FEMA has issued an Advanced Notice of Rule Making on a proposal for a disaster deductible concept: http://www.regulations.gov/#!documentDetail;D=FEMA_FRDOC_0001-4874
ASFPM will be submitting comments by the due date, so we are asking our leadership (board, committee co-chairs and others) to provide comments to Larry Larson and the executive office at ASFPM@floods.org by March 14. If committee co-chairs want to send to your committee for comments, that is your option, just set appropriate dates to meet the March 14 deadline. The EO will combine these into the final set of ASFPM comments and submit them the Federal Register. Leaders should also feel free to submit comments from your agency/company/community, etc., and directly to the regulations website.
In general, ASFPM supports the this concept because we believe it can promote mitigation actions and build state capability for mitigation and disaster resilience. As one of our leaders said, "This is one of the more important potential policy adjustments I have seen in disaster programs since 1993 when HMGP funding became real via the Volkmer amendments to the Stafford Disaster Relief Act."
Disaster relief can be a crutch for states to externalize the consequences of poor state policies for development in flood hazard areas and lack of mitigation actions. While some states have developed programs that are complimentary to federal disaster assistance or hazard mitigation programs, most have not. In other words, they have little "skin in the game." The number of disasters declared by presidents has gone up dramatically over the past few decades (from an average of 13 per year in 1950 to 141 recently), and the amount of disaster costs picked up by the federal taxpayer has increased from less than 20 percent to more than 75 percent. We don't know for sure, but disasters in the U.S. are now costing between $20 billion and perhaps five times that amount per year.
Many are concerned that current disaster relief policy creates a "moral hazard" where communities and the public build and live in known flood risk because they believe the federal taxpayer will bail them out. If we hope to change that we must incentivize states to build mitigation and resilience capability. We are seeing loss reduction in proactive states, but it would serve national taxpayers well if we can make that happen across the board. We are particularly excited to see the concept where that states who undertake proactive actions can count those actions as credit toward the next disaster. This rewards states that do the right thing for its citizens and taxpayers.
Link to the proposed policy in the Federal Register is above. Please note they ask a series of questions they are seeking comments on. Please comment on as many of those as you can when you reply. For example, what state actions, such as a mitigation funding program, or other actions should be credited toward that deductible? Should certain actions that result in totally removing risk, such as relocation, get more credit than those where residual risk still remains? Would a sliding cost share work for the range of mitigation actions? We believe this does move in the direction of a shared responsibility and resilience.
We look forward to receiving your comments
Thanks for your assistance,
Chad Berginnis, CFM, ASFPM Executive Director
Larry Larson, P.E., CFM, ASFPM Senior Policy Advisor