FEMA Review Council Report Analysis

If we have not met, here are my credentials: I have been involved with disaster work for 20 years beginning with the recovery of New Orleans after Hurricane Katrina and the levee failure. I worked major disasters from BP to Joplin as part of the disaster nonprofit sector. I then went on to earn my master’s and PhD in emergency management. I have spent the last decade researching the U.S. emergency management system, teaching emergency management including courses on Disaster Policy, and providing analysis of the emergency management system to the public via major news outlets. 

The FEMA Review Council released its final report on May 7, 2026, after more than a year of committee meetings, leaked drafts, and the ousting of a committee chair. 

The Takeaway

President Trump’s politically motivated and non-representative FEMA Review Council has recommended sweeping changes to the agency that would substantially minimize federal support to state and locals before, during, and after disasters. State, territorial, tribal, and local governments would face a staggering increase in financial responsibility for emergency management. In cases where federal disaster funding will still be made available, decisions about who receives help, when, and how much would fall to state officials, including those with little disaster experience and minimal resources and capacity. The Council’s recommendations would disproportionately harm smaller, poorer, and rural states and deepen discriminatory outcomes along class and racial lines. The FEMA Review Council provides no evidence that their recommendations would create a more effective, efficient, and equitable emergency management system. 

 The History of The FEMA Review Council

President Trump issued an Executive Order on January 24, 2025, just days after taking office, which announced the creation of the FEMA Review Council. The Council was created in the context of President Trump’s suggestion that FEMA should be eliminated. This idea that stemmed from his claim the Biden Administration’s response to Hurricane Helene was a failure (it was not) and that FEMA is politically biased against republicans (it is not). The Executive Order provided specific questions for the Council to address including the appropriate role of each level of government, FEMA’s response effectiveness during the Biden administration, and the possible need for changes to FEMA’s statutory structure, among others. While the Council addressed some of these questions, they ultimately took the approach of recommending widespread FEMA reform.

Before the Review Council was even fully formed, the Trump administration, particularly former DHS Secretary Kristi Noem, began to dismantle the agency. (The elimination of FEMA legally requires Congressional action.) The administration fired some FEMA staff and created such a hostile work environment that many more decided to leave the agency. The administration froze and revoked federal grant dollars which wreaked havoc for state and local emergency management agencies. Trump became the first president to issue declarations disproportionately along party lines with red states receiving far more federal disaster aid far faster than blue states. For nearly a year, former DHS Secretary Noem required her personal sign off for any FEMA spending over $100,000. This brought much of what was left of the agency to a grinding stop.

 As the Trump administration took a sledgehammer to FEMA, the Review Council began meeting. The Council was co-chaired by the Secretary of DHS and the Secretary of Defense. It included several current and former governors including Greg Abbott (R-TX), Phil Bryant (R-MS), and Glenn Youngkin (R-VA). Mark Cooper, a republican and former Chief of Staff for former Governor John Bel Edwards (D-LA) was also added. These current and former state officials were joined by two current state emergency management directors, W. Nim Kidd of Texas and Kevin Guthrie of Florida.

To represent the local perspective Jane Castor, Mayor of Tampa Florida (a republican turned democrat) and Rosie Corder-Stutz the Sheriff of Miami-Dade County Florida (republican). The Council also included Michael Whatley, the former chairman of the Republican National Committee. He had no prior emergency management experience before Trump appointed him Recovery Czar for Western North Carolina. The sole voice representing FEMA, and arguably the one person qualified to evaluate the agency, was Bob Fenton (who as of this writing is serving as the Acting FEMA administrator).

The membership of the Council is biased in multiple ways. It is important to understand this bias because it is reflected in their recommendations. First, the state perspective is disproportionately represented as compared to the local perspective. There is not a single local emergency manager, Tribal emergency manager, or territorial emergency manager represented on the Council. There is no representative from the private or nonprofit sectors. No emergency management researchers or policy experts are on the Council. No survivor groups are represented.

Second, there is very little emergency management expertise on the Council. While politicians are certainly involved in emergency management, they do not have the expertise required to recommend sweeping law and policy changes to the field. Only three Council members are emergency managers. Two out of these three, despite having long emergency management careers, have actively worked to implement the Trump administration’s illegal and violent immigration agenda. Governor Abbott used the Texas Division of Emergency Management to bus immigrants out of Texas. This created a situation in which state emergency management directors were pitted against each other. More critically, a three year old was killed while being bussed by the Texas Division of Emergency Management to Chicago. The same strategy was used by Florida. Further, Kevin Guthrie is using the Florida Division of Emergency Management to build and run two concentration camps. I have written about this extensively. These actions violate the spirit of the emergency management profession, which is rooted in a humanitarian mission, and violate the predominant existing emergency management Code of Ethics. Both have faced criticisms, which should make us question their moral standing and right to be the representatives of the field.

Third, there is a clear geographic bias. The Gulf Coast states are disproportionately represented with eight out of the Council’s ten members being from/ representing the region. The other two members come from North Carolina and Virginia. Emergency management varies widely across the country based on geography because of varying hazardscapes, risk profiles, government capacity, and culture. Emergency management in Louisiana necessarily looks very different from emergency management in Idaho.

Finally, there are a disproportionate number of republican Council members. Of known political affiliations only two members consider themselves to be democrats. For this reason, the report should be interpreted as a conservative document aligned with conservative ideology.

The make-up of the Council’s committee has visibly informed the recommendations provided in the report. Recommendations are disproportionately focused on state level issues and demonstrate a lack of functional and operational understanding of emergency management. The recommendations are overtly biased towards states that experience more frequent disasters (i.e., the Gulf) and persistently reflect right-wing ideology, with some recommendations coming straight from the Heritage Foundation and CATO Institute.

To better understand the frustrations among those in emergency management with the FEMA Review Council, it is helpful to know that a group already existed – the FEMA Advisory Council – with the responsibility of advising the administration on emergency management policy issues. The composition of the Advisory Council was much more representative of emergency management with individuals from all major stakeholder groups, coming from geographically diverse backgrounds, and various ideological perspectives. The Trump administration, in following a Project 2025 recommendation, unceremoniously disbanded the Advisory Council upon taking office.

According to the executive order, this was not necessarily intended to be an effort for comprehensive reform, but rather an effort to suggest “improvements or structural changes to promote the national interest and enable national resilience”. While some people in emergency management may agree with some elements of these recommendations, I do not believe they reflect the majority opinion in the field of emergency management. 

At various points, versions of the FEMA Review Council Report were leaked online. The report’s release was repeatedly delayed with little public explanation. Perhaps the most controversial moment came when Secretary Noem took a red pen to the report. Noem was fired before the final report was released and her seat on the Council was turned over to the current DHS Secretary, Markwayne Mullin. It has been within this political turmoil that the report was conceived and published.

The FEMA Review Council Report

The FEMA Review Council Report begins with a brief discussion of problems identified by “stakeholder and public feedback”. The majority of the report features 10 key recommendations along with implementation considerations. I have analyzed each, in some detail, below. These are non-binding recommendations. As the report acknowledges, the vast majority would require Congressional action. However, the legality of taken a given action does not seem to be a concern for this administration, as they have repeatedly demonstrated. Additionally, the political influence of the Council’s report, at this point, is still unknown. So, although the report does not carry the force of law, it is important to understand what is being recommended.

The caveat I gave when analyzing Project 2025 applies again here: “We must be careful to avoid normalcy bias but it is also not my intention to fearmonger or catastrophize. Rather I am looking to help us all understand the potential changes and their implications. This document is poorly written and suffers from a lack of understanding of emergency management structure and policy. As a result, it approaches being nonsensical at times and there is as much subtext as there are half-baked ideas. There are several places where assumptions do need to be made and there are gaps I have needed to fill to even be able to explain to the casual reader what is being suggested. I highlight where I have made assumptions and why, for the sake of transparency. Still, I am taking what is written literally.”

I encourage you to read the full report yourself. In an effort to keep my word count reasonable, I was unable to address every single change recommended by the Council. I prioritized analyzing changes that, if implemented, would have the greatest consequences and the changes I think are most likely to be implemented. I also prioritized analyzing any changes that have radically different implications if viewed within a certain political context. Several recommendations are written in such a way that seem benign but in the context of this administration’s actions, probably actually mean something much different. There are places where it feels like the Council is trying to get consequential changes implemented without people fully understand the ramifications. That may sound a bit conspiratorial, so here is an example that illustrates my point.

Within Recommendation No. 1 the Council notes that FEMA should:

“Promote the Integration of Additional Partners, to include Volunteer and Faith-Based Organizations: To enhance the effectiveness and inclusivity of emergency management efforts, the transformed agency should prioritize the integration of volunteer, faith-based, and nonprofit organizations into national preparedness, response, and recovery frameworks. The transformed agency should establish and maintain a national inventory of volunteer, faith-based, and 501(c)(3) organizations, and integrate pre-vetted private sector resources to create a comprehensive national capability picture.”

My entry into emergency management was through the nonprofit sector, I have researched disaster volunteers and nonprofits for the past decade, and teach a disaster nonprofit course. So, this one piqued my interest! At first, this recommendation seems perfectly reasonable. Collaboration and coordination between and among stakeholder groups is associated with more effective emergency management. Similarly, we often strive to be inclusive of different stakeholder groups (i.e., including the “whole community”). The nonprofit sector (here defined as voluntary and faith-based organizations) should be included in the emergency management frameworks. In fact, they are already included, but certainly more could be done to increase collaboration. Finally, if by “national inventory” of 501(c)(3) organizations, they mean a list of disaster nonprofits, then sure! This makes sense. As we say, it is always better to exchange contact information pre-disaster. (Although, I was a little surprised to read this does not already exist?) The lifespans of these organizations are quite variable, and often ephemeral, but it is worth trying! Being aware of what disaster nonprofit resources may be nearby when a disaster happens is objectively useful.

The nonprofit sector, including both volunteer and faith-based organizations, play a critical role in our emergency management system and increasing their involvement would help meet the increasing needs of communities across all phases. In the past decade, disaster nonprofits have struggled with a lack of capacity (i.e., volunteers, donations, resources) as they spread themselves thin over the growing number of disasters. It could be helpful if FEMA increased support to these organizations.

However, as I read those two sentences, a red flag went up that made me stop and reconsider what the Council was implying: inconsistent terminology. “Volunteer organizations”, “faith-based organizations”, “nonprofit organizations” and “501(c)(3) organizations” are used here inconsistently. Each term refers to a very distinct type of organization. Misusing these terms is common among non-experts but is strange to see in a government report like this one.

The Council says these organizations should be integrated into “national preparedness, response, and recovery frameworks”. If you have completed your first year in any emergency management degree program or done any basic emergency management training, you will immediately see the problem. The United States has response, recovery, and mitigation (which is inexplicably left out here) frameworks. We do not have a preparedness framework. Perhaps they mean the National Preparedness Goal? Great news! The nonprofit sector is literally included in the first sentence. (Incidentally the nonprofit sector is already integrated into the other frameworks as well. So, it is not clear what change is being recommended.)

Once I started looking at this section more closely, I noticed the emphasis specifically being put on “faith-based organizations”. This raised an even bigger red flag for me because of some broader political context. Using the term “faith-based organizations” is not unusual in the disaster context. Many of our disaster nonprofits are faith-based and it is very common for emergency managers to work with these organizations – the vast majority of them do incredible work. However, I wonder if there is some sub-text here that gets missed in a first read.

A list of “Private Industry and Faith-Based Organization” who engaged in “extensive participation” with the Council is provided on page 67. This includes Mennonite Disaster Service, Mercy Chefs, Samaritan’s Purse, The Salvation Army, and Convoy of Hope. These are five well known faith-based disaster nonprofits who have long responded to disasters across the country. Anyone working in emergency management is familiar with these organizations. It is also obvious to anyone working in emergency management what they all have in common. Every single one is a Christian organization and all but one of them is specifically Evangelical Christian.

It is also obvious to anyone working in emergency management which organizations are glaringly absent from this list. Every major religion has a disaster-related nonprofit working in the United States. You can look through the list of National Voluntary Organizations Active in Disaster (NVOAD) members to see the incredibly diverse collection of faith-based disaster organizations. From the Buddhist Tzu Chi Foundation to the Churches of Scientology Disaster Response and Islamic Relief USA, the gang’s all there! Not to mention the many non-faith based disaster nonprofits. Recently, a similar group of organizations were featured on FEMA’s social media. The comments show that others have noticed who is missing.

So, what is going on here? Are Evangelical Christian groups just the most engaged disaster nonprofits? Not in my experience! One way to know this is by reviewing the VAL snapshots which reflect the much more diverse range of nonprofit organizations engaging in disaster work across the country. (I happened to notice a recent change in these snapshots being posted on FEMA’s socials in the past two weeks. Interesting to see that coincide with FEMA’s latest leadership change.) Did the Review Council intentionally only seek out “extensive participation” from Evangelical Christian organizations? Perhaps it is the case that the Review Council sought “extensive participation” from other disaster nonprofits, but they did not want to participate. It is understandable that some of these groups may be hesitant to engage with this administration.

 There are many faith-based disaster nonprofits who do great work but there are others who use disasters as an opportunity for recruitment and conversion, unwanted preaching, and are discriminatory in their provision of aid. The federal government should not be funding these organizations. The federal government also should not be funding only faith-based disaster organizations from some religions but not others. 

Since returning to office, the Trump administration has had an aggressive stance towards some of the country’s most prominent disaster nonprofits related to their (appropriate) use of grant funding. For example, Habitat for Humanity was one of the organizations wrapped up in the unfounded investigation over the use of EPA climate funding. Catholic Charities came under intense scrutiny for their work providing humanitarian assistance to immigrants along the Texas border. Other disaster nonprofits have found themselves at odds and confused by various new DHS policies affecting their work.  

If you follow emergency management Congressional hearings you may have noticed a shift in recent years in how some republicans talk about disaster nonprofits. Following the 2016 Baton Rouge flood Representative Graves incredulously asked FEMA’s Tony Robinson: “We’re going to donate in charity and volunteer our way out of the fourth most costly disaster in the United States—flood disaster in United States history. That’s what you’re saying?” In 2024 following Hurricane Helene, Representative Perry was suggesting that FEMA model themselves after the United Cajun Navy, a search and rescue nonprofit. Bloomberg covered this heel turn and found that, of course, those involved with the various Cajun Navy groups (it’s complicated) know they could never replace FEMA and, in fact, believe FEMA should “spend more lavishly”. Interesting. Far-right politicians’ affinity for a certain kind of disaster nonprofit and volunteerism came into clearer view during the Helene response.

 Look, I do not know for sure what is going on with these two sentences about voluntary and faith-based organization. Maybe whoever wrote this section is just unfamiliar with these terms. Maybe it just happened to be the Evangelical Christian groups who wanted to be involved with the report. However, there is enough uncertainty here for me to not accept this recommendation at face value.

This is true of many, if not most, of the recommendations in this report. Where I am aware of additional context that may substantially influence what is meant by a given recommendation I have tried to include it for the purposes of transparency, while acknowledging I am engaging in some amount of speculation – as is required when being put in a position of having to “read between the lines”.

Part of the reason I found this important to do is because I have written this analysis for a more general audience. You are probably going to need some level of emergency management knowledge to make it through this, but I wanted it to be as accessible as possible. What I have written, however, still lacks the full nuance recommendations of this caliber warrant. If you are an emergency management policy nerd, you will note that everything is even more complicated than even what I have covered here. I hope this analysis is a starting point for further analysis and debate, if it is the case that any of these recommendations are pursued by the White House, the Department of Homeland Security (DHS), FEMA, or Congress. 

Finally, I want to be transparent about the lens through which I am analyzing these recommendations. I believe that if our intention is to meet the needs of people and communities across the four phases (i.e., mitigation, preparedness, response, and recovery) and for all hazards, then urgent changes are needed to our existing law & policy. My goal has always been, and remains, to make a more effective, efficient, and equitable emergency management system. Others have different goals when recommending emergency management policy changes.

Below you will first find a synthesis of persistent problems across the report’s recommendations. This is really the conclusion of my analysis, but I have provided it first because it will help you see the problems with many of the recommendations as you read those in more detail. This is followed by a section that breaks down all ten recommendations. This part is a bit more in the weeds and will be of most interest to those who do work related to emergency management policy.

Synthesis of Persistent Problems Across Recommendations

The FEMA Review Council Report is plagued by a foundational issue: the unspoken political goal of the Council was to provide a written justification to rebrand, shrink, or even eliminate FEMA, which are all unpopular ideas. The problem is that this goal conflicts with the reality of risk, emergency management research, bipartisan political thought, and public opinion. The Council was created to find justification for the Administration’s claim that emergency management needs to be returned to a “federally supported” model but we already use a federally supported model of emergency management. So, although the Council frames much of the report using terms like “return” and “federally supported”, the actual recommendations read as a series of confusing, inconsistent, and conflicting ideas.

There are several persistent issues that together undermine the Council’s ten recommendations.

1.Misidentification of Existing Problems & Proposal of Ineffective Solutions

The report often takes the approach of identifying problems related to given emergency management tasks, and then presenting various policy ideas as solutions to those problems. There are some instances where the Council identifies a problem but does not provide any supporting evidence. Readers familiar with emergency management may be left surprised and questioning whether the problem identified is actually a problem. (See No. 1)

In other cases, the Council identifies a legitimate problem in emergency management. For example, throughout the report they note that the current recovery process moves too slowly for individuals and communities. Although not provided in the report, there is extensive evidence of this claim throughout practice and research. However, even when a problem is correctly identified it is revealed in the proposed policy solutions that the Council does not actually understand the problem. As a result, most of the proposed solutions seem to be ineffective for actually correcting the problem.

A notable example of this is the suggestion that potentially do a “one-time EMPG increase to better facilitate the return of responsibilities” would help increase state and local capacity. Putting aside that the Council does not say how much that one-time increase would be (are we talking a couple thousand dollars or millions?), it is unclear how a one-time infusion of funding could increase state and local capacity in the long-term. Particularly, if as stated elsewhere on the report, federal funding is not allowed to be spent on equipment. The support that state and local governments need to grow their capacity is an increase of sustained and reliable funding to hire permanent emergency management staff. That cannot come from a one-time increase in EMPG funding.

At times it seems the Council has some clarity on the key problems in emergency management but could not recommend the obvious solutions because they do not align with the administration. Many of the problems identified by the Council based on public comments and their survey find broad support in practice and research but the Council does not systematically address those problems. At other times it feels as though the solution came to the Council, before they had identified the problem it might “solve”.

2. Failure to Provide Needed Detail About Recommendations

As is often the case with these types of reports, it is difficult to interpret the scope and intention of the recommendations– the devil is in the details and at only 74 pages, the details just are not here. I personally struggled with this because it made me question if it were even worth it to write an analysis of the recommendations. However, the report does provide greater detail than other recent proposals for emergency management such as Project 2025. As I wrote previously, we have seen that 5 out of 8 Project 2025 policy recommendations have at least been discussed by the current administration, if not implemented, since taking office. So, despite the lack of detail, taking these recommendations seriously, even when they do not sound serious, is likely in our best interest.

I did not expect a report produced under these political circumstances, and with this make-up of committee members, to produce recommendations with the kinds of policy details needed for implementation. However, I am taken aback by the profound lack of detail presented here and particularly for the recommendations that suggest upending decades of existing law and policy. As a result, it is unclear how the Council would expect FEMA or Congress to implement the recommendations as written in this report.

I have found this lack of detail has been the primary challenge in analyzing the recommendations. Some have so little meat to them that analyzing them feels futile. The vagueness of the recommendations is also a challenge because they allow for a wide range of interpretations. On the final episode of American Emergency, Micah Loewinger described the report as a Rorschach test, with everyone seeing something different. It is possible to read many of the recommendations as a far-right policy proposal, and another way to read them as a left-wing policy proposal. 

For example, the observation that a “disaster industrial complex” has emerged (in Recommendation No. 6) sounds like it could have been written by Naomi Klein. When this recommendation leaked months early I even joked in my newsletter that perhaps the Council had gone so far right that they ended up on the left (and more seriously recommended some legitimate books about disaster capitalism and emergency management privatization for those who were interested in learning more). It does seem to be politically convenient to release a report that adjusts to the eyes of the beholder, but it is unclear if the vagueness is intentional.

A consequence of this, however, is that it is especially important to remember who wrote this report and who it was written for. The inclination to wonder if these recommendations represent some kind of bipartisan consensus does not align with the reality of the very specific agendas of the people involved in producing the report. A critical interpretation of these policy recommendations viewed through a right wing lens seems justified considering the current administration has approached FEMA with hostility since taking office.

3. Driven By Ideology, Not Evidence

The justification for the recommendations vaguely rests on the “public comments and stakeholder engagement” conducted by the Council. The report reviews their effort to hear from a range of stakeholders. While there are certainly concerns with basing broad policy reforms on only the methodology used in the report, the bigger issue is that many of the core recommendations produced by these efforts do not align with the recommendations ultimately included in the report.

There are only a handful of citations included in the entire 74-page report, with almost all simply referencing other FEMA produced documents. There is a single news article cited and only four vague references to GAO reports. A few recommended changes rest on internal FEMA data that, to my knowledge, is not public (for example: the amount of money spent on overhead as described in Recommendation 6). It would be helpful if that data, including explanations for how terms like “overhead” are being defined, were made public and available for independent analysis.

I did not expect to see emergency management research deep cuts here; the people on this committee do not have any familiarity with that work. However, there is an entire discipline that studies the exact issues the Council claims to be trying to find solutions for and none – seriously, none – of that work is considered in the report. The committee members have staff – they should have done more research. Even research that has recently been funded by FEMA and is directly relevant to topics addressed in the report such as state and local emergency management capacity is absent. (For example, see the recently released study on State, Territorial, Tribal, and Local emergency management from Argonne National Laboratory. If your job is to propose policy changes that affect the safety and well-being of the entire country I believe you should be expected to provide evidence that your recommended changes will do that.

The report provides nearly no evidence for any of their proposed recommendations, and, in fact, there is often substantial evidence that undercuts their recommendations. So, while there is some empirical research to support some of their claims, problems, and solutions, the evidence simply does not exist to support other parts of the report either because the research has not been done, or because existing research contradicts their claims (e.g., staff reductions).

As someone who is familiar with the existing research on emergency management policy issues, I am able to read through this report and know if the recommendations could be supported by empirical research. The average reader, and even most who work in emergency management, simply do not have this level of familiarity and therefore cannot effectively assess the recommendations. In that sense, the exclusion of easily accessible reports such as those from the GAO and the Argonne Study feels intentional.

This lack of evidence further supports the need to consider the report as a political document, and not a legitimate effort for FEMA reform. It was not created through a legitimate policy process; this is reflected from the composition of the Council to the multiple versions of the report that were re-written to better align with particular political beliefs. Ultimately the Council has chosen to employ the same pseudo-intellectualism of Project 2025 in that it can read as somewhat reasonable to those unfamiliar with existing emergency management policy and who do not have the benefit of understanding the underlying political sub-text.

4. Internal Inconsistency  

There is a tremendous amount of inconsistency within and between the Council’s recommendations. For example, the Council includes a recommendation to de-privatize the consulting aspect of emergency management (No. 8) while simultaneously advocating for the increased privatization of flood insurance (No. 7). They also recommend policy changes that realistically would require states to hire consultants (No. 4, 5, and 6). At the same time, the Council also recommends specifying that a certain percentage of HMGP funding be spent only on NFIP-related mitigation efforts (No. 4) but then recommend “depopulating” NFIP so that the federal government stops subsidizing flood insurance (No. 7). Which is then in direct conflict with their recommendation to provide tax breaks to people who carry private flood insurance (No. 6).

Relatedly there is persistent confusion and inconsistency in the underlying measures the Council recommends using for various programs. Throughout the report the Council uses measures of impacts, hazard characteristics, capacity, capability, need, and hazard event type interchangeably and/ or without explanation as to why a measure may be more appropriate for a particular program as compared to another. This contributes to the overall inconsistency and is also a source of the likely inequitable outcomes these recommendations would create.

It is unclear if these issues are a product of sloppy writing, lazy thinking, internal disagreements, ideological divisions, or an attempt to appease outside political influences.

5. Failure to Reckon with State & Local Capacity

A key argument of the Trump administration, Project 2025, and now the Review Council Report is that state and local governments should be contributing significantly more to emergency management. In my experience this is a belief that is shared among everyone who works in emergency management. As mentioned above, a recent national study led by Dr. Amanda Savitt at Argonne National Lab evaluated state, territorial, tribal and local emergency management agency capacity. The findings demonstrate the severity of the capacity problem nationally and lend support for the widespread understanding that changes are needed.

Where opinions diverge significantly is related to why sub-national capacity needs to grow vis-à-vis FEMA’s involvement in the broader emergency management system. The Council’s argument is that state and local capacity needs to grow so they can take over key programs currently run by FEMA (i.e., mitigation grants, individual assistance, and public assistance). Others, me included, argue state and local capacity must grow to reduce the number of unmet needs created by our current system. I would argue emergency management capacity at all levels of government needs to grow to keep up with our increasing risk. In other words, states and locals need to do more, but so too does FEMA and the federal government more broadly.

The Council proposes several recommendations that would require state and local emergency management agencies to significantly grow their capacity. Even smaller recommendations such as creating (or building out) state level training could be a huge and expensive undertaking for many states. It is the scale of capacity increase, particularly at the state level, that is most alarming. This is not state emergency management agencies hiring a few more people, we are talking dozens and dozens of people (or more!) even in small states – and hundreds of people during the recovery from major disasters. There is no indication FEMA would help provide funding to states for pre-disaster hires, and the amount of FEMA funding that could be spent on post-disaster hires is unclear (see Recommendation No. 6 and 8).

Despite acknowledging the need for state and locals to grow their capacity, the Council falls far short of grasping the current state of emergency management (and even broader government) capacity at the state and local level. This is where the Council’s bias towards Florida (and a lesser extent Texas) becomes a problem for all of us. Florida has more emergency management capacity than most states (as do California and Texas) so their perception of what it would take to make this work is radically different than others. (Although, I will note that despite Florida have greater capacity, local emergency managers still have highlighted how a lack of resources prevents them from effectively doing their jobs and have already raised concerns specifically about the report.) These recommendations do not at all account for the reality faced by the majority of states, and especially smaller rural states. The directors of Nevada Emergency Management and Vermont Emergency Management have both already spoken publicly about their concerns with these recommendations.

The Council does not say how state and locals will fund these new responsibilities. Nothing indicates the Council believes FEMA should help states and locals with these costs. In fact, one recommendation suggests FEMA will further limit funding states have been using to bolster capacity during recovery (No. 8). It seems they expect states to figure this out on their own. Perhaps some governors and state legislatures will be supportive and pass the many millions of dollars in funding that would be required for them to even maintain their eligibility of FEMA assistance. However, it is quite likely that others will not. In fact, in the past when federal emergency management grants have been cut state and local agencies have tended to be on their own to figure out how to continue without that funding. States do not tend to step in and make up the difference. On the other hand, increasing federal funding to enable states and locals to build their capacity could be a more effective approach based on past experience (see for example: EMPG).

6. Mistakes Speed for Efficiency

A frequent problem in emergency management is that it feels like everything from mitigation projects to rebuilding communities moves too slowly. Anyone who has tried to get a mitigation grant from FEMA or individual assistance post-disaster will attest to this issue. In fact, researchers have long explored this issue as has FEMA, Congress, and others involved with the field. There are a lot of ways to make emergency management move more quickly and the Council often claims their recommendations will do this. Unfortunately, the Council is equating speed with efficiency. These are not the same thing. Having an efficient (and effective) system means that sometimes you need to slow things down to get them right, rather than just barrel through and get things done quickly. Speed may be an element of an effective recovery, but it is not what makes for an effective recovery which seems to be what the Council is suggesting. I do not think it is helpful to speed up a process if that process does not meet the need it is meant to address.

7. Fails to Consider Emergency Management as a System

The Council has fallen into a common trap – they have recommended changes to one part of emergency management (the public sector) while ignoring the effects of those changes on the other parts of emergency management (the private sector, nonprofits, other government agencies). Emergency management is a system. The changes made to one part of that system affect the other parts of that system. This is why I strongly advocate for any discussion of reform to be comprehensive.

The Council has made recommendations for FEMA in isolation from the broader recovery system. As a result, the nature and capacity of all the other stakeholders are left unaccounted for. This is where the lack of broad representation of stakeholder groups on the Council becomes a real problem.

A clear example of this in the report is the Council ignoring the many factors that influence recovery. The empirical research on disaster recovery has grown substantially in the years since Hurricane Katrina and the levee failure. That literature provides an empirical foundation for understanding the many factors that influence the recovery process and outcomes. This report does not engage with that knowledge. As a result, their recommendations do not align with what the research suggests would make for better recoveries.

The changes proposed to Individual and Public Assistance rest on the assumption that the reason recovery takes so long is because of the complexity of FEMA funding. That is one reason, but it is not the only reason. I am not even sure it is the biggest reason. The speed and amount of insurance payouts, speed of federal funding from other agencies, decision-making and timing of decision-making among local and state government officials, contractor shortages, supply chain issues, meeting cost-shares, complexity of recovery planning (especially when done in a way that engages the “whole community”), local and state capacity, the capacity, speed, and involvement of the recovery nonprofit sector, and the sheer amount of time it takes to build things, all affect the recovery process and outcomes. The Council does not address any of these factors.

Finally, I have done my best to understand what the Council is recommending. However, because of the lack of clarity in the report on certain details, it is very possible I have misinterpreted some of what has been written. I do recommend reading the report for yourself.

FEMA Review Council Recommendations

Recommendation No. 1

“Equip States, Local governments, Tribes, and Territories to lead disaster response with the federal government in a supporting role” 

Key Recommendation: Lower levels of government should lead response, with the federal government supporting that work. 

Critical context: Our system is already designed this way. (There are very rare instances during catastrophic events where local leaders may become incapacitated and outside leadership is needed.) I have never encountered anyone who disagrees with this approach. When disasters happen, locals respond and then as they become overwhelmed outside people and groups converge to help.  

The inclusion of this recommendation implies our system is not adhering to this approach. Specifically, that the federal government is overreaching into what is supposed to be the responsibility of state and local government. As evidence, the Council says that “most of the public’s first instinct during a major natural disaster is to rely on or expect the federal government to complete a whole-of-government national response irrespective of whether the incident necessitates any federal response” (pg. 7). That may be true, but that is not evidence of federal overreach actually happening. It just shows that the public misunderstands the current roles and responsibilities of the various stakeholders who make up our emergency management system. This is a well known issue in the field (see for example: IAEM’s recent effort for Emergency Management Awareness Month). As shocking as it may be, the average person has not read the National Response Framework. It is a public education problem, not an operational one.

In the absence of any credible evidence that FEMA has taken over leading responses, you may wonder why this is included as a recommendation, and especially as the first recommendation. Here’s the sub-text: Since returning to office, members of the administration have taken to declaring that our approach to emergency management should be “federally supported, state led, and locally executed”, implying that it currently is not. By doing this, the administration is making the argument that FEMA has become responsible for leading the response to every disaster, big and small, that happens across the country as a justification for shrinking the agency and pulling back from federal support to emergency management.

Specific Changes: To return “the federal role from leading to supporting” the Council recommends two categories of changes. The first is to create “a national standard for incident response and recovery”. They recommend the adoption of a national capability standard, scalable training, a common exercise approach, increased catastrophe planning, and professionalization of emergency management. The second category of changes is to increase the ability to “share and coordinate resources”. They recommend a revitalization of the Unified Resource Catalog, use grants to create mission-ready teams instead of purchasing specialty equipment, improve credentialing within NIMS and NQS, and do more to integrate volunteer and faith-based organizations into response.

Critical Context: Given the lack of detail and political context within which this report was created it is difficult to know or trust how the changes in this recommendation would be implemented. A version of these changes could mostly just double-down on what FEMA is already doing (further contradictory evidence of the need to “return” to a different model), but there are also versions that are not beneficial emergency management.  

I will use their mention of professionalization as an example. The field of emergency management has been professionalizing for many years. Some argue professionalization has been achieved; I think we are close. The field widely supports professionalization, so this recommendation is likely well received. Since this report’s focus is specifically about FEMA, the inclusion of this recommendation implies they believe the agency should be involved in professionalization. However, they do not say in what way. Without any explanation, it is impossible to know if the Council intends this to be generic support of the field as a whole continuing to professionalize or an indication of bigger FEMA-directed changes? FEMA certainly has a stake in professionalization, but it would be inappropriate (if even possible) for the actual process of professionalization to be driven by a federal agency.

A current ongoing frustration with FEMA that demonstrates why the agency should not be the arbiter of professionalization is related to their unwillingness to distinguish between training and education. Both are critical aspects of professionalization. So, while FEMA’s support in professionalization could be helpful, a FEMA-centric professionalization effort could undermine the role of other stakeholders. In fact, it could push FEMA from a position of support to one of leadership, the very thing this report claims to correct.

Conclusion: The commonality across the changes in the first recommendation is that FEMA should do more. In fact, depending on implementation, some could require FEMA to lead, which counters their stated goal. For example, by definition catastrophe planning needs to be federally led. Standardizing emergency management nationally requires increased federal involvement and oversight of state and local governments. This would require substantially more federal coordination including, presumably, more resources going to state and locals. Unless the Council intends for these to be unfunded federal mandates. The challenges implementing NIMS post-9/11 seem important to remember here.

Recommendation No. 2

“Enhance Critical Federal Programs & Resources to Support Communities”

Key Recommendation: “The federal government must maintain the ability to provide federal support resources through a single federal entity”.

Critical Context: No significant changes are proposed here. Instead, the Council continues to lay out an argument for the value of FEMA (or at least a federal emergency management function). They argue FEMA is critical to national security, noting the agency’s responsibilities in building cyber-attack response capabilities, supply chain resilience, and continuity of government. FEMA’s work does contribute to national security, but this particular framing is almost always employed as a strategy to make federal emergency management spending palatable to republicans. This recommendation, to me, reads as a direct rebuke to the President’s repeated threat of eliminating the agency. 

Recommendation No. 3

“Realign the Criteria for Federal Disaster Assistance”

Key Recommendation: Approve fewer Presidential Disaster Declarations to minimize federal involvement in disaster response, recovery, and mitigation. The Council recommends three specific changes to achieve this: 1) raise the per capita indicator, 2) create a measure of state capacity, and 3) establish a state deductible.

Specific Change: The Council recommends “resetting” the “per capita indicator” for Public Assistance. Public Assistance is the federal funding source for response costs like sheltering and evacuation, and recovery costs like debris removal and rebuilding public infrastructure. This funding is “unlocked” by a Presidential Disaster Declaration. FEMA uses the per capita indicator to measure the amount of damage per capita. It is used to help FEMA decide if they will recommend to the President that a declaration is needed. Critically, the per capita indicator is just an indicator – it is not required that a community meet the threshold to receive a declaration. The Council recommends changing the per capita indicator from $1.94 to $2.99 to more fully account for inflation since it was created in 1986. (Here’s a longer explanation and a shorter explanation of the per capita indicator.)

Critical Context: Increasing the per capita indicator was also recommended in 2025 (you can read my analysis here). In 2025, when Cameron Hamilton was running FEMA, a leaked internal memo recommended increasing the per capita indicator to a shocking $7.56. Comparatively the Council’s recommendation is much more palatable.

Importantly, there are serious people from FEMA who believe the threshold should increase. The reason I hear them give is that FEMA does not have the capacity to respond to all of the events that are receiving declarations. This is a very real problem. As much as we lack state and local capacity, we are also increasingly hitting our federal capacity (for example: the 2017 hurricane season, COVID). These folks argue it would be better to save their capacity for the bigger events rather than run themselves into the ground on smaller events. My question is why responding to fewer events (and therefore, presumably, leaving needs unmet among affected communities) is presented as the only solution. The other obvious solution is to increase FEMA’s capacity to enable the agency to meet the needs associated with the increasing number of disasters.

The $1 threshold set back in 1986 was not rooted in an evidence-based analysis of what level of damage overwhelms state capacity. In fact, to my knowledge, this has never been studied. It may be the case that the per capita indicator should be lower or higher. It may also be the case that the per capita indicator is a bad measure for when FEMA assistance is needed. In the absence of rooting this recommendation in empirical evidence, it seems to be based on an ideological belief that the federal government is spending too much on disasters.

Implication of This Change: Any increase to the per capita indicator (assuming that is what the President bases his declaration decisions on) would mean fewer communities receive disaster assistance. Fewer disasters would be granted a disaster declaration which means they will not receive response, recovery, or certain mitigation funding through FEMA. These would be the smaller disasters that already do not capture widespread media attention, volunteers, and donations. State and locals would need to find alternative funding sources or debris will remain in the streets, roads will not be rebuilt, and schools will sit damaged.

Specific Change: The Council recommends creating “common criteria” to evaluate when state capacity and capability is overwhelmed. The Council does not provide the criteria.

Critical Context: The per capita indicator is a measure of the severity of damage. This is one way to assess the size of a disaster, but it is not a measure of whether or not a state needs federal assistance. Two states that have the exact same amount of damage may have two different needs. For example, Florida and New Hampshire could receive the exact same amount of storm damage but New Hampshire would need more assistance than Florida because they have significantly less emergency management capacity. Communities that have more and better insurance, are wealthier, and/or have more disaster experience will need less assistance as compared to communities that are underinsured, do not have many resources, and/or have little disaster experience. A Presidential Disaster Declaration is meant for when state and local efforts need to be supplemented by federal assistance, so assessing whether or not state resources are over capacity is appropriate.

I can see a way in which this change could benefit low-capacity states. Even if they do not hit the per capita threshold, if they have minimal capacity, they could still get assistance (an informal calculation Presidents have long considered). However, reading this in the context of the other capacity-related changes in the report (see Recommendations 4 & 6) I can see a way this change would reward states with greater emergency management capacity, while those without it would be punished. Without the Council proposing actual criteria, it is impossible to evaluate this recommendation.

Specific Change: The Council recommends “an annual calendar year minimum expenditure should be established” for states based on size. The Council said detailed guidance on this recommendation was included in the Appendix. I am assuming this is a reference to part of a chart on p. 17 that says every state must have 5% of their state budget set aside in a cash reserve.

Critical Context: While the Council did not use the term, this sounds like a version of the “Disaster Deductible”. This is an idea that has floated around emergency management circles for many years. President Obama’s former FEMA Administrator Craig Fugate has advocated for this strategy. Interestingly, it was also included in Project 2025. Again, the recommendation could help encourage states to financially contribute more to disasters, but I imagine certain states may take significant issue with this approach.

Conclusion: The Council recommends that specific measures of both severity (i.e., the per capita indicator) and capacity/capability (i.e., using unspecified criteria) should be used to determine if a disaster warrants a Presidential Disaster Declaration. However, the Council never reconciles how these two measures will be weighed in relation to one another.

Notably, changing the per capita indicator and the addition of a formal capacity measure would not require legislative changes (the state deductible would). As the Council notes, the President could implement these changes today when deciding on whether or not to grant Presidential Disaster Declarations. The President has nearly complete autonomy over the declaration process. FEMA may suggest to the President that these criteria are used but he would not be legally bound by them.

However, at present Trump has broken the tradition of not politicizing the declaration process (something the per capita indicator can help protect against). A recent analysis found a clear pattern of the President issuing more declarations for events of similar size to red states as compared to blue states. It is also taking Trump far longer to approve blue state declarations as compared to red state declarations. One might call this political bias.

As long as the President continues to politicize declaration timing and decisions, the changes recommended by the Council seem unlikely. So, while I strongly disagree with the politicization of the Declaration process, I have long argued that the flexibility provided by the Stafford Act is beneficial to emergency management – particularly in the case of events occurring that do not fit our traditional, or historic, idea of what qualifies as a disaster requiring federal assistance.

Finally, the Council has quietly slipped in some bold claims about the Stafford Act in this recommendation. This requires its own separate analysis but ultimately, they seem to be suggesting a re-interpretation of the Presidential Declaration process. The Council is arguing an interpretation of the Stafford Act which suggests the President has less autonomy over the declaration process than what has currently and historically been exerted. The suggestion that presidential declaration authority should be limited reads as a direct rebuke to a President that is the first to have systematically politicized the process.

Depending on how these changes are implemented they could do much more than “realign” the criteria for FEMA’s involvement in disaster: they could fundamentally alter who receives help. Specifically, fewer communities would receive help from FEMA post-disaster.

Recommendation No. 4

“Replace the Hazard Mitigation Grant Program with a Two-Phase Funding Structure”

Key Recommendation: The Council recommends turning the Hazard Mitigation Grant Program (HMGP) into the “Refined Risk Reduction” (R3P) program. The primary goal seems to be moving mitigation dollars to states earlier in the recovery process so they can better integrate mitigation into recovery. They seem to argue that by making this a state-level mitigation program, projects will happen faster.

States would be eligible for up to 15% of the estimated total amount of federal assistance for the disaster (which will be based on a parametric measure, see No. 6). The Council recommends a 50-75/50-25 cost share with states receiving a higher federal-share based on good state emergency management performance (i.e., “states and territories with approved hazard mitigation plans and a history of successful HMGP performance, encouraging identification and sharing of best practices, inventorying high risk properties and building sound funds management systems” (p. 9)). 

R3P would have two funding phases: a Rapid Mitigation Advance and a Strategic Mitigation Allocation.

Critical Context: First, HMGP, like all FEMA grants, is quite complex. It is unclear which existing aspects of the program would continue in R3P. It looks like the Council is recommending a more federally beneficial cost share (currently the cost-share for HMGP is 75/25 between federal and non-federal). It also seems the Council is lowering the total eligible amount to 15%. Currently 16 states qualify for up to 20% funding, and it is unclear if that option will still be available.

Relatedly, the current HMGP program is already structured in a way that rewards state investment in mitigation (i.e., the enhanced mitigation plan). Given they do not mention the current enhanced mitigation plan approach I assume they are recommending something more extreme. If that is the case, I am concerned that this could further grow the national mitigation-gap. This could create a self-fulfilling mitigation cycle in which mitigation dollars pour into states like Florida and Texas while other states like Alabama and West Virginia get shut out of mitigation dollars and see their risk increase. In other words, vulnerable states will systematically be kept from access to mitigation funding. In the absence of that funding their risk will increase. Meanwhile, states that have the resources and political support to do more mitigation will continue to be rewarded with a disproportionate amount of our national mitigation dollars.

Finally, it is notable that none of the other existing mitigation programs were addressed by the Council. This is another example of how the problems identified, and recommendations suggested through the public comments and survey process, are not reflected in the Council’s recommendations. For example, stakeholders persistently recommended increasing funding for BRIC through the survey and public comments. The Council ignored this consensus. My guess is this was a partisan political decision. During the writing of the report, the Trump Administration tried to end the BRIC program, and twenty-three states successfully sued the administration to have it reinstated.

Specific Change: The “Rapid Mitigation Advance” would be given to the state within the first 30 days of a declaration. It provides up to 5% of the federal government contribution for the disaster to facilitate immediate residential mitigation and for communities impacted by the event or in other high-risk zones. All projects must be funded within one year and all funding spent within 8 years.

Critical Context: Some communities have existing mitigation plans and want to implement specific shovel-ready projects post-disaster. For example, some communities have standing waiting lists for buy-outs. Within 30 days of a declaration, under this model, theoretically, a homeowner could learn federal funding is available to buy them out. They would still need to go through the rest of the buy-out process but, in theory, this could speed up the recovery for those homeowners.

Yet, this is one of the places where the Council equates speed with efficiency. Running mitigation programs for individuals (such as buy-outs) and completing mitigation projects generally is complicated, especially for states that do not have extensive experience with these types of programs/ projects. Do states have the capacity to complete this work effectively on the provided timeline while simultaneously completing overall recovery on their proposed expedited timeline (No. 6)?

While it is certainly the case that emergency managers have a responsibility to pursue mitigation in the communities they work with post-disaster, this is a delicate and complicated issue. The Council does not acknowledge that funding is not the only barrier to post-disaster mitigation. Survivors and local communities are often hesitant about implementing post-disaster changes to their communities. Recovery on its own is overwhelming enough, the added pressure of having to figure out what changes should be made can be too much. At the same time, other communities may be ready for those changes – especially if they have been through multiple disasters. The issue here is that every community is put on the same expedited timeline. If pre-disaster mitigation planning, which includes widespread community involvement and support, has not been done this could lead to even more turmoil in communities going through recovery.

Some mitigation projects can be conceived within a year and implemented within eight years. Others that are bigger and more complex can easily run into unexpected problems that push planned timelines. Mix in some unexpected local legal issues, state agency staff turnover, supply chain bumps, another flood, worker shortages and eight years passes by faster than it seems. As communities have to do more, and bigger, mitigation projects related to climate change, it could be quite likely that project timelines would expand.

My guess is that this change could foster the implementation of ineffective mitigation projects as communities rush to meet FEMA deadlines without the ability to request extensions. I absolutely appreciate the need to put some pressure on states to move funding down to the local level. I imagine there are some local emergency managers who are in communities that could benefit from this kind of federal pressure on their state agencies, but the reality is that different disasters are going to unfold along different timelines. The Council recommends that no extensions be given. [For a longer discussion on the eight-year time limit see Recommendation No. 6.]

Specific Change: The “Strategic Mitigation Allocation phase”: “Within the first six months provide up to the remaining 10% of the federal government contribution to improve the performance of the NFIP by mitigating properties and critical infrastructure based on Federal Administration priorities”.

Critical Context: You will notice I included the complete quote associated with this change. That is because I find it among the most baffling things in this report and I want you to see it with your own eyes. In the opening of this recommendation, the Council notes one current problem with HMGP funding is that it has been used with “a narrow focus on certain risk while neglecting others”. I am finding it impossible to reconcile that critique with the recommendation for this Strategic Mitigation Allocation phase which suggests this funding specifically be used for flood mitigation as it relates to NFIP. I have spent a considerable amount of time wondering if this could be a typo. Did the Council mean to mention NFIP as one example of how this funding could be used? The Council cannot mean that up to 10% of post-declaration mitigation funding should be dedicated only to flooding. Yet, in the slightly more detailed discussion of this recommendation on page 34 they continue the focus on the NFIP.

This analysis needs to be based on what is actually written, so: While it is certainly the case that flood mitigation should be a priority in communities across the country, FEMA should help fund mitigation projects for all types of hazards. It is unclear why such a significant source of mitigation funding would be limited to only one hazard.

Specific Change: The Council recommends that “states must take on greater program management responsibility” for this mitigation program. Standardized oversight requirements will be set by FEMA but implemented at the state level.

Critical Context: A complete picture of what this program looks like, and how it differs from the current approach, is unclear based on the minimal details provided by the Council. What is clear is that the Council is expecting the program to be run in a way dictated by FEMA, and in alignment with “national priorities for mitigation funding” (i.e., not climate change-related in this administration) but putting the responsibility of doing so onto the states. This again underscores this odd argument that having the states, rather than FEMA, manage funding will speed up the process. If the states still have to check all the same boxes FEMA was having to check, will it actually be faster?

The amount of state-level infrastructure that would need to be built out mitigation offices is astounding. We have many states that have 2 or 3 people in mitigation offices -- you’re talking about needing to triple or quadruple staffing at the state level just for these mitigation changes – in every single state, territory, and many Tribes. The recommendations do not include any additional federal funding to support this build-out, especially because these changes would have to be in place pre-disaster. The 30 day window does not allow states to pull this together post-disaster using PDD funds as a crutch. These also are not limited time positions, to be effective it seems they would need to be sustained positions.

Specific Change: The Council recommends that all open disasters transition to R3P.

Critical Context: The Council does not provide even a single detail for this transition. If you are a state with a disaster that has been open for nine years, and you are still actively spending HMGP funds, do you now lose that money? Would projects already approved and started be allowed to finish even if they are past the eight year timeline? For example, has all the COVID HMGP funding been spent? Under the Council’s recommendation it would need to be spent by early 2028. This would mean any unspent HMGP funds associated with the 2017 hurricanes would be unusable. This could have big implications for communities across the country. It also seems quite notable that for the majority of time they have been in office, the Trump administration has not approved any HMGP funding.

Conclusion: It is difficult to say how big these recommended changes are based on the exceptionally limited number of details provided by the Council. There are additional issues here that are worthy of further analysis. I did not even touch on the massive changes to the environmental review process! But, I think I provided enough evidence to at least raise substantial concerns with the Council’s orientation towards mitigation.

As I have noted, it is important to consider these recommendations in relation to one another. I have already mentioned that this recommendation will interact significantly with the Public Assistance changes coming up in No. 6. However, I want to draw a connection between this change to HMGP and No. 3. When fewer states receive disaster declarations, it means fewer states are able to access this pool of mitigation funding. So, if the changes in No. 3 are implemented, it means not only missing out on reimbursement for response, and help with recovery, but also fewer federal dollars going to mitigation.

Recommendation No. 5

“Streamline the Individual Assistance Program into a Single Direct Payment Program”

Key Recommendation: The Council recommends consolidating existing Individual Assistance programs into the Framework for Accessible Individual Relief (FAIR) Program which would provide “one direct payment to survivors whose homes are uninhabitable after a disaster”. The Council recommends a state-managed Individual Assistance program for states who “wish to do so” but otherwise FAIR will be administered by FEMA.  

Critical Context: The report explains that the Individual Assistance Programs (i.e., the money that goes directly from FEMA to individual survivors for response, housing, and other recovery costs) is “overly slow, confusing, and inefficient”. This is an extremely well documented issue. I wrote a piece for the New York Times about it.

Specific Change: The Council recommends the elimination of federal involvement in evacuation and temporary emergency sheltering. Specifically, they say, “transfer evacuation and temporary emergency sheltering responsibilities to state, tribal, and territorial (STT) governments”.

Critical Context: I interpret this as a recommendation to end the “mass care and emergency sheltering” program. (This is funding is actually through Public Assistance which is addressed in No. 6 (see page 17 of this document)).

The vast majority of evacuations and shelters are already handled locally across the country. The federal government helps with sheltering and evacuation when they exceed state, local, and nonprofit capacity. FEMA can be involved by sending people to help open shelters or sending additional shelter resources. They also become involved by reimbursing sheltering and evacuation costs through Public Assistance for certain disasters. The Council believes states and locals should completely take this over.

One of the best kept secrets in emergency management is that we have a shockingly small national sheltering capacity. For most events this works out because, as we know from the research, most people prefer staying with friends/ family, or at hotels, rather than community shelters. However, some events, due to scope of the disaster, timing of impacts, or a lack of transportation and financial resources among evacuees, need greater sheltering capacity. At times federal assistance is absolutely needed. In any sheltering operation that crosses state lines, federal involvement can be helpful to ensure an effective distribution of resources. States competing for sheltering resources during multi-state incidents is not good for anyone. Over a quarter of a million people needed sheltering assistance during Katrina and the levee failure. No state could have managed that alone.  

The other best kept secret in emergency management is that many governors and mayors do not like calling for evacuations if they do not know who is picking up the tab. Mass evacuations are hugely expensive. One reason big hurricanes get a pre-landfall declaration is to reassure states that the federal government will chip in on the evacuation costs. The Council recommending FEMA no longer reimburse mass evacuations is deeply dangerous. It is fair to argue this change could directly lead to increased disaster deaths.

Specific Change: The Council recommends dividing disaster survivors on the basis of either being a homeowner or a renter. This distinction determines all of their aid eligibility from FEMA.

Critical Context: This is a baffling recommendation. The Council is using a survivor’s housing designation and damage to their housing to determine all of the assistance they may receive from FEMA. This includes all the other needs that existing Individual Assistance programs may cover (i.e., Other Needs Assistance including personal property replacement, transportation, moving and storage, medical and dental, funeral assistance, and childcare). This is baffling because many of these other needs are unrelated to someone’s housing status. It is not at all clear why the amount of damage someone’s home experience has to do with something like medical expenses. In fact, I have to imagine that it is more likely for someone who owns their home to have health insurance as compared to someone who is experiencing homelessness. As such, in addition to this being a nonsensical measure of individual need, it also leaves gaps in potential assistance.

The Council does address how people who are neither renters nor homeowners will receive aid leaving me to expect they will not. Anyone who is experiencing homelessness would also be ineligible for aid. Anyone who sleeps on the streets, in their car, in a hotel, or on a friend’s couch may still incur significant costs (e.g., medical, lost personal items, transportation replacement, funeral expenses) from a disaster but would not receive any assistance from FEMA under the Council’s recommendation. Currently individuals who can demonstrate they lived in the affected area pre-disaster, even if they do not have a permanent address, may be eligible for some forms of aid.

Specific Change: The Council recommends changing the eligibility for homeowners to receive disaster assistance. They recommend that a homeowner receive up to 15% of “the local government’s assessed value” (capped at a $1 million valuation) of their home based on level of need.

Critical Context: I have long advocated FEMA should give more money to disaster survivors. This recommendation raises the cap of what an individual could theoretically receive from FEMA to $150,000. Currently the maximum you can receive is $43,600 for housing and $43,600 for other needs which gives you a maximum of $87,200 for recovery.

However, you might be aware that most people do not live in million dollar homes. I wondered what this formula would look like for the average U.S. homeowner. So, I did some quick math.

The average home value in the U.S. is $368,198. Using the Council’s 15% rule, that means the average homeowner is eligible for $55,229 in FEMA assistance. That is $32,000 less than the average American homeowner is eligible for today. Further analysis here is necessary to understand what this distribution looks like in different parts of the country. For example, the average home value in Lake Charles, Louisiana (a place that experiences frequent disasters) is around $200,000 which means the average homeowner there would be eligible for a maximum of $30,000. This is a potential loss of $57,200 in Individual Assistance compared to today.

Keep in mind, we have been talking in “maximums” here meaning the most someone could theoretically be eligible to receive from FEMA. The Council notes that how much a person receives up to the maximum amount will be determined based on their “level of need”. The Council does not say how “level of need” will be determined so it is impossible to say how much a survivor might realistically be awarded. However, between 2002 and 2024 the average Individual Assistance payout was $3,446, substantially less than the maximum they could be eligible to receive. Given the broader theme of this report, I am skeptical that the Council intends to take a generous approach in determining “level of need”.

This recommendation also raises several additional issues.

First, home value is not an effective measure of needed assistance. Pre-disaster home value is not the same as the amount of money necessary to rebuild that home (not to mention other recovery related expenses). We have been over this many times.

Second, when assistance is based on home value, the outcomes will be inequitable. This recommendation, as stated in the report, will result in an inequitable distribution aid to survivors on the basis of race and class.

From the Center for American Progress:

“Homes that are owned by Black Americans are typically valued less than homes owned by white Americans with a median difference of $80,000. Studies have shown that African American homeowners remain concentrated in formerly redlined neighborhoods, where homes have failed to appreciate at the same pace as homes in white neighborhoods. This stems from decades of heavy investment in white neighborhoods by developers, mortgage lenders, financial institutions, and the U.S. government.”

I am also very sure about this because it has happened before. The most infamous instance is of course the post-Katrina Road Home Program funded by the federal government and run by the state of Louisiana that ended in a racial discrimination lawsuit. The program used home value to determine the amount of aid survivors received, and homes in white neighborhoods were valued higher than neighborhoods where people of color lived. You could have the exact same house with the same amount of damage but because it was in the predominately Black Lower Ninth Ward, the homeowner received less than they would have if the house had been located in the predominately white Lakeview neighborhood.

The FEMA Review Council is recommending we implement what our field uses as a case study for racial discrimination as the approach for dispersing recovery aid to disaster survivors. It is unfathomable that anyone who has worked in emergency management for any length of time to not know this which leaves me to wonder why the emergency managers on the Council allowed this to be recommended.

A third issue is that 15% the value of your home for many people is still not enough assistance. Again, additional analysis is needed here but just some back of the envelope math here shows that for many individuals this will not even be enough to make their home habitable again, let alone cover the costs of temporary housing, transportation needs, and other expenses. The average homeowner can expect even less assistance from FEMA than they currently receive which we know is not enough.

A fourth issue you will notice is that they emphasize only helping homeowners who experience damage to the point that their homes become uninhabitable. Habitability is a specific term FEMA uses when determining eligibility for housing related Individual Assistance programs. Changes were made to expand this eligibility during the Biden administration. Currently if you have “minor damage” to your home you are still eligible for certain types of housing assistance and other needs assistance.

Finally, the Council does not provide evidence that their recommendations will address the stated problem of aid being too slow. If assistance amount is still ultimately based on “level of need” there will presumably still be some process of determining what need is and if they are factoring in the habitability of a residence, some kind of house by house damage assessment will be needed. FEMA may not be the agency that sends staff out to determine individual eligibility anymore, but state emergency management agencies will need to assess every single structure for habitability.

Will states be able to do these assessments faster than FEMA? Well, it depends on how many trained staff the agency has on hand. The vast majority of states do not currently have an adequate cadre of trained people to do this. It seems this recommendation would just transfer the responsibility of home evaluations to state agencies (in some cases, see issue raised below). And, in fact, the Council is proposing transferring this task from an agency with trained staff and immense experience in determining habitability, to agencies that likely do not have either. One might consider this change may actually slow the process of individual aid distribution, at least in most states.

These changes would make the assistance process less confusing and more efficient in the sense that they eliminate critical aid programs. I am pretty sure that is not what disaster survivors, and other stakeholder groups, meant when they asked for a faster and less confusing process for getting help.

Specific Change: The Council recommends that renters receive up to three months (or maybe six months) of rent at the HUD Fair Market Rate. Again, they say this will be based on “level of need”.

Critical Context: Similar problems arise here for renters as they did for homeowners.

First, this represents a significant decrease in the amount of rental assistance provided by FEMA. Currently renters may receive up to 18 months of rental assistance depending on the circumstances of the disaster and their eligibility. The Council mentions some renters could receive up to 6 months of rent but do not say who would qualify. As was the case with homeowners, and probably related to the number of months of rental assistance approved, the Council never says how “level of need” will be determined.

Second, this approach will lead to significant inequity among renters. Some more quick math in the absence of a more sophisticated analysis: I looked up the HUD Fair Market Rate for four-bedroom apartments in 2026. In San Francisco the rate is $4,772. In Issaquena County, Mississippi the rate is $1118. Of course, the cost of living is significantly higher in California as compared to Mississippi, but what this means is a renter of a four bedroom apartment in Issaquena County can receive an absolute maximum of $6,708 compared to $28,632 in San Francisco. [Note: I used the 6 month option and four bedroom option to capture the highest possible amount someone could receive, most renters do not live in four bedroom dwellings, and I am doubtful most people would get whatever this 6 month option is that the Council mentioned.]

If it were the case that this payout was only for housing, there would still be a discrepancy, but I think you could make a case for this approach. The exact same apartment is going to cost more in California than it would in Mississippi. (FEMA currently uses the HUD Fair Market Rate) However, because the Council is saying this funding also covers non-housing related needs, this difference becomes egregiously inequitable. Replacing a laptop destroyed in a flood costs the same in Mississippi as it does in California.

Third, this approach will expand the inequity between renters and homeowners. Using this formula, renters will be eligible for far less money than homeowners. While a homeowner can receive up to $150,000, the most a renter can receive (based on a 4 bedroom in San Francisco for 6 months) is $28,632. Again, if this were only for housing costs it could be less of an issue. Renters do not have the same rebuilding costs as homeowners (although they can face enormous financial hurdles).

By attaching non-housing related needs to housing, the Council has created an approach that will result in deeply inequitable outcomes. Homeowners and renters can have the exact same non-housing related needs and costs. A hospital visit in San Francisco after an earthquake, replacing a flooded car in Houston, or buying new clothes in LA after a fire cost the same regardless of homeownership. The inequity will also fall along racial and class lines. For example, only 45% of Black households own their homes as compared to 74% of white households.

I want to emphasize that this analysis is based on the highest possible amount survivors could be eligible to receive. I have used the maximums here because without the Council saying how “level of need” will be determined, it is impossible to know the average payouts. Remember that historically, few survivors receive the maximum amount of assistance they are eligible for from FEMA. As was the case with homeowners, the Council is recommending a decrease in aid for renters.

Specific Change: The Council writes FEMA should, “Focus the transformed agency’s role on emergency and temporary housing (mass care/ sheltering and temporary housing/rental assistance) instead of long-term housing, and only for Americans whose homes are uninhabitable (not those who experience minor damage).” They recommend that FEMA no longer be involved or provide funding for permanent housing. They recommend giving this responsibility to HUD, and specifically the Community Development Block Grant Disaster Recovery (CDBG-DR) and “other federal housing programs”. They also note that ultimately “private insurance companies remain responsible for permanent housing”.

Critical Context: This is a good example of the kinds of inconsistencies in the report. They say FEMA should focus on “emergency housing” which according to their parentheticals includes “mass care” and “sheltering”, and “temporary housing”, which according to their parentheticals includes “temporary housing” (repetitive but, okay) and “rental assistance”.

The inconsistent use of “sheltering” and “housing” is a decades long issue in the field. You can go back and read Quarantelli’s attempt at a typology to try and sort this out back in the 1990s. I fear we have not made much progress since.

Since neither the Review Council nor FEMA uses Quarantelli’s definitions of sheltering and housing, and in the absence of the Council defining their own terms, I think it is fair to assume they are using current FEMA definitions. Here we run into another problem. “Emergency housing” is not a commonly used term by FEMA. I cannot find a specific definition for it. The Stafford Act, and most FEMA policy/guidance, uses “temporary housing” and “permanent housing” to distinguish the two broad types of housing. The generic term “sheltering” is usually further specified as “congregate sheltering” or another form. “Mass Care” is a broader term that can include congregate sheltering but also typically involves feeding, distribution of emergency supplies and other urgent response tasks related to caring for displaced people. “Rental assistance” is considered one type of assistance for temporary housing.

Amid this confusion you can see why Quarantelli found the lack of clarity and consistent usage of these terms to be setting us up for a problem! Should we listen to disaster researchers more often? Perhaps!

We are really dealing with three broad tasks here: community disaster sheltering, temporary housing, and permanent housing. As discussed above, the Council states very clearly that FEMA should pass responsibility for sheltering off to the states. They also state very clearly that FEMA should pass permanent housing off to HUD and other federal agencies.

There are extensive problems with survivors relying on SBA loans including the fact that they are difficult to get, distributed inequitably, and can be difficult to pay back. I do not have the space here to dig into the issues with HUD but to put it simply, there are big problems there too. It is not clear to me how passing off survivors and communities to multiple other federal agencies for this one part of emergency management is efficient. In fact, the Biden administration made changes related to SBA applications to try and help minimize the need for survivors to interact with multiple agencies. Historically when FEMA makes another agency responsible for an emergency management activity it becomes more confusing and less effective. FEMA should be taking back responsibility for permanent housing from HUD and other agencies.

Interestingly, this recommendation that FEMA no longer be involved in permanent housing would seem to completely contradict their recommendation for providing housing assistance (i.e., Individual Assistance) through their new FAIR program (No.6). So, my understanding is that leaves temporary housing as something FEMA should continue to be involved in (unless a state wants to take over administering Individual Assistance themselves).

As you can see, contradictions and confusion abound. Frankly, I am not sure where this leaves us in terms of understanding which aspects of housing recovery FEMA should be involved in according to the Council.

A final note here: it is true that the Limited Intervention Model of recovery, which the United States uses, assumes that private insurance will be the primary source of housing assistance.

However, the Council does not address the immense problems currently undermining the effectiveness of insurance across the country. This includes insurance companies raising rates, stopping coverage in some states, failing to payout post-disaster, and a growing number of lawsuits. The Council can “reaffirm” that Americans should rely on insurance but if the insurance industry does write affordable policies and pay out post-disaster, this is simply not rooted in reality. This is another example of the Council failing to consider the emergency management system as a whole while writing this report. Framing private insurance companies as responsible for permanent housing is disingenuous. Ultimately each of us as individuals are responsible for our own recovery. In the best case scenario, a survivor has been able to acquire affordable insurance, and their policy pays out as expected, allowing them to receive the significant financial assistance that is often needed.

Conclusion: The Council claims these changes to Individual Assistance will “positively impact affected Americans” but what is described here is a program designed to provide less assistance to Americans – unless you own a million dollar home. These changes would shrink the overall number of people eligible for FEMA assistance and further entrench systematic discrimination into our recovery system.

Recommendation No. 6

“Reform the Public Assistance Program to Provide Direct Funding”

Key Recommendation: The Council recommends transferring the operation of Public Assistance from FEMA to the states, using a formula to determine Public Assistance funding amounts, and introducing strict recovery timelines with no extensions.

Critical Context: The report identifies a number of problems with the current approach to Public Assistance including administrative delays, compliance overload (specifically related to the National Environmental Policy Act), high administrative costs, unpredictable cash flow, centralized decision-making (i.e., a top-down federal approach, federal overreach (FEMA is responding to too many disasters)), and administrative backlog (too many open projects). While it is true that some of these are empirically documented problems, many of them are much more complex than is presented here. I have selected a few to address in detail.

Specific Change: The Council recommends replacing the current Public Assistance program with a new model: “RAPID Program” which would provide the total Public Assistance funding to the state all at once. Once a declaration is granted, FEMA would transfer all funding to the state within 30 days.

Critical Context: This recommendation represents a complete upending of the current approach to recovery funded through Public Assistance. The Council is recommending that states receive all Public Assistance funding for the entire event within 30 days. For some events we are talking about billions of dollars being given to a state overnight. (Incidentally, Congress would have to change their approach to funding the Disaster Relief Fund because this would make it very easy to quickly drain the account. This is not addressed in the report.)

One immediate issue is that basing this on the date of a declaration means that the 30 days may hit before the incident period is over. This will likely be a problem for most long-duration disasters when it is not unusual for there to be impacts that have not even happened yet 30 days post-declaration (e.g., river floods, events with long-term power outages such as Hurricane Maria, COVID). The Council does not address this.

A starting point to break this recommendation apart is to figure out how it would be possible to know exactly how much a recovery will cost within the first 30 days. Of course, the answer is that, in many cases, it is not possible. The Council’s solution to this problem is to use a parametric measure.

Specific Change: The Council recommends using a parametric funding mechanism to determine the amount of money a state will receive for Public Assistance. [Note: the way this is described in the text of the report does not totally align with a flow chart example provided in the Appendix. I am going to explain this here based on what is actually written but there is a serious lack of clarity here to be aware of as you read this.]

Critical Context: Of all the preposterous recommendations made by this Council, this is the one that seems to have freaked everyone out the most – and for good reason! CRS wrote an explainer on it based only on the media coverage of the leaked drafts of the report. Whew! You can read their explainer to get a sense of the pros and cons.

Basically, the Council is recommending that the Public Assistance a state receives for a given disaster will be a predetermined amount based on some set of hazard characteristics (a parametric measure). This is something insurance agencies globally have become very interested in doing lately.

The reason this is such a terrible approach is that it uses hazard characteristics to determine aid rather than need (currently FEMA primarily uses a mix of impacts and need). Who cares about hazard characteristics?! It does not matter how many inches of rain fell; it matters if your house is flooded or not. Using hazard characteristics to determine aid employs an archaic way of understanding disasters. It completely removes the concept of vulnerability which is at the heart of what makes something a disaster or not.

Presumably FEMA would have to have different parametric measures for different parts of the country. With working pumps two inches of rain in New Orleans over three hours is a Tuesday. In an Arizona desert town, two inches of rain over three hours can easily be a disaster. So, are they suggesting we go town by town (or county by county?) across the entire country to set up parametric measures for every possible hazard? What if a hazard happens that no one had considered possible in that location?

The Council does not acknowledge how this would be determined, nor do they say how much money may be attached to the parametric measures – do you get $100 million for a hurricane, or do you get $5 billion? The amount of money a small desert town needs to rebuild is going to be much different than the amount of money a city needs to rebuild. This could lead to some communities receiving more funding than they need while others receive less funding than needed, or even no funding at all. Is this efficient, effective, or equitable?  

CRS provides some success stories but there are just as many (maybe more) stories of failure from the perspective of survivors. (The insurance companies seem to like this approach which one might consider to be a red flag.) I have followed this most closely in Mexico where they have been using this approach for longer than it has been popular in the United States. What I have seen there has led me to urge anyone who asks me about this, to not use it.

Using a parametric measure is a huge gamble. When it works, it works! When it doesn’t, there are detrimental consequences. The Council is arguing that the possibility of a state receiving all their recovery funding more quickly is worth the risk of receiving none. I just do not believe that something as important as federal funding for Public Assistance is worth that gamble. It does not need to be a gamble. There are other ways of moving money more quickly.

This is especially true when you consider that states do not need all of their Public Assistance funding within the first 30 days. States need some Public Assistance funding quickly, but much of that funding is not needed until years into the recovery. There are many other approaches that fall between the current process, which is certainly too slow, and bombarding states with funding immediately post-disaster that does not meet their needs.

As has become a pattern in this report, the Council did not include details of how the parametric funding mechanism would work. They acknowledge this noting that “the transformed agency should convene a group of STT representatives to collectively establish a parametric funding model that is based on existing data from the authoritative federal agency or organization over each type of eligible event (i.e., earthquake, hurricane, flood, etc.)”.

“Authoritative federal agency or organization” really caught my eye. It feels particularly obtuse to include this recommendation at a time when the Trump administration has been defunding and otherwise dismantling our “hazard agencies”. The administration has started breaking apart our national hazard monitoring systems. Are we even still collecting the data needed to do this on a nationwide scale (and for every hazard)?

[Sorry, I cannot get past the need to do this for every conceivable hazard that could affect a community. We are talking cyber-related failures, pandemics, earthquakes, snowfall, heat, saltwater intrusions, corroded drinking water pipes, transportation accidents, snowfall, chemical explosions, oil spills, floods of all types, cold, ice, bombings, fires of all types, failed infrastructure, tsunamis, asteroids, volcanos, earthquakes of all types, wind, tornados, fire tornadoes, erosion, and any number of other things that go wrong in our communities. What about multi-hazard events? If you have an oil spill caused by a hurricane, can you use two parametric measures and get extra aid? Is it only the “triggering” hazard? How could this possibly make sense to anyone.]

With this new model, the President is still the sole authority for determining declarations (or maybe not “sole” depending on your read of No. 3). The parametric measure is just what FEMA will use to determine the amount of money that a state will receive for Public Assistance after receiving a declaration. I have some follow up questions. For example, what happens if the President declares a disaster, but the hazard characteristics do not meet the parametric threshold? Do you get a declaration but no assistance? Then what is the point of a declaration? What is used to determine when Individual Assistance is approved? Is that related to the parametric measure? The Council does not tell us.

I cannot help but notice that, as has become a pattern, by the end of the section the Council seems to start walking back their own recommendation. They add in a note that in addition to the parametric trigger there must be “evidence that response demands exceed the resources and capacity of local and state government”. So then, doesn’t this approach still require damage assessments to be done (and wouldn’t you need to do those to get a declaration anyway)? So then, we already know there are events that take more than 30 days to do a PDA. Perhaps their measure is simply the per capita threshold? That is a measure of impact severity, not capacity and capability. None of this is clear.

Specific Change: Simplify Public Assistance by giving all funding directly to the states.

Critical Context: One of the big promises of this RAPID program is that everything will be simplified because the state is in charge. Yet, in the description of what is expected of states, it seems the Council wants them to follow the current approach (i.e., eligibility of applicant, eligibility of facility, eligibility of work (emergency work vs. permanent work), and eligible cost. It is unclear from what is written which Public Assistance types (A-G) will remain, but they specifically keep the two broad types of work.

If it is the case that eligible work stays the same, I would like to hear the Council justify FEMA funding supporting the rebuilding of parks but not permanent housing (as proposed in No. 5). How can the Council justify FEMA funding rebuilding recreational fishing piers but not helping cover the costs of evacuation? I think we should do evacuation when needed, build permanent housing post-disaster and rebuild parks and recreational fishing piers, but in an environment of limited funding, which the Council seems to believe we are operating in, some of those are more important than others.

 Further, we have experience with states leading post-disaster recovery/mitigation programs. I already mentioned the racial discrimination lawsuits (among other problems) with Louisiana’s Road Home Program but both Texas and Florida have come under fire from survivors about their programs. So, evidence that states are better at managing complicated housing recovery programs is in short supply.

Specific Change: States will check in with FEMA two times during their recovery process. The first phase is completed within one year of receiving the initial funding. The state must submit a CPA-conducted audit. Through this audit “any funds not associated with an eligible project must be classified as underruns”. Underruns must either be returned, or a state can request keeping it to put towards “mitigation or insurance measures”. They specify that “additional federal funding is not available for overruns”. The second and final check in with FEMA will occur as a Program Closeout Audit. This happens when all projects are completed. The audit is completed by the state government.

Critical Context: The Council is recommending that all recovery projects must be completely planned within one year. There is no explanation for when a request to use extra recovery funding on mitigation projects will be granted. It is very often the case that recovery ends up costing more than initially assumed. There is no flexibility here for communities that find out damage was more severe than initially understood, supply chain issues, inflation, or the many other issues that commonly arise during recovery that change initial cost estimates.

Specific Change:  Recommends creating a “High Performance Designation” for states that “consistently submit timely, accurate, and transparent reconciliation” which would allow the President the option of approving “more than 75% of the parametric amount as a federal contribution”.

Critical Context: As explained in earlier recommendations, this approach inherently favors high capacity states and states that have frequent disasters.  

Let’s do what I call the “Cascadia Test” on the Council’s recommendation for Public Assistance. If Washington and Oregon do not have this “high performance designation” when the Cascadia Subduction Zone pops off (i.e., a 9.0 earthquake and subsequent tsunami), the federal government will pay no more than 75% of their Public Assistance funding. This Council is going to look at us with a straight face and say Washington and Oregon will be financially responsible for 25% of Public Assistance for Cascadia (and who knows how much else based on whatever parametric measure is used).

If Louisiana had not had this designation (which in 2005 would have been likely) they would have had to pay a 25% share of Katrina? How many states would have had to pay a 25% share of COVID?!

Specific Change: All Public Assistance funding must be spent or returned within eight years.

Critical Context: The Council does not share how the eight-year timeline was determined. Many recoveries can relatively easily be completed within eight years. However, there are simply some recoveries that will take longer because of the nature of the event, available resources, and the circumstance of the affected community. There is no failsafe here for them.

As a rough measure: nothing bigger than the Joplin Tornado is going through recovery in fewer than eight years. For example, here’s the Harris County Flood Control District just last month asking for Harvey recovery funding extensions. They are in their ninth year of recovery. This suggests even a state with extensive resources, emergency management capacity, and disaster experience cannot currently do this.

I do not think it would have been possible to complete all federally funded recovery and mitigation projects in New Orleans post-Katrina in only eight years. It will take more than eight years to rebuild after Cascadia. It may be fine to set eight years as a goal but there must be an extension available for communities who need it. Without a safety valve it could pressure communities to rush and cut corners to meet the spending deadline. Rather than threatening state and locals with an 8 year cut off for Public Assistance, why not help facilitate pre-disaster recovery planning and capacity building to enable them to move more efficiently and effectively through the recovery process? 

Research supports shortening the length of time it takes communities to move through the recovery process. However, I am unaware of any evidence that suggests recovery takes so long because there is no federal spending cut off. The Council does not clarify where the eight-year deadline originated. I am particularly frustrated by this recommendation because I suspect that at least the emergency managers sitting on that Council know that there are many communities that cannot or will not spend the money that fast. In that sense, it feels like the Council suggested this cut off as a way to minimize federal recovery spending.

Specific Change: The Council calls for converting all open disasters to the RAPID system.

Critical Context: The Council does not say how this would be implemented. Most states do not have these systems in place. How long would they have to create them? Would there be federal funding made available to support creating them? If a disaster has been open for more than eight years, will it just be immediately closed out even if a state is actively spending on recovery? This would affect big disasters including Harvey, Maria, Irma, Sandy, Katrina, and others. Would these communities just lose their unspent recovery and mitigation funding? It would be helpful to see a detailed analysis here, but my instinct is this would represent a significant loss of funding that has already been promised to states across the country.

Conclusion: The Council does not provide a provision for Public Assistance, like they did with Individual Assistance, that gives states the option to take this responsibility over from FEMA. Therefore, every single state will have to build their own Public Assistance system. It would not be possible for a state to implement this type of recovery system needed from scratch in the 30-day window. The state-level infrastructure for recovery grants, for example, would need to be stood up 24/7. This means every single state is going to require a huge recovery office within their emergency management agency, if they are to be adequately prepared to respond to a major recovery, regardless of likelihood. For states like Louisiana, Tennessee, Kentucky, Florida, and California that have frequent enough disasters to be in a perpetual state of recovery, this model makes more sense. But is this an efficient use of resources for states like Wyoming or New Hampshire?

Even with a bigger standing recovery office, states would still have to rapidly expand those offices when really big disasters happen. FEMA deployed thousands of staff across the states affected by Helene, each state would need to do something similar on their own. To make up for the loss of FEMA staff support after major disasters we are talking about states having to hire hundreds of new staff. Without a national staff to pull from, states will have to hire people themselves. Will they be trained? Will they be knowledgeable about recovery?

There are some states with so little recovery experience that I am not sure they even have the knowledge of how to even attempt to create an effective recovery program. Will states turn to private contractors to facilitate these recovery programs? If so, this would represent another big step towards privatization.

This recommendation would certainly speed up FEMA’s involvement in Public Assistance, but it does not seem like it would actually speed up the overall recovery process. As with the previous recommendations the Council is just transferring responsibility. State run housing recovery programs have faced extensive criticisms from survivors and many lawsuits. This is setting state emergency management agencies up for failure.

Recommendation No. 7

“Reform the FEMA National Flood Insurance Program (NFIP) for Financial Stability and Risk Resilience”

This recommendation is a tremendous waste of your time and mine. I am not going to get into details here but rather just give you the quick hits.

The Council mentions various elements of the NFIP “debate” we have been having for years and regurgitates the same fundamental misunderstandings about insurance generally and the NFIP specifically. They delve into the usual erroneous narrative about how NFIP is a failure because it has not mitigated flood risk (it is primarily a recovery program) and is $20 billion in debt (the ability of the program to go into debt is literally why a federally backed program was created).

The Council suggests moving NFIP towards privatization but falls just short of recommending full privatization (as Project 2025 did). My sense here is that the Council knows privatizing flood insurance will be disastrous for the housing markets in many communities, the reason this is here is because they feel political pressure to pursue it. 

They recommend “a comprehensive reform plan centered on a strategic shift toward a primary role for the private market, with the goal of fostering a more resilient and financially stable flood risk management system” (p. 11). Confusingly it is not clear if what is outlined in the report is meant to be a comprehensive reform plan or if they are recommending a comprehensive reform plan be written by someone else.

A brief list of their recommendations: incentivize better land-use policy through modernizing the Community Rating System, continually update Risk Rating 2.0 and improving flood maps, implement risk-based pricing and actual cost, address affordability of flood insurance “for select homeowners”, update compensation for Write Your Own insurance companies, shift NFIP to the private market via a depopulation program approach, design a new flood insurance marketplace, mitigate repetitive loss properties, and exempt NFIP from the Endangered Species Act.

Some of these could be fine depending on how they are implemented. Others would not be fine if your goal is to ensure people have access to affordable flood insurance. Their changes would make it more difficult for people to purchase flood insurance by making it less available, more expensive, and more complicated. Simply put the Council is recommending a reduction in the number of people who have policies through NFIP. (We actually need to be increasing the number of people who have policies through NFIP.) Their recommendations here largely create a whole new set of problems – especially when it comes to recovery.

One final curious discrepancy from the Council on the issue of insurance. In this recommendation the Council is arguing the federal government should not be subsidizing flood insurance. Yet, buried in No. 6 the Council recommends the federal government help individuals with the high cost of private flood insurance. They write, “individuals doing the right thing by carrying insurance policies should be rewarded for their investment and effort to protect against disaster” through tax credits. This is a subsidy.

Recommendation No. 8

“Maximize every dollar spent by Reducing Administrative Costs”

Key Recommendation: Grant programs should be reduced in complexity to minimize the need for spending on administrative costs and private contractors.

Critical Context: The use of private contractors in emergency management is so pervasive that I refer to them as our “shadow emergency management system”. I have long argued that this “shadow system” is inefficient and exploitative. There is a place for consultants in emergency management (for example: on specialized mitigation projects) but emergency management agencies should not be reliant on consultants for day to day tasks. For almost a decade now I have recommended to most journalists who interview me that they should look more closely at the use of private contractors. Very few have taken me up on it. I am shocked ProPublica, Frontline, or some other investigative outlet has not done an expansive deep dive.

The Council claims that 25% of FEMA’s spending goes towards administrative and management expenses. The report claims that in the past five years FEMA has spent $3.6 billion on administrative expenses related to their Individual Assistance programs while only $8.6 billion has actually gone to survivors. That means that 30% of FEMA spending on the Individual Assistance programs has gone to “overhead”. The Council also provides similar numbers within the Public Assistance recommendation. They claim that in the last five years FEMA has paid out $180 billion in Public Assistance with $21 billion of that used for grant and project management. Plus, FEMA has spent an additional $11 billion to administer the $180 billion, which adds up to $32 billion, or 17.7% of Public Assistance funding spent on overhead.

Although they mention grant and project management, a comprehensive of “overhead” categories is not given. It does seem like overhead is being measured differently for Public Assistance than for Individual Assistance. The Council does not recommend what percentage of spending should be put towards these costs, only that the current amount is too high.

Are these numbers accurate? Maybe! GAO did an analysis of FEMA’s administrative costs for major disasters for the years 2004-2013. They found 13% of the money obligated from the DRF during this time period went to administrative costs. I would not be surprised to learn that the costs have gone up in the past ten years, but the Council does not show their work here. I cannot find a reliable source that breaks out all individual and Public Assistance spending in the past five years and a reliable source that breaks out what of that spending went to “overhead”. There should be a publicly available analysis that shows the scope of this overhead spending for independent verification of what exactly the problem is here.

Look, I absolutely believe that FEMA is spending unnecessary money on administrative costs, and I think that we should figure out how to prevent it. I would argue, however, that the total cost of using a contractor seems to be just a byproduct of a bigger concern which is that we need to understand where there are profit driven incentives for contractors to operate in a way that is not to the benefit of disaster survivors and affected communities. There have long been concerns that contractors are incentivized to artificially increase the amount of time it takes to do specific tasks in order to maximize billable hours (see for example: the appeals process for Individual Assistance). However, this spending needs to be publicly audited for us to accurately identify where the problem is and how FEMA’s approach should change to undermine perverse incentives. It does not appear that the Council has considered these questions. Without fully understanding the problem, or even understanding what exactly the problem is, it is impossible to assess the effectiveness of proposed solutions.

[Note: The Council spread this issue out over multiple recommendations, but I put them all under this section for your benefit.]

Specific Change: The Council recommends establishing “strict, federally mandated caps on the percentage of grant funds that can be used for administrative costs” (p. 53).

Critical Context: The Council fails to provide the details necessary to know if this could be an effective strategy. If the Council wants to put a strict cap on how much of grant funding can be used on administrative costs, they will need to simplify grant systems and requirements. They have not fully articulated how they will do this. States and locals must be trained on these new approaches. Second, the Council does not provide a recommendation of what the cap should be. They also, critically, do not clarify if “administrative costs” includes paying outside consultants or if it also extends to covering the salaries of state and local employees. The answer to these questions will dramatically alter the implications of this specific change.

Specific Change: The Council calls for implementing stricter post-FEMA employment rules, writing, “former FEMA and state political appointees and career employees have joined or established private companies that now serve as major contractors in the disaster management space. This raises questions about whether former officials leverage insider knowledge and connections for private gain”. 

Critical Context: Yes, we would not want anyone in the federal government personally profiting off their public service!

 I can certainly provide anecdotal evidence that historically this has happened. However, to my knowledge, the prevalence of this issue has not been studied. Under normal circumstances I would not disagree that the implementation of a waiting period could be appropriate in certain cases. However, I could not support this currently. The Trump administration has actively created hostile working conditions within FEMA, and fired thousands of FEMA employees. Where are they supposed to work? States, locals, nonprofits have very little funding to hire additional staff. Including this recommendation in a report that also recommends firing staff from that agency (see No. 10) is quite ruthless.

Conclusion: The major changes recommended here do not align with the other recommendations in the report. These changes do not inherently make emergency management programs/projects easier to navigate, they simply change which level of government is responsible. Where there is simplification, it results in a loss of assistance to survivors (see No. 5). It could be the case that states create simpler programs and ultimately the money moves more quickly, but currently the vast majority of states do not have the infrastructure, nor the capacity, nor seemingly the interest to facilitate this responsibility.

Given this lack of state and local capacity and expertise, the obvious solution would be for states to hire consultant companies to, at the very least, create these new systems, if not run them entirely. The reality of how the public sector system operates means that very often it is consultants who are the ones who have the knowledge of how to navigate that system, rather than state and local officials. Reverting to a system where systems are simplified and that knowledge resides within the public sector is fine (maybe preferable!) but doing so requires a very careful transition to avoid negative impacts for people who work in emergency management and the communities they serve.

So, while the Council calls for a reduction in the use of consultants, the other recommended changes in this report seems to open the door for an increased use of consultants. In this sense, it seems like the Council is creating the conditions for even more administrative spending. Instead of having one agency administering Public Assistance, they are suggesting that 55+ agencies need to have this capability. Is that efficient?

Recommendation No. 9

“Revitalize A Unified National Network for Partnership”

The recommendation here is to effectively give the National Preparedness Goal a facelift (my words, not theirs obviously!). The Council claims terms including “frameworks, incident command systems, lifelines, core capabilities, and emergency support functions” are used interchangeably. Incidentally there are many terms in emergency management that do need to be better defined, they have just seem to have picked the wrong ones! These terms all have clear definitions, meanings, and purposes. My freshmen emergency management majors can easily explain each of these to you. This is why emergency managers should receive an education in emergency management.

I suspect this recommendation stems from Executive Order 14239 which raises concerns about defining “federal national functions constructs”. Or maybe one of the several members of the committee who has no background in emergency management is confused by these terms and decided to make it our problem. Sure! If you do not work in emergency management, you probably do not know what these terms mean. I also do not think you need to know what they mean.

The Council seems to be simply doubling down on the first two recommendations. They are ending the report that solidifies that FEMA should continue to exist and do more to create a national emergency management system.

Recommendation No. 10

“A Transformed Agency”

Key Recommendation: This recommendation is made up of a bunch of “catch all” preparedness recommendations. The Council recommends the states take over training and FEMA’s workforce be cut. They recommend the National Urban Search and Rescue Program, the Centers for Domestic Preparedness, and the U.S. Fire Administration be expanded because they have been effective (by what measure we are not told). Other recommendations are repeated such as closing out historical disasters and broadly shifting FEMA’s responsibilities to the states.

Critical Context: This final recommendation, again, reveals the report as a political, rather than policy, document. It largely reads as “The Kristi Noem Addendum”.

The Council writes that “‘FEMA’ as a brand and as an agency has been irreparably damaged by the last four years of mission creep and programmatic failures”. The idea that FEMA needed to be re-branded is one Noem repeatedly pushed after it became clear that republican governors did not want the administration to abolish FEMA. In fact, public polling shows Americans do not want to eliminate or shrink FEMA.

Specific Change: Adjust FEMA to appropriate staffing levels over the course of a 2-3 year strategic review.

Critical Context: The Council calls for “internal workforce adjustments” within FEMA. Earlier iterations of the report which were leaked online called for a 50% staff reduction, seemingly an addition from Noem. The final report does not attach a specific percentage to the recommendation. However, if the recommendations in this report were fully implemented, then a substantial staff reduction at FEMA would be necessary. In fact, more than 50% seems possible.

All evidence suggests FEMA cannot fulfill its mission without increasing staffing numbers by the thousands. FEMA is already extremely understaffed. Going into the second Trump administration the GAO reported a shortage of thousands. Another several thousand people have been fired or left the agency during this administration. In that sense, this recommendation is already in progress.

Specific Change: The Council recommends that the responsibility for training be transferred to the states.

Critical Context: “Training” in emergency management is a very broad area. The Council does not specify which training they are referencing. Looking across the report there are places where they specify federally supported training should not change (e.g., The National Urban Search and Rescue Program, the Centers for Domestic Preparedness, and the U.S. Fire Administration), or even increase (e.g., FEMA technical assistance) at the federal level.

FEMA does facilitate a lot of emergency management training, but there is also substantial training that is already executed at the state and local level. If substantially more training is to become a state level responsibility that will require most states to build out bigger training programs which will require additional staff and resources. The Council gives no indication if the federal government will provide any financial support for this undertaking. Developing 55+ separate training programs on basic emergency management functions seems inefficient. 

There is also no indication of how the Council would address the historical challenge of maintaining consistency in training programs if they are each state executed. This will need to be addressed in order to maintain the earlier recommendations from the Council about maintaining “national standards for disaster response”.

Conclusion: The inconsistency and conflict in the Council’s recommendations are on full display here at the end of the report. For example, they claim to want to retain FEMA’s core mission but also argue for eliminating FEMA’s role in long-term recovery. The Council argues FEMA needs to return to being a ‘player of last resort’, without acknowledging they already are. They recommend that duplicative federal funding should be eliminated but also make recommendations that specifically duplicate funding (e.g., insurance not affecting RAPID payouts in No. 6).

Report Analysis Conclusion

There is no evidence that the Council’s recommendation will make for a more effective, efficient, and equitable emergency management system.

The FEMA Review Council has proposed recommendations that would force unfunded mandates on state and local emergency management agencies. They have recommended slashing the amount of aid individuals are eligible to receive post-disaster by tens of thousands of dollars. They have deepened, and introduced new forms, of racial and class discrimination into recovery aid. They have outlined a timeline for post-disaster mitigation and recovery that even our best emergency management agencies will likely be unable to achieve. They are setting state emergency management agencies up to fail and leaving local emergency management agencies without a support system. They have recommended a stunningly regressive formula for determining Public Assistance that ignores not only social vulnerability but physical vulnerability as well. They have included handouts to private insurance companies while recommending policies to make it more difficult for individuals to find affordable and reliable flood insurance. They have laid the groundwork for mass firings of FEMA staff.

They ultimately believe that fewer communities, and fewer survivors, should receive less help during and post-disaster.