Disaster Assistance: Information on Declarations for Urban and Rural
Areas (Letter Report, 09/14/95, GAO/RCED-95-242).

Pursuant to a congressional request, GAO provided information on the
federal disaster declaration process, focusing on: (1) whether the
Federal Emergency Management Agency's (FEMA) and the Small Business
Administration's (SBA) disaster declaration policies differ for rural
and urban areas; (2) the length of time taken to respond to disaster
declaration requests for rural and urban areas; (3) the proportion of
requests granted for rural areas, as compared with the corresponding
proportion for urban areas; and (4) factors that influence disaster
declaration processing time.

GAO found that: (1) FEMA and SBA disaster declaration policies do not
differ with respect to whether the affected area is rural or urban; (2)
both FEMA and SBA use criteria such as measures of damage to homes,
businesses, or public facilities, rather than measures of population
density, to assess requests for disaster declarations and to determine
whether to grant assistance; (3) in 1993 and 1994, the median processing
time for disaster declaration requests to FEMA was 11 days for rural
counties and 7 days for urban counties; (4) FEMA has made more rural
counties eligible for disaster assistance than any other type of county,
while SBA has made more urban counties eligible for assistance than any
other type of county; and (5) factors affecting the time required for
the disaster declaration process include how quickly damage assessments
are made and how well the damage is documented.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-95-242
     TITLE:  Disaster Assistance: Information on Declarations for Urban 
             and Rural Areas
      DATE:  09/14/95
   SUBJECT:  Disaster relief aid
             Eligibility determinations
             Federal aid to localities
             Comparative analysis
             Relief agencies
             Intergovernmental relations
             Planning
             Emergency preparedness
             Federal aid to states

             
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Cover
================================================================ COVER


Report to the Chairman, Committee on Commerce, Science, and
Transportation, U.S.  Senate

September 1995

DISASTER ASSISTANCE - INFORMATION
ON DECLARATIONS FOR URBAN AND
RURAL AREAS

GAO/RCED-95-242

Urban/Rural Disaster Declarations

(385459)


Abbreviations
=============================================================== ABBREV

  FEMA - Federal Emergency Management Agency
  PDA - preliminary damage assessment
  SBA - Small Business Administration

Letter
=============================================================== LETTER


B-261931

September 14, 1995

The Honorable Larry Pressler
Chairman, Committee on Commerce,
 Science, and Transportation
United States Senate

Dear Mr.  Chairman: 

When disasters such as floods, tornadoes, or earthquakes strike,
state and local governments are called upon to help citizens cope. 
Assistance from the Federal Emergency Management Agency (FEMA) and/or
the Small Business Administration (SBA) may be provided if requested
by state governors.  FEMA's assistance is triggered if the President
declares that an emergency or disaster exists and that federal
resources are required to supplement state and local resources.  A
presidential "disaster declaration" authorizes federal assistance in
the affected state(s); FEMA determines which counties within the
state will receive assistance and the type(s) of assistance.  Federal
assistance authorized by the President includes assistance from other
federal agencies, including SBA.  In the absence of a presidential
declaration, the SBA Administrator may declare that counties struck
by disasters are eligible to receive some types of assistance from
SBA. 

Concerned about potential differences in the federal government's
treatment of disaster declaration requests for rural areas as
compared with requests for urban areas, you asked us to provide
information on the disaster declaration process.  Specifically, you
asked us to (1) determine if FEMA's and SBA's disaster declaration
policies and procedures differ for requests for rural, as compared
with urban, areas; (2) compare the length of time taken for each
agency to respond to requests for rural and for urban areas; (3)
compare the proportion of requests for rural areas that were granted
with the corresponding proportion for urban areas; and (4) perform a
limited number of case studies to identify factors that influence the
length of time taken for the disaster declaration process. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Neither FEMA's nor SBA's disaster declaration policies differ with
respect to whether the affected area is rural or urban.\1 Both
agencies use criteria such as measures of damage to homes,
businesses, and public facilities to assess requests for disaster
declarations and to help determine whether or not to grant
assistance.  Neither agency's criteria include a measure of
population density. 

For requests received in calendar 1993 and 1994, the time that
elapsed between the governors' requests and the declaration decisions
by the President or SBA was longer for rural and very rural counties
than for urban or very urban counties.\2 For example, the median
processing time for requests to FEMA for very rural counties was 11
days, and for very urban counties, it was 7 days.  Similarly, the
time that elapsed between the occurrence of a "disaster incident" and
the governor's request for a disaster declaration was longest for
very rural counties and shortest for very urban counties (medians of
10 days and 4 days, respectively, for requests made to the
President). 

In disasters declared by the President, FEMA made a greater
proportion of very rural counties (93 percent) eligible for
assistance than any other type of county.  In contrast, SBA declared
a greater proportion of urban and very urban counties (58 percent and
70 percent, respectively) eligible for assistance than rural and very
rural counties. 

In the cases we reviewed,\3 various factors affected the time
required for the declaration process.  One factor affecting the
length of time between a disaster incident and a gubernatorial
request for a declaration was how quickly damage assessments could be
made.  Among the factors that affected the length of time between a
gubernatorial request and a declaration decision was the extent to
which the damage was documented in the governor's request. 


--------------------
\1 For this report, we categorized U.S.  counties using
classifications suggested to us by the Census Bureau that are based
on population density.  The categories are "very rural" (less than 10
persons per square land mile), "rural" (10 to 49.9 persons), "urban"
(50 to 249.9 persons), and "very urban" (at least 250 persons).  A
declaration request may cover more than one county, and the counties
included in one request may vary by population density category. 

\2 We selected requests received by both FEMA and SBA in calendar
1993 and 1994 because they were the most recent requests and the best
documented. 

\3 We reviewed four requests for presidential disaster declarations
(handled by FEMA) and four requests for SBA's disaster declarations. 
These eight requests covered seven incidents.  The cases were
judgmentally chosen on the basis of the length of time that elapsed
during the declaration process, the type of disaster, the disaster's
geographical distribution, and other factors. 


   BACKGROUND
------------------------------------------------------------ Letter :2

SBA and FEMA have independent authorities for providing disaster
assistance.  State governors' requests for SBA's assistance are
directed to the SBA Administrator through SBA's regional offices. 
Under the Small Business Act, the Administrator is authorized to make
or guarantee loans to victims of sudden physical disaster.  The loans
are made to repair or replace damaged property.  In fiscal 1994, SBA
obligated about $4.2 billion for disaster assistance. 

Under the Robert T.  Stafford Disaster Relief and Emergency
Assistance Act (42 U.S.C.  5121 and following), a state governor may
request the President to declare that an "emergency" or "major
disaster" exists in the state.  The scope of authorized assistance
for emergencies is smaller than that for major disasters.  The act
provides that requests for declarations (and therefore federal
assistance) shall be based on a finding that the incident "is of such
severity and magnitude that effective response is beyond the
capabilities of the State and the affected local governments and that
federal assistance is necessary." FEMA gathers and analyzes
information and recommends to the President whether or not federal
assistance is warranted. 

In the event of a presidential declaration, FEMA directly supplies
some assistance and coordinates the overall federal effort.  The
types of assistance provided include money (grants and loans),
equipment, supplies, housing, and personnel.  FEMA's public
assistance grants help state and local governments and eligible
private nonprofit organizations to fund repairs to damaged public
facilities and address health and safety threats.  Individual
assistance grants to individuals and families to help them recover
from the effects of disaster-related damage include housing and
unemployment assistance.  In fiscal 1994, FEMA obligated about $5.4
billion for disaster assistance. 


   AGENCIES' POLICIES AND
   PROCEDURES DO NOT DIFFERENTIATE
   BETWEEN RURAL AND URBAN
   COUNTIES
------------------------------------------------------------ Letter :3

Neither SBA's nor FEMA's disaster declaration policies and procedures
differ with respect to whether the affected area\4 is considered
rural or urban.  Both agencies employ a process of assessing
postdisaster conditions and using a set of factors, or criteria, to
determine whether or not to grant assistance.  Neither agency's
factors include any measure of population density.  (App.  I shows
the steps in each agency's declaration process.)


--------------------
\4 While this report focuses on the county level, both FEMA and SBA
consider the impacts of an incident on the state government as well
as on local governments. 


      SBA'S DISASTER DECLARATIONS
---------------------------------------------------------- Letter :3.1

SBA's declaration process and criteria are published in the Code of
Federal Regulations.  The criteria provide that assistance from SBA
may be provided if, as a result of disaster-related damage to a
county,

  at least 25 homes or businesses have sustained uninsured losses of
     at least 40 percent of their replacement value or

  at least three businesses have sustained uninsured losses of at
     least 40 percent of their replacement value and, as a direct
     result of the disaster, at least 25 percent of the workforce in
     the community would be unemployed for at least 90 days. 

To determine the extent of the damage, SBA, state, and local
officials jointly assess conditions in the affected counties
following a governor's request.  SBA's policy is to suspend action on
the requests it receives if the governor has requested a presidential
declaration that includes individual assistance.  SBA does not act on
such requests until the President has made a decision on the
governor's request. 

In hearings before the 103rd Congress, the incoming SBA Administrator
noted that all disaster declaration requests to SBA are handled in
the same manner.  Also, SBA's Associate Administrator for Disaster
Assistance stated that SBA treats all of the requests from states the
same, whether the disaster area is rural or urban. 


      PRESIDENTIAL DISASTER
      DECLARATIONS
---------------------------------------------------------- Letter :3.2

The Stafford Act establishes the disaster declaration process.  The
act does not prescribe specific criteria to guide FEMA's
recommendation or the President's decision.  As a prerequisite to
federal disaster assistance under the act, a governor must take
"appropriate response action" and provide information on the nature
and amount of state and local resources committed to alleviating the
results of the disaster.  (FEMA may conduct a preliminary damage
assessment, along with state, local, and/or other federal officials,
before the governor requests assistance.) The President then decides
whether federal assistance is needed to supplement state and local
resources. 

The Stafford Act does not identify criteria for evaluating governors'
requests.  According to the Chief, Program Policy Branch, Response
and Recovery Directorate, FEMA generally considers some or all of the
following factors in making a recommendation to the President: 

  The number of homes destroyed or sustaining major damage. 

  The number of homes sustaining minor damage. 

  The extent to which the damage is concentrated or dispersed. 

  The estimated cost of repairing the damage. 

  The demographics of the affected areas (e.g., income levels,
     unemployment, and concentrations of the elderly). 

  The extent to which the damage is covered by insurance. 

  The extent to which the disaster area is traumatized. 

  The extent of disaster-related unemployment. 

  The level of assistance available from other federal agencies
     (e.g., SBA's home and business loans). 

  The state and local governments' capabilities for dealing with the
     disaster. 

  The level of assistance available from voluntary organizations
     (e.g., the American Red Cross). 

  The availability of rental housing. 

  The extent of health and safety problems. 

  The extent of damage to facilities providing essential services
     (e.g., medical, utilities, police, etc.). 

While these factors do not explicitly take into account the
urban/rural status of an affected area, they include factors that
could vary with measures of population density.  For example, the
number of homes destroyed or sustaining major damage might be
expected to be larger in more densely populated areas than in less
densely populated areas. 

According to the Branch Chief, these factors serve as guidelines for
FEMA staff who evaluate disaster declaration requests.  Staff are
encouraged to apply the factors consistently, but there is no formula
for applying them quantitatively.\5 FEMA officials stated that FEMA
relies most heavily on how the assessment of a state's capability
compares with the costs entailed by the disaster.  However, they
acknowledged that "capability" is not precisely defined and that
determining a state's capability is subjective. 

The flexibility and generally subjective nature of FEMA's criteria
have raised questions about the consistency and clarity of the
disaster declaration process.  FEMA's Inspector General reported in
1994 that (1) neither a governor's findings nor FEMA's analysis of
capability is supported by standard factual data or related to
published criteria and (2) FEMA's process does not always ensure
equity in disaster decisions because the agency does not always
review requests for declarations in the context of previous
declarations.  We previously reported that disclosing the process for
evaluating requests would help state and local governments determine
the circumstances that warrant federal assistance.\6

Several attempts have been made to address these concerns, and FEMA
is currently negotiating a partnership agreement with each state,
designed in part to clarify the conditions under which FEMA's
assistance will be available. 


--------------------
\5 A 1988 amendment to the Stafford Act (P.L.  100-707) provided that
"no geographic area shall be precluded from receiving assistance
under this Act solely by virtue of an arithmetic formula or sliding
scale based on income or population."

\6 Requests for Disaster Assistance Need Better Evaluation
(GAO/CED-82-4, Dec.  7, 1981). 


   AVERAGE TIME FROM DISASTER
   INCIDENT TO DECISION WAS
   GREATER FOR RURAL COUNTIES
------------------------------------------------------------ Letter :4

The disaster declaration process can be divided into two intervals: 
(1) the time between the disaster's "incident date"\7 and the
gubernatorial request and (2) the time between the gubernatorial
request and a declaration decision.  The latter interval covers the
period when federal agencies are actually processing disaster
declaration requests.  In addition, FEMA and SBA frequently help
assess damages and/or advise state emergency personnel before a
governor requests assistance. 

During calendar 1993 and 1994, FEMA received 120 gubernatorial
requests for presidential declarations covering 2,157 counties.\8

As shown in figure 1, the median\9 number of days that elapsed during
both intervals was greater for rural and very rural counties than for
urban and very urban counties. 

   Figure 1:  Median Decision
   Times for Presidential Disaster
   Declaration Requests, 1993 and
   1994

   (See figure in printed
   edition.)

Note:  Figure excludes add-on counties. 

Source:  GAO's analysis of FEMA's data. 

During calendar 1993 and 1994, SBA received 73 requests covering 179
counties.  Figure 2 shows that the number of days that elapsed during
both intervals was generally greater for rural and very rural
counties than for urban and very urban counties. 

   Figure 2:  Median Decision
   Times on Requests for SBA's
   Disaster Assistance, 1993 and
   1994

   (See figure in printed
   edition.)

Source:  GAO's analysis of SBA's data. 

Governors' requests for SBA's assistance may be made directly to SBA
or may be included in a request for a presidential declaration. 
SBA's policy is to suspend action on the latter type of requests
until a presidential declaration decision is made.  For the requests
that were made directly to SBA during calendar 1993 and 1994
(covering 124 counties), the median number of days between the
gubernatorial request and SBA's decision was 7, or 34 days less than
for requests that had been included in a request for a presidential
declaration. 

For all requests made to FEMA and SBA, in addition to computing the
medians, we also computed the mean number of days for each interval. 
The results showed the same general pattern:  The mean times tended
to be longer for rural and very rural counties.  (See app.  II for
more details on the processing times for disaster declaration
requests.)

As noted above, neither FEMA's nor SBA's factors for assessing
requests for disaster declarations and helping determine whether or
not to grant assistance include any measure of population density. 
Therefore, while the data show a general pattern of smaller median
and mean elapsed times as county population density increases, they
should not be interpreted as demonstrating that population density
determines the length of elapsed time from request to declaration. 


--------------------
\7 We defined incident date as the first day of the incident period
as determined by FEMA.  For example, a storm may have started on
January 1 and lasted through January 3; in this case, we defined the
incident date as January 1. 

\8 We counted each county each time it was included in a request for
a presidential declaration.  In addition to the 2,157 counties
included in such requests, governors asked FEMA to make 717 counties
eligible for assistance subsequent to presidential declarations. 
Information on these "add-on" counties is in app.  II. 

\9 The median is the midpoint in a sequentially ordered list; in this
case, half of the requests are below the median number of days, and
half are above.  Because the sizes of the intervals vary widely among
the requests, the median may be a more useful representation of the
"typical" number of elapsed days than the mean. 


   PROPORTION OF REQUESTS APPROVED
   DIFFERED BETWEEN URBAN AND
   RURAL COUNTIES
------------------------------------------------------------ Letter :5

As shown in figure 3, a greater proportion of requests for very rural
counties resulted in presidential disaster declarations than did
requests for counties in the other categories.  SBA, on the other
hand, denied a greater proportion of requests for rural and very
rural counties than for urban and very urban counties. 

   Figure 3:  Proportion of
   Requests Granted and Denied, by
   Population Density Category

   (See figure in printed
   edition.)

Source:  GAO's analysis of FEMA's and SBA's data. 

Similar to the data on elapsed time, the data on the proportion of
requests approved and denied should not be interpreted as
demonstrating that population density determines the approval/denial
decision. 


   VARIOUS FACTORS AFFECT TIMING
   OF DISASTER DECLARATION PROCESS
------------------------------------------------------------ Letter :6

FEMA and SBA officials stated that many factors can affect the time
that elapses during the declaration process.  For example, according
to the FEMA Branch Chief, it generally takes longer to travel to
remote areas to assess damages. 

We reviewed (1) selected requests for disaster declarations by the
President and SBA that were processed more quickly or more slowly
than the median number of days between the incident date and the
gubernatorial request and (2) additional selected requests for the
time elapsed between the gubernatorial request and the declaration
decision.  The results are summarized below and detailed in appendix
III. 


      PERIOD BETWEEN INCIDENT AND
      GUBERNATORIAL REQUEST
---------------------------------------------------------- Letter :6.1

One factor affecting the length of time between a disaster incident
and a gubernatorial request for a declaration was how quickly a
preliminary damage assessment could be made.  For example, when a
severe winter storm struck 44 counties in Virginia in 1994,
preliminary damage assessments were not made immediately because (1)
federal, state, and local emergency personnel were still responding
to a severe winter storm that had struck the same counties less than
1 month previously, (2) it was difficult to differentiate the damages
from the two storms, and (3) the storm made travel to some areas
difficult.  Furthermore, the situation was not life threatening.  The
governor waited until the damage assessments were completed for most
of the affected counties before asking for a declaration. 

Conversely, a preliminary damage assessment was completed more
quickly than usual following a 1993 earthquake in a very rural Oregon
county.  The speed with which the assessment was completed
contributed to the governor's requesting a disaster declaration from
SBA in less-than-average time. 

Another factor affecting the timing of requests to SBA is whether or
not the governor first requests a presidential declaration for the
same disaster incident.  For example, following 1994 floods and
tornadoes in North Carolina, the governor first requested a
presidential disaster declaration.  The same day that FEMA denied
this request, the governor requested a declaration from SBA--more
than 4 weeks after the disaster incident. 


      PERIOD BETWEEN GUBERNATORIAL
      REQUEST AND DECLARATION
      DECISION
---------------------------------------------------------- Letter :6.2

The factors that affected the length of time between a gubernatorial
request and a declaration decision included (1) the extent of
documentation in the governor's request and (2) in the case of
requests for SBA's assistance, whether or not the request was
included in a request for a presidential declaration. 

Gubernatorial requests that are well documented generally can be
processed more quickly, while missing documentation can contribute to
delays, as in the following example.  South Dakota experienced severe
storms and flooding from March through July 1994, and in June the
governor requested a disaster declaration from SBA.  SBA required
additional documentation showing that the incident was "sudden" (the
Small Business Act does not authorize assistance for "gradual"
incidents), lengthening the time required before reaching a decision. 

Conversely, state officials credited the clarity of SBA's criteria
for the agency's relatively quick decision on a request for
assistance following a 1994 flood in a very urban Pennsylvania
county.  Because the criteria were clear, the governor could clearly
address them in the disaster declaration request.  Also contributing
to SBA's quick declaration was that the damage occurred in a
concentrated area, and it is easier to evaluate damage when it is
concentrated than when it is more widely dispersed. 

The time that elapses between a governor's request and SBA's decision
can be affected by whether or not the governor has requested a
presidential declaration for the same disaster incident.  As noted
above, SBA's policy is to suspend action on requests it receives if
the governor has requested a presidential declaration that includes
individual assistance. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

We provided a draft of this report for comment to the FEMA Director
and received comments from the Associate Director, Response and
Recovery Directorate.  We also provided a draft to the SBA
Administrator and received comments from the Associate Administrator
for Disaster Assistance.  (SBA's written comments and our responses
are in app.  IV.) FEMA generally concurred with the information
presented in the draft report.  FEMA suggested minor revisions to
clarify our description of the disaster declaration process, and we
incorporated those changes as appropriate.  (App.  V contains FEMA's
written comments.)

The SBA Associate Administrator stated that the draft report
contained four points that could be misleading without further
explanation.  First, he suggested that we clarify that the time that
elapses between a request for SBA's assistance and SBA's decision may
be influenced by whether the request is made directly to SBA or is
included in a request for a presidential declaration.  To address
this point, we added clarifying language as well as tables II.4 and
II.5 (see app.  II), which show the elapsed time for those requests
included in a request for a presidential declaration and those made
directly to SBA, respectively. 

SBA's second point was that because gubernatorial requests are made
on a state basis, analyzing response time to disasters on a
county-by-county basis could "skew" the overall results.  SBA
suggested using the state as the unit of analysis.  Our unit of
analysis was the county because that enabled us to better distinguish
between "rural" and "urban" areas.  Accordingly, our analysis treats
each county in a request equally, and our computed median times
reflect the effects of the number of counties in each population
density category and the length of time that elapsed between the
request and SBA's decision.  We do not believe that using states as
the unit of analysis would allow us to distinguish between the
experiences of rural and urban areas. 

The third point SBA raised was that for the gubernatorial request
date, we used the date of the governor's request for assistance
rather than the actual receipt of the governor's letter by SBA.  SBA
provided a sample of requests showing, on average, a 2-day difference
between the date of the governor's letter and the actual date SBA
received the request.  We used the date of the letter to ensure
consistency with FEMA's data set.  We included SBA's sample in the
final report. 

SBA's fourth comment was that the report should clarify that in those
cases in which SBA denied the governor's request for a declaration,
the requests were denied because they did not meet the agency's
criteria.  Because our draft report stated that SBA relies on its
criteria to determine eligibility for a declaration, we did not
revise the final report. 


---------------------------------------------------------- Letter :7.1

To respond to your request, we reviewed relevant legislation and
FEMA's and SBA's regulations for requests for disaster assistance and
interviewed cognizant officials at each agency.  Using copies of
gubernatorial requests for disaster declarations and other documents
from both FEMA and SBA and automated data provided by FEMA, we
compiled a database to analyze the timing of events and the
proportion of requests approved for each category of county.  For the
case studies, we interviewed federal headquarters and regional office
personnel and state emergency management officials and obtained
relevant documentation.  We performed our work between February and
July 1995 in accordance with generally accepted government auditing
standards.  (See app.  VI for further details on our scope and
methodology.)

We are sending copies of this report to the Administrator, SBA; the
Director, FEMA; appropriate congressional committees; and other
interested parties.  Should you or your staff have any questions, you
can reach me at (202) 512-7631.  Major contributors to this report
are listed in appendix VII. 

Sincerely yours,

Judy A.  England-Joseph
Director, Housing and Community
 Development Issues


DISASTER DECLARATION PROCESSES
=========================================================== Appendix I

Although the two agencies operate under separate authorities, the
Federal Emergency Management Agency (FEMA) and the U.S.  Small
Business Administration (SBA) follow similar processes for federal
disaster declarations. 


   FEMA'S PROCESS
--------------------------------------------------------- Appendix I:1

The Robert T.  Stafford Disaster Relief and Emergency Assistance Act
(42 U.S.C.  5121 and following) authorizes the President to declare
that an emergency or major disaster exists in a state, if requested
by the governor of the state, and to make federal assistance
available to supplement state and local resources.  Figure I.1 shows
the steps generally involved in the disaster declaration process. 

The preliminary damage assessment (PDA) is a mechanism used to
determine the impact and magnitude of damage and the resulting unmet
needs of individuals, businesses, the public sector, and the
community as a whole.  Information collected is used by the state in
preparing the governor's request and by FEMA in making a
recommendation to the President about whether and what type(s) of
assistance is warranted. 

A presidential declaration authorizes federal assistance (which may
be public assistance, individual assistance, or both) in the affected
state(s) after a governor's request.\1 The federal assistance
authorized by the President includes assistance from other federal
agencies, including SBA.  The President delegates authority to FEMA
to determine which counties within the state will receive assistance
and the type(s) of assistance to be provided.  At any point after the
governor's initial request letter, the governor may request that
additional counties be made eligible and/or that additional types of
assistance be provided, as part of the same disaster declaration. 
These requests are submitted to FEMA's regional offices. 

   Figure I.1:  Presidential
   Disaster Declaration Process

   (See figure in printed
   edition.)


--------------------
\1 Section 501(b) of the Stafford Act authorizes the President to
provide emergency assistance in certain instances without a
gubernatorial request. 


   SBA'S PROCESS
--------------------------------------------------------- Appendix I:2

Under the provisions of the Small Business Act, the SBA Administrator
is authorized to make or guarantee loans to victims of sudden
physical disaster if requested by the governor of a state.  Figure
I.2 shows the steps involved in the SBA declaration process. 

   Figure I.2:  SBA's Disaster
   Declaration Process

   (See figure in printed
   edition.)


PROCESSING TIMES FOR DISASTER
DECLARATION REQUESTS
========================================================== Appendix II

With some exceptions, the times taken for governors to request a
presidential or SBA disaster declaration and the times taken for the
President or SBA Administrator to reach a decision were longer for
rural and very rural counties.  Consequently, the overall times from
disaster incidents to decisions on federal aid were longer for these
counties than for urban or very urban counties. 


   REQUESTS FOR PRESIDENTIAL
   DECLARATIONS
-------------------------------------------------------- Appendix II:1

To determine the amount of time that the declaration process takes
for requests to the President through FEMA, we reviewed all counties
for which emergency and/or major disaster declarations were requested
in calendar 1993 and 1994.  These totaled 2,874 counties, divided as
follows:  (1) 2,157 counties that were included in original
gubernatorial requests ("initial" counties) and (2) 717 counties that
governors subsequently asked FEMA to make eligible for assistance
("add-on" counties).\1 Because FEMA does not maintain centralized
records of add-on counties that were turned down, the add-on counties
for which we obtained information are limited to those that were
declared eligible for federal assistance. 

The total time that elapses between a disaster incident and a
decision on federal aid depends on how quickly a governor asks for
assistance, as well as how quickly federal officials act on the
request.  Accordingly, for each initial county we computed the
numbers of days that elapsed from the disaster incident to the
gubernatorial request; from the gubernatorial request to the date
that a declaration decision was made; and the total time that elapsed
from incident to declaration decision.  As shown in table II.1, the
number of days that elapsed both before and after gubernatorial
requests generally tended to be shorter for initial counties as
county population density increased. 




                               Table II.1
                
                 Time Required to Process Presidential
                 Disaster Declaration Requests, Initial
                                Counties

                            (Number of days)



                                          Very              Very
                                          rura  Rura  Urba  urba
                                             l     l     n     n   All
                                          (157  (827  (837  (336  (2,1
                                             )     )     )     )   57)
----------------------------------------  ----  ----  ----  ----  ----


From incident to governor's request:
----------------------------------------------------------------------
Median                                      10    10     4     4     4
Mean                                      29.1  12.8  10.6   9.1  12.6
Minimum                                      0     0     0     0     0
Maximum                                    129   114   114    87   129

From governor's request to decision:
----------------------------------------------------------------------
Median                                      11     9     8     7     8
Mean                                      13.0  14.7  13.8  12.7  13.9
Minimum                                      0     0     0    -1    -1
Maximum                                     88   134   134   134   134

From incident to decision:
----------------------------------------------------------------------
Median                                      29    19    18    12    18
Mean                                      42.1  27.6  24.4  21.8  26.5
Minimum                                      2     1     1     0     0
Maximum                                    153   188   188   151   188
----------------------------------------------------------------------
Notes:  Numbers in parentheses are numbers of counties for which
requests were made in the category.  "0" indicates that the two
actions occurred on the same day.  "-1" represents a case (the
Northridge earthquake) in which the governor orally requested an
expedited declaration which the President authorized.  The written
request was dated and submitted the day following the actual
declaration. 

Source:  GAO's analysis of FEMA's data. 

As noted above, for the "add-on" counties, FEMA does not maintain
centralized information; therefore, we were able to compute only the
total times elapsed between disaster incidents and declaration
decisions.  As table II.2 shows, while there is somewhat more
variation, the overall pattern was the same as for initial counties: 
The number of days that elapsed generally tended to be smaller as
county population density increased. 



                               Table II.2
                
                 Time Required to Process Presidential
                 Disaster Declaration Requests, Add-On
                                Counties

                            (Number of days)


                          Very                          Very
From incident to         rural     Rural     Urban     urban       All
decision:                (107)     (393)     (161)      (56)     (717)
--------------------  --------  --------  --------  --------  --------

Median                      44        42        34        36        40
Mean                      63.2      51.0      40.9      39.0      49.6
Minimum                     10         3         2         4         2
Maximum                    140       153       206        98       206
----------------------------------------------------------------------
Note:  Numbers in parentheses are numbers of counties for which
requests were made in the category. 

Source:  GAO's analysis of FEMA's data. 

A greater proportion of add-on counties fell into the "very rural" or
"rural" categories than did initial counties.  According to FEMA
officials, it typically takes longer to obtain accurate damage
reports from more remote areas where the extent of damages may not be
apparent as quickly. 


--------------------
\1 Governors may request declarations for counties that were not
included in the original request for various reasons, such as more
detailed damage information becoming available. 


   REQUESTS FOR SBA DECLARATIONS
-------------------------------------------------------- Appendix II:2

For requests to SBA, we reviewed those counties for which physical
disaster loan\2 requests had been made during calendar 1993 and 1994;
these totaled 179.  Similar to our treatment of presidential
declarations, for each county we computed the number of days that
elapsed from the disaster incident to the gubernatorial request; from
the gubernatorial request to the date that a declaration decision was
made; and the total time that elapsed from incident to declaration
decision. 

In addition, we separately analyzed requests to SBA that (1) were
referred by FEMA and (2) were made directly by governors.  Governors
may explicitly request SBA's assistance as part of their request to
FEMA for a presidential disaster declaration.  If the request is
granted, then SBA may provide assistance without a separate SBA
declaration.  If such requests for presidential declarations are
turned down, then FEMA refers the requests to SBA.  FEMA does not
refer to SBA turned-down requests in which a governor has not
explicitly requested SBA assistance; therefore, in those cases, the
governor must request a declaration directly from SBA. 

Table II.3 shows that for all requests for SBA disaster assistance,
the number of days that elapsed before and after a gubernatorial
request generally tended to be smaller as county population density
increased. 



                               Table II.3
                
                Time Required to Process SBA's Disaster
                          Assistance Requests

                            (Number of days)



                                          Very              Very
                                          rura  Rura  Urba  urba   All
                                             l     l     n     n  (179
                                          (16)  (52)  (66)  (45)     )
----------------------------------------  ----  ----  ----  ----  ----


From incident to governor's request:
----------------------------------------------------------------------
Median                                     108    19    18    11    17
Mean                                      83.1  26.7  27.2  15.4  29.1
Minimum                                     10     2     2     0     0
Maximum                                    108   108   287    54   287

From governor's request to decision:
----------------------------------------------------------------------
Median                                      27    29     8     8     9
Mean                                      24.5  27.5  13.0  14.7  18.6
Minimum                                      6     0     1     1     0
Maximum                                     41    56    56    58    58

From incident to decision:
----------------------------------------------------------------------
Median                                     135    58    37    32    42
Mean                                      107.  54.2  40.2  30.0  47.7
                                             6
Minimum                                     16     9     3     1     1
Maximum                                    135   135   306    64   306
----------------------------------------------------------------------
Notes:  Numbers in parentheses are numbers of counties for which
requests were made in the category.  "0" indicates that the two
actions occurred on the same day.  Fifteen of the 16 very rural
counties were included in one declaration. 

Source:  GAO's analysis of FEMA's data. 

Tables II.4 and II.5 present the time elapsed for SBA disaster
assistance requests (1) referred by FEMA and (2) made directly to
SBA, respectively.  The tables show a similar overall pattern:  The
number of days that elapsed before and after a gubernatorial request
generally tended to be smaller as county population density
increased, whether the requests were referred by FEMA or made
directly to SBA.  The tables also show that the median and mean
processing times were somewhat greater for requests referred by FEMA. 



                               Table II.4
                
                  Processing Times for SBA's Disaster
                 Declaration Requests Referred by FEMA

                            (Number of days)



                                          Very              Very
                                          rura  Rura  Urba  urba
                                             l     l     n     n   All
                                           (1)  (30)  (13)  (11)  (55)
----------------------------------------  ----  ----  ----  ----  ----


From incident to governor's request to FEMA:
----------------------------------------------------------------------
Median                                      17    17     6     4    17
Mean                                      17.0  15.1  12.5   7.3  12.9
Minimum                                     17     3     3     2     2
Maximum                                     17    19    44    17    44

From governor's request to FEMA turn-down decision:
----------------------------------------------------------------------
Median                                      35    34    24    23    34
Mean                                      35.0  33.1  27.5  28.5  30.9
Minimum                                     35    19     7    19     7
Maximum                                     35    50    50    54    54

From FEMA turn-down decision to SBA decision:
----------------------------------------------------------------------
Median                                       6     7     7     6     7
Mean                                       6.0   6.7   7.0   6.8   6.8
Minimum                                      6     3     3     1     1
Maximum                                      6    10    10    10    10

From incident to SBA decision:
----------------------------------------------------------------------
Median                                      58    58    58    35    58
Mean                                        58  54.9  46.9  42.5  50.6
Minimum                                     58    32    23    32    23
Maximum                                     58    60    60    64    64
----------------------------------------------------------------------
Source:  GAO's analysis of SBA's data. 



                               Table II.5
                
                     Processing Times for Disaster
                 Declaration Requests Made Directly to
                                  SBA

                            (Number of days)



                                          Very              Very
                                          rura  Rura  Urba  urba   All
                                             l     l     n     n  (124
                                          (15)  (22)  (53)  (34)     )
----------------------------------------  ----  ----  ----  ----  ----


From incident to governor's request:
----------------------------------------------------------------------
Median                                     108    30    30    13    30
Mean                                      87.5  42.5  30.9  18.0  36.3
Minimum                                     10     2     2     0     0
Maximum                                    108   108   287    54   287

From governor's request to decision:
----------------------------------------------------------------------
Median                                      27     7     7     7     7
Mean                                      23.4  10.7   7.7   8.0  10.2
Minimum                                      6     0     1     1     0
Maximum                                     27    27    19    16    27

From incident to decision:
----------------------------------------------------------------------
Median                                     135    37    37    20    37
Mean                                      110.  53.2  38.6  26.0  46.5
                                             9
Minimum                                     16     9     3     1     1
Maximum                                    135   135   306    62   306
----------------------------------------------------------------------
Source:  GAO's analysis of SBA's data. 


--------------------
\2 We did not review requests for economic injury disaster loans, nor
did we review assistance provided under presidential declarations. 
We reviewed only SBA declaration requests.  Furthermore, SBA, upon
granting a declaration, deems automatically eligible those counties
that are contiguous to the affected county(ies).  We did not include
contiguous counties in our analysis. 


FACTORS AFFECTING TIMING OF
DECLARATION PROCESS
========================================================= Appendix III

To identify factors that may influence the time that elapses during
the disaster declaration process, we reviewed selected cases of
disaster declaration requests at FEMA and SBA.  (We defined a "case"
as a request to either the President or the SBA Administrator for a
declaration in a state for one disaster incident; details on our
selection criteria are in app.  V.) We selected a total of eight
cases, four dealing with the time period between disaster incident
and gubernatorial request and four dealing with the time period
between gubernatorial request and declaration decision.  These eight
cases represent seven disaster incidents (one incident resulted in a
request for a presidential disaster declaration that was turned down,
and a subsequent request for a declaration from the SBA
Administrator). 

The following provides descriptive information about each case,
citing factors that may have affected the time that elapsed in each
case.  However, because the cases were not randomly selected, they
should not be viewed as representative of all disaster declaration
requests. 


   TIME BETWEEN INCIDENT AND
   GUBERNATORIAL REQUEST
------------------------------------------------------- Appendix III:1

The cases we reviewed suggest that a principal factor affecting the
length of time between a disaster event and a gubernatorial request
for a declaration was how quickly preliminary damage assessments
(PDA) could be made.  A number of variables can affect the speed with
which PDAs are conducted.  A second factor that affected requests to
SBA was whether or not the governor had requested a presidential
disaster declaration for the same disaster event. 


      SEVERE WINTER STORM IN
      VIRGINIA
----------------------------------------------------- Appendix III:1.1

Virginia experienced a severe winter ice storm on March 1-5, 1994. 
The situation was not considered life threatening.  The governor
requested a presidential declaration of a major disaster on March 15. 
The governor asked for public assistance for 44 counties, about half
of which were rural. 

The storm came on the heels of an earlier (February 8-12) severe
winter storm that struck generally the same areas of Virginia.  (The
President had declared a major disaster following the earlier storm.)
Damage survey teams composed of federal, state, and local personnel
were still on the scene responding to the earlier storm when the
later storm hit.\1 This situation created a dilemma:  The survey
teams are generally composed of the same personnel who conduct PDAs
and often, in rural areas, include volunteers.  One option was for
the survey teams to interrupt their work to conduct PDAs for the
second storm.  However, federal and state officials determined that
it would be more efficient to concurrently conduct surveys for the
first storm and PDAs for the second storm. 

Therefore, the principal contributing factor to a prolonged period
between the incident date and the gubernatorial request was that the
PDAs were not conducted immediately following the storm.  Officials
thought it was prudent to delay the assessments since the request was
for "cleaning up" rather than saving lives and because a delay would
allow more efficient use of the limited and exhausted human resources
available. 

Other factors that contributed to the length of time between the
incident and the governor's request: 

  The governor did not submit the request until most of the PDAs were
     complete.  Frequently, governors will request a declaration once
     it is established that at least some counties are eligible and
     that the state lacks the capability to respond to the incident. 
     Federal and state officials noted that for this storm, waiting
     until most of the PDAs had been completed enabled them to obtain
     a clearer understanding of the extent of the damage, and as a
     result, FEMA was able to process the request with few questions
     about eligibility. 

  The PDAs were more difficult to conduct since differentiating the
     damages caused by the two storms was difficult. 

  The nature of the storm--ice accompanied by 3 inches of snow, winds
     of 50-60 miles per hour, and subsequent flooding--made travel to
     conduct the assessments challenging. 

As a result of the second storm, the President declared a major
disaster for Virginia, and FEMA determined that 33 of the 44 counties
requested by the governor would be designated as eligible for public
assistance grants. 


--------------------
\1 Damage survey teams are responsible for a detailed analysis of the
damage after a presidential declaration has been made. 


      SEVERE WINTER STORM IN UTAH
----------------------------------------------------- Appendix III:1.2

Utah experienced a severe winter storm from January 2 through January
11, 1993, that affected five counties--Salt Lake County, another very
urban county, one urban county, and two very rural counties.  Up
until January 8, when the storm intensified, the state and local
governments were able to respond to the storm.  The governor declared
a state of emergency on January 11 after a record-breaking snowfall
and on January 16 requested a presidential emergency declaration. 
The PDA indicated that snow debris removal was the most significant
need.  The request was denied on the grounds that the situation was
not deemed to be beyond the combined capabilities of the state and
local governments.  Utah unsuccessfully appealed the denial. 

One factor contributing to our computed longer-than-average time is
the incident date recorded by FEMA.  FEMA's records show the incident
date as January 2; however, a more accurate incident date might be
later because the storm intensified starting January 8.  The event
period was never fully defined because the request was denied. 

A second potential factor was the nature of the incident.  The
request was unique because it was the first snow-removal request FEMA
had received in nearly 15 years.  FEMA's "snow" policy had become
inactive, and confusion prevailed over matters such as determining
which costs were eligible.  A third factor was that the
record-breaking snow levels made communications between the
localities and the state difficult, delaying the state's ability to
obtain critical information on the extent of storm damage. 


      FLOODING IN NORTH CAROLINA
----------------------------------------------------- Appendix III:1.3

North Carolina experienced damage caused by floods and tornadoes on
August 16 and 17, 1994.  SBA and FEMA personnel as well as state and
local officials conducted a PDA of several counties on August 22-24. 
The governor requested a presidential declaration for 14 counties,
mostly urban, on August 30; the request was denied on September 21. 
On that same day--more than 4 weeks after the incident--the governor
requested assistance from SBA.  On September 27, the SBA
Administrator declared 2 of the 14 counties eligible for SBA
assistance.  Another eight counties were eligible for assistance
because they were contiguous to the two declared counties. 

Much of the time that elapsed between the disaster incident and the
governor's request to SBA can be attributed to processing the
presidential request.  While SBA made a decision 6 days after
receiving the request, over 6 weeks had already elapsed before the
governor requested SBA assistance. 


      EARTHQUAKE IN OREGON
----------------------------------------------------- Appendix III:1.4

Klamath County, Oregon (a very rural county), experienced an
earthquake on September 20, 1993.  On September 27-29, FEMA and SBA
jointly conducted a damage assessment to determine the extent of the
damage.  On September 30, the governor requested an SBA disaster
declaration for the county.  On October 1, the governor requested a
presidential major disaster declaration for public assistance. 

According to state officials, a principal factor that may have
contributed to a gubernatorial request in less-than-average time for
very rural counties was the prompt damage assessment, which was
conducted before the governor's official request for assistance. 


   TIME BETWEEN GUBERNATORIAL
   REQUEST AND DECLARATION
   DECISION
------------------------------------------------------- Appendix III:2

On the basis of the cases we reviewed, factors that affected the
length of time between a gubernatorial request and a declaration
decision included (1) the extent of documentation of the damage in
the governor's request and (2) whether the damage occurred in a
concentrated or more widely dispersed area. 


      FLOODING IN SOUTH DAKOTA
----------------------------------------------------- Appendix III:2.1

South Dakota experienced severe storms and flooding from March
through July 1994.  On June 6, the governor requested a presidential
major disaster declaration primarily to repair road and bridge damage
for 15 counties (11 very rural and 4 rural counties).  The President
made the declaration on June 21, and FEMA designated all 15 counties. 
The governor subsequently requested that FEMA designate an additional
six counties, and FEMA did so. 

FEMA officials explained that because the land is flat and water
subsidence takes longer than in less flat areas, flooding incidents
often--as in this case--last longer in South Dakota as well as North
Dakota where the topography is similar.  Therefore, subsidence of the
flood waters to determine the extent of damage took longer than
subsidence in less flat areas.  Also, the Dakotas are not highly
populated and contain relatively more public facilities that are less
expensive to repair and replace than do more densely populated
areas--for example, gravel roads, which are common in the Dakotas,
are less expensive to repair than highways. 

Also, the overriding factor that FEMA employs in determining
eligibility for a disaster declaration is state and local capability. 
Since the road and bridge repair costs incurred by this disaster
appeared to be relatively inexpensive, FEMA, in determining state and
local government capability, scrutinized the request more closely
than events with more obvious and expensive damage.  FEMA officials
noted that although the costs may be less, they recognized that the
impact was not necessarily less. 

In addition to the request to the President for public assistance,
the governor requested an SBA declaration for assistance to
households and businesses in the same 15 counties as requested in the
presidential request.  The gubernatorial request was made on June 17;
and on July 14, the SBA Administrator declared two counties eligible
for SBA assistance.  (Six other counties, because they were
contiguous to the two declared counties, became eligible for
assistance.) SBA's records indicate that the gubernatorial request
did not establish that the flooding was a "sudden" physical event. 
Because the Small Business Act prohibits providing assistance for
gradual events, SBA required additional information and adequate
documentation that the event was sudden, lengthening the declaration
process.  Also, SBA did not receive the gubernatorial request letter
until 6 days after the date of the letter. 


      FLOODING IN PENNSYLVANIA
----------------------------------------------------- Appendix III:2.2

Philadelphia County, Pennsylvania (a very urban county), experienced
widespread urban flooding due to thunderstorms and heavy rain on July
14, 1994.  On August 3, the governor requested SBA assistance.  On
August 4, SBA personnel along with state and local officials
conducted a survey to determine the extent of the damage caused by
the flooding.  On August 8, the SBA Administrator declared the county
eligible for SBA assistance. 

State officials suggested that SBA's processing of disaster
declaration requests is expedited because SBA provides clearly
detailed criteria and instructions for evaluating whether the
criteria have been met.  They noted that by closely following the
instructions and carefully addressing the criteria in the
gubernatorial request, the declaration is usually forthcoming. 

Also, SBA officials explained that the flooding occurred in a
concentrated area.  It is easier to evaluate the extent of damage
when it occurs in a geographically concentrated area than when the
damage is more widely dispersed.  Therefore, SBA was able to quickly
assess the damage. 


      SEVERE WINTER STORM IN
      TENNESSEE (AND OTHER EASTERN
      AND MID-ATLANTIC STATES)
----------------------------------------------------- Appendix III:2.3

From March 13 through March 17, 1993, Tennessee (as well as 16
eastern and mid-Atlantic states and the District of Columbia)
experienced a severe winter storm with excess snowfall.\2 The states
and the District requested that the President declare an emergency
and requested public assistance for cleaning up the storm-related
damages.  The time from the governor's request to the presidential
decision was shorter than average for all 18 requests received. 

FEMA officials explained that the overriding factor in considering
the 18 declaration requests was the storm's "crippling" impact.  The
requirement to conduct PDAs was waived, and the decision to provide
emergency assistance was made more quickly than usual.  FEMA policy
is to waive PDAs (i.e., expedite processing) only for disasters of
the greatest magnitude, such as Hurricane Andrew.  FEMA expedited the
processing of gubernatorial requests for this storm.  In addition to
waiving the PDA requirement, FEMA provided a draft request letter to
the affected states and drafted a snow-removal policy.  The states
and the District requested public assistance only. 



(See figure in printed edition.)Appendix IV

--------------------
\2 While we selected the state of Tennessee for our analysis, the
same storm hit the other states, and the declaration process was
similar for all. 


COMMENTS FROM THE SMALL BUSINESS
ADMINISTRATION
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on the Small Business
Administration's letter dated July 31, 1995. 


   GAO COMMENTS
------------------------------------------------------- Appendix III:3

1.  SBA's first comment was that for requests for SBA disaster
assistance, our data on median elapsed times did not distinguish
between (1) requests that are made directly to SBA and (2) requests
that are referred by FEMA in cases in which requests for a
presidential disaster declaration have been turned down.  Our draft
report stated that SBA's policy is to suspend action on requests it
receives if the governor has requested a presidential declaration
that includes individual assistance and that SBA does not act on such
requests until the President has made a decision on the request for a
presidential declaration. 

To respond to SBA's comment, we disaggregated requests for SBA
assistance between (1) requests that are made directly to SBA and (2)
requests that are referred by FEMA.  We then computed the median and
mean elapsed times for each group and included these data in appendix
II.  Among other things, the data show that for the requests that
were made directly to SBA during 1993 and 1994, the median number of
days between the gubernatorial request and SBA's decision was 7, or
34 days fewer than the median of 41 days for requests referred by
FEMA.  We added language to the letter noting this distinction. 

2.  SBA's second comment was that we used counties rather than states
as the units of analysis and that governors' requests are on a "state
basis." We used counties because doing so enabled a somewhat better
distinction between "rural" and "urban" areas.  Our report noted that
(1) in cases of requests for a presidential disaster declaration,
FEMA determines which counties within a declared state will receive
assistance and (2) in the absence of a presidential declaration, the
SBA Administrator may declare that counties struck by disasters are
eligible to receive some types of SBA assistance.  Our analysis
treats each county in a request equally.  Our computed median times
reflect the effects of the number of counties in each population
density category and the length of time that elapsed between the
request and SBA's decision.  We do not believe that using states as
the unit of analysis would allow us to distinguish between the
experiences of rural and urban areas. 

3.  SBA's third comment concerned our definition of "date of
governor's request" for SBA assistance.  We used the dates that
appeared on the governors' letters to ensure a data set consistent
with FEMA's records.  Our draft report noted that according to SBA
officials, a gubernatorial request letter may not necessarily be
mailed on the date of the letter and that any delays in mailing would
help account for the time lapse between a gubernatorial request and
an SBA decision, as shown by our analysis.  We added the figures
cited in SBA's comments to the final report. 

4.  SBA's fourth comment was that the report should clarify that any
counties that were denied SBA assistance did not meet the agency's
published criteria.  Our draft report stated that SBA uses criteria,
published in the Code of Federal Regulations, to determine whether or
not a county is eligible for disaster assistance; therefore, we do
not believe any change is necessary on the basis of this comment. 




(See figure in printed edition.)Appendix V
COMMENTS FROM THE FEDERAL
EMERGENCY MANAGEMENT AGENCY
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)


SCOPE AND METHODOLOGY
========================================================== Appendix VI

To determine if FEMA's and SBA's disaster declaration policies and
procedures differ for requests for rural, as compared with urban,
areas, we reviewed the Robert T.  Stafford Disaster Relief and
Emergency Assistance Act (42 U.S.C.  5121 and following), the Small
Business Act, and FEMA's and SBA's procedures as outlined in the Code
of Federal Regulations.  We also interviewed FEMA and SBA officials
responsible for administering the disaster declaration process and
obtained and reviewed guidance used in evaluating disaster
declaration requests at each agency. 

To compare the length of time each agency took to respond to requests
for rural and urban areas and to compare the proportion of requests
for rural areas that were granted with the corresponding proportion
for urban areas, we developed a database using FEMA's and SBA's
disaster declaration request records and Bureau of the Census' county
and state information.  We did not verify the accuracy of these
records.  The database included all counties that were included in
requests for "emergency" or "major disaster" declaration requests
under the Stafford Act, or for SBA physical disaster assistance,
received during calendar 1993 and 1994.  We counted each county each
time it was included in a request.  We limited the scope of our
review to calendar 1993 and 1994 because those were the years for
which the best information was available.  FEMA and SBA officials
told us that these years were not atypical. 

We used county population and land area data from the 1990 U.S. 
census to compute a measure of population density for each county. 
We then used the Bureau of the Census' population density categories
to classify each of the counties as very rural, rural, urban, or very
urban, as shown in table VI.1. 



                               Table VI.1
                
                  County Population Density Categories

Census Bureau population density (persons/sq. mile)           Category
------------------------------------------------------------  --------
Less than 10                                                  Very
                                                              rural

10-49.9                                                       Rural

50-249.9                                                      Urban

At least 250                                                  Very
                                                              urban
----------------------------------------------------------------------
Using FEMA's and SBA's records, we included for each county the dates
of (1) the disaster incident, (2) the gubernatorial request, and (3)
the decision by the President or SBA Administrator. 

For Presidential declaration requests: 

  We obtained the disaster incident dates from FEMA's automated
     information system and notices published in the Federal
     Register.  In cases in which an incident spanned more than 1
     day, we used the first day of the period. 

  We used the dates on the governors' request letters for the
     gubernatorial request dates. 

  For the decision date, we used the date of the declaration as
     published in the Federal Register if the request was granted. 
     Requests that are turned down do not result in a Federal
     Register notice.  When all counties included in requests were
     turned down, we obtained the date from FEMA's automated
     information system.  However, FEMA does not centrally maintain
     records of add-on counties that were denied eligibility for
     assistance.  Therefore, we excluded those counties in our timing
     calculations. 

We disaggregated requests for SBA assistance between (1) requests
that were made directly to SBA and (2) requests that were referred by
FEMA.  For all requests, we obtained the disaster incident dates and
SBA decision dates from SBA's files.  For requests made directly to
SBA, we defined the "gubernatorial request date" as the date of the
governor's letter.\1 For requests referred by FEMA, we used the FEMA
"turn-down" date--the date that FEMA announced that a governor's
request for a presidential declaration had been denied--as the date
of the request to SBA. 

We used this information to compute the median and mean number of
days that elapsed, for each county, between the disaster incident and
the gubernatorial request, and between the gubernatorial request and
the decision.  We also included information on whether each county
was granted assistance or was turned down.  For the "add-on"
counties, FEMA does not maintain centralized records showing the
gubernatorial request dates; therefore, we were able to compute only
the total time elapsed from disaster incident to a declaration
decision. 

For each county population density category, we computed the median
and mean numbers of days for each of the two time periods, the
proportion of requests that resulted in assistance being granted, and
the proportion that were turned down. 

To select the case studies used to identify factors that influence
the length of time taken for the disaster declaration process at each
agency, we selected the cases that took approximately 25 percent more
than the median time between the disaster incident and gubernatorial
request and the cases that took approximately 25 percent less. 
Similarly, at each agency we selected the cases that took
approximately 25 percent more than the median time between
gubernatorial request and a disaster declaration decision and the
cases that took approximately 25 percent less.  We judgmentally
selected cases that were diverse, differing by such characteristics
as type and size of disaster, geographic location, type of
declaration requested (presidential emergency, presidential major
disaster, or SBA), and outcome (request granted or turned down). 

We interviewed relevant agency and state officials to identify the
factors in each case that appeared to affect the time intervals.  We
used the cases to illustrate what happened in a few instances to
speed up or slow down the disaster declaration process.  The cases
are not necessarily representative of all disaster declaration
requests, and they should not be interpreted as explaining all
variation in time elapses among requests. 


--------------------
\1 SBA officials noted that a gubernatorial request letter may not
necessarily be mailed on the date of the letter; any delays in
mailing would help account for the time lapse between gubernatorial
request and an SBA decision, as shown by our analysis.  For example,
according to SBA's Associate Administrator for Disaster Assistance,
in a sample size of 49 disasters for which a governor requested SBA
assistance only, there was a 2-day difference on average, with a
range of up to 6 days, between the date of the gubernatorial request
and the date SBA actually received the request.  SBA does not act on
any request until it is received by mail or by facsimile. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix VII

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Jim Wells, Associate Director
David Wood, Assistant Director
Carole Buncher, Senior Evaluator
Curtis Groves, Senior Operations Research Analyst
Lynne Goldfarb, Publishing Adviser

OFFICE OF THE GENERAL COUNSEL,
WASHINGTON, D.C. 

John T.  McGrail, Attorney Adviser

RELATED GAO PRODUCTS

Disaster Assistance:  Information on Expenditures and Proposals to
Improve Effectiveness and Reduce Future Costs (GAO/T-RCED-95-140,
Mar.  16, 1995). 

GAO Work on Disaster Assistance (GAO/RCED-94-293R, Aug.  31, 1994). 

Los Angeles Earthquake:  Opinions of Officials on Federal Impediments
to Rebuilding (GAO/RCED-94-193, June 17, 1994). 

Federal Disaster Insurance:  Goals Are Good, but Insurance Programs
Would Expose the Federal Government to Large Potential Losses
(GAO/T-GGD-94-153, May 26, 1994). 

Disaster Management:  Improving the Nation's Response to Catastrophic
Disasters (GAO/RCED-93-186, July 23, 1993). 

Disaster Assistance:  DOD's Support for Hurricanes Andrew and Iniki
and Typhoon Omar (GAO/NSIAD-93-180, June 18, 1993). 

Rural Disaster Assistance (GAO/RCED-93-170R, June 14, 1993). 

Disaster Relief Fund:  Actions Still Needed to Prevent Recurrence of
Funding Shortfall (GAO/RCED-93-60, Feb.  3, 1993). 

Disaster Assistance:  Timeliness and Other Issues Involving the Major
Disaster Declaration Process (GAO/RCED-89-138, May 25, 1989). 

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