defined as the 
susceptibility of social groups to the adverse impacts of natural 
hazards, including disproportionate death, injury, loss, or disruption 
of livelihood. Social vulnerability considers social vulnerability as 
the social, economic, demographic, and housing characteristics of a 
community.
---------------------------------------------------------------------------
    We recommended that FEMA better use flood risk data to prioritize 
flood mapping investments toward priority areas, such as vulnerable 
communities. FEMA leadership was interested in examining ways the 
agency could use data to inform future annual mapping investment 
decisions and agreed with our recommendation. They are taking steps to 
address the recommendation and we will continue to monitor their 
efforts.
    Access to specialized assistance for older and disabled 
individuals. In May 2019, we reported that officials from entities that 
partnered with FEMA reported challenges providing assistance to 
individuals who are older or who have disabilities following the 2017 
hurricanes.\24\ For example, officials said that many of these 
individuals required specialized assistance obtaining food, water, 
medicine, and oxygen, but aid was sometimes difficult to provide. We 
also reported that aspects of the process to apply for assistance from 
FEMA were challenging for older individuals and those with disabilities 
and that FEMA did not provide individuals clear opportunities to 
disclose disability-related needs.
---------------------------------------------------------------------------
    \24\ GAO, Disaster Assistance: FEMA Action Needed to Better Support 
Individuals Who Are Older or Have Disabilities. GAO-19-318. Washington, 
D.C.: May 14, 2019.
---------------------------------------------------------------------------
    We recommended, among other things, that FEMA implement new 
registration-intake questions to improve FEMA's ability to identify and 
address survivors' disability-related needs. FEMA agreed with this 
recommendation and implemented it in May 2019 by using revised 
registration-intake questions that asked directly if survivors had a 
disability. According to FEMA's analysis, the percentage of survivors 
that identified having a disability-related need increased 
substantially after implementing the revised questions.
               Future Disaster Resilience and Mitigation
    We have previously reported on the extent to which FEMA programs 
encourage resilience before a disaster and as part of recovery efforts 
following a disaster. We have found that federal and local efforts to 
improve resilience can reduce the effects and costs of future 
disasters. FEMA has made progress in this area by establishing an 
investment strategy to help federal, state, and local officials 
identify, prioritize, and guide federal investments in disaster 
resilience. FEMA published the National Mitigation Investment Strategy 
in August 2019. However, our prior work highlights opportunities to 
improve disaster resilience. Specifically, we reported on FEMA efforts 
to (1) to identify flood hazards and (2) improve hazard mitigation:
    Identify flood hazards. We found that FEMA had increased its 
development of flood maps and other flood risk products, but the agency 
faced challenges ensuring they comprehensively reflect current and 
future flood hazards.\25\ For example, its flood risk products do not 
reflect hazards such as heavy rainfall and the best available climate 
science. FEMA was addressing some of these challenges, but many may 
require years to address. Also, the agency was operating under an out-
of-date plan that did not reflect new goals, objectives and timeframes, 
among other things. In order to address challenges in reflecting 
current and future flood hazards, we recommended, among other things, 
that FEMA update its plan to identify program goals, objectives, 
activities, performance measures and time frames for its various 
efforts. FEMA concurred and is working to update its ``Risk MAP Multi-
Year Plan,'' to include the items we identified, by December 2022 to 
address our recommendation.
---------------------------------------------------------------------------
    \25\ GAO-22-104079
---------------------------------------------------------------------------
    Improving hazard mitigation. In February 2021, we found that state 
and local officials from selected jurisdictions reported challenges 
with FEMA's hazard mitigation grant programs.\26\ Specifically, 
officials we interviewed from 10 of 12 jurisdictions said grant 
application processes were complex and lengthy. To address this, FEMA 
officials augmented guidance and began monitoring application review 
time frames to identify opportunities to streamline the programs. 
However, the agency had no documented plan to do this. In addition, 
officials from eight of the 12 jurisdictions cited challenges with 
applicants' technical capacity to successfully apply for grants. To 
address this, FEMA developed training and guidance, but we found that 
these resources could be difficult for state and local officials to 
locate on different parts of FEMA's website.
---------------------------------------------------------------------------
    \26\ GAO, Disaster Resilience: FEMA Should Take Additional Steps to 
Streamline Hazard Mitigation Grants and Assess Program Effects, GAO-21-
140 (Washington, D.C.: Feb. 2, 2021). Hazard mitigation is any 
sustainable action that reduces or eliminates long-term risk to people 
and property from future disasters.
---------------------------------------------------------------------------
    We recommended that FEMA establish a plan with time frames to 
assess hazard mitigation grant processes to identify and implement 
steps to reduce the complexity of and time required for grant 
applications. FEMA concurred with this recommendation. As of January 
2022, the agency stated it had several ongoing efforts to address our 
recommendation, such as drafting strategic plans meant to reduce 
complexity. To address difficulties in locating application resources, 
we recommended that FEMA create a centralized inventory of hazard 
mitigation resources on the FEMA website. FEMA concurred with this 
recommendation and, as of January 2022, the agency said it was in 
process of updating its web pages and guidance. We will continue 
monitoring FEMA's efforts to fully address both recommendations.
    Thank you Chair Titus, Ranking Member Webster, and Members of the 
Subcommittee. This concludes my prepared statement. I would be happy to 
respond to any questions you may have at this time.

    Ms. Titus. Thank you very much, Mr. Currie.
    We will now go to Ms. Bornemann.
    Ms. Bornemann. Good afternoon. Thank you, Chairwoman Titus 
and Ranking Member Webster, for this hearing today. And I would 
be remiss if I missed out on acknowledging Chairman DeFazio of 
the full committee.
    Your retirement is bittersweet for the emergency management 
community. Your steadfast leadership during your time at the 
helm of the Transportation and Infrastructure Committee has 
truly been impactful to the profession. Your retirement is 
well-earned, and we really wish you the best. Fortunately, the 
current leadership of the committee will remain intact for the 
coming year.
    However, there are several areas that State emergency 
managers feel we can be effective in working with FEMA and 
Congress. The most recent iteration of the FEMA Strategic Plan 
is thoughtful, and demonstrates a real commitment to the next 
generation of emergency management. As we look toward managing 
an ever-changing climate, instilling equity in programs, 
diversifying our workforce, and ensuring the Nation has the 
highest level of readiness, there are several issues on which 
we should focus.
    Emergency managers are in need of policies and regulation 
that provide more flexibilities to navigate increasingly 
complex challenges faced in a rapidly changing environment. 
Threats such as the ongoing pandemic, cybersecurity, climate 
change, infrastructure failures, and continuing natural hazards 
require a streamlined and coordinated Federal approach. As the 
complexity of the disasters we respond to and recover from 
increases, so do programs that were meant to aid Americans in 
their worst hour.
    NEMA recently completed work on three position papers, 
which Chairman DeFazio referenced in terms of the wildfire one, 
which I have submitted for the record with my written 
statement. They address the need for greater collaboration on 
establishing grant requirements, enhancing coordination between 
FEMA and the Cybersecurity and Infrastructure Security Agency, 
and addressing wildfire policy.
    You may remember back in October, when my colleague from 
Oregon, Andrew Phelps, testified before this committee on 
wildfires. NEMA took advantage of this opportunity to 
participate in that hearing, and codified in policy many issues 
that were discussed. I request your attention to the 
recommendations provided in that position paper, and we really 
look forward to working with the committee as we look for 
opportunities for implementation.
    Wildfires are just one hazard that highlight the need for 
further examination of the equity of application and 
implementation of disaster programs. Small changes in policy or 
statute can equal significant impact when measuring results. A 
small step, such as implementing a universal application for 
disaster survivors, is a seemingly simple measure that equates 
to better access for States that may have less resources, and a 
better disaster survivor experience.
    We remain encouraged by FEMA's forward-leaning approach to 
garnering feedback for preparedness grant programs, and expect 
clear objectives to be outlined to address known equity 
challenges within the program themselves. Beyond equity, 
however, there are many other challenges in response and 
recovery programs.
    For several years now, practically every NEMA witness 
before this and other committees has spoken of the need to 
simplify Federal programs, to streamline State emergency 
management, and make them more accessible to the public. This 
doesn't require broad measures. It can be simple steps, such as 
clarifying FEMA as a lead Federal agency for all consequence 
management; supporting legislation such as the SPEED Recovery 
Act, which raises the small project threshold; reviewing the 
authorities, roles, and responsibilities of the consolidated 
resource centers to ensure they are not overly bureaucratic; 
and allowing for the rollover of management cost from one 
disaster to the next, thereby building capacity at the State 
level and speeding disaster closeout.
    Finally, the changing face of disasters means we must 
consider challenges such as our changing climate. 
Unfortunately, current programs lack adequate guidance and 
support to address all hazards intensified by climate change. 
NEMA needs to strategically identify, prioritize, and invest in 
climate resilience projects that help reduce future losses. 
This should be done also with an eye toward measurable 
outcomes, so that we know what success looks like.
    These goals are not unattainable, and the State emergency 
management community believes that, working together across all 
levels of Government, we can make preparedness and disaster 
programs more accessible and accountable.
    On behalf of the entire NEMA membership, thank you again 
for holding this hearing, and I look forward to any questions 
you have for me.
    [Ms. Bornemann's prepared statement follows:]

                                 
  Prepared Statement of Erica Bornemann, Director, Vermont Emergency 
 Management, on behalf of the National Emergency Management Association
    Thank you, Chairwoman Titus, Ranking Member Webster, and 
distinguished members of the Committee for allowing me to testify 
today.
    I am proud to represent the National Emergency Management 
Association (NEMA). NEMA represents the state emergency management 
directors of all 50 states, territories, and the District of Columbia. 
As Director of Vermont Emergency Management and on behalf of my 
colleagues in state emergency management, we thank you for holding this 
discussion on recommended priorities of the Federal Emergency 
Management Agency (FEMA) in 2022.
    The relationship between federal, state, and local emergency 
management is unique in that each maintains separate authorities and 
capabilities but must rely on one another to save lives and protect 
property. State emergency management relies on the strength of our 
locals, so the success of FEMA is also determined by the strength of 
the states. The relationship between state and federal emergency 
management is sometimes stressed, but no disagreement cannot be 
overcome by understanding each other's priorities, remaining flexible, 
and maintaining the shared goal of focusing on disaster survivors. The 
ongoing COVID-19 pandemic response and recent change in administration 
gave the NEMA membership several opportunities to address continuous 
improvements with FEMA and we welcome the committee to this discussion 
as we look to 2022.
    The state emergency managers applaud the recent strategic plan 
developed by FEMA and look forward to working with Administrator 
Criswell during implementation. To that end, many of the priorities 
outlined in this testimony can find congruency with the goals and 
objectives of the strategic plan.
             Streamlining and Coordinating Federal Programs
    In partnership with the states, FEMA should pursue a comprehensive 
review, re-envisioning, and reform of emergency management policies and 
regulation to provide more flexibility for emergency managers to 
navigate increasingly complex challenges faced in a rapidly changing 
environment. Threats such as the ongoing pandemic, cybersecurity, 
climate change, infrastructure failures, and continuing natural hazards 
requires a streamlined and coordinated federal approach.
    As a part of this re-envisioning, FEMA should conduct a review of 
headquarters-versus-regional decision-making roles and authorities to 
aid in streamlining and consistency. The relationship between FEMA 
headquarters and the regions must result in a common, fair, and 
equitable application of policy, guidance, and regulations across the 
country. COVID-19 demonstrated many of the shortcomings in the existing 
disconnect between FEMA headquarters and the regions. Throughout the 
pandemic states and FEMA Regions struggled to interpret guidance 
changes regarding eligibility of response activities and interpretation 
of these policies often differed from Region to Region. For example, 
the eligible uses of PPE depending on type of facility and occupation 
utilizing the PPE was very difficult for applicants to decipher and 
continues to be an issue throughout the country. Public Assistance 
program guidance assumes impact from disaster caused by natural hazards 
and it is often difficult to apply to other disasters such as pandemics 
or cyber-attacks. Simplifying guidance as well as interpretation to be 
as straight-forward as possible will lessen the administrative burden 
on applicants as well as FEMA and will cost taxpayers less wasted time 
in fruitless deliberations.
    NEMA recently approved three position papers that address other 
aspects of federal coordination and policy implementation. Submitted 
with this testimony to be entered into the Congressional Record, these 
papers address the following:
    1.  Coordination of State Homeland Security Grant Program Guidance. 
As emergency management and homeland security professionals, the 
membership of NEMA appreciates the need for grant programs to remain 
dynamic and meet emerging threats. FEMA and the department must develop 
a more collaborative process, however, to devise, evaluate, and 
implement proposed changes. Therefore, FEMA should encourage DHS to 
establish a codified review process for grant guidance that is properly 
vetted through the appropriate stakeholders.
    2.  Interagency Collaboration. With the continued maturation of the 
Cybersecurity and Infrastructure Security Agency (CISA), the need for 
collaboration with FEMA is paramount. Whether addressing cybersecurity 
threats or critical infrastructure protection activities, FEMA and CISA 
must work closely in the development of policies and regulations. An 
Integrated Program Office (IPO) seems the best logical way to ensure 
such policy is integrated, coordinated, and clarified for those charged 
with saving life and property in the response to a major event. This 
would further serve as an opportunity to coordinate policy and avoid 
negative consequences prior to major events through better integration 
at the federal level.
    3.  Wildfire Policy. Recent wildfires exposed gaps in assistance 
and flaws in the interpretation of existing policy. Leveraging federal 
grants for response or mitigation efforts becomes problematic when they 
do not have adequate allowances for some of the unique needs of 
fighting wildfires. In the long-term approach, state and local land 
managers can be proactive in lessening threats to communities, while 
federal land managers struggle to implement meaningful fuels reduction 
projects near communities. In total, there would be great benefit to 
federal agencies taking a more active role in protecting communities 
before, during, and after wildland fires originating on federal lands. 
The paper includes a robust set of recommendations touching nearly 
every aspect of FEMA response and recovery programs.
               Addressing Equity in Emergency Management
    Disasters are indiscriminate in their impact. They do not 
distinguish between party affiliation, arbitrary borders, or income 
level. Emergency management programs and policies in this nation must 
recognize these qualities and evolve to meet the needs of all 
Americans. NEMA embraces the priorities outlined in the FEMA strategic 
plan to address equity in emergency management programs. This year the 
association created a new policy committee to address diversity and 
equity issues. FEMA can aid in this national effort by addressing, 
supporting, and cultivating an inclusive and diverse workforce 
representing the diversity of communities impacted by emergencies. This 
includes removing barriers inhibiting vulnerable and underserved 
populations from applying for and receiving aid after a disaster. The 
federal government should implement a universal application at the 
federal level for all disaster assistance programs, creating a more 
equitable and less burdensome process for survivors already 
experiencing some of the hardest times in their life.
    Furthermore, NEMA encouraged FEMA to create a formalized process by 
which to evaluate whether existing or new disaster and non-disaster 
grant programs increase or decrease equity for disaster survivors, and 
do not aggravate any financial and social disparities that may exist 
prior to the event. In addressing these goals, however, FEMA should use 
caution in guarding against unintended consequences that could 
inadvertently reduce or limit assistance to those in need.
    For example, layering additional grant requirements to address 
equity concerns can become an equity issue by applying a one-size fits 
all approach to all states and assuming all states have the same 
resources to meet additional grant requirements. We remain encouraged 
by FEMA's forwarding-leaning approach to garnering feedback for the 
preparedness grant programs and expect clear objectives to be outlined 
to address known equity challenges within the program themselves.
                   Simplify Federal Recovery Programs
    The ongoing response to COVID-19 and other, overlapping events 
presented a tidal shift in the view of emergency management at all 
levels of government. But where issues may arise during response, the 
true test of our capabilities and resiliency as a nation come in the 
recovery process. The past two years revealed several issues FEMA 
should address in 2022 and beyond, including:
      Working with the administration to clarify, improve, and 
add capacity to support the agency's role in long-term recovery. They 
should be the coordinating agency on behalf of the federal government 
with the authority to support federal functions across the disaster 
recovery spectrum.
      Raising the small project threshold of the Public 
Assistance program from $131,100 to $1 million, thereby reducing the 
complexity of recovery and expediting recovery dollars to disaster 
survivors. If FEMA remains unwilling to effect this change 
administratively, NEMA reiterates our support of H.R. 5641, the SPEED 
Recovery Act, introduced by Representative Graves.
      A review of the authorities, roles, and responsibilities 
of Consolidated Resource Centers (CRC). Originally intended as 
processing centers, CRCs morphed into bottlenecks in the recovery 
process, circumventing decisions made by Federal Coordinating Officers, 
and slowing processing of recovery funds at headquarters.
      An evaluation of the Individual Assistance (IA) Program 
to include eligibility indicators, funding amount, processes, and speed 
of resources to disaster survivors. IA should maintain a focus on the 
beginning of a disaster and a whole community approach in meeting the 
objectives of the needs of individuals.
      Immediately beginning the process of amending 44 C.F.R. 
Part 207 to allow for the rollover of management costs from one 
disaster to the next. This would provide each state an unfunded grant 
for both the Public Assistance Program and Hazard Mitigation Grant 
Program. It would also allow remaining funds after the close-out of a 
disaster to be available to build recovery and mitigation capacity at 
the state and local levels, and more expeditiously close-out remaining 
disasters which may be more complicated and build resilience for the 
next disaster.
      A clarification of the challenges experienced by states 
as it relates to the sharing of personally identifiable information 
(PII) in the IA National Flood Insurance programs. FEMA should create a 
standardized information sharing form which disaster survivors can sign 
to allow the pertinent recovery agencies with identified resources or 
program support to receive their information.
               Integrating Climate Adaptation Priorities
    Adapting to the more complex weather we experience and the 
consequences that come along with it require flexibilities to emergency 
response systems. Current programs lack the adequate guidance and 
support which helps manage these new extreme climate disasters. FEMA 
needs to strategically identify, prioritize, and invest in climate 
resilience projects that help reduce future losses. This would include 
coordinating interagency investments for consistency, efficiency, and 
maximum return.
    In addition to a review of current programs through a more climate-
conscious lens, FEMA should ensure the utilization of all reasonable 
and pertinent federal partnerships to achieve relief and recovery from 
all aspects of a disaster. This coordination of climate change relates 
to mitigation, preparedness, response, and recovery programs with other 
federal agencies--including risk, vulnerability, and consequence 
assessments. In doing this, FEMA must guard against simply adding 
``climate change'' into existing guidance, verbiage, and doctrine. 
Efforts outlined at the federal level must be measurable to include 
benchmarks to determining success. Furthermore, program eligibility 
must incorporate the full spectrum of disasters exacerbated by climate 
change including wildfire and drought. Only through a whole-of-
government approach can FEMA allow for adequate capacity to respond and 
with a focus on information sharing, it will allow programs to properly 
provide relief to victims as they work to recover.
                               Conclusion
    On behalf of the state emergency managers, thank you again for 
holding this hearing on where FEMA should focus in the coming year. 
Collectively, emergency managers believe we must work together in 
building our respective capacities to respond, enhance equity in state 
and federal programs, and streamline FEMA programs to get assistance 
more quickly to the people who need it most. We can accomplish this by 
working together across all levels of government and ensuring the role 
of emergency management is clear regardless of the hazard. In doing all 
this, we look forward to continuing the strong relationship we have 
with this committee and with FEMA, and I welcome any questions.

                               __________
                                                   Position Paper 1
               National Emergency Management Association
                      Homeland Security Committee
                             Position Paper

DATE:     January 10, 2022
SUBJECT:  State Homeland Security Grant Program Policy Changes

DISCUSSION:
    The basis of the State Homeland Security Grant Program (SHSGP) pre-
dates the terrorist attacks of September 11, and the Urban Area 
Security Initiative (UASI) came about shortly after the creation of the 
Department of Homeland Security in 2003. These two programs form the 
cornerstone of preparedness funding for states and locals to address 
emerging and dynamic threats to the homeland. They support the 
building, sustainment, and delivery of core capabilities in states, 
territories, urban areas, and local and tribal governments and to 
develop a more secure and resilient nation.
    These programs represent a partnership between states and locals to 
aid the federal government in their mission to close nationwide 
preparedness gaps. In 2018, the National Homeland Security Consortium 
conducted a study to evaluate the past investment of funds on terrorism 
preparedness, the augmentation of that funding by federal assistance, 
and what capabilities states, and localities now have that were not 
available pre-2001. To collect this information, a survey was issued to 
all 50 states and to jurisdictions from 50 urban areas currently and 
formerly eligible for UASI funds to determine how much money has been 
invested by state and local governments.
    A key finding from the survey is that for every SHSGP and UASI 
grant dollar invested, the median return was $1.70 for responding state 
emergency management and homeland security agencies; for local 
emergency management and homeland security agencies, it was $0.92. 
Furthermore, return on investment also generally increased when 
considering other jurisdictional agencies that were involved with, but 
not responsible for preparedness activities.
    In recent years, administrations waited until the completion of the 
appropriations process and the Notice of Funding Opportunity (NOFO) to 
roll-out proposed programmatic changes to the SHSGP and UASI programs. 
An example of these proposed changes includes a requirement for certain 
percentages of funding to meet core priorities. Furthermore, in 2020 
the department ``banded'' states based on threat which fundamentally 
altered the funding formula for states. While the department ultimately 
sidelined these proposed changes primarily due to the continuing 
response to COVID, they reflect a repeated pattern of attempts to 
change the rules during the application process.
    As emergency management and homeland security professionals, the 
membership of NEMA appreciate the need for these programs to remain 
dynamic and meet emerging threats. The department must develop a more 
collaborative process, however, to devise, evaluate, and implement 
proposed changes. The planning process for grant funding typically 
takes several years, so the 45-day window of a standard NOFO is wholly 
inadequate to affect smart and effective changes. Also, with a multi-
year performance period for the grant, changing the national priorities 
in the middle of the period means states and locals cannot achieve or 
sustain impactful progress.

RECOMMENDATIONS:
    1.  DHS should establish a codified review process for grant 
guidance that is properly vetted through the appropriate stakeholders. 
Organizations such as NEMA, the National Homeland Security Consortium, 
or National Advisory Council are natural partners in such an effort.
    2.  Completion of the review and concurrence should occur not less 
than 12 months from the end of the previous fiscal year to give 
grantees adequate time for planning adjustments.

Moved: Brian Hastings, Alabama
Second: Chris Stallings, Georgia
DISPOSITION: Passed Unanimously
Authenticated: Mike Willis, NEMA Secretary

                               __________
                                                   Position Paper 2
               National Emergency Management Association
                      Homeland Security Committee
                             Position Paper

DATE:     January 10, 2022
SUBJECT:  CISA-FEMA Integrated Program Office

DISCUSSION:
    With the reorganization of the Cybersecurity and Infrastructure 
Security Agency (CISA) and awarding the agency operational status, the 
Department of Homeland Security (DHS) created an agency focused on 
protecting critical infrastructure and assisting the nation in 
enhancing cybersecurity. The unintended consequence of this new 
organization, however, is the separation of mission of critical 
infrastructure protection and the response and recovery mission of the 
Federal Emergency Management Agency (FEMA). Despite the organization 
separation within the department, these mission sets are inextricably 
linked in policy.
    For response and recovery functions after a natural or man-made 
physical disaster, the Federal Emergency Management Agency (FEMA) is a 
logical state partner with regional personnel, grant structure, and 
experience in consequence management. After a cyber-incident, with or 
without a physical impact, state and local governments and the private 
sector look to CISA for support. Naturally, CISA needs FEMA and vice 
versa in both policy development and practical application of response 
capabilities. This reliance among DHS components, however, can cause 
barriers to reasonable and appropriate response time and action.
    For example, throughout the stakeholder community, questions abound 
relating to the federal government's processes for responding to major 
cybersecurity attacks. Preparedness, response, and recovery functions 
for such events work together with one another, therefore so too should 
federal policy and operations. Furthermore, the recently passed 
Bipartisan Infrastructure Framework included $1 billion over the next 
four years for a cybersecurity preparedness grant. As this new grant is 
brought online, collaboration will be required between CISA as the 
subject matter experts and FEMA as the department's grant-making 
entity.
    An Integrated Program Office (IPO) seems the only logical way to 
ensure such policy is integrated, coordinated, and clarified for those 
charged with saving life and property in the response to a major event. 
This would further serve as an opportunity to coordinate policy and 
avoid negative consequences prior to major events through better 
integration at the federal level.

RECOMMENDATIONS:
    1.  DHS should establish IPO, modeled after those at the Department 
of Defense, between FEMA and CISA. The mission of this office would be 
to coordinate all policy and response doctrine as it would apply to 
cybersecurity, critical infrastructure protection, and any other 
subject of shared interest.

Moved: Brian Hastings, Alabama
Second: Chris Stallings, Georgia
DISPOSITION: Passed
ABSTAIN: Florida
Authenticated: Mike Willis, NEMA Secretary
                                                   Position Paper 3
               National Emergency Management Association
                    Response and Recovery Committee
                             Position Paper

DATE:     January 2, 2022
SUBJECT:  State Emergency Management Wildfire Hazard Recommendations

DISCUSSION:
    In 2020, 58,950 wildfires burned 10.1 million acres, the second-
most acreage impacted in a year since 1960.\1\ According to the U.S. 
Department of Agriculture Forest Service, recent increased fire 
activity is due to at least four factors: increasingly hot and dry 
summers; stronger winds; insect and disease infestations; and human 
population growth in the Wildland Urban Interface.
---------------------------------------------------------------------------
    \1\ Congressional Research Service, In Focus, September 8, 2021.
---------------------------------------------------------------------------
    Wildfires cannot be viewed as merely a fire service function of 
first responders. As these fires continue to spread and have broader 
impacts, they become a whole-of-community hazard which must be treated 
as such to include robust prevention activities. To understand 
wildfires, one must first understand forest management, drought, and 
the interplay with existing programs at the Federal Emergency 
Management Agency (FEMA). NEMA would not recommend creating new, 
hazard-specific programs; existing programs within response, recovery, 
and mitigation could be tailored to meet the evolving wildfire threat.
    Leverage Federal Partnerships. The United States government owns 
around 640 million acres of land across the Nation. The Bureau of Land 
Management, Forest Service, Fish and Wildlife Service, and the National 
Park Service own 94 percent of that total \2\. Each wildfire that burns 
on federal land presents cascading effects that impact local, tribal, 
and state government, so policy coordination and land-use agreements 
are critical prior to heightened wildfire activity to ensure there are 
no delays in recovery due to ownership issues.
---------------------------------------------------------------------------
    \2\ Congressional Research Service, Federal Land Ownership: 
Overview and Data, February 21, 2020.
---------------------------------------------------------------------------
    Recommendations:
    1.  FEMA should engage earlier, facilitate the integration of non-
natural resource/non-firefighting federal agencies into wildfire risk 
reduction, response, and recovery planning and operations, and take a 
stronger role in interagency coordination for the federal government in 
multi-agency incidents across all phases of a wildfire, including 
recovery.
    2.  FEMA should have the authority to work with and help direct 
those federal agencies that own and manage land to reduce wildfire risk 
and recovery from wildfires that impact local, tribal, and state-owned 
lands. This should include coordinating and directing with agencies 
whose missions are to sustain environmental and energy resources on 
risk reduction and recovery planning and operations.

    Declaration Criteria and Incident Period. Unlike events that are 
predictive and leave specific damages, wildfires are unpredictable, 
overlapping, and often combine with one another. Current policies 
dictating the establishment of an incident period are not conducive to 
this type of hazard across multiple jurisdictions and authorities. 
Currently, if a federally declared Fire Management Assistance Grant 
(FMAG) burns in more than one county, FEMA requires all counties to 
meet declaration criteria independently. This creates inequity in 
recovery initiatives for counties that were damaged by the fire but may 
not reach the threshold for assistance. Furthermore, the declaration 
criteria used for Individual and Public Assistance disasters are not 
well-suited for informing fire declaration decisions as they do not 
consider the full range of impacts of large fires on the diverse local, 
and especially rural, communities and states.
    Recommendations:
    1.  Revise declaration criteria to qualify the initial attack of a 
wildfire for emergency protective measures once the National Geographic 
Area Coordination Center (GACC) or the National Interagency Fire Center 
(NIFC) reach Preparedness Level (PL) 5.
    2.  Revise declaration criteria to consider statewide impacts 
including ongoing firefighting incident instead of only localized 
impacts.

    Prepositioning Deployments. When preparing to fight wildfires, one 
of the most valuable capabilities is that of prepositioning 
firefighting assets. Currently, pre-deployment through a FMAG is 
limited to out-of-state resources.
    Recommendation:
    1.  Allow the state to utilize FMAG assistance for the 
prepositioning of in-state resources for wildfire response, including 
the pre-staging of firefighting resources to prevent fires from 
reaching the severity where an FMAG is needed.

    Emergency Work and FMAG Eligibility. Large fires expose burn scars 
to erosion from wind and soil saturation that most often lead to 
landslides and mudslides. The federal firefighting services recognize 
this hazard and take emergency protective measures to protect property 
within their jurisdiction under the Burned Area Emergency Response 
(BAER) and the Emergency Stabilization and Rehabilitation (ESR) 
programs. Similar emergency stabilization measures taken by state and 
local governments are eligible Category B measures under FEMA Public 
Assistance (PA) declarations. In managing an FMAG, however, emergency 
protective measures outside the FMAG incident period are ineligible, 
putting additional strain on state and local resources. Furthermore, 
the provision of funding for FMAGs is authorized by linking the 
authorities of the Stafford Act Section 403 Essential Assistance within 
Section 420 Fire Management Assistance. Section 403 is also the section 
that authorizes the provisions of funding in the FEMA PA program 
despite being authorized under the same section of the Stafford Act and 
with identical definitions of entities eligible to receive assistance.
    Recommendation:
    1.  FMAG program guidance should mirror the same eligibilities and 
timeframes for emergency work as those found elsewhere in the PA 
program.
    2.  FEMA should revise the FMAG policy, program, and regulations to 
include the same categories of eligible applications under the PA 
programs.
    3.  FMAG project on-line project tools should include a portfolio 
of best practices and lessons learned.

    Public Assistance Program and Policy Guide (PAPPG) Modifications. 
Current language of the PAPPG disproportionately favors other hazard 
events (such as floods, tornadoes, and hurricanes) with little regard 
to the unique qualities of wildfires. For example, when considering 
wildfire damage to trees, the current guidance specifically covers tree 
damage typically realized from wind and hurricane force wind but does 
not provide guidance on wildfire effects such as tree burns \3\.
---------------------------------------------------------------------------
    \3\ PAPPG, V4 2020, p. 102
---------------------------------------------------------------------------
    Recommendation:
    1.  FEMA should update the PAPPG to include wildfire-specific 
challenges such as debris removal emergency protective measures and the 
toxicity that is left behind when a wildfire moves through a community 
including the contamination of drinking water resources.

    Leverage the DRRA. Wildfires dramatically alter the terrain and 
ground conditions of the affected area. Communities impacted by 
wildfire may be at an even greater risk of flooding and mudslides. 
Thus, the Disaster Recovery Reform Act (DRRA) made clear that post-
wildfire mitigation efforts to avoid future damage, hardship, loss, or 
suffering in any area affected by a wildfire (like activities that 
avoid flooding and landslides) are eligible for funding.
    Recommendation:
    1.  FEMA should utilize the flexibility afforded in the DRRA to the 
maximum amount possible and apply the same criteria used by other 
federal agencies for approving soil stabilization and reseeding 
projects on non-federal land when post-fire mitigation funds are used.

    Hazard Mitigation Grant Programs (HMGP) Evaluation. Through HMGP, 
FEMA could leverage the programs that fall under grants to be more 
inclusive of the wildfire hazard. There is a very short timeframe 
between fire season and flood season, especially as the fire season is 
quickly becoming a year-round hazard. The Building Resilient 
Infrastructure and Communities (BRIC) grant program is one example that 
can elevate such fire mitigation projects. Another example FEMA could 
use to elevate their mitigation tactics is in evaluation of community 
programs.
    Recommendation:
    1.  Expand the HMGP performance periods to assist in expediting 
mitigation projects.
    2.  Leverage programs such as BRIC and home hardening projects to 
enforce more sustainable mitigation programs for wildfires.
    3.  FEMA should accept pre-identified, pre-vetted `packages' for 
home hardening that can be easily and rapidly replicated to achieve 
meaningful and timely risk reduction.
    4.  Allow fire districts to have the same leeway as Private Non-
Profits (PNPs) to receive HMGP funding.

    Benefit Cost Analysis (BCA) criteria adjustments. The current BCA 
for hazard mitigation assessments is linear and disproportionately 
weighs the financial impact of loss, such as the dollar value of a 
property or asset. The BCA to a lesser extent considers socioeconomic 
vulnerabilities and other non-financial factors that contribute to 
risk. In addition, BCAs are among the largest technical barriers to 
entry for many economically disadvantaged rural communities that seek 
to conduct basic wildfire mitigation measures. Data collecting has 
advanced to the point where there is enough national data on defensible 
space project costs and benefits to determine basic thresholds and 
criteria.
    Recommendations:
    1.  FEMA must evaluate current BCA criteria and adjust accordingly 
to consider the broader range of factors, ensuring prioritization of 
projects based upon new BCA criteria to address highest priority needs 
and optimize greatest return on investment.
    2.  Establish a BCA pre-calculated benefits criterion for common 
defensible space mitigation projects.
    3.  Ecological and societal health, carbon sequestration, improved 
water quality, and lessening disaster impact on traditionally 
underserved communities should be factors that contribute to the BCA.

    Wildland Urban Interface (WUI) Considerations. WUI is the space 
where development of communities meets wildland vegetation. As an 
establishment may be considered for pre-calculated benefits criteria, 
defensible space activity proposals in pre-determined WUI areas that 
meet the National Environmental Policy Act (NEPA) Categorical 
Exclusions N11 and adhere to basic Firewise-like standards should 
automatically be deemed cost-effective if its project is below an 
established threshold amount.
    The current HMA programmatic guidance prohibits actions related to 
improving or increasing water supply in high-risk wildfire areas, based 
on the premise that these actions constitute preparedness or even 
response support rather than mitigation. Water utilities and special-
purpose districts serving WUI neighborhoods need encouragement to 
upgrade and expand their storage and delivery systems to accommodate 
and support wildfire threats, including the purchase and installation 
of dry-hydrants and heli-hydrants in extreme-risk areas. Current HMA 
guidance already allows for other wildfire-related upgrades and 
expansions of WUI water systems (such as installing back up power 
generators on wellheads and retrofitting system components with 
ignition-resistant materials) and could easily be broadened within 
programmatic guidelines.
    Recommendations:
    1.  Establish pre-calculated benefits criterion for WUI areas for 
defensible space activity proposals that would align with the 
established BCA pre-calculated benefits criterion.
    2.  FEMA should reconsider the interpretation that improving water 
supply in high-risk wildfire areas is not a measure for mitigation, 
especially given the ever-worsening water availability situations in 
areas with extreme wildfire risk profiles.
    3.  Provide WUI projects a more streamlined approach utilizing 
collected data to help implement a full review and expansion on NEPA 
categorial exclusions where necessary to hinder administrative delays.
    4.  Expand the eligible wildfire project types to include water 
availability upgrades in WUI areas.

    Expedite Environmental and Historic Preservation (EHP) Reviews. EHP 
reviews have become lengthy specifically for Hazard Mitigation 
Assistance (HMA) wildfire mitigation proposals. This is often due to 
the lack of applicable NEPA Categorical Exclusions, which leads to 
needing full environmental assessments that can take at minimum a year 
or more to complete. This process may result in the delay of simple 
targeted pruning and thinning in rural-residential neighborhoods; or 
planting native samplings on a burned hillside. These administrative 
delays impact these communities that need simple mitigation tactics 
quickly.
    Recommendations:
    1.  Conduct a full review of the EHP processes to explore metrics 
for all mitigation projects to be processed more expeditiously.
    2.  Allow creative approaches and/or reductions to cost share, as 
well as flexibility in the grant application timeframe, particularly 
for disadvantaged communities.

    Conclusion. Wildfires are a threat that are year-round and 
persistent across most of the Western United States but is certainly no 
longer exclusive to this region as Florida, Georgia, Alabama, 
Tennessee, and other states east of the Mississippi River also 
experienced large wildfires in recent years. We are seeing increasingly 
large and severe wildfires; drought conditions, low reservoir levels, 
and parched landscapes; and stress on the electric grid due to extreme 
heat. These challenges are interconnected and cannot be looked at, or 
responded to, in isolation, yet FEMA's policies and response strategies 
have not evolved with the hazard. These shortcomings can be resolved by 
a recognition of the unique threat posed by wildfires, the need for 
adaptive policies, and a whole-of-government approach to finding 
solutions. The state directors of emergency management, through NEMA, 
stand ready to work with Congress and FEMA in identifying and 
implementing the necessary changes to better respond to this dynamic 
threat.

RECOMMENDATIONS:
    1.  FEMA should engage earlier, facilitate the integration of non-
natural resource/non-firefighting federal agencies into wildfire risk 
reduction, response, and recovery planning and operations, and take a 
stronger role in interagency coordination for the federal government in 
multi-agency incidents across all phases of a wildfire, including 
recovery.
    2.  FEMA should have the authority to work with and direct those 
federal agencies that own and manage land to reduce wildfire risk and 
recovery from wildfires that impact local, tribal, and state-owned 
lands. This should include coordinating and directing with agencies 
whose missions are to sustain environmental and energy resources on 
risk reduction and recovery planning and operations.
    3.  Revise declaration criteria to qualify the initial attack of a 
wildfire for emergency protective measures once the National Geographic 
Area Coordination Center (GACC) or the National Interagency Fire Center 
(NIFC) reach Preparedness Level (PL) 5.
    4.  Revise declaration criteria to consider statewide impacts 
including ongoing firefighting incident instead of only localized 
impacts.
    5.  Allow the state to utilize FMAG assistance for the 
prepositioning of in-state resources for wildfire response, including 
the pre-staging of firefighting resources to prevent fires from 
reaching the severity where an FMAG is needed.
    6.  FMAG program guidance should mirror the same eligibilities and 
timeframes for emergency work as those found elsewhere in the PA 
program.
    7.  FEMA should revise the FMAG policy, program, and regulations to 
include the same categories of eligible applications under the PA 
programs.
    8.  FMAG project on-line project tools should include a portfolio 
of best practices and lessons learned.
    9.  FEMA should update the PAPPG to include wildfire-specific 
challenges such as debris removal emergency protective measures and the 
toxicity that is left behind when a wildfire moves through a community 
including the contamination of drinking water resources.
    10.  FEMA should utilize the flexibility afforded in the DRRA to 
the maximum amount possible and apply the same criteria used by other 
federal agencies for approving soil stabilization and reseeding 
projects on non-federal land when post-fire mitigation funds are used.
    11.  Expand the HMGP performance periods to assist in expediting 
mitigation projects.
    12.  Leverage programs such as BRIC and home hardening projects to 
enforce more sustainable mitigation programs for wildfires.
    13.  FEMA should accept pre-identified, pre-vetted `packages' for 
home hardening that can be easily and rapidly replicated to achieve 
meaningful and timely risk reduction.
    14.  Allow fire districts to have the same leeway as Private Non-
Profits (PNPs) to receive HMGP funding.
    15.  FEMA must evaluate current BCA criteria and adjust accordingly 
to consider the broader range of factors, ensuring prioritization of 
projects based upon new BCA criteria to address highest priority needs 
and optimize greatest return on investment.
    16.  Establish a BCA pre-calculated benefits criterion for common 
defensible space mitigation projects.
    17.  Ecological and societal health, carbon sequestration, improved 
water quality, and lessening disaster impact on traditionally 
underserved communities should be factors that contribute to the BCA.
    18.  Establish pre-calculated benefits criterion for WUI areas for 
defensible space activity proposals that would align with the 
established BCA pre-calculated benefits criterion.
    19.  FEMA should reconsider the interpretation that improving water 
supply in high-risk wildfire areas is not a measure for mitigation, 
especially given the ever-worsening water availability situations in 
areas with extreme wildfire risk profiles.
    20.  Provide WUI projects a more streamlined approach utilizing 
collected data to help implement a full review and expansion on NEPA 
categorial exclusions where necessary to hinder administrative delays.
    21.  Expand the eligible wildfire project types to include water 
availability upgrades in WUI areas.
    22.  Conduct a full review of the EHP processes to explore metrics 
for all mitigation projects to be processed more expeditiously.
    23.  Allow creative approaches and/or reductions to cost share, as 
well as flexibility in the grant application timeframe, particularly 
for disadvantaged communities.

Moved: Andrew Phelps, Oregon
Second: Tina Titze, South Dakota
DISPOSITION: Passed
ABSTAIN: Alabama
Authenticated: Mike Willis, NEMA Secretary

    Ms. Titus. Thank you very much.
    We will now go to our last witness, Ms. Carolyn Harshman.
    Ms. Harshman. Yes, good afternoon, Committee Chairman 
DeFazio, Subcommittee Chairwoman Titus, Ranking Member Webster, 
and members of the subcommittee.
    My name is Carolyn Harshman, and I am a certified emergency 
manager and the very proud president of the International 
Association of Emergency Managers. IAEM is a professional 
organization comprised of dedicated emergency management 
practitioners who wake up every day thinking about and planning 
for natural and human-caused emergencies.
    As the profession of emergency management continues to 
shake off the ``Chicken Little'' stereotype of days gone by, we 
are benefiting greatly from the abundance of higher education 
programs and graduates. The usefulness of our profession was 
infinitely clear during the early stages of COVID-19, as we 
coordinated organizations and resources to adapt to the 
evolving needs of our communities.
    In the meantime, the frequency of disasters and ever-
present changes in climate are increasing the numbers of people 
and property impacted by hazards. I see us standing at the 
crossroads now, as the ravaging days of the pandemic begin to 
wind down, and we are seeing a range of emergency managers 
emerge from a broad spectrum of industries and disciplines. 
With that expansion, and emergency management protocols 
becoming more and more politicized, the profession needs strong 
guidance that will ensure we forge the best path forward.
    FEMA's Strategic Plan could not have come along at a better 
time. In order to be effective emergency managers, it is 
imperative that we treat all of the members of our communities 
as equals. All politics, income level, socioeconomic standing, 
and other polarizing characteristics need to be set aside in 
order to ensure equitable delivery of services in a community's 
greatest time of need.
    FEMA's Strategic Plan goal number 1 instills equity as a 
foundation of emergency management. I began my career in 
emergency management with the county of San Diego back in the 
1980s. I transferred into the position from the regional 
planning department, where I worked as a land-use planner 
processing subdivisions, facilitating community plans, and 
preparing the county's first water conservation ordinance. 
Writing the ordinance nudged me into realizing we don't live in 
a limitless environment, and that the negative impacts have the 
greatest effect on the most impoverished.
    As a budding emergency manager, I took my knowledge of 
demographics and quickly saw patterns of inequity when aligned 
with the region's hazards. Public service announcements 
regarding the storage of food and water were only dreams to the 
families struggling to live day to day. Equally ineffectual 
were the culturally insensitive deliveries of emergency food 
supplies. Emergency managers need tools in order to better 
understand the cultures and realities of the communities they 
serve.
    Strategic Plan goal number 2 inspires emergency managers to 
lead the whole community in matters relating to climate 
resilience. Like the water conservation I mentioned earlier, 
emergency managers must work hand in hand with planners, 
engineers, and fire professionals to create a better-built 
environment. As new and redeveloped construction projects are 
considered by a jurisdiction, it is very rare for an emergency 
manager to have a say in whether or not a project should be 
approved. Instead, the enforcers of codes and ordinances 
conduct reviews to determine whether or not a project conforms. 
Building better in the first place will eliminate the need for 
spotty retrofits and other incremental solutions. Most 
importantly, solidifying relationships will bring the enforcers 
into mitigation planning and open the door for emergency 
managers to participate in climate adaptation plans and other 
programs aimed at climate resilience.
    Strategic Plan goal number 3 promotes and sustains a ready 
FEMA and prepared Nation. These actions will greatly strengthen 
emergency management community capacity. At present, many of 
our emergency managers wear multiple hats: administrators, 
first responders, and other officials. The same is true for our 
nongovernmental organizations, where the emergency managers are 
also the risk manager, safety officer, and in charge of 
environmental compliance. Any and all of FEMA's efforts to 
standardize training, plans, and exercises will be well 
received, especially by those struggling with multiple hats.
    Equally important is the need to train and empower 
individuals and community groups to serve as force multipliers 
as we recognize the potential and willingness of our citizens 
to actively engage in an emergency's initial response.
    In closing, the U.S.A. Council of IAEM is 5,100 members 
strong, and already working very hard within its 25 committees 
and caucuses to share ideas and develop new solutions for our 
members and the communities they serve. We stand ready to 
contribute to the success of FEMA's new Strategic Plan.
    Thank you so much.
    [Ms. Harshman's prepared statement follows:]

                                 
    Prepared Statement of Carolyn J. Harshman, MPA, CEM, President, 
            International Association of Emergency Managers
    Good afternoon, Chairwoman Titus, Ranking Member Webster, and 
members of the Subcommittee. My name is Carolyn Harshman, and I am a 
Certified Emergency Manager and President of the International 
Association of Emergency Managers. IAEM is a professional organization 
comprised of dedicated emergency management practitioners who wake up 
every day thinking about and planning for both natural and human-made 
emergencies. I appreciate your giving me the opportunity to testify 
today before this Subcommittee to provide input on FEMA priorities for 
the coming year.
    As the profession of emergency management continues to shake off 
the ``Chicken Little'' stereotype of days gone by, we are benefitting 
greatly from the abundance of higher education degree programs and 
graduates. The usefulness of our profession was infinitely clear during 
the early stages of COVID-19 as we coordinated organizations and 
resources to adapt to the evolving needs of our communities. In the 
meantime, the frequency of disasters and ever-present changes in 
climate are increasing the numbers of people and properties impacted by 
hazards.
    I see us standing at a crossroads now as the ravaging days of the 
pandemic begin to wind down and we're seeing a range of emergency 
managers emerge from a spectrum of industries and disciplines. With 
that expansion and emergency management protocols becoming more 
politicized, the profession needs strong guidance that will ensure we 
forge the best path forward. FEMA's Strategic Plan could not have come 
along at a better time.
    In order to be effective emergency managers, it's imperative that 
we treat all of the members of our communities as equals. All politics, 
income levels, socioeconomic standing, or other polarizing 
characteristics need to be set aside to ensure equitable delivery of 
services in a community's greatest time of need. FEMA's Strategic Plan 
goal #1 instills equity as a foundation of emergency management.
    I began my career in emergency management with the County of San 
Diego back in the early 1980s. I transferred into the position from the 
Regional Planning Department where I worked as a land-use planner 
processing subdivisions, facilitating community plans, and preparing 
the county's first water conservation ordinance. Writing the ordinance 
nudged me into realizing we don't live in a limitless environment and 
that the negative impacts have the greatest effect on the most 
impoverished. As a budding emergency manager, I took my knowledge of 
demographics and quickly saw patterns of inequity when aligned with the 
region's hazards. Public service announcements regarding the storage of 
food and water were only dreams to the families struggling to live day-
to-day. Equally ineffectual were the culturally insensitive deliveries 
of emergency food supplies. Emergency managers need tools to better 
understand the cultures and realities of the communities they serve.
    Strategic Plan goal #2 inspires emergency managers to lead the 
whole of community in matters relating to climate resilience. Like the 
water conservation ordinance I mentioned earlier, emergency managers 
must work hand-in-hand with planners, engineers, and fire professionals 
to create a better-built environment. As new and redeveloped 
construction projects are considered by a jurisdiction, it is very rare 
for the emergency manager to have a say in whether or not a project 
should be approved. Instead, the enforcers of codes and ordinances 
conduct reviews to determine whether or not a project conforms. This 
means emergency managers need to get onboard with codes and ordinances 
to assist in altering the future. Building better in the first place 
will eliminate the need for spotty retrofits and other incremental 
solutions. Most importantly, solidifying relationships will bring the 
enforcers into mitigation planning and open the door for emergency 
managers to participate in climate adaptation plans and other programs 
aimed at climate resilience.
    Strategic Plan goal #3 promotes and sustains a ready FEMA and 
prepared nation. These actions will greatly strengthen emergency 
management community capacity. At present, many of our emergency 
managers wear multiple hats--administrators, first responders, and 
other officials. The same is true in non-governmental organizations 
where the emergency manager is also the risk manager, safety officer, 
and in charge of environmental compliance. Any and all of FEMA's 
efforts to standardize training, plans, and exercises will be well 
received especially by those struggling with multiple hats. Equally 
important is the need to train and empower individuals and community 
groups to serve as ``force multipliers'' as we recognize the potential 
and willingness of our citizens to actively engage in an emergency's 
initial response.
    In closing, the USA Council of the International Association of 
Emergency Managers is 5,100 members strong and already working hard 
within its 25 committees and caucuses to share ideas and develop new 
solutions for our members and the communities they serve. Collectively, 
we stand ready to contribute to the success of FEMA's new Strategic 
Plan.

    Ms. Titus. Well, thank you, and I think we see some themes 
emerging, based on the statements that we made earlier, and 
some of your observations, and those reports that have been 
issued by FEMA.
    Well, now I would go to Chairman DeFazio, who has to leave 
us, to ask questions first.
    Mr. DeFazio. Oh, thanks, Madam Chair. Yes, actually, I am 
going to have to depart momentarily for the chairs meeting. But 
I was informed by Chief of Staff Kathy Dedrick that we think we 
will have an opportunity next month to bring that legislation I 
mentioned earlier to the floor. So, that will be good.
    But beyond that, I want to just say this is great 
testimony, and you have given us an awful lot of things that we 
have to think about and deliver on. I think the most difficult 
is going to be some coordination that was mentioned by GAO, and 
I believe implied by the others between SBA, HUD, and FEMA. And 
that is, I guess, our job, to work with those other committees, 
and I don't think I have to ask a question on that.
    I do want to ask quickly, one of the issues that GAO noted 
was high staff turnover, which has led to a lack of expertise 
and delayed recovery. What do you think accounts for that, is 
it just burnout because it is so constant? Or what other issues 
could we address that would help mitigate that?
    I would ask Mr. Currie from GAO, if he could.
    Mr. Currie. Thank you, Mr. Chairman. Good question. I think 
there is a number of things that account for the retention 
issues.
    Obviously, just the workload over the last few years, 
really starting in 2017, with Hurricanes Irma and Maria and 
Harvey, just the back-to-back sequential nature, then followed 
by the wildfires you are aware of. There is no disaster season 
anymore; the whole year is disaster season. So, that has really 
complicated FEMA's ability to plug people in nationwide, where 
they are needed.
    But on top of that, I think there are some rules and some 
administrivia behind how they can deploy certain employees that 
complicates their ability to train and get them qualified and 
ready.
    For example, their reservists are part-time. They are only 
called up for a specific disaster, and they can only do 
training and development and get coaching when they are 
assigned to a disaster. And you can imagine, as an employee, 
that is probably not the best time to be trained and get 
development. Part of that has to do with just the restrictions 
on only being able to use disaster relief fund money for a 
specific disaster. So, I think that is one cause.
    But there are many other things like that. That is why I 
think it is really important that, well, we need to look at 
FEMA workforce through a lens of comprehensive reform, similar 
to what was done years ago with the National Guard and the 
military reserve, in terms of how we get them trained and ready 
for deployment.
    Mr. DeFazio. Yes, it is an excellent point regarding how we 
target certain National Guard units for the highest level of 
training to be ready to instantly deploy without, really, 
much--any additional preparation. So, that is an excellent 
point that I would hope FEMA should follow up on, and perhaps 
we can, too.
    The other major concern is--for any of the panelists--
resilience, BRIC, and how are we going to do mitigation more 
quickly. And if anybody wants to address that quickly, that 
would be great.
    Ms. Bornemann, I see you moving around. Did you want to 
address that?
    Ms. Bornemann. Yes, sir. Thank you, Chairman DeFazio.
    That is definitely a challenge that we experience, long 
periods of time between application, submission, and 
obligation. I won't horrify you with some of the timelines I 
have, but just take my word for it that they are very long. And 
you can--what we--we call it getting RFI'd to death, receiving 
sequential requests for information, for clarifying a certain 
application, just really overly complicated.
    We have to accelerate climate adaptation, and we have an 
opportunity with BRIC. And as a mitigation program, the award 
under the Hazard Mitigation Grant Program under the COVID-19 
disaster declaration was just an amazing opportunity. But we 
can't--we have to do our work at the State level to develop 
those projects.
    But we also have to have the trust that FEMA is resourced 
and ready to be able to turn around obligations on those 
projects quickly. That comes down to staffing and understanding 
and training around the regulations, and making sure that the 
regulations have evolved to reflect the hazards that we have in 
front of us today. That is not just flooding, although flooding 
is a large one, but it is about the hazards posed by wildfire, 
by drought, and so many others, and making sure that we have 
the tools available to us to be able to mitigate those hazards.
    Mr. DeFazio. OK, thank you. Thank you for that answer. 
Thanks to all the panelists.
    My time has expired, and I have got to go to this other 
meeting. So, thanks, everybody.
    Ms. Titus. Thank you. I will now recognize Mr. Webster, 
ranking member.
    [Pause.]
    Ms. Titus. And I can't hear you, Mr. Webster, I don't know 
if anybody else can or not.
    Mr. Webster of Florida. Maybe now.
    Ms. Titus. Yes.
    Mr. Webster of Florida. How is that?
    Ms. Titus. That is better.
    Mr. Webster of Florida. OK.
    Ms. Bornemann, you had mentioned in your opening remarks a 
bill, House bill 5641, SPEED Recovery, sponsored by--I am a 
cosponsor of that, but it was sponsored and introduced by 
Ranking Member Sam Graves--which raises the small project's 
threshold to $1 million. And can you talk a little more about 
how raising that threshold can reduce the complexity of 
projects, and maybe speed up recovery?
    Ms. Bornemann. Yes, sir, I can. Right now, we have 
different categorizations between small projects and large 
projects. And small projects can be managed at the State level, 
but the threshold for those projects is relatively low. And 
when you look at especially larger disasters, you can actually 
have multiple small projects within one jurisdiction, which 
just becomes administratively burdensome. And so, raising the 
small project threshold allows the States to utilize their 
management costs that are a part of that disaster declaration 
to be able to manage those more effectively.
    We know the terrain, we know the people, we know the 
contacts, and so, often we are able to move those projects 
along, to close out a little bit quicker. FEMA is a large 
bureaucracy. And so, they are trying to manage project by 
project. If we raise the large project threshold, that means 
FEMA can spend their time doing the more complicated projects 
that are larger, and they can potentially have some cost 
savings around the time that they spend doing all of the 
administrative pieces for small projects.
    I want to highlight, though, it is really important--we 
very much support raising the small project threshold, but it 
is also really important to have a measure that will allow us 
to carry over management costs from disaster to disaster. I 
will just raise the example of Vermont. I think we have, like, 
10 or 11 open disaster declarations in a very short period of 
time--we have disasters quite often here--but we are only able 
to use management costs for that specific disaster, and that 
doesn't allow us to build any capacity or sustain any capacity 
over a number of years, that--this already right-sized because 
it is only based on the size of the disaster.
    So, if we are going to be able to raise the small project 
threshold, we really want to try and also be able to carry over 
management costs that will give us the capacity to do the 
additional management of small projects.
    Mr. Webster of Florida. OK, thank you so much.
    Mr. Currie, the statistics GAO cites, relative to the 
percentage of FEMA--the workforce and the training they have 
had, are a little bit concerning. And I was wondering, is there 
something we can do to get the training information they need, 
so, it would be more a part of the solution than the problem?
    Can you talk more about your recommendations for FEMA 
workers?
    Mr. Currie. Yes, sir. Well, the challenge in the past has 
been that--and what we have found is that FEMA has struggled 
for years. It has a system of qualifying its employees. It has 
almost 20,000 people that are available to deploy to a 
disaster. And so, they have a system that qualifies each person 
at a certain level and a certain area, and then they use that 
to deploy around the country wherever they are needed.
    The challenge has been, that system has not always been 
that reliable for indicating a person's readiness or their 
experience level to go staff a disaster. So, they get in the 
field, and they are not ready, and they are not able to do the 
job as well. And we heard this directly from FEMA field 
leadership, too, the people that manage the disaster.
    What we have recommended internally is they take a number 
of steps to try to clean that up, and get better information so 
they can make better staffing decisions realtime.
    But I think it is important to say that I think there needs 
to be a more holistic look at the entire workforce structure 
and what authorities and legislation might be needed to 
overhaul that. The truth is the mission today and the pace 
has--it has totally changed. The current workforce was designed 
for 20 years ago, and it is just a different world today, and 
the workforce is not going to be able to meet the mission that 
is expected of it unless we look at it as a whole.
    Mr. Webster of Florida. Thank you so much. I appreciate it.
    I yield back.
    Ms. Titus. Thank you, Mr. Webster. I am glad you brought up 
the SPEED Recovery Act, and we have mentioned it several times. 
That was a bill that I was pleased to work on with Mr. Graves 
and you, Mr. Webster, and Chairman DeFazio. It shows that 
bipartisan efforts can work, and we have done a good job of 
that on the committee.
    I was also glad to hear Mr. DeFazio bring up how we should 
perhaps look at FEMA and training and deployment like we look 
at the National Guard. I have been hearing--I heard you, Mr. 
Currie, say that is a good idea. I have been introducing this 
bill, and talking to former heads of FEMA and everybody I can 
about treating these reservists like we do treat the National 
Guard, and providing them with some employment security. It 
seems like that would just help a lot to recruit and retain 
people, if they don't have to go off and work on a disaster for 
4 months, and then come back and can't get their job.
    I wonder, Mr. Currie, if you could address that, if you 
support that notion, if you think it would help, and if we 
should move on with legislation to that effect.
    Mr. Currie. Yes, ma'am. I think that securing their 
employment would need to absolutely be a piece of any sort of 
workforce reform. So, absolutely, I think you would have to 
look at that, particularly in this day and age, with--I mean, 
nationwide we face a challenge. Everyone is having trouble 
getting workers and people to work for them, and FEMA is--they 
are part of that, too. So, I think that needs to absolutely be 
part of any sort of reform effort.
    Ms. Titus. Well, good. I am glad to hear you say that, 
because I am going to come with that legislation again, and I 
welcome all the members of the committee to sign on to it. 
Maybe we can get at least that one little piece done.
    Another thing that I would ask all of you is, when we talk 
about FEMA and these programs, we act like we are operating in 
a vacuum, but we really aren't. There are a lot of politics 
that surround this, and a lot of that is related to accepting 
climate change, and how to address climate change, and whether 
climate change even exists or not.
    I would ask the two representatives from associations if 
you have similar problems like that among your members, and if 
you do, how do you try to address it or get beyond it?
    Ms. Harshman. This is Carolyn. For several years, because 
of the politicized aspects of climate change, we didn't have a 
caucus or working committee that was tasked with that. The 
effects of climate change were built into things like flood 
control and other caucus areas that we did spend a lot of time 
on. And just recently, over the last couple of years, we do 
have a dedicated group that is looking specifically at climate 
change. We also have a new mitigation caucus that includes 
climate resilience and adaptation.
    And so, I think that, as the gates are sort of being lifted 
on some of the political sensitivities, the association is 
definitely standing up, and there are lots of our members eager 
to be working towards a solution, and really delighted that 
they have been able to be, you know, let free to be able to 
maybe write ordinances, help jurisdictions prepare climate 
adaptation plans, and things like that.
    One of the things I would like to mention--it kind of ties 
over a couple of the other subjects that we have been touching 
on--and part of what I alluded to in my presentation is that, 
as a recovering land-use planner, I can tell you that, after 
working in that field, planners are not trained on hazards. 
There is one little piece of the general plan that talks--in 
the safety element, that talks about if you have earthquake 
faults, and you are prone to tornadoes, and things like that. 
But planners don't really perceive that they have 
responsibility for doing anything about that. And as a result, 
it just gets passed off to the emergency manager, who now has 
to clean up the mess.
    And so, I think, until we really address that sort of 
elephant in the room, we will continue to have two professions 
that should be more closely aligned and, instead, they hardly 
know each other exists.
    Ms. Titus. Thank you. That is a really good point.
    Ms. Bornemann?
    Ms. Bornemann. In the past couple of years, NEMA has 
reorganized ourselves, as well. We have several policy 
committees that just take a real focused look at different 
areas of the field. And last year, our previous president 
created the Resilience Committee, recognizing that there needed 
to be a focused effort on hazard mitigation, but also climate 
adaptation.
    When we look at the emergency management of the future--
hopefully I will be still doing this in 30 years--in 30 years, 
I expect that the disasters and hazards that we are presented 
with today will likely be different.
    When we talk with emergency managers throughout the 
country, it is in front of their face. Climate change is in 
front of their face, especially anybody that has been doing 
this for a period of time. They see the change right in front 
of them. And so, honestly, we don't see politics play into some 
of the planning and work that we do, because it is right there, 
and there is really just no denying it. But we are very focused 
on how we can adapt to climate change.
    Ms. Titus. Well, I am glad to hear that. These discussions 
shouldn't be ideological, they should just be based on science 
and facts. It sounds like that is what your two associations 
are doing.
    I may come back to ask about how the three levels of 
Government, as well as the different agencies, horizontally can 
coordinate better. But at this point I will go to, let's see, 
Mr. Guest.
    Mr. Guest. Thank you, Madam Chairman. And first I want to 
thank all of our witnesses for being here today. I want to take 
the few moments that I have to talk a little bit about the FEMA 
mitigation buyout program, and specifically how these programs 
impact rural America.
    Mississippi and other rural States often struggle to get 
local governments and our citizens to participate in the FEMA 
mitigation buyout program, so, we know that these programs are 
extremely successful. These programs result in the avoidance of 
future damages. I think studies have shown that, for every 
dollar that is spent on land acquisition, we avoid roughly $5 
in future damages, particularly those damages that would be 
caused by things such as flooding.
    But when looking at these programs, we know that the FEMA 
buyout programs are weighted more heavily toward urban 
communities, and they are--and that is the reason, is because 
often we see in these urban communities that--we see the 
mitigation is often streamlined through larger resources at the 
local level. I think there were some statistics I saw that 
showed roughly 75 percent of mitigation buyouts have occurred 
in urban communities, and only 25 percent in rural communities. 
And the average completion of these projects can often be 
extremely lengthy in nature. I think it is approximately 5 
years for the completion of these mitigation buyout programs.
    And so, under the current FEMA buyout system, it seems that 
we are unintentionally underserving some of our rural and low-
income areas. The current structure, which reimburses local 
governments, benefits the high-revenue areas, because they can 
afford to take on the debt, and they can afford to hold that 
debt until the lengthy process of reimbursement occurs.
    We have also seen recently private companies that 
specialize in mitigation practices that are frequently being 
utilized by both State, local, and the private sector to 
quickly and efficiently complete mitigation strategies, and 
often do so at a lower cost.
    So, my question--and I will start with you, Mr. Currie, and 
then ask others if they would like to weigh in--I would like 
you to provide your thoughts on public-private partnerships, 
how we can best utilize the P3s to conduct mitigation buyouts, 
to do so in a more efficient way, and to see that we are best 
spending FEMA dollars.
    And specifically, if you can talk about how those relate to 
rural America, where the reimbursement structure and cost 
sharing of these programs are at times counterproductive to 
participation in the programs themselves.
    Mr. Currie. Thank you, Congressman. Great question. I think 
you have set that up really well.
    The first thing I would say is that buyout programs, like 
all mitigation programs, are incredibly complicated, and there 
is a really complex process. Unlike building infrastructure, 
and making it more resilient, there is a whole sort of local 
political process you have to go through with the buyout, all 
sorts of studies, cost-benefit evaluations, things like that. 
It makes it very, very difficult to do, first of all, even for 
large urban communities.
    But you think rural communities, it is all about an issue 
of capacity and funding, which you have set up. These are 
already difficult. So, which communities are going to be less 
likely to be able to navigate that process, and have the 
resources to do it? It is going to be rural communities, poorer 
communities, vulnerable communities, things like that.
    So, I could not agree more, that these programs are 
incredibly technically complicated, and even more so for rural 
and small communities.
    Mr. Guest. Would any of our other witnesses care to kind of 
weigh in on these programs, particularly the relationship that 
they have to some of our rural communities, and the fact that 
it makes it much more difficult for rural communities to 
participate in programs, which are very, very beneficial?
    I think the benefit of these programs is clearly proven. No 
one is trying to say that these programs don't, in the long 
run, save dollars, because clearly they do. But are there any 
ideas that members of this panel have as to how we can make 
these programs more accessible, and include more rural 
communities in these types of programs that FEMA has to offer?
    Ms. Bornemann. Yes, sir. As you probably know, the State of 
Vermont is a very rural State, and we really appreciate when we 
are able to exercise flexibility within the hazard mitigation 
programs. We need to have a maximum flexibility to be able to 
apply these programs in a way that fits the jurisdictions 
within our State.
    In Vermont, for example, at the State level, we utilize 
contract support, and make it available to local jurisdictions 
that don't have the resources to contract for those resources 
themselves. I don't have enough money to put hazard mitigation 
planners in every single jurisdiction. I would love to. But we 
do utilize some contract support in leveraging those public-
private partnerships to make that available on behalf of and to 
local jurisdictions.
    I would say the level of FEMA scrutiny and in 
micromanagement on some of these hazard mitigation projects is 
just crushing sometimes, especially when you are a community of 
2,000 people--that is where I live, I live in a community of 
2,000 people. They just don't have the capacity to be able to 
manage a project like that, yet they are getting repetitive 
damage every other year or every year.
    Making measured changes to the Hazard Mitigation Grant 
Program to treat it more like a block grant, and give States a 
little bit more flexibility to be able to apply the same hazard 
mitigation guidance and the same intent of the law, but at the 
State level, and being able to apply it utilizing that support 
at the State level, would be really beneficial.
    Mr. Guest. Thank you.
    Ms. Harshman. I would just----
    Ms. Bornemann. Thank you.
    Mr. Guest. Yes, ma'am.
    Ms. Titus. The gentleman's time is expired.
    Ms. Harshman. Oh.
    Ms. Titus. Thank you. We have got Ms. Holmes Norton.
    Ms. Norton. Thank you, Madam Chair. Can you hear me?
    [No response.]
    Ms. Norton. Can you hear me?
    Ms. Titus. Yes.
    Ms. Norton. OK. I appreciate this important hearing on 
FEMA's priorities, and I particularly appreciate our witnesses 
and their testimony. It has been very useful.
    My first question is for Mr. Currie. I noted a New York 
Times article in June 2021 that reported that White disaster 
victims and communities receive more aid from FEMA than people 
and communities of color, even when the amount of damage to 
their homes and property is the same. I was befuddled by that.
    Mr. Currie, how does GAO's December 2021 recommendation to 
FEMA on improving the process for identifying potential 
barriers to access racial inequality--no, I am phrasing that 
wrong.
    How does GAO's December 2021 recommendation to FEMA on 
improving their process for identifying potential barriers to 
access take racial inequality into account?
    Mr. Currie. Thank you, Congresswoman, for the question.
    So, what we looked at in that report is we went out to 
answer that question and see to what extent FEMA--not just 
FEMA, but SBA and HUD, too--look at the outcomes of their 
programs to see who they are affecting and how they are 
affecting different groups.
    What we found is that none of the agencies really collect 
the kind of data on the outcome to really identify what the 
barriers are for certain communities. And that is a problem 
because, if you don't collect the data, then you can't measure 
it, and certainly, if you can't measure it, you can't fix it.
    But we have also identified a number of barriers in FEMA's 
process for Individual Assistance that apply to everybody, but 
particularly probably land harder on communities of color and 
vulnerable populations. For example, the Individual Assistance 
program, the one you register for when you are a survivor of a 
disaster, is incredibly complicated and confusing to survivors.
    I will just give you one example. The letters that FEMA 
provides when somebody registers whether they are going to get 
assistance often will say ``denied'' or ``not eligible,'' even 
if the person may be eligible, they just need to provide 
additional documentation, or additional information, or wait 
for insurance to pay out, and things like that.
    So, all these things--there are a lot of other examples I 
have in the process, and all these little things are 
disincentives. When you get a communication like that from the 
Federal Government, it doesn't incentivize people to continue 
on. So, the burden is on the survivor to keep pulling from 
FEMA, give more information, give more information. And 
ultimately, some of them just stop trying to get the 
assistance.
    So, I think we have made a number of--we think it needs to 
be much more simple for survivors, and integrated across 
agencies, and the burden shouldn't be on the survivor to prove 
for months and months that they are eligible for the 
assistance.
    Ms. Norton. So, have you made it more simple?
    Mr. Currie. We are working on it, and we have made--in that 
1 report on Individual Assistance, we have made 15 
recommendations to FEMA on different parts of their process.
    Now, what they have said is they are working on all those 
things, and they are reengineering the program completely. So, 
they are tackling it, step by step. But it is complicated. And 
as you know, Congresswoman, they don't move quickly.
    I think they get it. They understand the problem, and you 
see it in their Strategic Plan. You see the new Administrator 
is committed to equity. But like anything else, you are not 
going to fix a problem that was created over many years 
overnight. But I think they are on the right track. But 
continued oversight of them to make sure they do it, and not 
just talk about it, it is key.
    Ms. Norton. It certainly is.
    Ms. Bornemann, in your testimony you stated that--and here 
I am quoting you--``Layering additional grant requirements to 
address equity concerns can become an equity issue by applying 
a one-size-fits-all approach to all States.'' Could you please 
explain to me in what way adding equity requirements to a grant 
application might create racial inequality issues?
    Ms. Bornemann. Yes, ma'am. So, the point being made there 
is that the more complex a system or a grant is to access makes 
it inherently an equity issue, because the folks with the 
greater resources have the ability and resources to be able to 
access those grant programs and to meet the grant requirements. 
And the folks that don't have the resources, maybe from a rural 
community, maybe from historically underprivileged communities, 
they don't necessarily have the resources to be able to meet 
those grant requirements.
    We have talked a lot about this within NEMA, in addressing 
where equity--and equity, I know, is a term that gets thrown 
around quite a bit. But where grant programs are more complex 
and have additional requirements can actually be a barrier to 
entry. And therefore, if we can identify them, then we can 
address them. And that is really what the point was there.
    Ms. Norton. Well, how would you propose to streamline 
Federal and State emergency collaboration?
    Ms. Titus. I think--if you can answer that briefly, but the 
time has expired.
    Ms. Norton. Well, if the time has----
    Ms. Bornemann. I could keep you here all afternoon.
    Ms. Titus. OK, well, we better not, then. We better go on 
to Mr. Gimenez, and we can come back to that later.
    Ms. Bornemann. Thank you, ma'am.
    Ms. Titus. Thank you.
    Mr. Gimenez. Thank you, Madam Chair. I just find this 
conversation fascinating, being that I was the emergency 
manager for the city of Miami during Hurricane Andrew.
    And one of the comments was that, 20 years ago, that maybe 
they did things very well. I don't think they did things really 
well 20 years ago, back during Hurricane Andrew. And it took us 
in the city of Miami, and then later in Miami-Dade County, it 
takes over a decade to close out an account, which is crazy.
    And so, I guess my question--my questions are--yes--I am 
going to make comments.
    OK, number one, the forms need to be a lot easier. The 
problem, I think, is that the forms are made out by the 
people--we started out with all these acronyms, right? The 
forms are made out by the people inside the Agency, not really 
for the people that are the customer.
    So, I am wondering, do you have focus groups every time you 
put out a form, which ask, ``Do you understand what this form 
says?'' Something as simple as that? Anybody from FEMA?
    [No response.]
    Mr. Gimenez. Anybody?
    When a form is produced, do you actually go out to the 
customer and find out if the form is actually understood by the 
customer?
    Ms. Bornemann. Sir, I am not from FEMA, but I just want 
to--I do want to note that there are often times where NEMA, 
the National Emergency Management Association, will have 
opportunity to provide comment and to provide feedback on the 
accessibility of policies and different program changes.
    But that is a really excellent suggestion and definitely 
something I would like to take back to our organization to take 
a look at, as well.
    Mr. Gimenez. And by the way, don't use your people either, 
because your people understand FEMA a lot better than most 
people do. And so----
    Ms. Bornemann [interposing]. Right.
    Mr. Gimenez [continuing]. You need to go into the public 
and say, ``I have this form, we want it to do this. Do you 
understand it, that it wants to do this, or you think it is 
something else?'' Because a lot of these forms are really 
intimidating, especially if they come from the Federal 
Government.
    The second thing is we need to make this a heck of a lot 
easier. And maybe my idea would be to empower the States more, 
and empower the counties more, to be more accountable to the 
process, and to actually be more like a block grant that is 
given. You get an estimation of what the damages are, and then 
you give a block grant to these States of what they actually 
need, and then they have to justify it at the end, not so much 
this process that--and all these hoops that we have to go 
through.
    By the way, at the end, it is going to cost us more, 
because it takes us so many years to actually put out a 
process, and to get something built or rebuilt, that all these 
prices just keep escalating. And so, the process that FEMA has 
today is just astronomical.
    Does anybody know how much FEMA spends on administrative 
overhead?
    [No response.]
    Mr. Gimenez. I will bet you it is a lot. OK. And maybe that 
money would be better spent in other ways, and push this thing 
down to the States and to the localities.
    As an end user, I can tell you that FEMA was one of the 
most burdensome, bureaucratic agencies that I have ever dealt 
with. And that is not a good testament either to the 
localities, or to the people, or to the people who are trying 
to--these people have already gone through enough, and now we 
are making them go through another disaster, which is called 
``go through trying to get the money out of FEMA.'' You thought 
the hurricane was bad? This is going to be worse. And that is 
what I found during my time as mayor and emergency manager down 
in South Dade.
    And so, like, I had a bunch of comments. I really don't 
have too many questions. So, with that, I yield back. Thank 
you.
    Ms. Titus. Thank you, Mr. Gimenez. We will now go to Mrs. 
Napolitano.
    Mrs. Napolitano. Thank you, Madam Chair. I have a couple of 
comments to make. I am listening to this very intently, and I 
have several concerns.
    One is, we now have 365 days a year fire alarms in 
California. And I understand that about 40 percent of FEMA 
employment declined deployment to California, which leads me to 
believe that you have a problem with personnel. It is low 
morale, the burnout. So, what are you doing about getting new 
candidates for employment, and where are you looking for them?
    And is the training sufficient, and what about the 
training? The training is different, as it is in the East, for 
hurricanes. California has fire, floods, earthquakes, and the 
heat because of climate change.
    So, what are you doing to promote better employees with 
training, more employment for people who want to work for FEMA, 
and where are you doing such a thing, Mr. Currie?
    Mr. Currie. Yes, ma'am, thank you. So, at GAO we have 
looked at a number of things related to FEMA's workforce and 
wildfires. So, let me kind of take that one by one.
    So, on the training issue, I think they have faced 
challenges trying to get their folks qualified and trained at 
the level they need to be effective in their deployment. So, we 
have made a number of recommendations behind the scenes to try 
to address that issue. Earlier we talked about there needing to 
be more comprehensive reform around making sure we can train 
people before a disaster so they are ready to go after a 
disaster.
    I do want to say something about the wildfires, though, 
because I think you make a really good point. Prior to 2017, 
wildfires were common, but what was happening is FEMA disaster 
declarations for a wildfire were not as common. So, after 2017, 
there has been a ton of them, where the FEMA programs now are 
being used to respond and recover to wildfires in the Western 
United States and other parts of the country, too.
    The problem is that everything in a wildfire is different. 
The response and the recovery programs, they don't work the 
same for a wildfire as they do for a flood or a hurricane. And 
this is something we reported on a couple of years ago, and 
recommended that FEMA really look at all its programs to figure 
out what it needs to do to tailor these programs to better fit 
wildfires. For example, housing after a disaster. After a 
wildfire, the house is gone, and it is going to be gone for a 
long time. So, how and where you house folks is totally 
different than how you might house people after a flood, when 
the structure may be intact, and they are able to use a mobile 
unit, or something else like that.
    So, I think a lot of work needs to be done tailoring these 
programs more specifically to wildfires, as well.
    Mrs. Napolitano. Well, I have a great concern of the mental 
health of the employees, because if they are overburdened or 
burnt out, they certainly need some help. What do you do with 
the employees who need mental health services?
    Mr. Currie. So, what FEMA has told us that they are doing 
is they are trying to stagger these deployments for people, so 
they have a break.
    So, what was happening in 2017, for example, there were 
some people that deployed to Hurricane Harvey, then deployed 
immediately to Hurricane Irma, then immediately to Hurricane 
Maria, then immediately to the California wildfires. And so, 
what they have tried to do, since their disaster season--there 
is no season anymore, it is all year--is to try to factor in 
these breaks to give people some downtime, but also continue--
--
    Mrs. Napolitano [interposing]. Good.
    Mr. Currie [continuing]. Hiring more people and getting 
more people trained, so they don't have to keep redeploying the 
same people is a part of that, as well.
    Mrs. Napolitano. Well, I wonder if you would let us know, 
or have FEMA let us know, if you are conducting any 
recruitment, so we can notify our colleges and universities of 
the employment opportunities.
    Certainly, I am concerned about the low morale. And you are 
right, being without a break certainly could have an impact on 
them.
    Does FEMA talk to the other agencies on a regular basis, or 
this is something that is just catch-as-catch-can?
    Mr. Currie. This is an area that we have also identified as 
a challenge.
    FEMA, as we have talked about, has its own very complicated 
programs. But for a State or a locality, they are often 
absorbing a number of other very complicated Federal programs 
from HUD, from SBA, from Treasury, other agencies.
    There is some informal coordination, but, unfortunately, 
the programs are not synchronized and harmonized in a way that 
makes them easier to use. In fact, oftentimes what we hear from 
States and localities is that it just exponentially increases 
the complexity when more agencies are involved.
    Mrs. Napolitano. Well, they need to keep each other in 
touch with their own rules and regulations, so they can talk in 
tandem.
    Thank you, Madam Chair. My time is up.
    Ms. Titus. Yes, I know that Mr. Graves is concerned about 
that, when it comes to HUD coordination. And we will hear from 
him here in a minute, I know.
    And when you go to recruit at college campuses, we want to 
be sure that you are going to our historic Black colleges and 
minority-serving institutions, so we can help to build a 
diversity in that workforce.
    Next, we have Mr. LaMalfa.
    Mr. LaMalfa. Thank you, Madam Chair, for the hearing today. 
FEMA is always a key issue, especially in our Western States, 
as well.
    A lot of chatter about climate change, climate change, 
every committee, every conversation, yet we suffer out here 
with forests that are not managed. We had a million-acre Dixie 
fire just last year, and several other fires in the six-digit 
range, and as well, the Camp fire in Paradise was a big one. I 
will be talking about that in a moment here. Yet we can hardly 
get the Forest Service and others to get out of their tracks to 
actually manage the lands in a way that will give us some way 
to battle fire and contain fire much more easily. So, it is 
talk on one side, but not much action. But Forest Service has 
time this week to go down and shoot cattle from helicopters in 
New Mexico. They managed to find time to do that. Pretty 
freaking amazing.
    Anyway, to our folks in FEMA, when we look back at the Camp 
fire in Paradise, there was an issue post-fire, where there 
were a lot of damaged trees, dead trees, and blackened trees 
that were left behind because, I think, FEMA really had a lot 
of practice with those protocols on what you do with still-
standing trees and treating them as debris. So, you had many, 
many acres in an area that were still considered dangerous and 
left behind.
    So, we were able to update those policies, and get the 
debris cleaning to apply to more of those trees, which was 
helpful, so, I appreciate that effort. But it did take a lot of 
effort with local groups and local inputs about these kinds of 
realities after a wildfire, et cetera. So, what it really 
underlined is that we need FEMA to have more flexibility to 
adapt to situations, and not have a slowdown in bureaucracy and 
checking forms--and it has been alluded to several times in 
this conversation.
    So, let me toss that out to Ms. Bornemann and Ms. Harshman, 
about some of the things that FEMA could be doing, and how our 
committee might be able to help to be more flexible in disaster 
response and not just having to deal with forms and checking 
boxes, but immediate needs. Because what we are talking about 
is, in this situation with housing, post the Camp fire in 
Paradise and other ones, is that getting the FEMA trailers that 
were sometimes--well, indeed, needed in this case, and in other 
fires. It took a lot--it was a lot of difficulty with that.
    So, please allude to what we can do to increase the 
flexibility, and still have accountability on that.
    Ms. Harshman. This is Carolyn. Just a couple of quick notes 
on that.
    Some of the challenges that the local jurisdictions have--
and the majority of our members are from local government 
jurisdictions, a variety of different Government entities--one 
of the challenges that they have is, when they are going to be 
reimbursed by FEMA or some other Federal entity, that there is 
a fairly comprehensive purchasing process that they have to go 
through, and they have to get bids, and then they can't just go 
through their regular hiring practices. And so----
    Mr. LaMalfa [interrupting]. Yes, that has been very 
difficult to get----
    Ms. Harshman [continuing]. Lots of times----
    Mr. LaMalfa [interrupting]. To get the land set aside to do 
the bond, and then the land has to meet a certain 
specification. Then it becomes terrifically expensive, where 
maybe flexibility on getting--well, it is the temporary deal, 
usually 1 year, 1\1/2\ years, 2 years. That is what we need.
    Ms. Harshman. True, and that is part of the challenge, is 
that some of the creative solutions the local jurisdiction 
might come up with are the relationships that they have with 
maybe someone providing temporary housing, or a school that is 
not being used for the next 2 or 3 years while it is going 
through redevelopment.
    Mr. LaMalfa. Are you bound by statutes? Are you bound by 
statute from being able to do it that flexibly? Do you have to 
check boxes, so to speak, on that? What slows that ability down 
to be a little more adept on that?
    Ms. Harshman. Well, and I am sure Erica can speak to this, 
as well, it is the Federal regulations that are going to be 
reimbursed by the Federal Government, that there are purchasing 
requirements that are much more arduous than what the local 
jurisdiction usually does, which is typically a list of three. 
They have vendor lists that they rely on for everything. They 
don't have to go to outside bidders, in terms of outside of the 
State, outside of the county.
    So, the regulations are very different, because we are 
watching--the Federal Government is watching----
    Mr. LaMalfa [interrupting]. Is this something you see as a 
complaint across the board that makes it more difficult for 
FEMA personnel--makes their jobs more stressful?
    Because we get the calls, people are frustrated, or even 
angry. They are still living on someone's couch or in hotel 
space. Is this something that we could be helping to legislate 
with you to take the burden off you, as well as get a better 
result for people?
    Ms. Harshman. Well, I am here to represent the Association 
of Emergency Managers, and not FEMA. We certainly have many 
FEMA members.
    Mr. LaMalfa. OK.
    Ms. Harshman. So----
    Mr. LaMalfa. Mr. Currie, can you jump in on that real 
quick?
    I am sorry, time is so short.
    Ms. Harshman. No worries.
    Mr. LaMalfa. Thank you. Mr. Currie, can you jump in on 
that?
    Mr. Currie. Yes, sir. I think--and the GAO, we evaluate 
FEMA. This issue of housing and wildfire-specific programs, it 
has been a challenge.
    First of all, FEMA's programs were typically used in the 
past for floods and hurricanes and things like that. So, some 
options just don't make sense. And so, part of this is just 
Agency applications of the existing programs. A lot of these 
things are new.
    So, for example, the Paradise fire, housing was a huge 
challenge because, first of all, you couldn't live near some of 
those locations because they were toxic.
    Mr. LaMalfa. Right.
    Mr. Currie. And then second of all, when you tried to 
relocate people, you couldn't find housing, because it is so 
expensive. And there was no housing in the area. So, they came 
up with campground options, as I am sure you are aware of, as a 
secondary option.
    So, part of this is that these programs were not really 
designed for these types of, like, urban-wild interfaces that 
are just destroyed. And they need to be, given how many fires 
we are facing. And so, that is what we have recommended, is 
these programs that were designed for floods and hurricanes, 
they need to be tailored for the wildfire situation, because 
these are not a surprise.
    I mean, it is not a surprise that we are going to have 
housing shortages in northern California after a wildfire.
    Mr. LaMalfa. Yes.
    Mr. Currie. So, we need to preplan and prepare better.
    Ms. Titus. Thank you.
    Mr. LaMalfa. That would be helpful. Thank you, I appreciate 
that.
    And although we had some fits and starts, FEMA really did 
listen to us, and responded about as well as possible in the 
situation.
    So, thank you, Madam Chair. I will yield back.
    Ms. Titus. All right, Mr. Garamendi.
    Mr. Garamendi. Thank you, Madam Chair, and for the 
witnesses. It is very, very important to all of us. Mr. LaMalfa 
and I share much of the problems that he just talked about in 
our current districts. Going forward, it seems to me that a lot 
of questions that have been raised have to do with the 
bureaucracy, the rules, the regulations that FEMA has.
    About--let's see, that would be 2013--this committee 
addressed some of those by establishing the section 428 
alternative procedures program, presumably for the purpose of 
trying to provide flexibility at the local level. Some of that 
had to do with upfront funding by FEMA for the recovery 
programs and for the mitigation programs, so that the small 
counties, cities, and others who are unable to fund it 
themselves would have the money to do so. It really hasn't 
worked at all.
    And I would like to get at it, because it might be a 
solution to much of what we talked about here: giving the local 
governments the authority and the responsibility of putting the 
program together and the funding to do it. So, let's go at 
this, Mr. Currie. If you would, opine on this briefly, if you 
have studied it. If you have not, we tried to put this in 
legislation that you would study it. We may have to go back at 
that.
    And then I would like to go to Ms. Bornemann, and your view 
on the section 428 programs.
    Mr. Currie. Yes, sir, I will answer that.
    So, we have looked at section 428 several times, both in 
the context of the post-Hurricane Sandy recovery in the 
Northeast, but also more recently in Puerto Rico and the Virgin 
Islands. And I think it has been a mixed story.
    What you said is absolutely right. I think the goal of that 
was to create a process where we could upfront, maybe in the 
first year, come up with a complicated cost estimate, and then 
allocate the funding all at once, and be done with the back-
and-forth for a decade that we usually have. We have had--that 
has not been the case.
    For example, in Puerto Rico, frankly, sir, it has actually 
been more complicated, I think. We have spent 4 to 5 years 
trying to get to a cost estimate upfront, and all the work and 
engineering and technical work that has gone into that, and 
both sides, I think, have been really kind of hesitant to kind 
of come up with a final number. So, just getting to that 
obligation upfront has been incredibly difficult, let alone the 
stage where we are just actually going to start work on these 
projects and go back and forth to verify the cost.
    So, frankly, I think we almost added a way more complicated 
part upfront. That is not what was intended in the law, but I 
actually think this is something that gets more towards just 
FEMA execution of the law. I think the law was pretty clear in 
what it was trying to do. I just don't think it has been 
executed that way.
    Mr. Garamendi. Thank you.
    Ms. Bornemann?
    Ms. Bornemann. I am going to speak from a little bit of 
experience here with section 428, because Vermont implemented 
the first section 428 project after [inaudible] right here, in 
the office complex that I am sitting in. It was a project that 
was in recovery from Tropical Storm Irene, which devastated 
Vermont in 2011.
    And it was successful here. But, we have to say that the 
issue with the section 428 procedure is that FEMA is generally 
very involved, and it speaks to what Mr. Currie just said. It 
was supposed to be a simple process to streamline Public 
Assistance. But if FEMA is going to be as involved as they are 
in developing the cost estimate and project management as with 
the regular Public Assistance process, most locals don't really 
want to take that gamble, and they don't want to close the door 
on recovery cost overruns that are pretty common when you are 
looking at recovery from a disaster, as well as trying to build 
back in a way that makes that structure, or whatever you are 
trying to put back, more resilient.
    It is a huge gamble, especially for rural communities. And 
so, there may be ways that we can work together to make that 
legislation be, in implementation, what it was meant to be. But 
it is very risky for us.
    Mr. Garamendi. It just seems to me that the fundamental 
problem is that the local government has to come up with a 
plan--engineering, construction--and then held to that number 
with no flexibility provided by FEMA. Is that correct?
    Ms. Bornemann. That is--yes, that is the crux of the issue.
    And again, especially when you are looking at large 
projects that are multimillion-dollar projects, it is very easy 
for the cost estimate in 2013 to look very different in 2018, 
when you are trying to close on that project.
    Mr. Garamendi. Understood. And that is what change orders 
are all about in every construction project that I have ever 
seen over the last many, many decades. Change orders.
    So, if there was a procedure that provided the flexibility 
on the cost or the change orders that might occur, could the 
section 428 program resolve many of the issues that have been 
discussed here today?
    Ms. Bornemann. Oh, that is a really good question----
    Ms. Titus. Well, we will have to ask you to keep it brief, 
because the time is expired.
    Ms. Bornemann. I was going to----
    Mr. Garamendi. Chair, I yield back. We will get at this. It 
is not going to go away. Thank you.
    Ms. Titus. That is right. OK, thank you. Now, Mr. Graves.
    Mr. Graves of Louisiana. Thank you, Madam Chair, and I 
appreciate the witnesses, and I really appreciate you all 
having this hearing today.
    Director Currie, I am curious if you could talk about some 
of your all's recommendations related to 
DisasterAssistance.gov. I know you talked about this a little 
bit.
    We had numerous instances where we had folks that had 
applied for DisasterAssistance.gov. They were just denied, 
weren't given any reason. The reality is it wasn't a final 
denial. It was a lack of information, or incomplete 
applications. There was not a process for these people to go 
back and amend applications. Has GAO made recommendations in 
terms of the user friendliness or just applicability of 
DisasterAssistance.gov?
    Mr. Currie. Yes, sir, we have. We dove into the Individual 
Assistance process and the ``.gov'' interface to it, as you 
mentioned, and we found a number of challenges with usability 
in that process. You mentioned one of them.
    One of them was just how they communicate with the survivor 
through a letter that often says denied or ineligible. But that 
doesn't mean a denial. It could just mean, for example, that 
the person's insurance needs to pay first, or they need to 
provide more documents. But the effect of that is sort of 
chilling, because if you get a letter from the Federal 
Government that says denied, you are going to think denied, you 
are not going to continue the process. And that is what we 
found, is that people that could have been eligible maybe 
didn't even get the amount they would be eligible for, or 
didn't continue the process. And that is just one of many 
things.
    Mr. Graves of Louisiana. Well, thank you. I appreciate it.
    And then something else I wanted to bring up, and I know 
the Chair mentioned this earlier, and I know that Congressman 
Carter is also interested in it.
    And that is right, I just called you out. You saw that, 
Troy?
    And so--but we have got this issue. Congressman Carter and 
I both have been dealing with constituents that have been just 
tremendously impacted from Hurricane Ida last year. And you 
have got the immediate assistance that may be available from 
SBA or FEMA. And then you have got HUD that comes in, later on.
    I mean, look, we worked really hard to get funds included 
in the C.R. back in September for the 2021 disasters. HUD 
hadn't even allocated the funds yet. And as you know, 
allocation simply means you are going to get this much to the 
State, which then the States have to go through, do action 
plans, apply. So, here we are, appropriated money in September. 
It is now February, and they haven't even allocated the funds. 
After they make the allocation, we are probably looking at--and 
I am probably being generous--about 9 months before the State 
can actually start cutting checks. I mean, so these are, 
meanwhile, disaster victims.
    So, can you just speak to, kind of, the handoff with the 
different agencies, whether it be SBA who starts, or FEMA, 
depending on the loan or grant situation, and then HUD?
    And if you all have made recommendations about just 
stopping the Federal Government from continuing to victimize 
these people that are victims?
    Mr. Currie. Yes, sir, definitely. And there is no better 
State than Louisiana to understand all the Federal programs 
over the last few years----
    Mr. Graves of Louisiana [interrupting]. You could have 
stopped at Louisiana. You could have stopped at Louisiana.
    Mr. Currie. Yes. So, yes, we have pointed this out.
    So, there are multiple levels of problems. I mean, there 
are problems within FEMA in its own programs and the timeframes 
and the different regulations. But then there are problems 
across the Department.
    So, I think what is key to understand is these programs 
were never designed to work together. They were all created 
separately. There are separate regulations. They have separate 
timeframes. They have separate execution. They have separate 
documentation requirements not designed to work together. But 
they are used together in disasters routinely now. It used to 
be they weren't. Now they are. So, that is a problem that has 
to get addressed.
    But on the HUD issue, just one example, it has been bad in 
Louisiana, but I will give you an example of Puerto Rico. Those 
funds, they haven't even really started to be spent yet from 5 
years ago. It has taken that long to get a HUD rule and plan 
together and start executing the funding.
    So, what we hear from States and locals is: How are we 
supposed to plan recovery projects, let alone invest in 
mitigation projects, which are even more complicated, if we 
have no idea when we are going to get the money, or if we are 
going to be able to use it together?
    Mr. Graves of Louisiana. So, I am going to show you this. 
This is our Restore Louisiana website [displaying the website 
on his laptop]. We appropriated $1.7 billion in late 2016 and 
early 2017. Here we are, over 5 years later, and this is how 
much they have made available to homeowners: $666 million out 
of $1.7 billion, 5 years later.
    This performance is inexplicable, and Madam Chair, I want 
to thank you. I know you had worked with us on the bill we did 
with Congresswoman Stacey Plaskett, trying to help put this all 
under FEMA's roof, so that way, you have one agency that is out 
there doing more of the immediate and the long term, and giving 
States a larger role. I know Mr. Rouzer has a bill, as well, 
and I just want to re-urge that we continue looking at this. I 
think it is a really important issue that we have seamless 
handoff, and have our Government stop revictimizing some of 
these survivors or flood victims.
    And I apologize to the other two witnesses. We are going to 
be submitting questions for the record for you, but thank you 
for your participation.
    I yield back.
    [Pause.]
    Mr. Carter of Louisiana. You are muted. Dina, if you are 
speaking, you are muted.
    Ms. Titus. Oh, I am sorry, excuse me. That sounded so 
brilliant, too. I am sorry you all missed that.
    [Laughter.]
    Ms. Titus. I was just saying to Mr. Graves we hear that the 
problems are coordination vertically and horizontally across 
agencies, and among the different levels of Government.
    They often find, though, that when people get in these 
silos, jurisdiction becomes so critical. Nobody wants to give 
up power, personnel, jurisdiction. You have to kind of break 
those down. So, I am committed to working with you, Mr. Graves, 
to continue to do this sort of work, because I think that it is 
important, and there is a lot of it ahead of us.
    We will now go to Mr. Carter.
    Mr. Carter of Louisiana. Thank you very much, Madam Chair 
and Ranking Member. I stand in concert with my colleague from 
Louisiana, my dear friend, Mr. Graves.
    We, oftentimes, in the immediate aftermath of Katrina, 
found ourselves tag-teaming, fighting for Louisiana residents, 
asking what we thought and what we agreed--and even later, 
everyone agrees--were just very basic, simple questions of why 
so much redtape? Why insult to injury? Why add more redtape and 
more difficulty to what is already a very difficult time for 
people?
    As Garret mentioned, many times it was applications that 
were not completely filled out, or maybe a box that was not 
checked properly, and there was no appeal process to come back 
and fix it without us painstakingly getting involved and really 
getting people back to the table. Well, the fact of the matter 
is, people who have already been hurt by a storm should not 
have added insult by having a bureaucracy that swallows them 
up.
    So, I have got a question: What steps can be done to help 
FEMA be more user-friendly, to take out some of the redtape, 
and minimize some of the changing policies?
    We know our State and local governments are developing 
public policy projects, and we need to make sure that they 
dovetail, and they work together, and not cause a further 
logjam. So, can you share with me some thoughts on how FEMA 
could do a better job, and how we might help them do a better 
job?
    Mr. Currie. Yes, sir, it is Chris Currie.
    Ms. Bornemann. I----
    Mr. Currie. Oh----
    Ms. Bornemann. Sorry.
    Mr. Currie. Sorry.
    Ms. Bornemann. No, go ahead.
    Mr. Currie. All right, I will start quick, so you have 
time.
    So, I think that, first of all, the mindset and the culture 
has to change, that these programs need to be focused on 
service delivery and efficiency. And there was an Executive 
order that the President issued in December, focusing on 
Federal Government programs and improving service delivery. 
FEMA's disaster programs is one of them.
    But you can't just talk about it. You have got to get in 
there, and you have got to pick apart these programs, and look 
at every part of the process, look at the barriers that are 
within them. We have pointed out many of them in our reports. 
And then you need to completely reengineer them and retrain the 
staff so there is a cultural shift in how they are run.
    It is no different from how a business would want to shift 
its focus to customer service. That is what needs to be done, 
program by program. And then, across these departments, they 
need to look at how they can work together to streamline and 
harmonize these programs. It can be done with effective 
leadership. It has just got to be a priority.
    Mr. Carter of Louisiana. Mr. Currie, let me interrupt you 
for a second. Are there plans to do that?
    Because, very respectfully, we have storms that come every 
year. They come stronger, they come faster, they come bigger, 
they come harder. And this is not new to us. And these kind of 
battles that we have had with FEMA or other Federal agencies, 
it seems like we are having the same conversations every time. 
Some of the things are so basic and so elementary that it 
really should not require rocket science to move them.
    Mr. Currie. Yes.
    Mr. Carter of Louisiana. So, I hear you, that there 
shouldn't be more talk, there should be more action. Can you 
share with me some ideas that we can help facilitate that will 
become action items in advance of the next series of natural 
disasters?
    Mr. Currie. Well, I think part of this is asking FEMA 
through oversight, through hearings like this, but also through 
requests for information, or meetings, or whatever, press them 
on specifics about what they are doing within these programs to 
break down some of these barriers.
    It is great to implement some of these things in the 
Strategic Plan, and talk at a high level about priorities. But 
that takes a while to trickle its way down into the programs 
and into the people that run them. This requires a cultural 
change.
    We have a number of recommendations on areas that they are 
working on. I think they do get it. They understand they need 
to--there is a lot of pressure on them to----
    Mr. Carter of Louisiana. I am not just dumping on them. I 
am not just dumping, because I think they have heard us, and 
they have tried, and they have made adjustments as we brought 
it to their attention.
    But some of the adjustments are so elementary that, one, 
they should not have needed our intervention. But two, some of 
the changes appear to be partial, and then they slip right back 
to the old way they were doing it. It needs to be memorialized 
in a policy change, and not just, oh, the congressman called, 
and therefore, we fixed it.
    And real quickly, before I go, because my time is going to 
be up, I asked this question before, and I am going to double 
down on it. As cyberattacks increase, is the GAO studying the 
potential for cyberattacks during a natural disaster?
    And if not, is there something that is going to be done 
that you are going to look into that? Because that is one step 
away from something that we can find ourselves in a very 
devastating position in the middle of a natural disaster, and 
some terrorist group decides to take advantage of an otherwise 
strained system. Have you given some thought to that? Are there 
some things going on that you can share with us?
    Mr. Currie. Thank you, sir. I am not aware of any study or 
any evaluation we have done of cyberattacks specifically during 
a natural disaster. We have done work on cybersecurity across 
all the agencies that would be involved in a disaster. But I 
will take that back and talk to our cybersecurity experts, and 
I can get back to you on our plans for that, or whether we need 
to work together to do that in the future.
    Mr. Carter of Louisiana. I would definitely do that. I 
suspect that it is something that we should be concerned about, 
and suspect that there may be some work going on. And if we can 
collaborate among agencies to make sure that we have the best 
practices in place to be prepared, I would greatly appreciate 
it.
    I yield back, Madam Chair. Thank you very much.
    Ms. Titus. Thank you----
    Mr. Graves of Louisiana. Madam Chair, if you don't--just 
one point on what Mr. Carter just brought up.
    We had thousands of constituents that essentially got 
hacked. Somebody else applied for their disaster assistance, 
and then our constituents that were real disaster victims were 
blocked out. He made a great point.
    Ms. Titus. Thank you. Thank you, Mr. Carter and Mr. Graves.
    We now go to Miss Gonzalez-Colon, who can certainly talk 
about this issue from her perspective and her district in 
Puerto Rico.
    Miss Gonzalez-Colon. Thank you, Madam Chair and Ranking 
Member, and I think this is a timely hearing and the witnesses 
are sharing with us their expertise. And I was hearing Mr. 
Garamendi and Mr. Graves, and I cannot agree more. I know that, 
beside the witnesses today, there are numerous stakeholders 
presenting written briefs for the record, whose input I will 
deeply appreciate.
    Unfortunately, Puerto Rico has become too familiar with 
FEMA over the past 5 years and the current COVID emergency, the 
2019 and 2020 earthquakes, and of course, our top of the list, 
Hurricane Maria in 2017. And our recovery is on track to be 
one, if not the largest, in FEMA's history.
    FEMA has allocated more than $41.6 billion, and obligated 
$38.8 billion, and outlaid $15.8 billion to the island. 
However, in 2020, 3 years after Maria, no permanent work has 
started yet. Major obligations for long-term infrastructure 
rebuilding only began being announced in late 2020, and today 
we are still in planning and having RFPs status.
    So, many of my constituents have expressed a lot of 
frustration with these delays, and the risk of having clawbacks 
on already-approved benefits. I think greater agility and 
accountability are imperative.
    There are recent bills, such as Mr. Graves' H.R. 539, the 
Preventing Disaster Revictimization Act, and my H.R. 2016, the 
Federal Disaster Assistance Coordination Act, that both passed 
the House already, and H.R. 2020, the Post-Disaster Assistance 
Online Accountability Act, need to be considered to address 
these issues.
    And I do have a lot of questions, but I know the time is 
difficult here. But my first question will be to Director 
Currie.
    In your written testimony--and happy to see you again--in 
your written testimony, you review the prior GAO findings on 
workforce issues and speed of disbursement in the report on the 
recovery efforts in Puerto Rico in May of last year. You made 
two recommendations.
    First, that FEMA should, in coordination with the 
Government of Puerto Rico and other Federal agencies, identify 
and assess risks to the remainder of the recovery, including 
internal and external factors such as the capacity to carry out 
projects, and for example, taking into consideration if we have 
the resources to start and finish projects within a time limit, 
or if more time is needed.
    And the second one, that FEMA should identify potential 
actions to manage risks to the remainder of Puerto Rico's 
recovery, and continuously monitor those risks.
    My questions will be: What response or followup has there 
been to those recommendations?
    Second, would your office make such a followup, should the 
committee require one, or should we require FEMA to report to 
us the response?
    Should the committee, as part of the [inaudible] establish 
a timetable for FEMA to report what they are doing about those 
recommendations?
    I think those should be direct questions, and I do have 
more.
    Mr. Currie. Sure, I--yes, I think that it would be a good 
idea to hold FEMA accountable to those recommendations.
    And let me just say that at GAO, we are very focused on the 
recovery in Puerto Rico. Almost 5 years later, September, we 
have done several reviews on it. We are starting up another 
one. I plan to go back to Puerto Rico next month. I have been 
there five times since Hurricane Maria. The Federal Government 
potentially is going to spend well over $50 billion there. So, 
it is a huge priority for GAO, but not just from the amount of 
money that is being spent.
    I am very concerned about the long-term recovery. 
Congressman Graves made a good point earlier, and he said that 
it is one thing to get the money obligated, but that doesn't 
actually mean that money is being spent, and shovels are 
working, and projects are going. And my concern about the 
situation in Puerto Rico, unlike other States that have the 
funding and the upfront money, is that there is not going to be 
the capacity, the funding, and the people to do all of this 
work. We are having labor shortages across the entire country, 
and I think we are going to have huge challenges actually 
executing a lot of this work.
    So, we stand behind those recommendations to FEMA. I think 
this needs to be a huge area of focus continuing in the future. 
And we are not going anywhere, ma'am. We are going to continue 
to focus on this, and do oversight on it.
    Miss Gonzalez-Colon. Thank you.
    I know my time has expired. But Madam Chair, I think we 
should look into that opportunity for the committee to ask for 
those responses for FEMA, including [inaudible] if we need to.
    And I do have other questions for the record, and those are 
for FEMA, but I will submit it in written form.
    Thank you, Madam Chair, and thank you, all the witnesses.
    Ms. Titus. Thank you. I want to thank the witnesses for 
their testimony. I think it has been a very interesting 
conversation.
    There seems to be a lot of consensus among those who 
testified, as well as the members of the committee who were 
asking questions. But we have got a lot of work to do, but I 
think we will be able to accomplish that, and want to look at 
FEMA as it meets those requirements or suggestions that have 
been made by GAO.
    We can go back to Mr. Currie's four points. I think that 
summarizes very well what we need to work on. Most of it comes 
down to bringing FEMA into the 21st century: changes we need to 
make in the workforce; doing away with the confusion and 
redtape; streamlining complex projects and working with all 
levels of Government and all agencies of Government; and 
finally, building in resistance and mitigation to any kind of 
changes that we should make. So, I look forward to doing that.
    I welcome any members of the committee to make suggestions, 
introduce legislation. You have my commitment that we will try 
to work with the chairman of the committee to push some of this 
through, because, as you heard from him early on, he is 
concerned about these things, as well.
    COVID affected all of us. It is a national disaster. So, 
you overlay that with wildfires, like Nevada's--the driest and 
the hottest State in the country, and getting worse--tornadoes, 
earthquakes, floods, it is all there, and it is coming faster 
and harder.
    So, that is my commitment to you, and I appreciate you all 
tuning in this morning for the hearing.
    Now, let me get my script here for the conclusion. While I 
am doing that I would like to say that Aaron has left us in 
good hands.
    I want to introduce our new staffer, who is Lauren Gros. 
She has a degree from Georgetown. She worked for Rick Larsen's 
office, and comes to the committee as a legislative assistant, 
and will be our main person on the committee. So, we welcome 
her.
    I am looking for it here. Let me see what we have left to 
do.
    All right, that concludes our hearing. I want to thank, as 
I have already done, all the witnesses for their testimony. It 
has been very helpful.
    I ask unanimous consent that the record of today's hearing 
remain open until such time as our witnesses have provided 
answers to any questions that you might have and might be 
submitted for the record in writing.
    I also ask unanimous consent that the record remain open 
for 15 days for any additional comments and information 
submitted by Members or witnesses to be included in the record 
of today's hearing.
    Without objection, so ordered.
    Has anybody got anything they want to say?
    All right. The committee is adjourned. Thank you very much.
    [Whereupon, at 3:47 p.m., the subcommittee was adjourned.]



                       Submissions for the Record

                              ----------                              

  Prepared Statement of Hon. Sam Graves, a Representative in Congress 
     from the State of Missouri, and Ranking Member, Committee on 
                   Transportation and Infrastructure
    Thank you, Chair Titus, and thank you to our witnesses for being 
here today.
    On a bipartisan basis, this committee has worked to improve FEMA 
and the federal government's emergency management system.
    The goal is to help communities prepare for, mitigate against, and 
respond and recover from disaster.
    It helps no one when communities must spend significant resources 
to figure out how to fill out FEMA paperwork and navigate the process.
    That is why I introduced bipartisan bills, including the Preventing 
Disaster Revictimization Act and the SPEED Recovery Act, to help 
individuals and communities cut through the red tape in FEMA 
assistance.
    I look forward to hearing from the GAO and stakeholders today on 
their priorities.
    Thank you, Chair Titus. I yield back.

                                 
Statement of the American Flood Coalition, Submitted for the Record by 
                            Hon. Dina Titus
    The American Flood Coalition (AFC) applauds Chairwoman Titus, 
Ranking Member Webster, Chairman DeFazio, and Ranking Member Graves for 
holding this subcommittee hearing to solicit stakeholder perspectives 
on top 2022 Federal Emergency Management Agency (FEMA) priorities. AFC 
is grateful for the opportunity to submit written testimony for the 
record.
    Comprised of more than 280 members across 21 states, AFC is a 
nonpartisan group of political, military, business, and local leaders 
that have come together to drive adaptation to the reality of higher 
seas, stronger storms, and more frequent flooding. AFC is a coalition 
of people on the front lines of flooding: cities and towns, state and 
local elected officials, military leaders, businesses, and civic 
groups. Together, we seek to advance national solutions that support 
flood-affected communities and protect our nation's residents, economy, 
and military installations.
    While much work remains to be done, AFC recognizes and appreciates 
FEMA's efforts over the past year to support flood-affected 
communities, particularly as the agency tackles challenges including 
the COVID-19 public health emergency, devastation caused by wildfires 
and extreme weather events, and additional urgent demands on the 
agency's staff and resources.
    While FEMA has many responsibilities and priorities, AFC's comments 
focus on the agency's essential work to build resilient communities and 
ensure equitable, timely, and thoughtful recovery in the wake of major 
flooding. We urge the agency to build on its progress to date by 
prioritizing the following areas in the year ahead.
    Continue and expand efforts to instill equity across all FEMA 
programs. AFC commends FEMA's work to evaluate its programs and 
policies to further the agency's goal of delivering equity for all, 
including through its April 2021 Request for Information (RFI) \1\.
---------------------------------------------------------------------------
    \1\ Federal Register, ``Request for Information on FEMA Programs, 
Regulations, and Policies,'' April 22, 2021.
---------------------------------------------------------------------------
    As the agency reviews responses to the RFI and other comments 
submitted by stakeholders, AFC emphasizes that participation in such 
agency processes remains a privilege. In the wake of a flood, many 
individuals often cannot advocate for themselves and their communities. 
Survivors have valuable feedback to contribute but likely lack the time 
and capacity to submit comments or attend meetings because they are 
rebuilding homes and businesses, while coping with the emotional and 
physical toll of the disaster. Similarly for community-based 
organizations, seeking to improve federal processes, undertaking a 
comprehensive review of proposed federal legislation, or submitting 
comments by a deadline can be virtually impossible while simultaneously 
supporting flood victims.
    With these realities in mind, FEMA must recognize underserved 
community members' time constraints and create spaces to meet community 
members where they are. Additional engagement strategies, such as 
providing childcare at meetings or seeking input from residents at an 
existing community event, can make a meaningful difference. AFC cannot 
overstate the importance of directly engaging flood-affected 
communities to better understand their unique challenges and needs.
    Beyond these important recognitions and the urgency of community 
engagement, AFC's RFI comment letter \2\ provides overarching themes 
and specific policy recommendations to help FEMA deliver on its goal of 
equity for all.
---------------------------------------------------------------------------
    \2\ Regulations.gov, ``Comment submitted by the American Flood 
Coalition,'' July 22, 2021
---------------------------------------------------------------------------
    Expand access and technical assistance for Hazard Mitigation 
Assistance (HMA) Programs. AFC urges FEMA to provide robust technical 
assistance for all grant programs, in addition to targeted application 
and project assistance to underserved communities. We also encourage 
Congress to review the statutory definition of ``small and 
impoverished'' communities and to consider adjusting federal cost-share 
ratios so that FEMA programs can better support more high-need areas.
    Smaller, rural, and underserved communities often lack the time and 
expertise to decipher FEMA's complex application processes. They also 
typically lack resources to hire external consultants to outsource this 
work. As a result, underserved communities are less able to develop 
competitive applications and can be effectively shut out of FEMA's HMA 
funding opportunities. A recent survey of AFC's membership affirmed 
that capacity challenges are among the greatest hurdles to securing 
federal funds to execute resilience projects.
    These realities were reflected in the applicant pool and ultimate 
grant recipients for FEMA's inaugural Building Resilient Infrastructure 
and Communities (BRIC) program. More than $3 billion in project 
applications were submitted for just $500 million in available funding, 
which demonstrates both significant demand for mitigation dollars and 
an extremely competitive application process. These dynamics remain 
true even with the administration's commitment to allocate $1 billion 
for BRIC funding in 2021,\3\ as well as an additional $200 million in 
annual funding for the next five years codified under the 
Infrastructure Investment and Jobs Act (P.L. 117-58).\4\ Of 991 total 
applicants for BRIC's 2020 grant cycle, only 98 were small and 
impoverished communities.\5\ Furthermore, five of the nation's 
wealthiest states received 70% of the $500 million in available 
funding, while small, impoverished communities were awarded just$36 
million in total.\6\
---------------------------------------------------------------------------
    \3\ The White House, ``FACT SHEET: Biden Administration Invests $1 
Billion To Protect Communities, Families, and Businesses Before 
Disaster Strikes.''
    \4\ Congress.gov, ``Infrastructure Investment and Jobs Act.''
    \5\ FEMA, ``FY2020 Building Resilient Infrastructure and 
Communities Application Submissions.''
    \6\ E&E News, ``Climate grants meant for poor places went to rich 
states.''
---------------------------------------------------------------------------
    Another major hurdle to applying to FEMA's HMA grant programs is 
that many entities cannot cover local cost-share requirements. Most HMA 
grant recipients must pay for 25% of a project's cost while the federal 
government covers the remaining 75%. Under current law, communities 
defined as ``small and impoverished'' benefit from an increased 90% 
federal cost-share, but that definition remains extremely narrow. AFC 
urges the subcommittee to explore expanding this definition so that 
more communities could qualify for an increased cost share. We also 
encourage Congress to provide a higher federal cost-share for the 
highest-need communities, as this would significantly increase FEMA's 
HMA programs impact among small, rural, and underserved communities.
    AFC believes that robust technical assistance is fundamental to 
addressing such barriers and ensuring BRIC's overall success. While we 
commend FEMA's increased efforts on this front, we note that in the 
2020 BRIC cycle, only eight communities were supported through the BRIC 
program's non-financial direct technical assistance.\7\ This is likely 
because most localities are unaware that such resources are available 
and often lack the capacity to seek out and manage assistance. 
Reframing technical assistance to be ``opt out'' rather than ``opt 
in''--so that FEMA and state governments proactively approach 
communities and offer direct assistance--would be a welcome shift.
---------------------------------------------------------------------------
    \7\ FEMA, ``Building Resilient Infrastructure and Communities FY 
2020 Subapplication Status.''
---------------------------------------------------------------------------
    Implement the Safeguarding Tomorrow through Ongoing Risk Mitigation 
(STORM) Act (P.L. 116-284).\8\ Finally, AFC urges FEMA to advance 
regulations for the STORM Act's Hazard Mitigation Revolving Loans 
Funds, which received $500 million in seed funding under the 
Infrastructure Investment and Jobs Act (P.L. 117-58).\9\ AFC commends 
Congress for creating this new program and for providing funding to 
help states establish revolving loan funds for resilience projects.
---------------------------------------------------------------------------
    \8\ Congress.gov; ``Safeguarding Tomorrow through Ongoing Risk 
Mitigation Act or the STORM Act.''
    \9\ Congress.gov, ``Infrastructure Investment and Jobs Act.''
---------------------------------------------------------------------------
    In particular, we appreciate that among other eligible uses, STORM 
Act revolving loans could support local government activities such as 
zoning, land-use planning studies, and establishing and enforcing 
building codes. AFC also supports the program's prioritization of 
projects that increase regional resilience, consider the regional 
impacts of hazards, and harden major economic sectors or critical 
national infrastructure. AFC encourages FEMA to proceed with rulemaking 
so that counties and local governments can begin accessing funding and 
more proactively manage their flood risk.
    Once again, AFC appreciates the subcommittee's attention and 
interest on these pressing issues, as well as FEMA's work to drive 
meaningful progress across our outlined priorities to date. AFC stands 
ready to work with both Congress and FEMA on shared efforts to build 
stronger, more resilient communities.

                                 
   Statement of June Isaacson Kailes, Disability Policy Consultant, 
              Submitted for the Record by Hon. Dina Titus
      Suggested Solutions for Changing the Training Environment--
               Content, Process, and Delivery Mechanisms
    My work focuses on building critical disability practice 
competencies and capabilities in health care and emergency management 
by using actionable details. These details operationalize the equity 
and specificity needed to include people with disabilities and others 
with access and functional needs. Much of her work converts the laws, 
the case laws, regulations, and guidance into tangible building blocks, 
tools, and operating procedures that close service gaps, prevent civil 
rights violations, and deliver inclusive, equally effective services.
    GAO has been making recommendations about FEMA workforce 
development since 2015. For example: ``The FEMA Administrator should 
create a staff development program for FEMA's disaster workforce that, 
at a minimum, addresses access to training, delivery of on-the-job 
training and mentoring, use of performance evaluations, and consistent 
developmental opportunities regardless of deployment status.'' FEMA 
Disaster Workforce: Actions Needed to Address Deployment and Staff 
Development Challenges GAO-20-360 May 04, 2020.
    However, FEMA personnel are just one part of the emergency 
preparedness workforce development audience. One of the significant 
issues is the lack of coordination and integration among the many 
federally supported preparedness training programs. (see links to these 
programs at https://www.fema.gov/emergency-managers/national-
preparedness/training)

          ``Funding for the Congressionally-authorized National 
        Domestic Preparedness Consortium (NDPC) is an annual 
        appropriation through the Homeland Security National Training 
        Program Cooperative Agreement . . . Congress has invested 
        millions of dollars into the development of the NDPC, ensuring 
        that all US emergency responders/receivers have access to high-
        quality training. This funding allows the NDPC to develop and 
        deliver training at no direct cost to state and local 
        agencies.''
          ``Traditionally, Continuing Training Grant (CTG) recipients 
        have not shown the ability to sustain training beyond the 
        initial funding period. As such, many of the CTG developed 
        courses, if deemed to have ongoing need and relevance, have 
        been assumed by existing NDPC members who have the facilities, 
        infrastructure, and ability to sustain them.'' https://ndpc.us/
        about/congress-and-the-ndpc/ (online 2-22-2022)

    While there may be a high-level coordinating body for training 
activities, each of the individual programs seems committed to ``stay 
in its lane'' and not meaningfully collaborating on the content or 
course development. Asking any entity to integrate with any other 
federally supported group seems to result in a range of responses from 
``that's not our role'' to ``we cannot change someone else's course 
material or delivery methods.''
    This is particularly problematic for new, emerging, and evolving 
content areas such as integrating people with access and functional 
needs. However, given the continuously evolving preparedness issues 
such as pandemic response, wildfire, and the yearlong disaster season, 
it seems clear that the training process needs to become better 
coordinated and more flexible, nimble, and responsive.
    It is well past time to update the national preparedness training 
environment--content, process, and delivery mechanisms--to address 21st 
century needs, platforms, and opportunities.
    If FEMA is going to be able to address workforce development 
priorities, FEMA's multiple training programs, activities, and funding 
support need to be placed in the context of overall federal investment 
in preparedness training. FEMA should not continue to reinforce or fund 
training ``silos.''
    While this issue is probably widespread across many areas of 
emergency management, to illustrate the point, I would like to address 
one specific area as an example. Some of the recommendation from the 
FEMA National Advisory Council (NAC) were included in the May 2017 
report to the FEMA administrator. https://www.fema.gov/sites/default/
files/2020-08/fema_nac-report_06-2017.pdf

          ``IV. Training for Incorporating People with Disabilities and 
        others Access and Functional Needs, including Children (3 
        recommendations)
          Issue 8: There is a lack of emergency management, response, 
        and recovery training incorporating people with access and 
        functional needs and children. This puts these populations at 
        risk. Note: the NAC has made previous recommendations regarding 
        this issue (see 2016-28 and 2017-09) and it remains unresolved.
          Recommendation 17-26: FEMA should create and support a Center 
        of Excellence (CoE) type training program for emergency 
        management personnel that enables experts to acquire, adopt, 
        disseminate and deliver content specializing in how to fully 
        integrate the needs of individuals with disabilities and others 
        with access and functional needs and children into all aspects 
        of emergency planning, response, recovery and mitigation.
          Recommendation 17-27: FEMA should more fully integrate 
        content related to persons with disabilities, access and 
        functional needs and children into all existing and future 
        emergency management trainings. To fulfill this objective, FEMA 
        should map and prioritize FEMA courses delivered to emergency 
        management personnel and first responders . . .''

    As noted in the May 2017 report, the FEMA National Advisory Council 
(NAC) made earlier recommendations regarding this issue, yet it 
remained unresolved.
    There has been little progress in almost five years since these NAC 
recommendations were made. Outdated and potentially damaging 
information remains in FEMA course and exercise content. This seriously 
undermines the significant progress that has been made in whole 
community inclusion in emergency preparedness. Integration of course 
and exercise content needs to consistently conform with contemporary 
planning, response, and recovery priorities to end counterproductive 
teaching of outdated, old model, old school, ``special needs'' content.
    Funding support is needed for a timelier way to incorporate access, 
and functional needs content consistently and routinely into all 
appropriate course materials. Attention to covering the issues in the 
appropriate depth, beyond just a separate and special course, is needed 
for appropriate workforce development. This may also be true for other 
emerging and evolving emergency preparedness issues.
    The process of how contractors are selected and utilized needs to 
be examined. A tremendous amount of time and resources is spent fixing, 
redoing, and repairing uninformed contractor work specifically related 
to access and functional needs. Contractors often lack expertise on the 
diversity of the populations included in access and functional needs, 
how to translate the nuanced words into applied practice, etc. FEMA 
should partner with led organizations (such as the Partnership for 
Inclusive Disaster Strategies https://disasterstrategies.org/) to 
establish rigorous criteria for identifying and evaluating course 
developers, trainers, and reviewers to ensure they are truly subject 
matter experts (including relevant specialized experience).
    Use training evaluation methods that measure the effectiveness of 
delivery, performance, impact, and outcomes rather than just rating the 
process: how many attended, how many answered so many post-test 
questions correctly, and the learners' reactions to and satisfaction 
with the training and presenters. A quality companion product focused 
on just-in-time training should also be developed for whatever training 
is created or revised. This is because the people we trained yesterday 
won't be there tomorrow. The gold standard should include metrics 
related to performance in the trenches.
    The Committee may also want to ask GAO to look at preparedness 
training issues in a broader context beyond just FEMA. To make 
recommendations about rewarding agencies for collaborative activities, 
streamlining course development and delivery, reducing redundancy and 
inconsistency, and identifying training gaps and new opportunities, 
which will move beyond the long-entrenched current approaches to 
workforce development.
    Moving forward, FEMA needs to be a part of the solution, not a part 
of the problem.

                                 
 Statement of the National Association of Home Builders, Submitted for 
                     the Record by Hon. Dina Titus
                            I. Introduction
    NAHB represents more than 140,000 members who are involved in land 
development, building single-family and multifamily housing, remodeling 
and other aspects of residential and light commercial construction. 
NAHB's members construct approximately 80 percent of all new housing 
built in the United States each year.
    NAHB's mission is to enhance the climate for housing and the 
building industry, including providing and expanding opportunities for 
all people to have access to safe, decent and affordable housing. Due 
to the wide range of activities they conduct on a regular basis to 
house the nation's residents, our members are often required to comply 
with various regulatory and incentive-based programs to address issues 
related to climate change and resilience.
    NAHB is leading the way to improve resiliency and the performance 
of new and existing homes. As a longtime leader in the drive to make 
homes more energy efficient, NAHB has also repeatedly demonstrated a 
commitment to sound federal disaster and floodplain management policies 
and cost-effective, market-driven solutions that maintain housing 
affordability while balancing the needs of growing communities with the 
need for reasonable protection of life and property.
                             II. Background
    The unusual number of significant natural disasters over the past 
several years has been sobering. At the same time, they have ignited a 
nationwide dialogue about risk, resiliency and mitigation. NAHB has 
been actively engaged in these discussions for many years and we have 
taken a leadership role in improving the resiliency and performance of 
new and existing homes. In fact, NAHB and its members have a long 
history of supporting, developing and participating in many state and 
local initiatives, as well as various federal activities aimed and 
reducing disaster losses and improving resiliency. We have repeatedly 
demonstrated our commitment to working with all levels of government to 
promote and implement sound disaster and floodplain management policies 
and improve the resiliency of the homes we build and the communities we 
serve. In doing so, we take pride in helping to develop cost-effective, 
market-driven solutions that maintain housing affordability while 
balancing the needs of growing communities with the need for reasonable 
protection of life and property.
    As stakeholders in both the public and private sectors wrestle with 
finding the right balance of regulations and programs to protect homes 
and their occupants from severe weather events and hazards, some argue 
that more should be done. But most additional efforts come at costs 
that not only curtail homeownership and significantly hinder housing 
affordability, but also can severely impact state and local economies. 
This is because these policies can greatly influence how existing 
structures and cities are reengineered, rebuilt and/or remodeled and 
impact how and where new homes and communities are built. Depending on 
how they are developed and implemented, they can also be inflexible and 
overly protective, fail to target areas of highest risk, reduce the 
availability of buildable land, tax limited resources, and have 
significant cost implications that can have a detrimental impact on 
housing affordability in many areas of the country.
    With this as a backdrop, NAHB has identified one specific priority 
and six general themes that should be woven into each of FEMA's actions 
as it ``Builds the FEMA our nation needs and deserves.''
      Complete Endangered Species Consultation for the National 
Flood Insurance Program
      Acknowledge that Structures Built to Modern Codes are 
Resilient
      Identify and Promote Opportunities to Mitigate/Modernize 
Existing Buildings
      Provide Incentives to Mitigate/Modernize Existing 
Buildings
      Recognize and Retain State/Local Land Use Authority
      Embrace and Improve Stakeholder Engagement
      Provide Updated Resources and Data
                    III. NAHB's Suggested Priorities
a. Complete Endangered Species Consultation for the National Flood 
        Insurance Program
    Over the last decade, FEMA has been locked in an ongoing legal 
battle regarding how specific NFIP programs, such as a letter of map 
revisions and minimum eligibility requirements for community 
participation demonstrate compliance with the Endangered Species Act 
(ESA). Most recently, in 2017, the National Marine Fisheries Service 
(NMFS) issued a biological opinion (BiOp) that concluded the 
implementation of the NFIP, as it exists today in the states of Oregon 
and Washington, violates the ESA's prohibition against any 
discretionary federal action that may result in ``jeopardizing the 
continued existence of'' an endangered or threatened species or the 
``destruction or adverse modification'' of designated critical habitat. 
NMFS's rationale as to why the NFIP violates the ESA is that the very 
existence of the program encourages future land development and 
construction activities in and around floodplains--areas that may serve 
as important critical habitat for certain federally-protected aquatic 
species. Because of these purported important ecological functions, it 
claims the federal government could prohibit or at least restrict 
future land development or construction activities from occurring 
within floodplains.
    Although FEMA is taking steps to address this issue by developing a 
national programmatic framework for ESA compliance, this task is long 
overdue. Equally problematic, FEMA's interim regulatory guidance to 
address ESA compliance, issued in 2016, creates a wholly new process 
that does not exist under the ESA or under the Service's consultation 
regulations and creates significant implementation problems across the 
board. In short, the Agency's regulatory guidance attempts to illegally 
pass off FEMA's responsibilities as a federal ``action agency'' and 
instead foist its obligations upon non-federal entities (i.e., local 
governments or private landowners) to perform the ESA's consultation 
functions. Instead of performing its duties under the ESA's 
consultation regulations, FEMA expects non-federal permittees to obtain 
documentation from the FWS that their proposed activities will have no 
impact upon federally protected species or their designated critical 
habitat and then provide FEMA with copies of FWS's ``no effect'' 
letters.
    Alternatively, FEMA's interim regulatory guidance directs non-
federal entities who request certain letters of floodplain map revision 
that could impact an endangered species or designated critical habitat, 
to first obtain an expensive and complicated ESA Sec. 10 Incidental 
Take Permit (ITP). This completely contravenes Congress's intent that 
ITPs only apply to private landowners whose proposed activities 
actually result in the ``take'' (i.e., death or injury) of an 
endangered species. Likewise, it confuses the ESA's existing 
authorization process, as ITPs are not intended to be used for private 
activities that have a ``federal nexus'' (e.g., activities that require 
federal approval or funding), such as a request to FEMA to revise 
floodplain maps, which federal courts have already determined trigger 
the ESA's consultation requirements. Clearly, FEMA's approach fails to 
recognize the Agency's own role and responsibilities under the ESA as a 
federal ``action agency'' whose activities are subject to the ESA 
Sec. 7 consultation process. Rather than developing creative ways to 
avoid its ESA responsibilities, FEMA needs to comply with the ESA's 
consultation regulations. If it is unwilling or unable to do so, it 
should work with Congress to seek targeted legislative reforms to NFIP 
or even the ESA to better define which portions of the NFIP are 
discretionary federal actions and thereby when ESA consultations are 
required. Whichever approach to demonstrating compliance with the ESA 
is chosen, NAHB urges FEMA to avoid outcomes that needlessly harm NFIP 
participating communities and developers' and builders' efforts to 
provide safe and affordable housing.
b. Acknowledge that Structures Built to Modern Codes are Resilient
    Building codes are designed to establish minimum requirements for 
public health and safety for commercial and residential structures 
(i.e., be disaster resistant). Despite this, FEMA continues to place 
undue effort on increasing their stringency. Not only is this 
unnecessary, as structures built to modern codes are shown to be more 
resilient, but also doing so oftentimes makes new homes unattainable 
for many home buyers. Instead of improving new construction, which is 
the focus of most building codes, FEMA should acknowledge that modern 
building codes are resilient and pivot its attention to improving the 
resilience of existing structures.
    Although they have existed in various forms for decades, building 
codes in the United States achieved a milestone in 2000 when the three 
regional code organizations were consolidated into the International 
Code Council (ICC) and their codes were combined to create the first 
set of ``I-Codes,'' which were published in 2000. While there are other 
building codes available, the I-Codes are the most widely used model 
building codes, with some form of the International Building Code (IBC) 
adopted in all 50 states and versions of the International Residential 
Code (IRC) adopted in 49 states. The I-Codes are modified through a 
formal public consensus process every three years. This has resulted in 
the publication of a new edition in 2003, 2006, 2009, 2012, 2015, 2018 
and 2021. Work has commenced on the 2024 version of the code and final 
votes will take place in the fall of 2022.
    When the I-Codes were created, a number of major improvements were 
immediately made to the traditional building code requirements within 
the residential building code to address issues observed after 
Hurricane Andrew in 1992 and the California earthquakes of 1989 and 
1994. Although additional improvements have been made since the I-
Codes' debut in 2000, the number of changes incorporated into the newer 
editions of the IRC that dramatically impact structural reliability and 
occupant life safety within residential structures have greatly 
diminished. In other words, the modern building codes (e.g., post-2000) 
have proven to be resilient and the need for triannual updates is not 
necessary for improved resilience.
    Despite this, many believe that homes built following the ``latest 
published edition'' of the building code equate to more resilient 
homes, but that is not necessarily the case when compared to those 
built to previous editions of the IRC. Homes built to modern building 
codes--defined as any edition of the IRC--have been shown to be 
resilient. Evidence from FEMA and others demonstrate the IRC, 
throughout its history, has been very effective in preventing the 
destruction of homes due to various storms and earthquakes and 
significantly reducing damage to wall and roof coverings. Further, 
because many of today's new homes are built with additional sustainable 
and high-performance building features, they are even more durable and 
resilient.
    The successful performance of the IRC is also an indication of the 
``maturing'' of building codes as they have gone through the iterative 
process of refinement since 2000. While tweaking the code to reflect 
technological advances will continue, it is clear that major changes 
aren't as necessary as they used to be. Similarly, because the codes 
are nearing a point of diminishing returns in terms of the cost/benefit 
ratio, additional updates may not be cost-effective. Homes can be built 
to withstand any disaster, but homes cannot yet consistently be built 
to withstand any disaster and be affordable. New homes built to modern 
codes are efficient. New homes built to modern codes are safe. New 
homes built to modern codes are resilient. FEMA must embrace this fact 
throughout its efforts and actions. Instead of taking every opportunity 
to increase the stringency of building codes (whether such updates are 
necessary or not), FEMA should trust the code development process and 
resultant codes and focus its energy on improving the resiliency of the 
existing housing stock.
c. Identify and Promote Opportunities to Mitigate/Modernize Existing 
        Buildings
    The American housing stock continues to age and due to the recent 
decrease in production, there is increasing pressure to keep existing 
homes in service longer--homes that may not perform as well or be as 
resilient as newer homes. One hundred and thirty million homes out of 
the nation's housing stock of 137 million were built before 2010, and 
therefore, most were not subject to the modern building codes that are 
now in effect. Equally problematic, the latest Census statistics show 
the number of homes built before 1970 that are taken out of commission 
is only about six out of every 1,000 being retired per year. These low 
rates of replacement mean that the built environment in the U.S. will 
change slowly and continue to be dominated by structures that are at 
least several decades old.
    Older homes are less resilient and energy efficient than new homes. 
They were not built to the stringent requirements contained in modern 
codes, use (and lose) more energy, and are more susceptible to damage 
from natural disasters. Many of FEMA's post-disaster investigations 
support this conclusion. For example, FEMA's Mitigation Assessment Team 
Report regarding Hurricane Sandy reads, ``Many of the low-rise and 
residential buildings in coastal areas [that had observable damage] 
were of older construction that pre-dates the NFIP.'' Similarly, the 
Insurance Institute for Business and Home Safety stated in its 
preliminary findings report for Hurricanes Harvey and Irma that, 
``[t]otal destruction from wind occurred to mobile homes, as well as 
older site built conventional homes,'' and ``[n]ewer homes generally 
performed better than older buildings.''
    Clearly, these statistics and studies demonstrate that improvements 
in construction practices and building codes have made significant 
strides in improving the efficiency and resiliency of new construction 
and that further gains will be difficult and costly. As FEMA takes 
steps to mitigate the effects of future natural disasters, it needs to 
create opportunities to facilitate upgrades and improvements to the 
older homes, structures and infrastructure that are less resilient to 
natural disasters.
              Support Voluntary Compliance
    Mitigation efforts that recognize and promote voluntary above code 
compliance for improved resilience in lieu of mandates have been proven 
to produce results, show value to consumers and are cost-effective. In 
other words, they are driven by the market. FEMA is strongly urged to 
develop and provide workable solutions to facilitate and promote the 
use of voluntary means to increase the resiliency of the existing 
housing stock.
    Because one size never fits most, it is important that builders, 
home buyers and homeowners have choices when it comes to finding 
strategies to increase the resiliency of their homes. One reason 
federal mandates are ineffective is because they fail to take into 
account the needs or desires of consumers and others, and typically 
lack the flexibility needed for realistic, widespread application. 
Flexibility allows builders to choose the specific efficiency 
component(s), program or green certification that best suits their 
needs and the desires of the home buyers based on their ability to 
afford and willingness to pay. In other words, having options versus 
requirements allows the market to function as intended.
    As a result, voluntary, above-code programs such as the ICC700 
National Green Building Standard, Leadership in Energy & Environmental 
Design (LEED) Resilient Design Pilot credits, RELi 2.0 pilot, FORTIFIED 
Home and the U.S. Resiliency Council (USRC) rating all have widespread 
participation. Numerous similar initiatives have also been successful 
and many homeowners voluntarily take other steps to improve their 
home's performance. The popularity of these programs has led to proven 
track records in improving home resiliency. For example, over 345,000 
units have been certified to the ICC 700 National Green Building 
Standard to date and 36,000 homes have the FORTIFIED designation. In 
addition to increasing resiliency, these programs provide value to 
consumers through insurance discounts, peace of mind and other 
benefits. The many choices also allow stakeholders to pick and choose 
the specific elements that fit their needs and budgets, which make 
voluntary alternatives inherently cost-effective.
              Provide Cost-Effective Options
    In September 2015, FEMA released a publication that describes 
alternative mitigation measures intended for a variety of housing types 
that could not feasibly be elevated.\1\ In the guidance, FEMA 
specifically acknowledged that the techniques had applicability in 
single-family homes, 1-4 family midrise multifamily residential 
buildings and high-rise multifamily residential buildings. This 
publication was intended to fulfill the requirement of Section 26 of 
the Homeowner Flood Insurance Affordability Act (HFIAA) passed by 
Congress in 2014, which directed FEMA to: (1) issue guidelines for 
property owners that provide alternative methods of mitigation efforts 
(other than building elevation), to reduce flood risk to residential 
buildings that cannot be elevated due to their structural 
characteristics; (2) inform property owners how the implementation of 
these methods may affect NFIP risk premium rates; and (3) take into 
account, when calculating the risk premium rate, the implementation of 
any mitigation method identified in the FEMA guidelines. However, 
FEMA's adherence to this mandate is only partially complete.
---------------------------------------------------------------------------
    \1\ FEMA, Reducing Flood Risk to Residential Buildings That Cannot 
Be Elevated, FEMA P-1037 / September 2015.
---------------------------------------------------------------------------
    First, the alternative mitigation options identified in the 
publication are extremely limited and only marginally more realistic 
for many properties than the elevation requirement they are designed to 
avoid. Second, FEMA has yet to complete its work on those measures that 
could more reasonably be implemented in a broader array of situations, 
such as Wet Floodproofing (Elevate Building Utilities, Floodproof 
Building Utilities, and use of Flood Damage-Resistant Materials), Dry 
Floodproofing (Passive Dry Floodproofing System) and Barrier Measures 
(Floodwall with Gates and Floodwall without Gates, Levee with Gates and 
Levee without Gates). While these clearly provide a more reasonable 
range of options to reduce flood risks, FEMA continues to conduct 
further analysis to determine the appropriate premium reduction 
associated with each measure.
    NAHB urges FEMA to prioritize the release of these analyses, as 
they will not only have a direct impact on the affordability of NFIP 
premiums today, but also will help incentivize the necessary mitigation 
and building activities to minimize risk moving forward. If we are to 
collectively work to provide resilient affordable housing where it is 
needed, local jurisdictions must have information about the full range 
of mitigation activities available and not be forced into a costly and 
less effective choice because it is the only option they feel they 
have. At a minimum, FEMA should revise its flood insurance rating to 
provide premium reductions for all of the mitigation measures 
documented in Reducing Flood Risk to Residential Buildings that Cannot 
be Elevated, not just the interior modification/retrofit measures. If 
these activities are shown to reduce risks, there is no reason not to 
recognize the benefits.
    Further, FEMA should continue to conduct research into other cost-
effective mitigation techniques. At a minimum FEMA should develop a 
comprehensive database of flood damage assessments and observations 
collected from its various MAT teams or other field teams that could be 
used by FEMA, its industry partners or research institutions to improve 
the understanding of how buildings perform under a variety of flood 
conditions and use that data and information to target and refine the 
NFIP construction standards to be more cost-effective.
    Finally, recognizing that many households do not have the interest 
or means to conduct larger scale renovation projects, NAHB, in concert 
with FEMA, the International Code Council, and the Insurance Institute 
for Business & Home Safety, is developing a series of Tech Notes that 
describe different types of retrofit techniques that can be used to 
increase the resiliency of existing buildings. Importantly, these focus 
on strategies that require minimal costs (generally less than $1,000 
for a typical home) but have a significant impact on reducing damage. 
The first six topics include sealed roof decks, attachment of roof 
coverings, flashing and sealing of roof penetrations, use of hurricane 
shutters, use of impact resistant doors and methods of preventing ice 
dams. These resources help homeowners understand their options, 
recognize that certain mitigation options can be cost-effective, and 
compel them to take action, and we urge FEMA's continued support of 
their development.
d. Provide Incentives to Mitigate/Modernize Existing Buildings
    Incentive programs that offset the increased costs for above-code 
and mitigation activities are an important tool to reduce the barriers 
that many resiliency opportunities pose and encourage more homeowners 
to invest in home modernization. For example, due to the high initial 
costs associated with purchasing and/or installing certain features to 
increase their home's resiliency, many homeowners are unable to finance 
desired or necessary upgrades and, without assistance, would likely 
forego the improvements. Incentives that are available at the federal 
and state levels, as well as those that could be offered through the 
real estate valuation and transaction processes, can address this 
issue, produce results and have proven to be attractive alternatives to 
mandates. FEMA should identify, embrace, support and promote a wide 
range of incentives and incentive programs to help improve overall 
resiliency.
    For example, the Disaster Recovery Reform Act of 2018 includes a 
number of actions related to improving the ability of existing 
structures to withstand catastrophes, such as the National Public 
Infrastructure Pre-Disaster Mitigation Program, which provides federal 
funding for pre-disaster mitigation. Increasing the resiliency of the 
existing housing stock would be a prudent use of this funding stream. 
Likewise, the Building Resilient Infrastructure and Communities grant 
program is an important tool, but portions of it need to be reworked so 
that it recognizes and incentivizes a wider range of mitigation 
options.
    States also play a role in enticing positive behavior--efforts that 
can be compounded with FEMA support. One alternative that has been used 
in several states is providing insurance discounts to homeowners who 
conduct specific activities. In Texas, the state's hurricane insurance 
pool, the Texas Windstorm Insurance Association, offers premium 
discounts of 19 percent to 33 percent for building code compliance. In 
Rhode Island, insurers are required to waive the hurricane deductible 
for insured homeowners who voluntarily implement mitigation measures 
that are specified in the insurance regulation. In Alabama, tax credits 
of up to $3,000 are available for retrofitting a taxpayer's legal 
residence to make it more resistant to hurricanes, tornadoes, other 
catastrophic windstorm events, or rising floodwaters.
    In addition, the Alabama state legislature established the 
Strengthen Alabama Homes Act in 2011 to provide grants to qualified 
homeowners to retrofit their homes to reduce property damage caused by 
hurricanes or other catastrophic windstorm events. Currently, the 
response to the program has been so overwhelming that the program 
administrator has temporarily stopped taking new grant applications.
    Clearly, these state programs have proven to be popular, as they 
provide value through loss reduction, yet enable and facilitate broader 
participation through reduced costs. The recognition and expansion of 
programs like these is one way to engage participation while offsetting 
the hefty costs associated with upgrades.
    There are also a number of other opportunities to facilitate, 
incentivize, and offset the costs of voluntary above-code construction 
and/or pre-disaster mitigation that could be achieved by FEMA working 
with its federal partners and/or other collaborations. These options 
include working with Fannie Mae and Freddie Mac to make modifications 
to property valuation and financing protocols; ensuring loans, grants 
and other federal funding programs are accessible and widely 
applicable; and providing insurance premium reductions within the 
National Flood Insurance Program (NFIP), among others.
    Under current practice, in most instances, mortgage companies, 
appraisers and real estate professionals do not consider the costs or 
benefits associated with various resiliency or energy efficiency 
upgrades. This creates a disincentive to take proactive steps to reduce 
a home's exposure, as those expenditures are not necessarily considered 
to add value. If the improvements are not included in the appraisal or 
appraised value of the structure, not only is the buyer uninformed 
about the home's qualities, his or her willingness to pay more can be 
significantly diminished.
    In an effort to spur private investment in efficiency and 
resiliency, the value and benefit of the above code practices and 
mitigation measures should be incorporated into standard real estate 
lending practices and real estate listings. By recognizing and 
valuating the upgrades, appraisers can consistently give weight to 
these improvements, lenders may reconsider qualifying loan ratios, 
realtors can promote their benefits, homeowners would get assurances 
that the investments they have made will retain value and be recognized 
in resale and homes would be more likely to get the upgrades needed to 
improve their performance.
    Similar to the valuation process and state insurance discounts, 
recognizing improved resiliency can also be done by tweaking the NFIP. 
Currently, all improvements to fortify a home against flood hazards do 
not result in flood insurance premium discounts. For example, in its 
``Reducing Flood Risk to Residential Buildings That Cannot Be 
Elevated'' document, FEMA outlines several alternative actions that can 
be taken in lieu of elevation. Of the measures discussed, however, only 
50 percent of them are eligible for flood insurance premium reductions.
e. Recognize and Retain State/Local Land Use Authority
    FEMA has frequently stated that it has no authority over local land 
use decisions and that state and local governments maintain primary 
authority over local land use and building practices to not only 
maintain their self-interests, but also because they have better 
knowledge of local conditions and needs. Indeed, one of the strengths 
of the NFIP, for example, is that it allows states and communities to 
dictate actions based on their individual risks and circumstances. 
Officials at all levels of government must work together so that lives, 
homes, schools, businesses and public infrastructure are protected from 
the damages and costs incurred by flooding and other disasters, local 
communities must retain the ability to provide the first line of 
defense in terms of land use policies and practices. They are in the 
best position to determine the risks and challenges they and their 
citizens face and follow code adoption, implementation, and enforcement 
processes that reflect their available resources and needs.
    Resiliency, risk avoidance, and mitigation planning should be 
viewed in the same context; it is best undertaken by localities who 
know their communities best. FEMA must not intrude on a locality's 
ability to conduct community planning, economic development, coastal 
zoning planning and other planning activities; instead, it must take 
care to ensure such state and local prerogatives are not undermined and 
that any FEMA activities are complementary to these local actions.
    To do so, FEMA could be of great help in providing resources, 
information and technical assistance. For example, FEMA could ask 
communities what assistance they need and fulfill those requests. 
Likewise, the Agency could provide benefit to mitigation planning by 
improving data tracking and integration--working with state or local 
agencies that track relevant data on sea level rise or flood levels and 
integrating their data to produce more accurate risk for the future and 
cataloging and disseminating that data. FEMA could also help 
incentivize the necessary mitigation and building activities to 
minimize risk in the future by providing state and local jurisdictions 
with the best available information about the full range of mitigation 
activities available so they are not forced into implementing the most 
costly or least efficient choice possible because it is the only one 
they feel they have. Local, state and federal governments all are 
looking for approaches to mitigate the effects of potential climate and 
natural disaster risk events. FEMA must be aware of such initiatives 
and develop policies and take actions that support, not conflict, with 
these efforts.
f. Embrace and Improve Stakeholder Engagement
    FEMA administers a number of programs and priorities aimed at 
preparing for, and responding to disasters, hazards, and other 
emergencies. It also manages the National Flood Insurance Program 
(NFIP), including overseeing the development and updating of the 100-
year floodplain maps, disaster assistance, and mitigation. In each of 
its past several strategic plans, FEMA has set out goals to improve 
collaboration and work with stakeholders. While NAHB believes this 
interaction has improved, more work needs to be done. FEMA must 
continue to prioritize its outreach, solicitation of feedback, and 
engagement of residential building experts and other members of the 
public.
    For example, in completing its work, FEMA relies on a myriad of 
guidance documents, handbooks, policy statements and other directives 
to explain its programs, expectations, and policies. Because many of 
these documents are used to direct the activities of landowners and 
citizens, they have the force and effect of the law and its 
implementing rules, and, hence, meet the definition of ``regulation'' 
outlined in E.O. 13771, yet FEMA has not consulted the public in their 
development. Examples include the Guidelines and Standards for Risk 
Analysis and Mapping, Community Rating System Coordinator's Manual, and 
Community Resilience Indicators and National-Level Measures. Not only 
have these documents not been vetted through the public, but many 
people do not know they exist and many are difficult to locate, yet the 
agency expects the public to be knowledgeable and comply. FEMA is 
strongly urged to revisit its standard protocol for advising the public 
of potential policy changes and soliciting feedback. Only through 
providing opportunities for adequate notice and comment, timely 
updates, and broad outreach will the agency be able to reach its 
constituency and ensure its programs are effective and workable on the 
ground.
    Similarly, although FEMA recognizes the value and need of bringing 
communities together to create more resilient places, the Agency rarely 
calls upon the expertise of the home building industry to help direct 
its actions. NAHB's members possess a wealth of experience and 
knowledge that is directly related to much of FEMA's work. Building 
technology, construction techniques, and best practices are the 
language of the trade, yet FEMA has failed to regularly involve NAHB or 
its representatives on projects affecting residential construction.
    Building homes and communities are our members' livelihoods, 
whether those homes are constructed in urban areas, mountainous 
topography, for low-income residents, or within the 100-year 
floodplain. Our staff and members have the experience and expertise to 
help ensure FEMA programs and practices that affect residential 
construction are effective, cost-efficient and workable on the ground. 
But to do so, NAHB needs to be at the table--appointed as a member of 
project review panels or Mitigation Assessment Teams or otherwise have 
its input solicited at early stages of any FEMA or FEMA-funded project 
affecting residential construction.
g. Provide Updated Resources and Data
    The increased focus on sea level rise, climate change, more intense 
storms and recent flooding events further illustrate the need for the 
public to have ready access to good data and information so that they 
can make informed decisions. NAHB urges FEMA to not only engage with, 
but also to provide the necessary resources to builders, developers, 
building code officials and others to enhance their knowledge of the 
national model codes and acceptable and realistic mitigation 
strategies. This will help to expand opportunities and improve 
compliance with the construction codes and land development 
requirements that will lead to enhanced resiliency in communities 
across the country.
              Maps
    Current, accurate and scientifically sound Flood Insurance Rate 
Maps (FIRMS) are essential components of the NFIP, as they are the 
backbone for depicting the location of the 100-year floodplain. FEMA 
has spent countless hours and federal resources to develop and maintain 
its floodplain-mapping program over the last four decades. Despite 
technical advances in the field and numerous efforts by Congress and 
the Administration to advance public policy in the area through the 
establishment of the Technical Mapping Advisory Committee (TMAC), 
creation of the Map Modernization Program, or its successor FEMA's Risk 
MAP Program, continuing technical and funding challenges have stymied 
attempts to modernize national mapping efforts. As the maps and the 
mapping process continue to evolve, there remain ongoing concerns about 
how the maps are made, what information is used and depicted, and how 
corrections are made. FEMA is urged to focus efforts on updating the 
maps and creating and following a plan to ensure the maps are 
maintained and updated on a regular basis. In doing so, the Agency must 
ensure that minimum construction requirements and mapping standards 
reflect the variation in flood risk across the country. Requirements 
developed based on observations, data and modeling for the Gulf Coast 
and Florida should not be imposed on coastal areas in the Northeast, 
around the Great Lakes, or in riverine flood plains where the geography 
is vastly different.
              RR 2.0 Mitigation Details
    FEMA has initiated a long-term effort to transform the NFIP to make 
it more consumer friendly and better reflect the actual risks 
properties face. Through Risk Rating 2.0, FEMA intends to create a more 
accurate and fair calculation of structure-specific risks and improve 
the policy application process--efforts that it hopes will compel more 
property owners to purchase flood insurance.
    To do so, FEMA is reassessing and recalculating the factors it 
looks at when determining flood insurance rates. The shift will move 
the NFIP from the current practice, which looks at risk across broad 
bands associated with flood zones and categories of properties to 
create an individualized picture of each property's risk. Information 
used to determine the new rates will include property-specific 
information, such as distance to the coast or other water sources, 
exposure to different types of flood risk, and the cost to rebuild the 
home, among others.
    Despite this program going into effect on October 1, 2021, for new 
policies and April 1, 2022, for renewals, FEMA has yet to fully 
disclose the basis for premium rates to the public, such as information 
about how location, elevation, and other factors are translated into 
rates and has deliberately been discrete about how premiums are being 
determined. Further, after repeated requests, the Agency has also 
failed to share the details regarding which mitigation practices can 
create policy credits, making it difficult for the nation's home 
builders to take steps during the construction process to reduce rates 
for future homeowners. Rate transparency is a vital component of the 
program and the public's perception of it. FEMA is strongly urged to 
disclose the rating factors and premium calculation methodology, along 
with details about what practices may result in mitigation credits 
prior to Risk Rating's full implementation.
                             IV. Conclusion
    NAHB appreciates the opportunity to provide this statement 
regarding FEMA's priorities for 2022. NAHB and its members understand 
the importance of building safe, strong, and resilient communities 
while also considering market-driven solutions that maintain housing 
affordability. NAHB looks forward to future opportunities to discuss 
how FEMA can protect homes and their occupants from severe weather 
events and hazards without detrimentally impacting housing 
affordability. If you have any questions or need additional 
information, please contact Heather Voorman.

                                 
Statement of the Reinsurance Association of America, Submitted for the 
                       Record by Hon. Dina Titus
    Chair Titus, Ranking Member Webster, and members of the 
Subcommittee, thank you for the opportunity to submit a statement for 
the record for today's hearing entitled, ``FEMA Priorities for 2022: 
Stakeholder Perspectives.''
    The Reinsurance Association of America (RAA) is the leading trade 
association of property and casualty reinsurers doing business in the 
United States. RAA membership is diverse, including reinsurance 
underwriters and intermediaries licensed in the U.S. and those that 
conduct business on a cross border basis. The RAA represents its 
members before state, federal and international bodies.
    The RAA encourages the Subcommittee, full Committee, Congress, and 
Administration to improve America's community resilience in the face of 
climate and natural disaster risks, including the risk of flooding. The 
RAA specifically recommends that legislation establish Community 
Disaster Resilience Zones (CDRZ). Our CDRZ proposal would direct public 
and incentivize private sector investment to help improve 
infrastructure resilience, including affordable housing resilience, for 
communities that are the most in need and most at risk from natural 
disasters. Our CDRZ proposal is described in detail below. The RAA also 
supports a long-term reauthorization of the National Flood Insurance 
Program (NFIP) and flood insurance reforms.
               Climate Change and Natural Disaster Risks
    The RAA's longstanding policy recognizes climate change and the 
impacts of climate change, and the RAA is committed to working with 
policymakers, regulators, and the scientific, academic, and business 
communities to assist in promoting awareness and understanding, as well 
as addressing the risks associated with climate change. A copy of the 
RAA's climate change policy can be found on our website and in Appendix 
A of this statement.\1\ At the federal, state, and local levels, it is 
especially critical that the private sector address significant natural 
disaster risks associated with floods, wildfire, earthquake, or other 
devastating natural disaster events. Urgently addressing these risks is 
particularly important as the frequency, severity, and costs of many 
natural disasters continue to increase due to climate change.
---------------------------------------------------------------------------
    \1\ https://www.reinsurance.org/Advocacy/RAA_Policy_Statements/
---------------------------------------------------------------------------
    The U.S. Department of Commerce National Oceanic and Atmospheric 
Administration's (NOAA) National Centers for Environmental Information 
reported that, ``The U.S. has sustained 310 weather and climate 
disasters since 1980 where overall damages/costs reached or exceeded $1 
billion (including CPI adjustment to 2021). The total cost of these 310 
events exceeds $2.155 trillion.'' \2\ According to NOAA, ``Each state 
has been affected by at least 1 billion-dollar disaster since 1980.'' 
\3\ Tables 1-4, by Aon's Catastrophe Insight division, demonstrate the 
increase in the number of natural disaster events and overall and 
insured losses in the U.S. and globally from 1980 to 2021. In 1980, the 
U.S. had 60 natural loss events that resulted in $60 billion in overall 
losses, including $5 billion in insured losses, compared to 210 natural 
loss events globally that resulted in $191 billion in losses, including 
$8 billion in insured losses.\4\ Fast forward to 2021, and the U.S. had 
96 natural loss events that resulted in $172 billion in overall losses, 
including $95 billion in insured losses, compared to 401 natural loss 
events globally that resulted in $353 billion in losses, including $134 
billion in insured losses.\5\
---------------------------------------------------------------------------
    \2\ https://www.ncdc.noaa.gov/billions/
    \3\ https://www.climate.gov/news-features/blogs/beyond-data/2010-
2019-landmark-decade-
us-billion-dollar-weather-and-climate
    \4\ Catastrophe Insight division, Aon plc, February 2021
    \5\ Catastrophe Insight division, Aon plc, February 2021
    
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
    
 
    

    Insurance is a critical component for economic and social recovery 
from the effects of extreme weather and climate driven events. In the 
financial services sector, property casualty insurers and reinsurers 
are the most exposed to natural disasters, especially those impacted by 
climate and weather. The industry would be at great financial risk if 
it did not understand global and regional climate impacts, variability 
and developing scientific assessment of a changing climate. Integrating 
this information into the insurance sector is an essential function. 
Insurance pricing also is a mechanism for conveying the consequences of 
decisions about where and how we build and where people choose to live.
    Our industry is science based. Blending the actuarial sciences with 
the natural sciences is critical to providing the public with the 
financial resources needed to recover from natural catastrophic events. 
As the scientific community's knowledge of climate change continues to 
develop, it is important for (re)insurers to incorporate that 
information into the exposure and risk assessment process and that it 
be conveyed to stakeholders, policyholders, the public and public 
officials that can or should address adaptation and mitigation 
alternatives. Developing an understanding about climate and its impact 
on various risks--for example, wildfires, droughts, heat waves, the 
frequency and intensity of tropical hurricanes, thunderstorms, and 
convective events, rising sea levels and storm surge, more extreme 
precipitation events and flooding--is critical to our role in 
translating the interdependencies of weather, climate risk assessment 
and pricing.
    Climate-related and natural disaster risk exposure is broad-
ranging. These risks are widespread, geographically diverse, and 
include a range of natural disaster perils impacting homeowners and 
renters, property owners, servicers, mortgage investors, taxpayers, and 
communities. It is important to ensure that these risk exposures are 
addressed and mitigated. Natural hazard mitigation includes physical 
enhancements and insurance to better protect residential properties and 
other infrastructure against damage caused by natural disasters. For 
government programs, government-sponsored enterprises, private sector 
financial institutions, and taxpayers, financial mitigation also is 
important to protect against any mortgage credit default risk 
associated with natural disaster risk.
    The RAA believes a variety of solutions should be used to improve 
community resilience to the benefit of all those in the value chain of 
climate and natural disaster risk exposure. The RAA also believes that 
it is important to address geographic, natural disaster peril, and 
socioeconomic diversity. Some traditional solutions, like property 
insurance protections for homeowners certainly can and should be 
utilized, but new analytical capabilities that increasingly and 
intelligently can help reduce risk and direct resources to achieving 
that goal also should be pursued.
Investing in Resilience for America's Communities is Critical, Logical, 
                               and Smart
    Dedicated federal appropriations in the form of grants are one 
option but limited, and for the federal government, the costliest 
mechanism to pay for resilience projects. Table 5 provides an example 
of the cost to federal taxpayers to fund a $100,000 resilience project 
using federal appropriations versus direct pay bonds and private 
activity bonds. For fiscal year 2020, FEMA made $700 million available 
for hazard mitigation grant programs but received over 1,200 
applications requesting an estimated $4 billion.\6\ There is demand, 
but traditional appropriation funding is inadequate.
---------------------------------------------------------------------------
    \6\ https://www.fema.gov/grants/mitigation/building-resilient-
infrastructure-communities/
fy2020-subapplication-status#2020-chart

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]


    In December 2019, the National Institute of Building Sciences 
issued its U.S. Department of Housing and Urban Development-funded 
``Natural Hazard Mitigation Saves'' report.\7\ The report describes 
that federal disaster mitigation has saved $6 for every $1 invested 
since 1995. Other mitigation-related activities, such as updating 
building codes to ensure resilient structures, and investments can save 
between $4 and $11 for every $1 spent. Investing in mitigation can 
reduce the impact of future disasters on lives, property, and the 
economy. Congress and the Administration can increase these investments 
by directing both public and incentivizing private sector resources to 
support infrastructure, including housing, resilience projects.
---------------------------------------------------------------------------
    \7\ https://www.nibs.org/projects/natural-hazard-mitigation-saves-
2019-report
---------------------------------------------------------------------------
    Reducing the impact of climate and natural disaster risk in the 
first place, followed by other protections like traditional insurance 
and risk transfer--particularly to benefit vulnerable homeowners and 
renters in rural and urban areas--should be a top public and private-
sector priority for climate and natural disaster resilience and risk 
management.
    As a member of the BuildStrong Coalition, the RAA supports the 
Coalition's work to further the achievements of the bipartisan 
``Disaster Recovery Reform Act of 2018,'' which significantly increased 
America's investment in pre-disaster mitigation to help communities 
protect against disaster risk. The RAA specifically supports the 
Coalition's objectives, including to:
      Enact the ``Resilient Assistance for Mitigation for 
Environmentally Resilient Infrastructure and Construction by Americans 
Act,'' or the ``Resilient AMERICA Act'' (H.R. 5689), introduced by 
Chairman DeFazio, Ranking Member Graves, Subcommittee Chair Titus, and 
Subcommittee Ranking Member Webster; \8\
---------------------------------------------------------------------------
    \8\ https://transportation.house.gov/news/press-releases/tandi-
leaders-introduce-bipartisan-
legislation-to-help-communities-prepare-for-and-respond-to-disasters/;
    https://www.congress.gov/bill/117th-congress/house-bill/5689/
text?q=%7B%22search%22%3A
%5B%22resilient+america+act%22%2C%22resilient%22%2C%22america%22%2C%22ac
t%22%5D
%7D&r=3&s=2
---------------------------------------------------------------------------
      Increase disaster mitigation funding for FEMA's Building 
Resilient Infrastructure and Communities (BRIC) program;
      Provide incentives for state and local communities to 
strengthen and enforce building codes;
      Invest in risk-reducing enhancements to improve the 
resilience of lifeline infrastructure;
      Create incentives and investments that help to improve 
resilience;
      Encourage the use of American-made products for 
resilience projects; and
      For state, local, and tribal governments, provide 
resources and eliminate barriers to enhance resiliency and protect 
against all hazards.\9\
---------------------------------------------------------------------------
    \9\ https://buildstrongamerica.com/about-us/; https://
homeland.house.gov/imo/media/doc/2021-06-08-EPRR-HRG-Testimony-
Williams.pdf

    The RAA also is a member of the SmarterSafer Coalition and supports 
the Coalition's priorities for Congress in relation to infrastructure 
legislation:
      Enhance infrastructure-related research, including that 
which pertains to climate risk, and match new findings from new 
research with advanced pre-disaster mitigation plans and investment in 
pre-disaster mitigation.
      Invest in natural and climate resilience infrastructure 
projects.
      Improve infrastructure resilience in America's 
floodplains, as envisioned in the ``Flood Risk Management Act'' (S. 
1688), the ``Flood Resiliency and Taxpayer Savings Act'' (H.R. 481) and 
the ``Built for Future Disasters Act of 2021'' (H.R. 2632); and 
consider and address the racial inequities inherent in federal disaster 
assistance and hazard mitigation assistance programs that reflect and 
perpetuate discriminatory practices and historic redlining.
      Facilitate and strengthen public-private partnerships, 
such as transferring risk to private financing, insurance, and 
reinsurance to shift some of the financial burdens associated with 
climate change from the government's balance sheet to willing private 
sector participants to improve the implementation of federal programs.
      Direct federal funds to outcome-driven projects that 
strengthen communities and reduce long-term risk, such as requiring 
stronger minimum design standards and incorporate forecasts of future 
conditions for federal infrastructure investments, as envisioned in the 
``Build to Last Act'' (S.1282/H.R.2760).\10\
---------------------------------------------------------------------------
    \10\ https://www.smartersafer.org/about-us/;
    https://www.smartersafer.org/2021/07/15/smartersafer-
infrastructure-priorities-letter/

    The RAA endorsed the ``Insurers' Principles of Climate Change 
Adaptation'' released by the Insurance Institute for Business & Home 
Safety (IBHS), which ``outline the steps policymakers--in collaboration 
with the insurance industry and other private sector stakeholders--
should take to improve the resilience of American homes, businesses, 
and communities.'' Details about the Principles can be found online, 
but an overview is as follows:
      Principle 1: Climate Change Adaptation is Necessary;
      Principle 2: Building Codes and Land Use Support 
Tomorrow's Resilience;
      Principle 3: Prioritize Funding for Increasing Resilience 
of Existing Structures;
      Principle 4: Make Resilience Available for All;
      Principle 5: Leverage Climate Data and Analytics to 
Support Climate Change Adaptation; and
      Principle 6: Enhance Resilience for Public Infrastructure 
and Facilities.\11\
---------------------------------------------------------------------------
    \11\ https://adaptingtoclimate.com/

    The RAA also supports legislation to use the tax code to provide 
homeowners and business with incentives to improve building resilience 
and better protect against the natural disaster risks they face, 
including:
      The ``Disaster Mitigation and Tax Parity Act'' (S.2432/
H.R.4675) provisions that, like federal disaster mitigation grants, 
would exempt from federal taxation state disaster mitigation grants 
that help people protect their homes against windstorms, earthquakes, 
or wildfires; and
      The ``Strengthening Homes and Eliminating Liabilities 
Through Encouraging Readiness (SHELTER) Act (S.1805/H.R.3925) to 
provide individuals and businesses a disaster mitigation tax credit, 
specifically 25% of qualifying mitigation expenses of up to $5,000.\12\
---------------------------------------------------------------------------
    \12\ https://www.cassidy.senate.gov/newsroom/press-releases/
cassidy-bennet-introduce-new-tax-credit-for-working-families-small-
businesses-preparing-for-natural-disasters-;
    https://crist.house.gov/news/documentsingle.aspx?DocumentID=2386

    FEMA's BRIC and other programs, U.S. Department of Housing and 
Urban Development programs, the U.S. Department of the Treasury's 
Capital Magnet Fund, and other federal programs should direct funding 
resources toward achieving housing climate and natural disaster 
resilience for ``extremely low- and very low-income households'' that 
face significant natural disaster risk and particularly that expose 
taxpayer-backed federal housing programs to climate and natural 
disaster risks.\13\ In general, the RAA also recommends that the 
Financial Stability Oversight Council (FSOC) and all of its members 
prioritize climate and natural disaster resilience efforts for 
federally funded and federally-backed residential properties in 
communities that are the most in need and most at risk from significant 
natural disaster(s).
---------------------------------------------------------------------------
    \13\ https://www.hudexchange.info/programs/htf/;
    https://www.cdfifund.gov/programs-training/programs/cmf
---------------------------------------------------------------------------
         The RAA's Community Disaster Resilience Zones Proposal
    Low-income and minority neighborhoods are disproportionately 
impacted by natural disasters.\14\ This fact should be a priority 
consideration for policymakers and the private sector as we work to 
understand and address the climate and natural disaster-related risks 
facing communities across America. The RAA has developed an innovative 
approach to addressing climate and natural disaster resilience, 
specifically to improve infrastructure resilience in the face of 
natural disasters and address socio-economic disparities. The RAA urges 
Congress and the Administration to include our proposal as part of 
infrastructure or other legislation that may become law during the 
117th Congress.
---------------------------------------------------------------------------
    \14\ https://www.americanprogress.org/wp-content/uploads/2013/08/
LowIncomeResilience-2.pdf
---------------------------------------------------------------------------
    In general, the RAA's proposal would create a federal structure 
that directs public and incentivizes private-sector funding for 
resilience projects to communities most in need and most at risk from 
significant natural disaster(s). More specifically, it would:
    1)  Address the impact of climate change through data-driven 
analysis;
    2)  Establish Community Disaster Resilience Zones (CDRZ) for 
communities most in need and most at risk from significant natural 
disaster(s); and
    3)  Direct and incentivize public and private-sector investment in 
the CDRZ to improve infrastructure resilience.

    Under the proposal, CDRZ communities would be provided a menu of 
funding and financing options to pay for resilience projects to better 
protect them against significant natural disaster risk(s). Climate and 
natural disaster resilience projects could include:
      Nature-based solutions designed to increase climate and 
natural disaster resilience, such as the creation of open space, the 
restoration of wetlands, coastal barriers, beaches, and natural 
protections;
      Retrofit existing facilities to increase climate and 
natural disaster resilience, including the construction of emergency 
storm shelters, safe rooms, upgraded roofs, and other risk-reducing and 
community-resilience enhancing actions;
      Construction of new facilities with design and 
construction features that provide climate and natural disaster 
resilience;
      Retrofit, construction, or other updates to lifeline 
infrastructure, including water, electric, and communications 
infrastructure, that increase the infrastructure's climate and natural 
disaster resilience; and
      Programs that provide funding to property owners to 
retrofit existing structures, including single-family homes, 
multifamily homes, and commercial buildings, with design and 
construction features that provide climate and natural disaster 
resilience.

    The RAA's legislative proposal has a few core components to help 
achieve these objectives:
    I.  Codify, enhance, and utilize FEMA's National Risk Index for 
Natural Hazards (NRI) data to find the intersection of risk, 
vulnerability, and low community resilience scores, as the basis to 
identify and establish the CDRZ that reflect diversity among the states 
by geography and type of peril, such as fire storm/wildfire, tornado, 
hurricane, flooding, ice storms, earthquake, wind, hail, and drought.
    II.  Within CDRZ, coalesce a variety of funding mechanisms, 
providing a menu of financing enhancements and tax incentives that can 
focus federal, state, local, charitable, and private-sector investment 
in resilience projects. To help fund resilience projects in CDRZ the 
proposal would establish:
          CDRZ taxable direct pay bonds, like Recovery Zone 
Economic Development Bonds, which were one of three types of Build 
America Bonds that Congress created in 2009 as part of financial crisis 
economic recovery legislation (these bonds are federally subsidized 
bonds issued by state and local governments for local projects that 
support community resilience);
          CDRZ tax-exempt facility private activity bonds 
subject to a separate volume cap, like Recovery Zone Facility Bonds 
(also in the 2009 recovery legislation), and provide for life and 
property/casualty insurers' exclusion from proration for investments in 
these CDRZ bonds (the proceeds from these federally tax-exempt bonds 
would be utilized by private or quasi-governmental entities to fund 
resilience projects that benefit a public purpose);
          Federal transferrable tax credits for individuals for 
resilience improvements to housing in CDRZ;
          Federal tax credits for charitable contributions for 
resilience projects in CDRZ; and
          Federal tax credits for community-level projects in 
CDRZ that are tradeable, transferrable, and do not expire, and allow 
proceeds from the sale of certified tax credits to be used to, for 
example, meet matching requirements for federally funded resilience 
projects.

          Limited federal funds can leverage non-federal funding if 
Congress establishes a variety of options to pay for resilience 
projects. Some CDRZ communities--with good credit issuer ratings and a 
tax base that can support resilience projects--will be eligible to use 
taxable direct pay bonds and private activity bonds. CDRZ communities--
that are unable to access the debt markets because they do not have a 
tax base that can support additional borrowing or have reached their 
debt limits will need Congress to provide options like transferrable 
tax credits, similar to the Low-Income Housing Tax Credit, and 
charitable tax credits, versus deductions, to incentivize and direct 
the business and philanthropic communities to invest and donate funds 
to pay for resilience projects.
          CDRZ resilience project bonds and tax credits are likely to 
be very attractive to corporations, especially given the increasing 
corporate focus on investing and charitable contributions to achieve 
objectives related to Environmental, Social, and Governance (ESG) 
factors. The insurance industry (property casualty, life, and health) 
is one of the largest holders of bonds in the U.S. The $1.2 trillion of 
$4.4 trillion in U.S. Treasury, corporate, and municipal bonds held by 
the insurance industry will mature and need to be reinvested over the 
next 5 years. Federal bond and tax incentives could encourage 
investments toward CDRZ resilience projects.
    III.  Set aside and unlock federal program funding to invest in 
resilience projects in CDRZ. This could include waiving, reducing, or 
allowing other forms of financing, such as the proceeds from the sale 
of tax credits mentioned above and in-kind and charitable donations, to 
qualify for matching funds for resilience projects in CDRZ. Allowing a 
variety of resources to contribute to and invest in resilience projects 
in CDRZ, as they relate to federal program matching fund requirements, 
could significantly unlock resources for CDRZ resilience projects. For 
example, with more flexibility to meet matching fund requirements, CDRZ 
resilience projects could more likely benefit from FEMA's BRIC program 
funding and funding from other federal programs. FEMA, HUD, and other 
federal agencies also should provide resources, such as financial and 
technical assistance, to CDRZ communities to help facilitate resilience 
project planning.

    The RAA developed a data analytics tool and the CDRZ legislative 
proposal that aligns with Congressional interests and President Biden's 
plan, Executive orders, announcement, and fiscal year 2022 budget 
proposal \15\ to rebuild America's infrastructure, enable green 
initiatives and smart building to address the impact of climate change, 
create needed jobs, fuel economic recovery, support historically 
underserved communities where the need is often greatest, and provide 
sources of much-needed resilience project funding to states and 
localities.
---------------------------------------------------------------------------
    \15\ https://www.whitehouse.gov/briefing-room/statements-releases/
2021/03/31/fact-sheet-the-american-jobs-plan/; https://
www.whitehouse.gov/briefing-room/presidential-actions/2021/05/20/
executive-order-on-climate-related-financial-risk/; https://
www.federalregister.gov/documents/2021/05/25/2021-11168/climate-
related-financial-risk; https://www.whitehouse.gov/briefing-room/
statements-releases/2021/05/24/fact-sheet-biden-administration-invests-
1-billion-to-protect-communities-families-and-businesses-before-
disaster-strikes/; https://www.whitehouse.gov/briefing-room/statements-
releases/2021/05/26/fact-sheet-the-american-jobs-plan-will-produce-
preserve-and-retrofit-more-than-2-million-affordable-housing-units-and-
create-good-paying-jobs/; https://www.whitehouse.gov/wp-content/
uploads/2021/05/budget_fy22.pdf
---------------------------------------------------------------------------
    The RAA's data analytics tool utilizes publicly available data to 
very clearly, by county, Congressional district, and census tract in 
each state, understand where natural perils, older housing stock, and 
disadvantaged populations converge. The data in the RAA's data 
analytics tool is from FEMA's NRI supplemented with data from the U.S. 
Census Bureau's American Community Survey (ACS). NRI includes data that 
identifies communities by census tract in each state and county that 
are the most at risk from 18 natural hazards, such as coastal and 
riverine flooding, earthquake, hail, hurricane, strong wind, tornado, 
and wildfire.\16\ The NRI is different from other natural disaster risk 
scoring approaches because it scores census tract level loss exposure 
values (buildings, agricultural and population equivalence), social 
vulnerability, and community resilience across 18 natural hazard risks, 
to provide a more holistic view of risk.\17\ The RAA urges policymakers 
to use the same information, particularly to understand the U.S. 
landscape and pinpoint and prioritize communities that are most in need 
and most at risk from significant natural disasters, diversified by 
state, Congressional district, and natural disaster peril.\18\
---------------------------------------------------------------------------
    \16\ https://www.fema.gov/flood-maps/products-tools/national-risk-
index
    \17\ https://www.fema.gov/flood-maps/products-tools/national-risk-
index/overview
    \18\ https://hazards.geoplatform.gov/portal/apps/MapSeries/
index.html?appid=ddf915a24
fb24dc8863eed96bc3345f8; https://www.census.gov/programs-surveys/acs
---------------------------------------------------------------------------
    The RAA's proposal was favorably mentioned during four 
Congressional 2021 hearings:
      March 18, 2021, House Transportation and Infrastructure 
Subcommittee on Economic Development, Public Buildings, and Emergency 
Management hearing on ``Building Smarter: The Benefits of Investing in 
Resilience and Mitigation''; \19\
---------------------------------------------------------------------------
    \19\ https://transportation.house.gov/committee-activity/hearings/
building-smarter-the-benefits-of-investing-in-resilience-and-mitigation
---------------------------------------------------------------------------
      May 18, 2021, Senate Committee on Banking, Housing, and 
Urban Affairs hearing on, ``Reauthorization of the National Flood 
Insurance Program, Part I''; \20\
---------------------------------------------------------------------------
    \20\ https://www.banking.senate.gov/hearings/05/11/2021/
reauthorization-of-the-national-flood-insurance-program-part-i
---------------------------------------------------------------------------
      May 19, 2021, House Committee on Ways and Means hearing 
on ``Leveraging the Tax Code for Infrastructure Investment'',\21\ and
---------------------------------------------------------------------------
    \21\ https://waysandmeans.house.gov/legislation/hearings/ways-and-
means-committee-hearing-leveraging-tax-code-infrastructure-investment
---------------------------------------------------------------------------
      July 20, 2021, Senate Committee on Banking, Housing, and 
Urban Affairs hearing on, ``21st Century Communities: Climate Change, 
Resilience, and Reinsurance'' (RAA testified).\22\
---------------------------------------------------------------------------
    \22\ https://www.banking.senate.gov/hearings/21st-century-
communities_climate-change-resilience-and-reinsurance
---------------------------------------------------------------------------
                           Housing Resilience
    Most Federal housing programs fall under the jurisdiction of the 
House Committee on Financial Services, which also has an important 
leadership role to play in prioritizing and directing federal program 
funding toward housing resilience, which is the third core component of 
the RAA's legislative proposal mentioned above. Housing, especially 
affordable housing, that can withstand the most significant disaster(s) 
that vulnerable communities across the country face is an investment in 
critical infrastructure. Witnesses from a variety of organizations have 
raised this point in testimony delivered during Congressional hearings, 
for example:
      ``We invest in disaster recovery and resilience work 
because people of modest means are most likely to be harmed by 
disasters and tend to be the slowest to recover. Through our Building 
Resilient Futures initiative, we are working to ensure that 
sustainable, resilient, affordable housing becomes the norm and that 
communities are equipped to withstand and recover from disasters. 
Despite growing interest and commitment, our housing, infrastructure, 
and regions are not mitigating or adapting at the necessary pace of 
change. It's time for America to invest in modern infrastructure that 
is built to last.'' \23\
---------------------------------------------------------------------------
    \23\ https://financialservices.house.gov/calendar/
eventsingle.aspx?EventID=407532
---------------------------------------------------------------------------
        --Jacqueline Waggoner, Enterprise Community Partners, Inc.,
         House Financial Services Committee hearing, April 14, 2021
      ``America built the transatlantic railroad in six years 
but somehow we struggle to deliver long term housing assistance to our 
most vulnerable citizens whose lives have been upended by natural 
disasters.'' \24\
---------------------------------------------------------------------------
    \24\ https://transportation.house.gov/committee-activity/hearings/
an-assessment-of-federal-recovery-efforts-from-recent-disasters
---------------------------------------------------------------------------
                     --Reese C. May, SBP (The St. Bernard Project),
House Transportation and Infrastructure Committee hearing, October 
                                                           22, 2019

    To that end, the RAA supports provisions in the ``Housing is 
Infrastructure Act'' (H.R. 4497), which was introduced by House 
Financial Services Committee Chairwoman Maxine Waters, that: prioritize 
applications for the $75 billion authorized for public housing agencies 
located in areas that have a plan to increase ``climate and natural 
disaster resilience and water and energy efficiency,'' authorize at 
least $19.1 billion for ``climate and natural disaster resilience and 
water and energy efficiency'' for ten federal affordable housing 
programs, and authorize at least $10.7 billion for affordable housing 
in areas of high and persistent poverty. The RAA also supports the 
bill's $11.9 billion authorization for the National Flood Insurance 
Program's (NFIP) Flood Mitigation Assistance Program (FMA).\25\
---------------------------------------------------------------------------
    \25\ https://financialservices.house.gov/news/
documentsingle.aspx?DocumentID=408154
---------------------------------------------------------------------------
    The RAA will continue to work with Chairwoman Waters on the 
``Housing is Infrastructure Act'' and other legislation the House 
Financial Services Committee and this Committee may consider so that it 
can most impactfully help improve resilience in vulnerable communities 
that are most in need and most at risk from significant natural 
disaster(s).
            The Protection Gap, (Re)Insurance, and the NFIP
Natural Disaster Insurance Protection Gap
    Homeowners and renters, property owners, mortgage investors, 
taxpayers, and communities face risks due to climate change, natural 
disaster risks, and the lack of insurance coverage or underinsurance of 
such coverage. There is a serious and significant natural disaster 
insurance protection gap in the United States. The U.S. Department of 
the Treasury's Federal Insurance Office's Federal Advisory Committee on 
Insurance (FACI) has a subcommittee that is dedicated to addressing it. 
Several RAA members serve on both the FACI and the ``Subcommittee on 
Addressing the Protection Gap through Public-Private Partnerships and 
Other Mechanisms.'' During FACI's December 2019 meeting, the 
Subcommittee cited statistics to provide examples of the insurance 
protection gap in the U.S. and issued recommendations that FHFA should 
consider.\26\ The National Association of Insurance Commissioners 
(NAIC) has published alarming statistics about the disaster insurance 
protection gap. For example, one NAIC statistic cited in the 
Subcommittee's presentation is that ``Only 1% of properties outside of 
flood zones have flood insurance, yet half of U.S. floods occur in 
these areas.'' Various studies and reports, including a 2018 report by 
AIR Worldwide, have warned that the next big earthquake to impact 
California, likely by 2044, could result in $170 billion in total 
damage and almost half would be residential-related loss, $37 billion 
of which would be uninsured.\27\ Given the likelihood of future, 
significant, and costly natural disasters throughout the U.S. and 
uninsured residential costs, it is important to have a coordinated 
effort focusing on closing the insurance protection gap.
---------------------------------------------------------------------------
    \26\ https://home.treasury.gov/system/files/311/
December2019FACI_ProtectionGap
Presentation.pdf; https://home.treasury.gov/system/files/311/
December2019FACI_ProtectionGap
ProposedRecs.pdf
    \27\ https://www.air-worldwide.com/Publications/Infographics/Who-
Will-Pay-for-the-Next-Great-California-Earthquake-/
---------------------------------------------------------------------------
    Congress, the Administration, the NAIC, state and local officials, 
and the private sector, including reinsurers, should develop a 
comprehensive strategy to identify and address the natural disaster 
insurance protection gap in the U.S. and the risks it poses to 
homeowners and renters, property owners, individuals, businesses, and 
federal programs and taxpayers. It also is important to close the 
insurance protection gap. Congress and federal regulators should help 
initiate efforts to close the insurance protection gap via traditional 
insurance and risk transfer. Congress and federal regulators can 
further facilitate a private market for flood insurance, potentially 
providing consumers with more flood insurance options. One way to 
achieve this is for the Federal Housing Finance Agency (FHFA) and HUD's 
Federal Housing Administration (FHA) to align their regulations and/or 
guidance for private flood insurance with those issued in 2019 by 
federal lending regulators.\28\ (In 2020, HUD issued a proposed 
regulation to align its regulations and guidance with that of the 2019 
federal lending regulators \29\).
---------------------------------------------------------------------------
    \28\ https://www.fdic.gov/news/financial-institution-letters/2019/
fil19008.html
    \29\ https://www.federalregister.gov/documents/2020/11/23/2020-
25105/acceptance-of-private-flood-insurance-for-fha-insured-mortgages;
    https://www.hud.gov/press/press_releases_media_advisories/
HUD_No_20_191
---------------------------------------------------------------------------
Primary Insurance
    Traditional insurance solutions--such as primary property insurance 
protection, including earthquake, wind, fire, and flood insurance--are 
critical for people, property, jobs, businesses, and communities to be 
resilient in the aftermath of natural disasters. That is especially 
true since federal disaster assistance is provided only when there is a 
federally declared disaster and typically results in a fraction of what 
insurance assistance can provide. For example, according to FEMA, in 
2019, the average, annual flood insurance premium was $700 (about $58 
per month), and the average claim payout was $53,000.\30\ Meanwhile, in 
2019, federal disaster assistance was capped at $34,900 with an average 
annual payment of $6,246.\31\ Ensuring that the protection gap is 
bridged, and property insurance adequately covers the climate and 
natural disaster risk(s) involved are of utmost importance. Risk 
transfer products that protect each stakeholder from climate and 
natural disaster risks can play an important role.
---------------------------------------------------------------------------
    \30\ https://www.fema.gov/data-visualization/historical-flood-risk-
and-costs
    \31\ https://www.federalregister.gov/documents/2018/10/22/2018-
22884/notice-of-maximum-amount-of-assistance-under-the-individuals-and-
households-program; FEMA communication with RAA, 4/16/2021
---------------------------------------------------------------------------
Reinsurance and Risk Transfer
    Reinsurance. Reinsurance is essentially insurance for insurance 
companies, federal programs, and state insurance programs. It is a risk 
management tool for insurance companies and government programs to 
reduce the volatility in their portfolios and improve their financial 
performance and security.
    Reinsurance also is the primary mechanism for spreading risk 
globally, thereby accessing a greater pool of capital to pay for 
inevitable catastrophic losses. Consistent with the intent of Congress, 
reinsurers believe the private sector can and should assume more 
federal government risk. Reinsurers are willing to offer reinsurance 
options to a wide variety of government programs to help manage their 
exposure to losses.
    Reinsurance is extensively used by the private markets to diversify 
risk and protect against future losses. Reinsurance is purchased for 
essentially four reasons: (1) to limit liability on specific risks; (2) 
to stabilize loss experience; (3) to protect against catastrophes; and 
(4) to increase capacity. Depending on the purchaser's goals, different 
types of reinsurance contracts are available to bring about the desired 
result. For federal programs, purchasing reinsurance would mitigate the 
financial impact of any large-scale future losses and help to prevent 
any future funding lags as it is pre-arranged financing for losses. 
Reinsurance also allows federal programs to gain financial flexibility 
and not be forced to rely on emergency federal funding in the event of 
defaults that could put programs in jeopardy.
    Risk Transfer. Risk transfer, including reinsurance, is a 
successful solution used by both the public and private sector 
including (re)insurers, financial institutions, and government 
programs. In addition to federal programs, which are described below, 
risk transfer also has been used by state programs, including the 
California Earthquake Authority, California Wildfire Fund, Florida 
Hurricane Catastrophe Fund, Florida Citizens Property Insurance 
Corporation. Government risk can and should be transferred voluntarily 
to the private market. The use of private capital will protect 
consumers, taxpayers, and communities, while spreading risk throughout 
the globe to insurers and other capital providers who are willing to 
assume such risk. Risk transfer will strengthen government programs by 
giving them the financial flexibility to ensure they continue to remain 
viable in the long term.
    Benefits of Risk Transfer. Risk transfer can help both government 
agencies and private businesses analyze and manage risk by providing 
financing stability and reducing the impact of future losses. For a 
variety of federal programs and operations, the reinsurance market has 
the capacity and interest to assist the government to appropriately 
manage its risk. Opportunities exist for the federal government to 
benefit from the competitive market's risk management services and risk 
transfer capabilities to deleverage federal program balance sheets and 
simultaneously increase protections for U.S. taxpayers. Expanded 
utilization of (re)insurance would reduce systemic risk by further 
diversifying insurance and credit risks and by transferring more of the 
enormous exposure currently borne by taxpayers, such as the mortgage 
default risk to the government sponsored enterprises (GSEs) following a 
major U.S. earthquake. Reinsurers are poised to work with the Congress 
and the Administration to expand and maximize the federal government's 
utilization of the private market to the extent the industry can write 
the risk.
    As noted above, reinsurance is routinely utilized by insurers and 
government programs to provide a crucial safety net for low frequency, 
high severity natural and man-made events that result in extreme 
insured losses. Insurers rely on reinsurers to assume losses for a 
single event or, in many cases, for an accumulation of losses from 
hurricanes, earthquakes, winter storms, wildfires, or terrorist 
attacks. Some historic events illustrate this. Hurricanes Katrina, Rita 
and Wilma in 2005 caused over $92 billion in insured losses, and 
reinsurers bore around 28% of the losses from those events.\32\ 
Reinsurers assumed 55% of $41 billion in insured losses from the 
terrorist events of September 11.\33\ Superstorm Sandy caused $25 
billion in insured losses with reinsurers taking 30% of those 
losses.\34\ The pattern of risk transfer for catastrophe-exposed 
property insurance to the reinsurance market applies across the global 
insured landscape as well.
---------------------------------------------------------------------------
    \32\ Holborn Corporation, ``Holborn Perspectives, Looking Closer At 
. . . SuperStorm Sandy,'' December 12, 2012
    \33\ Holborn Corporation, ``Holborn Perspectives, Looking Closer At 
. . . SuperStorm Sandy,'' December 12, 2012
    \34\ Holborn Corporation, ``Holborn Perspectives, Looking Closer At 
. . . SuperStorm Sandy,'' December 12, 2012
---------------------------------------------------------------------------
Examples of Successful Federal Government Risk Transfer Programs
    Several federal government agencies already have risk transfer 
programs in place. These programs highlight the ways in which risk 
transfer can succeed for government agencies.
    NFIP. The best example of an ongoing federal risk transfer program 
is the Federal Emergency Management Agency's (FEMA's) NFIP Reinsurance 
Program. The NFIP Reinsurance Program enables the NFIP to utilize the 
private market to help manage the financial burden of the NFIP's 
catastrophic flood risk by providing financial backing for the 
government's flood risk, protecting taxpayers, and helping the program 
to be more resilient and pay claims. In 2016, FEMA, launched its NFIP 
Reinsurance Program via a pilot and, in 2017, transferred $1.042 
billion of the NFIP's financial risk to 25 reinsurers, offsetting some 
of NFIP's risk to the private sector in lieu of U.S. taxpayers. In the 
program's first year (2017), FEMA collected from the private 
reinsurance sector the full $1.042 billion to help pay the cost of NFIP 
losses and claims resulting from Hurricane Harvey. This 2017 coverage, 
which also improved NFIP's financial viability and protected taxpayers, 
cost $150 million, and the program successfully renewed the subsequent 
year. This example is a true testament of successful private public 
partnerships. Following the 2017 placement, the program was renewed and 
currently has reinsurance coverage through 2025. For FEMA's traditional 
reinsurance placements from 2017 through February 2022 and capital 
market reinsurance placements from 2018 through February 2022, FEMA has 
paid a total of $1.75 billion in premium to reinsurers and the capital 
markets, received $1.042 billion from reinsurers as previously 
mentioned, and has up to $2.664 billion available to collect after a 
qualifying 2022 loss event.\35\ The initial 2017 purchase marked key 
first steps towards helping the NFIP achieve long term resilience and 
financial stability and was crucial in enabling the reinsurance program 
to be a long-term project. (Please see below for more detailed comments 
on the NFIP).
---------------------------------------------------------------------------
    \35\ https://www.fema.gov/press-release/20220223/fema-expands-its-
reinsurance-program-transfers-450-million-flood-risk; https://
www.fema.gov/flood-insurance/work-with-nfip/reinsurance; https://
www.fema.gov/sites/default/files/documents/fema_fy-2021-q4-
watermark.pdf;
    https://www.fema.gov/sites/default/files/2020-05/
FIMA_Watermark_FY19Q4.pdf;
    https://www.fema.gov/sites/default/files/2020-05/fima-watermark-
2018-q4.pdf
---------------------------------------------------------------------------
    EXIM. The Export-Import Bank of the U.S. (EXIM) also executed a 
reinsurance pilot program. In 2016, EXIM solicited risk management 
analytical services regarding risk sharing structures to assess 
transferring some of the risks in EXIM's portfolio to the private 
market. In March 2018, EXIM announced its reinsurance pilot program, 
which provided for $1 billion in loss coverage for a significant 
portion of EXIM's existing portfolio of large commercial aircraft 
financing transactions. EXIM stated that it was the largest public-
private risk-sharing arrangement for a U.S. government credit agency 
and minimized EXIM and U.S. taxpayers' liability for potential future 
losses without requiring additional funding. This purchase of 
reinsurance gives EXIM protection from future losses and financial 
flexibility for the future.\36\ In 2021, EXIM announced an expansion of 
its risk-sharing program.\37\
---------------------------------------------------------------------------
    \36\ https://www.exim.gov/news/exim-bank-announces-landmark-risk-
sharing-program-private-sector-reinsurers
    \37\ https://www.exim.gov/news/exim-increases-taxpayer-protections-
announcement-new-broker-partnership-aon-reinsure-portfolio
---------------------------------------------------------------------------
    FHFA. The Federal Housing Finance Agency (FHFA) also has a credit 
risk transfer program for the Government Sponsored Enterprises (GSEs), 
Fannie Mae and Freddie Mac, in support of the U.S. housing market. FHFA 
launched its credit risk transfer initiative in 2012 (when the GSEs 
were in their fourth year of conservatorship) to enlist the private 
sector to reduce taxpayer exposure to the GSEs' mortgage risk. In 2013, 
the GSEs initiated their pilot $77 million credit risk transfer 
transaction, and it has grown since then. Over 50 (re)insurers have 
participated in FHFA's credit risk transfer programs and assumed U.S. 
mortgage risk. From the program's 2013 inception through the fourth 
quarter of 2021, the GSEs have transferred roughly $157.1 billion of 
credit risk on unpaid balances of more than $5.15 trillion of single-
family mortgages through the capital markets, reinsurance, and front-
end reinsurance transactions.\38\ The GSEs purchased insurance 
primarily from diversified reinsurers. These partially collateralized 
transactions spread across many different reinsurers reduce risk in a 
variety of ways.
---------------------------------------------------------------------------
    \38\ Aon plc; https://clarity.freddiemac.com/; https://
capitalmarkets.fanniemae.com/tools-applications/data-dynamics
---------------------------------------------------------------------------
National Flood Insurance Program
    The RAA greatly appreciates the leadership of Members of Congress 
for starting a formal conversation on reauthorization of the NFIP. The 
RAA has urged Congress to reauthorize NFIP and to enact flood insurance 
and mitigation-related reforms. The RAA supports a long-term 
reauthorization of the NFIP and reforms that:
      Continue to strengthen NFIP's financial framework and 
resiliency so that it can pay claims, particularly after catastrophic 
events;
      Remove impediments to consumer choice and confirm 
consumer protections; and
      Modernize the statute to give FEMA additional tools to 
encourage additional private market participation, including capital, 
in NFIP to benefit consumers and taxpayers.

    The RAA supports the SmarterSafer and BuildStrong coalitions' 
reform proposals. The RAA also supports the ``State Flood Mitigation 
Revolving Fund Act'' (S.2192/H.R.1610--116th) as described in the 
letter in Appendix B of this testimony.\39\
---------------------------------------------------------------------------
    \39\ https://www.pewtrusts.org/-/media/assets/2019/03/state-flood-
mitigation-revolving-fund-supporters-draft-3-11-2019.pdf
---------------------------------------------------------------------------
    Confirm Consumer Protections. Flood insurance uncertainty for 
consumers, as it relates to continuous coverage and potential rate 
increases by the NFIP, is an impediment to consumers buying private 
flood insurance and limits consumers' choices. Insurance agents and 
brokers have stated that `` . . . the risk of a substantial NFIP rate 
increase should the consumer later wish to return to the NFIP often 
makes insurance agents and brokers hesitant to recommend private flood 
insurance policies.'' \40\ It is important that Congress and FEMA 
provide consumers with clarity about continuous coverage compliance so 
that current and future NFIP policyholders are confident that they have 
complied with the law's continuous coverage requirements by having an 
NFIP or private flood insurance policy. For example, if a consumer 
leaves the NFIP to secure a private flood policy with better coverage 
and a better price and later re-assumes an NFIP policy, so long as the 
consumer had continuous coverage, that NFIP policy should be at the 
same rate and terms as if the consumer had continuously maintained an 
NFIP policy.
---------------------------------------------------------------------------
    \40\ https://financialservices.house.gov/uploadedfiles/hhrg-116-
ba00-wstate-heidrickc-20190313.pdf
---------------------------------------------------------------------------
    The RAA supports H.R. 4699 introduced by Representatives Kathy 
Castor (D-FL) and Blaine Luetkemeyer (R-MO) to amend the National Flood 
Insurance Act of 1968 (NFIA) to ``consider any period during which a 
property was continuously covered by private flood insurance to be a 
period of continuous coverage, including for the purposes of NFIP 
subsidies.'' \41\ In two previous Congresses, similar legislation had 
broad bipartisan support. In 2016, by a vote of 419-0, the House passed 
a similar provision as part of H.R. 2901 and, in 2017, by a vote of 58-
0, the House Financial Services Committee passed a similar provision as 
part of H.R. 1422.
---------------------------------------------------------------------------
    \41\ https://www.congress.gov/bill/117th-congress/house-bill/4699/
text?q=%7B%22search
%22%3A%5B%22%22%5D%7D&r=7&s=1
---------------------------------------------------------------------------
    Support NFIP Reinsurance Program. The RAA supports FEMA's NFIP 
Reinsurance Program and requests that it be preserved in NFIP 
reauthorization and reform legislation.\42\ The RAA has long advocated 
for the NFIP to utilize the private market to help manage the financial 
burden of the NFIP's catastrophic flood risk by providing financial 
backing for the government's flood risk, protecting taxpayers, and 
helping the program to be more resilient and pay claims. In 2022, for 
the sixth consecutive year, FEMA has successfully administered its NFIP 
Reinsurance Program that transfers risk from the NFIP to the capital 
markets, specifically through reinsurance placements and catastrophe 
bond issuances.
---------------------------------------------------------------------------
    \42\ https://www.fema.gov/flood-insurance/work-with-nfip/
reinsurance
---------------------------------------------------------------------------
    Modernize 1968 NFIA Part A Authority. When enacted in 1968, over 50 
years ago, the National Flood Insurance Act (NFIA) incorporated two 
approaches to providing consumers with flood insurance, Part A and Part 
B. The NFIP operates under Part B with the federal government assuming 
the full underwriting risk subject to the risk transfer program 
mentioned above. Congress should modernize Part A of the NFIA and 
clarify that FEMA can use its authorities simultaneously with the Part 
B program. Re-purposing and modernizing the statutory language in Part 
A would give FEMA additional tools to partner with private insurers, 
facilitate the participation of private insurers in NFIP on a risk-
sharing basis, further improve NFIP's viability, increase the NFIP's 
resources to pay claims, and increase flood insurance opportunities for 
consumers. Part A reforms also can lead to a stronger public-private 
partnership, give private insurers experience in underwriting flood 
risk, and help close the flood insurance coverage gap.
    The Part A statutory language currently authorizes the FEMA 
Administrator to facilitate and assist the creation of a pool of 
insurers on a risk sharing basis with the federal government to provide 
flood insurance through their network of agents and policyholder 
relationships. Under the statute, the Administrator defines the 
qualifications of insurers for the pool and risk capital to be 
provided. The Administrator is authorized to enter into a contractual 
relationship with the pool defining the insured risk to be retained and 
the government's risk through its reinsurance of the pool. Pursuant to 
the statute, the financial arrangement recognizes that the NFIP 
provides subsidies to certain policyholders.
    The RAA specifically recommends that NFIP reauthorization 
legislation include the amendment offered to the ``National Flood 
Insurance Program Reauthorization Act of 2019'' and withdrawn by 
Representative Blaine Luetkemeyer (R-MO) during the House Financial 
Services Committee's June 11-12, 2019, mark up.\43\ The amendment 
language would: (1) Require FEMA to solicit ideas for risk-sharing 
demonstration programs; (2) Provide FEMA with authority, but not 
require it, to conduct risk-sharing demonstration programs; and (3) 
Make technical amendments to the NFIA Part A authority, which FEMA can 
use for risk-sharing demonstration programs.
---------------------------------------------------------------------------
    \43\ https://financialservices.house.gov/calendar/
eventsingle.aspx?EventID=407747;
    https://financialservices.house.gov/calendar/
eventsingle.aspx?EventID=403829
---------------------------------------------------------------------------
    The above-mentioned reforms can further facilitate the development 
of a private flood insurance market and improve the viability of NFIP. 
The reinsurance market is interested and has the capacity to underwrite 
flood insurance risk, including extreme flood risk, in the public NFIP 
program, private market, and any future public-private flood insurance 
partnerships. Actions taken in recent years by some states, such as 
Florida, have demonstrated the interest and benefits of private 
insurers assuming a broad cross-section of risk, and the same would 
result from the above flood insurance reforms. Reinsurers stand ready 
to partner with both the private- and public-sectors as the flood 
market transitions.
                               Conclusion
    The RAA looks forward to continuing to work with Chairman DeFazio, 
Ranking Member Graves, Subcommittee Chair Titus, Subcommittee Ranking 
Member Webster, and other members of the Committee on legislation to 
improve America's infrastructure, housing, and community resilience in 
the face of climate and natural disaster risks by prioritizing and 
directing public and private sector resources to communities that are 
the most in need and most at risk from natural disaster(s), closing the 
insurance protection gap, and enacting a long-term reauthorization of 
the NFIP and flood insurance reforms that facilitate the development of 
a private flood insurance market. Thank you for your consideration of 
our views and recommendations in this statement for the record. The RAA 
and its members welcome the opportunity to meet with you about our 
views and recommendations, work with you to develop CDRZ legislation, 
or answer any questions you may have.

                               __________
                                                         Appendix A
                       RAA Climate Change Policy
    [RAA Climate Change Policy is retained in committee files and is 
available online at https://www.reinsurance.org/Advocacy/
RAA_Climate_Change_Policy/]

                                                         Appendix B
    National Support for the State Flood Mitigation Revolving Fund:
                          as of march 8, 2019
    [The document is retained in committee files and is available 
online at https://www.pewtrusts.org/-/media/assets/2019/03/state-flood-
mitigation-revolving-fund-supporters-draft-3-11-2019.pdf]

                                 
   Statement of the Union of Concerned Scientists, Submitted for the 
                       Record by Hon. Dina Titus
    On behalf of the Union of Concerned Scientists' (UCS) more than 
500,000 members and supporters, we are pleased to provide our 
reflections on critical issues that FEMA ought to prioritize for 2022. 
We thank Chairwoman Dina Titus and Ranking Member Daniel Webster and 
other members of the Subcommittee on Economic Development, Public 
Buildings and Emergency Management for allowing guest testimony on this 
important topic.
    Recently, UCS provided extensive comments to FEMA on a variety of 
topics including minimum standards for the National Flood Insurance 
Program (NFIP), climate and equity, the technical mapping advisory 
committee (TMAC), and the BRIC and PA programs.\1\
---------------------------------------------------------------------------
    \1\ UCS comments on FEMA's RFI on the National Flood Insurance 
Program's Floodplain Management Standards for Land Management and Use, 
and an Assessment of the Program's Impact on Threatened and Endangered 
Species and Their Habitats. January 27, 2022--Docket ID: FEMA-2021-
2024. www.regulations.gov/comment/FEMA-2021-0024-0357; RFI on FEMA 
Programs, Regulations, and Policies, July 22, 2021. Docket ID FEMA-
2021-0011-0254. www.regulations.gov/comment/FEMA-2021-0011-0254; FEMA's 
Technical Mapping Advisory Committee (TMAC) https://blog.ucsusa.org/
shana-udvardy/femas-can-now-actually-say-climate-change/; BRIC 
www.regulations.gov/comment/FEMA-2019-0018-0084 and PA 
www.regulations.gov/comment/FEMA-2020-0038-0089 comments.
---------------------------------------------------------------------------
    Those extensive comments helped to inform the nine key issues that 
we believe FEMA should prioritize for 2022. These priority areas 
include: 1) climate change; 2) equity and Justice40; 3) NFIP minimum 
standards; 4) flood risk mapping; 5) flood risk disclosure; 6) 
implementation of the Federal Flood Risk Management Standard (FFRMS); 
7) FEMA grant programs; 8) NFIP affordability program; and 9) federal 
oversight and enforcement.
1) Climate change: Ensure the latest climate change science informs all 
        aspects of FEMA's portfolio especially as it relates to equity, 
        investments in climate resilience and disaster aid, flood risk 
        disclosure, mapping and NFIP minimum standards.
    The second goal listed in FEMA's recently released strategic plan 
is to ``Lead Whole of Community in Climate Resilience'' and the tasks 
include increasing climate literacy among emergency managers, building 
a climate resilient nation and empowering risk-informed decision 
making.\2\ It will take a considerable amount of investment and effort 
to advance each of these goals. Congress can help to ensure FEMA has 
the resources and legal guidance to advance these efforts as the cost 
and human toll of disasters continues to grow in response to climate-
driven increases in the frequency and/or severity of extreme weather 
events and slow-onset disasters like sea level rise.
---------------------------------------------------------------------------
    \2\ 2022-2026 FEMA Strategic Plan: Building the FEMA our nation 
needs and deserves. www.fema.gov/about/strategic-plan
---------------------------------------------------------------------------
    In 2021, there were twenty severe weather and climate change-
related disasters costing $1 billion or more each.\3\ The hurricanes, 
tropical storms and other events caused flooding across the country, 
including: $1.2 billion in damages from an atmospheric river in 
California, during which 15 inches of rainfall fell in some places; up 
to one foot of rainfall that swamped parts of Louisiana at a cost of 
$1.4 billion; two tropical storms, Elsa and Fred, which caused a total 
of $2.5 billion in damages; and two hurricanes, Ida and Nicholas, which 
caused a total of $76 billion in damages.\4\
---------------------------------------------------------------------------
    \3\ See www.ncdc.noaa.gov/billions/ also see 2021 summary 
www.ncdc.noaa.gov/billions/events/US/2021
    \4\ NOAA National Centers for Environmental Information (NCEI) U.S. 
Billion-Dollar Weather and Climate Disasters (2022). www.ncdc.noaa.gov/
billions/.
---------------------------------------------------------------------------
    The Western wildfires also were quite severe in 2021 in which more 
than 58,000 wildfires burned more than 7 million acres that totaled 
$10.6 billion in damages.\5\ Meanwhile, ongoing, smaller disasters or 
slow-moving changes--such as sea level rise--are also worsening 
climate-related risks and are not in the purview of the billion-dollar-
plus report.\6\
---------------------------------------------------------------------------
    \5\ National Interagency Coordination Center (NICC) Wildland Fire 
Summary and Statistics Annual Report 2021. 
www.predictiveservices.nifc.gov/intelligence/2021_statssumm/intro_
summary21.pdf also see www.ncdc.noaa.gov/billions/events/US/2021
    \6\ Note that NOAA NCEI combines the Western drought and heatwave 
and finds that together the cost totaled $8.9 billion in damages and 
caused 229 deaths. NOAA NCEI notes that the deaths are associated with 
the heatwave and that not all droughts are associated with heatwaves. 
www.ncdc.noaa.gov/billions/events/US/2021
---------------------------------------------------------------------------
    Over the last few years, multiple studies have provided new data 
that show how the climate change-driven trend of more frequent and 
extreme precipitation events can lead to more flooding of communities 
in many regions of the U.S. For example, a recent Stanford University 
study found that increases in extreme rainfall in the U.S. caused $73 
billion in flood damages over the last 30 years, a full third of total 
flood damage costs during that timeframe and consistent with global 
warming predictions.15 Anthropogenic sea level rise was also found to 
have worsened flooding and added roughly $8 billion in damages to the 
costs of Hurricane Sandy and extended the flood area affected to 
include 71,000 additional people.\7\
---------------------------------------------------------------------------
    \7\ Economic damages from Hurricane Sandy attributable to sea level 
rise caused by anthropogenic climate change. www.nature.com/articles/
s41467-021-22838-1
---------------------------------------------------------------------------
    Most of the eastern and northern parts of the U.S. have seen 
increases in extreme precipitation over the last century and this trend 
is projected to continue with significant increases in the frequency 
and intensity of precipitation events in the winter and spring. These 
trends will become even more challenging in urban areas that are 
already vulnerable to flooding during heavy rainfall events given the 
lack of capacity of sewer and stormwater systems that were designed 
decades ago.\8\
---------------------------------------------------------------------------
    \8\ Maxwell, K., S. Julius, A. Grambsch, A. Kosmal, L. Larson, and 
N. Sonti, 2018: Built Environment, Urban Systems, and Cities. In 
Impacts, Risks, and Adaptation in the United States: Fourth National 
Climate Assessment, Volume II [Reidmiller, D.R., C.W. Avery, D.R. 
Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart 
(eds.)]. U.S. Global Change Research Program, Washington, DC, USA, pp. 
438-478. doi: 10.7930/NCA4.2018.CH11.
---------------------------------------------------------------------------
    NOAA's data on new climate normals also shows that relative to the 
20th century average, much of the U.S. has experienced an increase in 
total annual precipitation in recent decades. According to NOAA, `At 
least some of that wetness relative to the 20th-century average is 
linked to the overall climate warming and ``wetting'' of the atmosphere 
that's occurred as rising temperatures cause more water to evaporate 
from the ocean and land surface.\9\
---------------------------------------------------------------------------
    \9\ NOAA. 2021. The new U.S. Climate Normals are here. What do they 
tell us about climate change? www.noaa.gov/news/new-us-climate-normals-
are-here-what-do-they-tell-us-about-climate-change
---------------------------------------------------------------------------
    In addition, with rising sea levels, high-tide floods are becoming 
more frequent and reaching farther inland. Hundreds of U.S. coastal 
communities face growing risks of chronic, disruptive flooding that 
directly affects people's homes and lives, critical infrastructure, and 
the economy. More than 300,000 of today's coastal homes, with a 
collective market value of about $117.5 billion in 2018, are at risk of 
chronic inundation in 2045--a timeframe that falls within the lifespan 
of a 30-year mortgage issued today.\10\ Approximately 14,000 coastal 
commercial properties, assessed at a value of roughly $18.5 billion, 
are also at risk during that timeframe. The properties at risk by 2045 
house 550,000 people and contribute nearly $1.5 billion toward property 
tax base. While all coastal states face risks, those with the most 
homes at risk by the end of the century include Florida, with about 1 
million homes (more than 10% of the state's current residential 
properties); New Jersey, with 250,000 homes; and New York with 143,000 
homes.
---------------------------------------------------------------------------
    \10\ Union of Concerned Scientists. 2018. Underwater: Rising Seas, 
Chronic Floods, and the Implications for US Coastal Real Estate. 
www.ucsusa.org/resources/underwater
---------------------------------------------------------------------------
    According to the First Street Foundation there are nearly 4.3 
million homes across the U.S., inland and coastal, with substantial 
flood risk today that would result in financial loss. The analysis 
indicates that if these homes were to be insured against flood risk 
through the National Flood Insurance Program (NFIP), the rates would 
need to increase 4.5 times to cover the risk today, and that the cost 
of expected annual loss of properties in the next 30 years will grow by 
as much as 61% due to climate change.\11\
---------------------------------------------------------------------------
    \11\ https://firststreet.org/press/aal_launch/
---------------------------------------------------------------------------
    FEMA must work aggressively to incorporate the best available 
climate change science agency-wide. A bill was introduced last year 
that would establish a climate change subcommittee under the National 
Advisory Council to help provide support to FEMA.\12\ FEMA should 
establish a climate change council under its own authority. In 
coordination with the Technical Mapping Advisory Committee (TMAC) and 
FEMA's National Advisory Committee,\13\ FEMA should direct the Council 
to report on FEMA's existing gaps when it comes to climate change and 
opportunities to incorporate climate change throughout its initiatives. 
In addition to the gap analysis, FEMA ought to direct the Climate 
Change Council to: 1) develop a climate adaptation handbook; 2) 
establish a subcommittee on managed retreat and relocation; 3) draft 
recommendations on how FEMA can address compound and cascading risks; 
4) draft recommendations on how to overcome maladaptation and barriers 
to adaptation; \14\ and 5) establish a subcommittee to address how FEMA 
can better help local government entities plan for climate change in a 
strategic, resource efficient, and comprehensive fashion.\15\
---------------------------------------------------------------------------
    \12\ H.R.744 and S.280 FEMA Climate Change Preparedness Act. 
www.congress.gov/bill/117th-congress/house-bill/744/text?r=8&s=1
    \13\ www.fema.gov/emergency-managers/risk-management/risk-
capability-assessment
    \14\ The recent United Nations IPCC report noted a few barriers for 
adaptation in the US including reword; ``misinformation and 
politicization of climate change science has created polarization in 
public and policy domains in North America Resultant public 
misperception of climate risks and polarized public support for climate 
actions is delaying urgent adaptation planning and implementation (high 
confidence). (ES-Ch14)'' https://report.ipcc.ch/ar6wg2/pdf/
IPCC_AR6_WGII_FactSheet_NorthAmerica.pdf
    \15\ The recent United Nations IPCC report noted ``Fragmented 
responsibility for planning, disaster management, and mitigation and 
adaptation actions hinders the development of integrated and equitable 
policies (high confidence) and their implementation. While community-
level planning tailors adaptation to the local context, misalignment of 
policies within and between levels of government can prevent 
implementation. Coordination, planning, and national support are needed 
as well as sufficient financial resources to implement climate-
resilient policies and infrastructure (high confidence). (14.7.2)'' 
https://report.ipcc.ch/ar6wg2/pdf/IPCC_AR6_WGII_
FactSheet_NorthAmerica.pdf
---------------------------------------------------------------------------
    A climate change council under FEMA is critical given that 
``Climate change impacts and risks are becoming increasingly complex 
and more difficult to manage.'' The complexity encompasses multiple 
geographical and governmental levels but at the forefront are the 
issues around compound and cascading climate impacts. The latest IPCC 
report gives particular attention to how ``multiple climate hazards 
will occur simultaneously, and multiple climatic and non-climatic risks 
will interact, resulting in compounding overall risk and risks 
cascading across sectors and regions. Some responses to climate change 
result in new impacts and risks.'' \16\
---------------------------------------------------------------------------
    \16\ See SPM.B.5 in IPCC, 2022: Summary for Policymakers [H.-O. 
Portner, D.C. Roberts, E.S. Poloczanska, K. Mintenbeck, M. Tignor, A. 
Alegria, M. Craig, S. Langsdorf, S. Loschke, V. Moller, A. Okem 
(eds.)]. In: Climate Change 2022: Impacts, Adaptation, and 
Vulnerability. Contribution of Working Group II to the Sixth Assessment 
Report of the Intergovernmental Panel on Climate Change [H.-O. Portner, 
D.C. Roberts, M. Tignor, E.S. Poloczanska, K. Mintenbeck, A. Alegria, 
M. Craig, S. Langsdorf, S. Loschke, V. Moller, A. Okem, B. Rama 
(eds.)]. Cambridge University Press. In Press. https://report.ipcc.ch/
ar6wg2/pdf/IPCC_AR6_WGII_Summary
ForPolicymakers.pdf
---------------------------------------------------------------------------
2) Equity and Justice40: Advance equity and Justice40 goals across all 
        aspects of FEMA's portfolio.
    We were pleased to see that FEMA's first goal in its 2022-2026 
strategic plan is to ``Instill Equity as a Foundation of Emergency 
Management.'' We know that climate change disproportionately affects 
disadvantaged and marginalized communities, in part because of the 
racism and discrimination long embedded in our economic, political, and 
social systems.\17\ Studies find that White Americans and those with 
more wealth often receive more federal dollars after a disaster than do 
minorities and those with less wealth \18\ and that disaster relief in 
the U.S. worsens the growing gap between White and Black wealth.\19\ 
President Biden's Executive Order (EO) 14008 on ``Tackling the Climate 
Crisis at Home and Abroad'' notified federal agencies to better address 
the needs of low-income, communities of color, and historically 
disadvantaged communities to ensure an equitable economic future.\20\ 
The EO also tasked the Council on Environmental Quality (CEQ) with 
developing the Climate and Economic Justice Screening Tool (CEJST), 
recently released in beta form. A well-designed tool supported by high-
quality data and informed by the perspectives of EJ communities will be 
an excellent resource for FEMA to help ensure that 40 percent of 
overall benefits of Federal investments, including FEMA investments, 
are targeted towards disadvantaged communities.\21\ FEMA will need to 
work creatively and swiftly to utilize the CEJST and its own Risk Index 
to implement Justice40 and respond proactively to climate and other 
hazards.
---------------------------------------------------------------------------
    \17\ See Miyuki Hino, M. and E. Nance. 2021. Five ways to ensure 
flood-risk: research helps the most vulnerable, https://
media.nature.com/original/magazine-assets/d41586-021-01750-0/d41586-
021-01750-0.pdf
    \18\ How Federal Disaster Money Favors the Rich. www.npr.org/2019/
03/05/688786177/how-federal-disaster-money-favors-the-rich
    \19\ As Disaster Costs Rise, So Does Inequality. Junia Howell, 
James R. Elliott. December 4, 2018, https://doi.org/10.1177/
2378023118816795
    \20\ Executive Order 14008, Tackling the Climate Crisis at Home and 
Abroad, www.federalregister.gov/documents/2021/02/01/2021-02177/
tackling-the-climate-crisis-at-home-and-abroad
    \21\ See The Equitable and Just National Climate Platform's 
February 18, 2022 press release, https://ajustclimate.org/
pressrelease.html?pId=1025
---------------------------------------------------------------------------
    FEMA's Flood Mitigation Assistance Program is one of the pilot 
programs selected to undertake an initial implementation of the 
Justice40 Interim Implementation Guidance to maximize the benefits that 
are directed to disadvantaged communities.\22\ The results of this 
pilot program should be made publicly available, and the lessons 
learned should be applied agency wide.
---------------------------------------------------------------------------
    \22\ www.whitehouse.gov/wp-content/uploads/2021/07/M-21-28.pdf.
---------------------------------------------------------------------------
    FEMA must integrate its equity goals with other objectives such as 
updating the minimum NFIP standards to ensure that more protective 
floodplain management standards do not reinforce or exacerbate existing 
challenges with safe and affordable housing, displacement and 
gentrification. Raising minimum floodplain standards can leave low-
income homeowners with few options if they are unable to afford the 
investments needed to mitigate flood risks. Further, our nation's 
history of mortgage redlining and other forms of structural racism has 
left communities of color at higher risk of being exposed to flood 
risks and/or with less public investment in measures to protect against 
flooding.\23\ FEMA must direct resources to these disadvantaged and 
marginalized homeowners and communities based on need and in line with 
Justice40 commitments, rather than relying on metrics that prioritize 
the market value of properties, which tend to reinforce existing 
inequities and channel investments to wealthier communities. It should 
also collect and track demographic information over time to monitor 
trends and ensure that Justice40 goals are being met. FEMA should work 
together with the Department of Housing and Urban Development (HUD) to 
evaluate the impact of floodplain management measures on public housing 
as well.
---------------------------------------------------------------------------
    \23\ Redfin. 2021. A Racist Past, a Flooded Future: www.redfin.com/
news/redlining-flood-risk/
---------------------------------------------------------------------------
    Finally, FEMA must also work to implement the recommendations 
included in FEMA's National Advisory Committee (NAC) report on 
equity.\24\ The NAC makes a critical point that FEMA provides federal 
disaster assistance based on the amount of damages and not on need that 
is not on those communities who have the least amount of access to 
information, technology and resources making grant programs often 
inaccessible to these communities. The NAC recommends that FEMA create 
an equity standard by which FEMA could better assess whether the grants 
increase or decrease equity over time. Another salient recommendation 
by the NAC is for FEMA to establish a Native American Working Group 
staffed with experts from Tribal and Indigenous communities that could 
better inform FEMA on the emergency management capacity in tribal 
nations. We respectfully ask that Congress follow up on FEMA's progress 
on implementing the NAC recommendations and encourage FEMA to release a 
NAC equity report annually.
---------------------------------------------------------------------------
    \24\ FEMA NAC report www.fema.gov/sites/default/files/documents/
fema_nac-report_11-2020.pdf
---------------------------------------------------------------------------
3) NFIP minimum standards: \25\ FEMA must advance the best, science-
        based minimum standards to reduce flood risk while also 
        ensuring that these standards are informed by communities that 
        are hit first and worst.
---------------------------------------------------------------------------
    \25\ See UCS comments on FEMA's RFI on the National Flood Insurance 
Program's Floodplain Management Standards for Land Management and Use, 
and an Assessment of the Program's Impact on Threatened and Endangered 
Species and Their Habitats. January 27, 2022--Docket ID: FEMA-2021-
2024. www.regulations.gov/comment/FEMA-2021-0024-0357
---------------------------------------------------------------------------
    With the establishment of NFIP in 1968, the intent of Congress was 
to ensure that minimum floodplain standards incentivize local and state 
governments to reduce flood risk by making science-informed decisions 
about how and where they build. There are 22,000 communities in NFIP 
with a total of 5 million policies that bring in $4 billion dollars in 
annual revenue.\26\ While roughly 1,500 communities have adopted higher 
standards through the Community Rating System (CRS),\27\ assessments of 
NFIP have found that, nationwide, there is a 70% to 85% rate of 
community compliance with the standards and 58% to 70% of buildings are 
built in full compliance with the standards.\28\ While these 
percentages are less than reassuring, the bigger picture is that the 
NFIP minimum standards are inadequate to ``stop and reverse the long-
term trend toward increasing flood damage'' for several reasons that 
the Association of State Floodplain Managers' (ASFPM) No Adverse Impact 
(NAI) report summarizes.\29\
---------------------------------------------------------------------------
    \26\ See CRS. 2021. Introduction to the National Flood Insurance 
Program (NFIP). https://sgp.fas.org/crs/homesec/R44593.pdf
    \27\ See FEMA. N.D. Community Rating System. www.fema.gov/
floodplain-management/community-rating-system
    \28\ Ibid at 3. https://sgp.fas.org/crs/homesec/R44593.pdf
    \29\ ASFPM. 2017. NAI How-to Guide for Floodplain Mapping How-to 
Guide for No Adverse Impact Hazard Identification and Floodplain 
Mapping. https://s3-us-west-2.amazonaws.com/asfpm-library/FSC/NAI/
NAI_Hazard_ID_Mapping_2017.pdf
---------------------------------------------------------------------------
    These poor compliance rates are for minimum floodplain management 
standards that haven't been updated for over four decades.\30\ The 
delay in updating these minimum standards that only have an average 
grade for compliance has only exacerbated risky land use in our 
nation's floodplains.
---------------------------------------------------------------------------
    \30\ See Federal Register, Vol. 86, No. 194, Tuesday, October 12, 
2021. www.govinfo.gov/content/pkg/FR-2021-10-12/pdf/2021-22152.pdf
---------------------------------------------------------------------------
    Meanwhile, human-caused climate change and long-standing 
socioeconomic inequities are worsening flood risks for many 
communities. We only need look at the National Oceanic and Atmospheric 
Administration's (NOAA) annual billion-dollar disasters report to know 
that the nation is failing at reducing flood risk.\31\ These statistics 
are not happening in a vacuum: Since FEMA first drafted the minimum 
standards, the climate has changed tremendously due to anthropogenic 
global warming caused by the burning of fossil fuels. Part of the 
challenge is that climate change is fueling more extreme events \32\ 
that continue to establish new climate ``normals''.\33\ This fact only 
underscores the urgency and need for FEMA to swiftly advance the best, 
science-based minimum standards to reduce flood risk while also 
ensuring that such standards are informed by those communities that are 
hit first and worst.
---------------------------------------------------------------------------
    \31\ NOAA National Centers for Environmental Information (NCEI) 
U.S. Billion-Dollar Weather and Climate Disasters (2022). 
www.ncdc.noaa.gov/billions
    \32\ IPCC, 2018: Summary for Policymakers. In: Global Warming of 
1.5 +C. An IPCC Special Report on the impacts of global warming of 1.5 
+C above pre-industrial levels and related global greenhouse gas 
emission pathways, in the context of strengthening the global response 
to the threat of climate change, sustainable development, and efforts 
to eradicate poverty [Masson-Delmotte, V., P. Zhai, H.-O. Portner, D. 
Roberts, J. Skea, P.R. Shukla, A. Pirani, W. Moufouma-Okia, C. Pean, R. 
Pidcock, S. Connors, J.B.R. Matthews, Y. Chen, X. Zhou, M.I. Gomis, E. 
Lonnoy, T. Maycock, M. Tignor, and T. Waterfield (eds.)]. World 
Meteorological Organization, Geneva, Switzerland, 32 pp. www.ipcc.ch/
sr15/chapter/spm/.
    \33\ Dahl, K. 2021. New NOAA Data Shows Just How Abnormal Our 
Climate Has Become https://blog.ucsusa.org/kristy-dahl/new-noaa-data-
shows-just-how-abnormal-our-climate-has-become/ and NOAA: The new U.S. 
Climate Normals are here. What do they tell us about climate change? 
May 4, 2021. www.noaa.gov/news/new-us-climate-normals-are-here-what-do-
they-tell-us-about-climate-change
---------------------------------------------------------------------------
    In addition, given the outsized role that floodplains, waterways, 
and adjacent areas play in the maintenance of ecosystem services such 
as water filtration, flood protection, and maintenance of biodiversity, 
FEMA must work to provide regulatory and nonregulatory incentives to 
protect these areas. Moreover, many of those areas act as buffers from 
climate change impacts such as increasing temperatures and spatial 
deterioration, protecting essential habitat and ecosystem structure and 
function, and species themselves--including those that are not 
threatened or endangered, and should remain so. To ensure the 
continuity of ecosystem services, the protection of species and 
biodiversity, and the maintenance of existing wildlife habitat, FEMA 
must take action to prevent negative impacts on natural processes.
4) Flood Risk Mapping: FEMA must advance regulatory and nonregulatory 
        mapping that is informed by the latest climate science.
    The Government Accountability Office (GAO) found that, while FEMA 
has increased the development of its regulatory Flood Insurance Rate 
Maps (FIRMs) and other non-regulatory flood risk products through its 
Risk Mapping, Assessment, and Planning (Risk MAP) program, it has many 
hurdles to ensure that these products ``reflect current and future 
flood hazards.'' \34\ GAO notes that the flood risk products fail to 
include heavy rainfall and the best available climate science, and that 
FEMA does not have an updated plan to meet the new timeframes, goals, 
and performance measures. It's been ten years since the Biggert-Waters 
Flood Insurance Reform Act of 2012 that directed FEMA, with the 
assistance of the Technical Mapping Advisory Committee (TMAC), to use 
the best available climate science to update the FIRMs, including an 
assessment of the impact of future changes in sea levels, precipitation 
and intensity of hurricanes, and of future development on flood 
risk.\35\
---------------------------------------------------------------------------
    \34\ GAO. 2021. FEMA Flood Maps: Better Planning and Analysis 
Needed to Address Current and Future Flood Hazards. www.gao.gov/assets/
gao-22-104079.pdf
    \35\ Ibid.
---------------------------------------------------------------------------
    FEMA must provide regulatory and nonregulatory/advisory map 
products that are based on the latest climate change science and future 
conditions, so that communities, homeowners, and potential home buyers 
understand their actual current and future flood risk and so that local 
governments have the support from the federal government in 
implementing higher minimum NFIP standards. While we recognize that 
mapping future conditions for riverine areas will be more challenging 
than for coastal communities, FEMA has abundant resources to advance 
this process including its own Technical Mapping Advisory Committee 
(TMAC), other federal agency data and staff through the Flood 
Resilience Interagency Working Group (IWG), and other methodologies and 
models in the public and private sectors.\36\
---------------------------------------------------------------------------
    \36\ UVM. 2022. Vermont Flood Costs Could Exceed $5.2 Billion. 
www.uvm.edu/news/gund/vermont-flood-costs-could-exceed-52-billion also 
see https://firststreet.org/flood-factor/
---------------------------------------------------------------------------
    In 2019 FEMA established the Future of Flood Risk Data (FFRD) 
program to help provide more flood risk data than what is in the FIRMs 
and to transition towards a mapping product that shows graduated risk 
instead of their dated binary approach.\37\ FEMA must use this new FFRD 
program to swiftly advance GAO's recommendations as well as provide 
advisory layers that reflect future flooding based on climate change 
projections for both coastal and riverine areas as feasible.
---------------------------------------------------------------------------
    \37\ GAO. 2021. FEMA Flood Maps: Better Planning and Analysis 
Needed to Address Current and Future Flood Hazards. www.gao.gov/assets/
gao-22-104079.pdf
---------------------------------------------------------------------------
    Regarding TMAC, FEMA and Congress must ensure that this technical 
expert group is incentivized to be bold in its recommendations when it 
comes to the committee's work on future conditions. As mentioned above, 
the nation is already reeling from back-to-back disasters and extreme 
weather events, many of which include flooding. TMAC must lean in on 
climate science and on the work by the U.S. Global Change Research 
Program's (USGCRP) National Climate Assessments (NCA). Specifically, 
TMAC must be encouraged to advance its work on future conditions of 
riverine flooding and on developing and advancing equity as a key goal. 
TMAC can better ensure its work is more equitable by expanding its 
outreach to stakeholders by conducting webinars and other approaches.
    We respectfully ask that Congress follow up on FEMA's progress on 
their implementation of TMAC recommendations to ensure these important 
advances in mapping are happening in a timely fashion and appropriate 
ample funding to FEMA to rapidly advance its mapping efforts.
5) Flood risk disclosure: FEMA must improve the public's understanding 
        of flood risk by implementing regulatory and nonregulatory 
        flood risk disclosure measures so that potential buyers and 
        renters understand the risk they're buying into.
    Congress and FEMA must work in concert to improve flood risk 
disclosure. Ideally, a flood risk disclosure policy provision would be 
included in the next reauthorization of the NFIP. Bills such as H.R. 
5256, H.R. 5802 and previous NFIP reauthorization bills have flood risk 
disclosure policies that could be advanced.\38\
---------------------------------------------------------------------------
    \38\ See H.R. 5256 www.congress.gov/117/bills/hr5256/BILLS-
117hr5256ih.pdf at Section 1328. Disclosure of flood risk information 
prior to transfer of property. Also see H.R.5802 (and companion bill 
s.3128). www.congress.gov/117/bills/hr5802/bills-117hr5802ih.pdf
---------------------------------------------------------------------------
    However, FEMA could also advance flood risk disclosure as it works 
to update the decades old NFIP minimum standards. For example, FEMA 
could:
      establish flood risk disclosures for sellers and lessors 
as a condition of participation in the NFIP. These flood risk 
disclosures must include all past flooding events and damages 
(including claims and disaster assistance data) from these events and 
future projections of flooding due to climate change or planned 
development. For coastal flooding, UCS developed the ``Know Your Risk'' 
guide for potential homebuyers that speaks to the many different 
important questions one ought to ask before purchasing a home.\39\ The 
unfortunate reality is that the FIRMs are out of date and do not 
reflect actual risk, never mind the future risk due to climate change.
---------------------------------------------------------------------------
    \39\ UCS. 2018. Know Your Risk: A Home-Buyer's Guide to Asking 
Smart Questions about Tidal Flooding. www.ucsusa.org/sites/default/
files/attach/2018/06/know-your-risk-brochure-LDF.pdf
---------------------------------------------------------------------------
      establish flood risk disclosures for dams and levees. 
People may be unaware that they live downstream of a dam or levee and 
therefore do not understand the risk they face or the evacuation 
procedures if either structure should fail. Future home and business 
buyers looking to purchase a property below a dam or adjacent to a 
levee have the right to know the risk they are buying into. Dams \40\ 
and levees have several things in common, including that they are aging 
and are costly to fix, they are not adequately regulated, and climate 
change is pushing the limits of the design life cycle of both. The 
Biggert-Waters Flood Insurance Reform Act of 2012 required that FEMA 
coordinate with the Technical Mapping Advisory Committee (TMAC) to 
incorporate ``residual risk'' of areas that are protected by levees, 
dams, and other flood control structures, as well as the level of 
protection provided by those structures, on NFIP flood maps. In TMAC's 
2016 report, the authors provided an overview of the many challenges 
and issues needing attention on this front, including the lack of 
public access to dam failure inundation information.\41\ Not mapping 
dam or levee failure inundation areas can have major consequences such 
as more development downstream, thereby turning a once low hazard 
structure into a high hazard structure and putting even more people at 
risk. FEMA must ensure that all aspects of dam and levee safety data 
are publicly available, including inspections, emergency action plans, 
and perhaps most importantly, inundation maps.
---------------------------------------------------------------------------
    \40\ CRS. 2019. Dam Safety Overview and the Federal Role. https://
crsreports.congress.gov/product/pdf/R/R45981
    \41\ FEMA. 2016. Technical Mapping Advisory Council (TMAC) Annual 
Report. www.fema.gov/sites/default/files/documents/
fema_tmac_2016_annual_report.pdf
---------------------------------------------------------------------------
6) Federal Flood Risk Management Standard (FFRMS) implementation: FEMA 
        must implement the FFRMS throughout its programs.
    President Biden's Executive Order 14008 reinstated the Federal 
Flood Risk Management Standard, (FFRMS), which directs all agencies to 
ensure that any federal taxpayer-funded activities be designed and 
constructed to be protected from future-expected flood conditions. FEMA 
must implement the FFRMS so that projects are designed with a higher 
margin of safety against flooding. FEMA can look to the Flood 
Resilience Interagency Working Group (IWG) for support on this 
front.\42\
---------------------------------------------------------------------------
    \42\ White House. 2021. Readout of the First White House Flood 
Resilience Interagency Working Group Meeting on Implementation of the 
Federal Flood Risk Management Standard. www.whitehouse.gov/ceq/news-
updates/2021/08/27/readout-of-the-first-white-house-flood-resilience-
interagency-working-group-meeting-on-implementation-of-the-federal-
flood-risk-management-standard/.
---------------------------------------------------------------------------
7) FEMA grant programs:
    We thank the Transportation and Infrastructure (T&I) Committee for 
introducing the bipartisan Resilient Assistance for Mitigation for 
Environmentally Resilient Infrastructure and Construction by Americans 
Act, (Resilient AMERICA Act) which will strengthen FEMA's disaster 
mitigation and resilience programs. In particular, we are very 
appreciative of the committee's leadership to increase the Disaster 
Relief Fund (DRF) set aside from 6 percent to 15 percent.
    Regarding the Building Resilient Infrastructure and Communities 
(BRIC) program, we would like FEMA to incorporate additional criteria 
that would better emphasize smaller flood resilience projects, target 
resources to those communities that need it most, and increase 
resources for technical assistance and planning.
    Regarding wildfire assistance we look forward to FEMA efforts to 
develop and update its policies, and training to improve response and 
recovery from large-scale and severe wildfires in the future.\43\
---------------------------------------------------------------------------
    \43\ See GAO. 2022. FEMA Opportunities to Help Address Mission and 
Management Challenges www.gao.gov/products/gao-22-105786
---------------------------------------------------------------------------
    As mentioned earlier, FEMA can improve its grant programs by 
ensuring they are more equitable, that is, that resources are targeted 
to those communities who need it most. FEMA will need to work swiftly 
to adopt the Justic40 goal. FEMA could adopt a two-fold process by 
first using a screening tool to help identify communities and second by 
targeting technical assistance to these communities to help them submit 
eligible and successful BRIC applications for example. To help identify 
communities, FEMA can use its own Resilience Analysis and Planning Tool 
(RAPT) (which provides resilience indicators at three geographic 
scales, county, census tract, and tribal territory) in concert with the 
Climate and Economic Justice Screening Tool.\44\
---------------------------------------------------------------------------
    \44\ Climate and Economic Justice Screening Tool https://
screeningtool.geoplatform.gov/en/
---------------------------------------------------------------------------
    Given FEMA's staff shortages and other challenges related to 
endless disasters, we encourage Congress to provide FEMA with the 
resources it needs to address the multiple recommendations by GAO.\45\
---------------------------------------------------------------------------
    \45\ GAO. 2022. FEMA Opportunities to Help Address Mission and 
Management Challenges www.gao.gov/products/gao-22-105786
---------------------------------------------------------------------------
8) Flood insurance affordability: Congress must work in concert with 
        FEMA to establish a flood insurance affordability program.
    FEMA's new Risk Rating 2.0 (RR 2.0) flood insurance pricing system 
better reflects the actual flood risk of a specific property but will 
mean that roughly 77% of policyholders will see increases in their 
premiums as RR2.0 rolls out. People with low to moderate incomes living 
in the nation's floodplains are less likely to be able to afford flood 
insurance and those without flood insurance will have less resources to 
recover after a disaster. President Biden proposed investing $358 
million in fiscal year 2022 to help people with low incomes purchase 
flood insurance and to increase risk mitigation measures to reduce 
flood damages.\46\ FEMA and Congress must work to leverage options to 
reduce the cost burden to policy holders, especially those who are 
least able to afford the premiums. Among others, over the last few 
years, studies by FEMA,\47\ the Government Accountability Office,\48\ 
the National Academy of Sciences,\49\ and, most recently, the 
Congressional Research Service (CRS) \50\ have provided analysis on 
different options for creating means-tested affordability program under 
NFIP. Current and past bills also have policy provisions that could be 
advanced in the next reauthorization of NFIP.\51\
---------------------------------------------------------------------------
    \46\ See Frank, T. 2021. Biden Budget Includes Plan to Help Poor 
Buy Flood Insurance, www.scientificamerican.com/article/biden-budget-
includes-plan-to-help-poor-buy-flood-insurance/
    \47\ www.fema.gov/media-library-data/1524056945852-
e8db76c696cf3b7f6209e1adc4211af4/Affordability.pdf
    \48\ GAO. 2016. National Flood Insurance Program: Options for 
providing affordability Assistance www.gao.gov/assets/680/675132.pdf
    \49\ NAS Report 1: www.nap.edu/catalog/21709/affordability-of-
national-flood-insurance-program-premiums-report-1 and NAS Report 2: 
www.nap.edu/catalog/21848/affordability-of-national-flood-insurance-
program-premiums-report-2
    \50\ https://crsreports.congress.gov/product/pdf/R/R47000
    \51\ See section 103. Targeted means-tested assistance in HR 5802 
(and companion bill S.3128). www.congress.gov/117/bills/hr5802/BILLS-
117hr5802ih.pdf
---------------------------------------------------------------------------
    FEMA and Congress ought to move swiftly to advance the 
establishment of a flood insurance affordability program to reduce the 
cost burdens on those that are least able to afford flood insurance. 
Such a program ought to incentivize mitigation measures as well to 
further reduce the cost burden and increase resilience to the next 
flood. Reducing the cost burden of flood insurance would have many 
benefits to homeowners and community and federal governments, and would 
help to meet the Administration's intent of the Justice40 goal.
9) Federal oversight and enforcement: FEMA must improve its enforcement 
        of NFIP minimum standards.
    Over the years, analyses have shown that FEMA has been challenged 
with ensuring communities' compliance with the minimum NFIP standards. 
FEMA assesses a community's compliance through Community Assessment 
Visits or ``CAVs.'' GAO's comprehensive study of FEMA's enforcement of 
the minimum standards found that some high-risk communities were not 
visited between 2008 and 2019 and that many were only visited one 
time.\52\
---------------------------------------------------------------------------
    \52\ GAO. 2020. National Flood Insurance Program: FEMA Can Improve 
Community Oversight and Data Sharing. www.gao.gov/products/gao-20-396.
---------------------------------------------------------------------------
    A recent New York Times investigative report found that many local 
governments continue to fail to enforce basic floodplain management 
regulations. The report, based on an analysis by researchers at 
University of California, Davis, shows that many local governments do 
not appear to be meeting one of the basic minimum standards required to 
maintain their NFIP status: that the ground floor of every new or 
repaired building be at least as high as the maximum height expected of 
a major flood.\53\ The study found that a quarter of a million 
insurance policies in these communities are in violation of the NFIP 
requirements and this breach in compliance over the last decade has 
come at a $1 billion cost to federal taxpayers.
---------------------------------------------------------------------------
    \53\ NYT. 2021. ``Cities Are Flouting Flood Rules. The Cost: $1 
Billion,'' by Christopher Flavelle and John Schwartz www.nytimes.com/
2020/04/09/climate/fema-flood-insurance.html
---------------------------------------------------------------------------
    Revised minimum standards will mean nothing if there is not 
adequate federal oversight of FEMA and the agency's enforcement of 
these standards.
    FEMA will need to address the outstanding compliance issues in 
multiple ways, including ensuring there are more trained staff and 
resources to do the work, there is better data sharing between FEMA and 
the communities, and that the CAVs are up to date and completed.\54\
---------------------------------------------------------------------------
    \54\ Ibid, at 44.
---------------------------------------------------------------------------
                               In closing
    Thank you for considering the nine issues we believe FEMA ought to 
prioritize in 2022. As the subcommittee advances recommendations for 
FEMA, UCS looks forward to being a resource. Please do not hesitate to 
contact us with any questions the subcommittee may have by reaching out 
to Shana Udvardy or Todd Wolf.

                                 
Statements from 10 Stakeholder Organizations, Submitted for the Record 
                           by Hon. Dina Titus
    Statements from the following 10 organizations are retained in 
committee files and are available online at https://docs.house.gov/
meetings/PW/PW13/20220216/114401/HHRG-117-PW13-20220216-SD002.pdf:

    1.  Association of State Floodplain Managers, Inc.
    2.  BuildStrong Coalition
    3.  International Association of Fire Chiefs
    4.  National League of Cities
    5.  National Low Income Housing Coalition
    6.  Natural Resources Defense Council
    7.  National Rural Electric Cooperative Association
    8.  The Pew Charitable Trusts
    9.  The Refuge Resource Group
 10.  SmarterSafer Coalition



                                Appendix

                              ----------                              


Question from Hon. Eleanor Holmes Norton to Erica Bornemann, Director, 
   Vermont Emergency Management, on behalf of the National Emergency 
                         Management Association

    Question 1. How would you propose to streamline federal and state 
emergency collaboration by using a state-by-state approach, while still 
ensuring that FEMA grants achieve our racial equity goals?
    Answer. This question relates to comments made during the hearing 
and points made about giving states funding tools to be able to build 
capacity in their recovery and mitigation programs. For example, 
allowing for the rollover of management costs from disaster to disaster 
will institute stability in the programs and allow them the room to 
focus efforts on reaching populations historically underserved, 
marginalized, or disadvantaged. Furthermore, outreach to these 
communities is key to establishing trusting relationships that allow 
greater access to programs meant to help survivors receive assistance 
expeditiously. Such outreach, however, must be tailored within each 
state as they know their populations best.
    The emergency management profession is routinely asked to do more 
with the same or less resources. If we want to promote progress in 
addressing racial justice, marginalized, and underserved populations 
with the issues those groups face in disaster response and recovery, we 
must invest in programs with those specific goals in mind. Congress 
should consider designating certain funding opportunities and expanding 
eligibility for existing programs that will boost aid to address needs, 
whether that be in the management rollover costs, or other grant funds. 
Furthermore, processes should be simplified for programs such as the 
Hazard Mitigation Grant Program (HMPG) where long timelines exacerbate 
impacts to communities that most need to break the cycles of disaster. 
By making some of these modest adjustments, emergency managers will 
have the tools to address populations that have been underserved, 
marginalized, as well as affected by racial inequality. This is a more 
equitable approach versus existing one-size-fits-all solutions.