EXPERT IDEATION TO SOLVE POLICY CHALLENGES
Digital Dialogue No. 4:
Improving the Disaster Recovery of Low Income Households
The costs of natural disasters can be wide ranging, including not just property damage, but broader negative impacts on economic, social, and physical well-being. Research has shown that low income households and communities suffer disproportionately from disasters. Disasters can act as tipping points for families and individuals on the edge, pushing the marginally homeless into homelessness, those living paycheck-to-paycheck into debt and financial insecurity, and consuming any small savings that had been accumulated for housing, education, or other purposes.
For larger scale disaster events, there are several federal assistance programs that are typically activated to support recovery. Unfortunately, these programs fail to provide needed assistance to the most vulnerable people. Many lower income families do not qualify for disaster loans, the FEMA Individual Assistance grants are insufficient to fund rebuilding, and funding from HUD takes months or even years to reach needed families. Insurance can provide greater funding, typically faster than federal aid, but many households who need the financial protection of insurance the most are the least able to afford it.
This Dialogue is a collaboration with the Urban Institute’s Metropolitan Housing and Communities Policy Center, where the submissions are simultaneously presented in Urban’s Policy Debates.
How can federal disaster aid programs be improved to assist low income households?
What policy changes need to be made to support effective recovery for low income households?
Senior Fellow, Metropolitan Housing and Communities Policy Center Urban Institute
Welcome to the latest Urban Institute Policy Debate and the ESG Initiative Digital Dialogue—the first online policy collaboration for both partners.
Both of our research teams have identified an increasingly apparent policy gap: the inconsistent and often exacerbating policies, program rules, and implementation actions that result in disparate and inequitable recovery rates for low-income households in the U.S. We have seen this from the trauma in disaster shelters after Katrina, to the challenges faced by rural homeowners in Puerto Rico when proving title to their lands, and to renters among California’s fire victims as they search for homes in tight markets.
Simply put, our nation’s disaster policy is failing our neediest households.
More accurately, the various and often conflicting rules across the dizzying array of federal programs are failing them. The submissions in this discussion highlight the fact that the programs that are explicitly charged with disaster recovery (namely, those in the Federal Emergency Management Agency, or FEMA, and the US Department of Housing and Urban Development’s Community Development Block Grants for Disaster Recovery, or HUD’s CDBG-DR) do not share common triggers for appropriating funds, consistent eligibility thresholds, or practical application and servicing vehicles that center the affected families. When adding in the other federal safety net assistance that is tweaked after emergencies, consistency in aid is blurred even more. The ability for households to understand programs, access them, and effectively and quickly use resources for personal mitigation and recovery diminishes—especially considering their precarious conditions after a disaster.
Low-income households, further, are disadvantaged at different points in the disaster timeline. These households’ challenges often intersect with other considerations—like physical mobility, race, gender, housing tenure, and familial status—that necessitate further thoughtful planning and actions by policymakers. Challenges start with the financial, social, and political disparities that exist well before disaster strikes and are mirrored in these households’ access to and use of emergency preparations, hazard mitigation technologies and funds, appropriate insurance, and “rainy day” savings among other long-standing resource disparities. During disasters, low-income households face challenges in receiving emergency alerts, getting evacuation guidance and transport, acquiring shelter, and receiving appropriate nutrition, medical care, and childcare and educational supports. As several of the experts who contribute to this discussion point out, public-sector assistance often comes too late, is too bureaucratic, is supportive only in the most severe of disaster scenarios, and does not fill the needs that are most pressing such as finding affordable long-term rental housing. The public sector often does not use its regulatory powers to incentivize private-sector assistance either.
Finally, this disparity manifests in many ways. The discussion below highlights the current programs and policies that typically are designed to provide direct assistance to households. Most aid is currently focused on property and housing, hence the preponderance of policy recommendations in this area. Yet, there are numerous other disaster effects that disproportionately affect low-income people. For example, low-income households are more likely to live near environmental pollutant sources that are breached during disasters. They rely more on public transportation that goes offline. Their communities are more likely to suffer from cumulative allostatic stress that is fueled by disaster. Their children attend schools with fewer resources to rebuild and provide the appropriate developmental and educational supports. They lack the financial resources to avail themselves of tax relief opportunities. The respective federal agencies for these concerns monitor these effects and are often appropriated funds to address them, yet that activity rarely considers the compounded vulnerabilities that intersect in the lives of low-income households.
Ultimately, this discussion focuses on the need to frame an adequate, humane, and precisely woven safety net after disasters. To that end, we have asked the following experts from academia, practice, and advocacy to share their recommendations for policy changes that will keep all Americans from slipping through the holes.
The contributors are unanimous in their calls for:
- Developing consistent triggers for disaster aid and recovery assistance based on disaster severity, general damage, and disproportionate damages for low-income households;
- Maintaining transparent, means-tested, and generally uniform eligibility thresholds;
- Prioritizing low-income households and low income-majority communities as the primary recipients for all mitigation, relief, and recovery programs;
- Developing partnerships and collaborations with organizations and residents in low-income communities to refine plans based on actual need and to directly serve residents;
- Expand the overall pool of resources, including mitigation funding, to more sufficiently fill unmet needs.
Professor of the Graduate School, Department of Architecture, University of California, Berkeley
Low-income families do not qualify for disaster loans, and FEMA Individual Assistance Grants are quite limited in scope and value, and not designed to pay for housing reconstruction. Further, many low-income households are renters. We know from past disaster experience that low- and moderate-income multi-family housing is rarely replaced after disasters. To develop meaningful federal aid for low-income households, a new HUD program is needed to provide financing for affordable rental housing. There are many nonprofit housing developers who have experience with retrofit of existing housing and new construction of affordable housing. These and other experienced affordable housing providers could apply for available funds to repair, build and manage affordable housing. Such groups are the best hope for replacement housing for low-income families in rental housing.
For homeowners, an alternative finance program is needed. National all-hazards insurance could be required for all mortgages. Yes, this is a massive expansion of the flood insurance program, but one that includes all homes (whether in or out of the flood maps) and all hazards. The cost of insurance would have to have realistic risk-based pricing and rules that limit reconstruction in high hazard or repeat hazard areas. An alternative to government insurance would be to create a disaster savings account within the mortgage. Banks would add a fraction of a percent (in the range of 0.10 to 0.25 to be determined) to all mortgages. This “overcharge” would, in effect, be a savings account, to be immediately returned to the homeowner for repairs in the event of disaster damage (or at the time of sale). If such a “mortgage based repair-savings scheme” were required for all federally backed mortgages, lender participation would be assured.
Another alternative financing option is for HUD CDBG to provide additional affordable housing financing to local governments to be distributed through normal channels for affordable housing development. Any government finance scheme would have to overcome traditional government bureaucratic inefficiencies and time delays, which would mean streamlining reporting and budgeting appropriations for affordable housing assistance as part of the annual agency budget, and not part of a special Congressional Appropriation.
Programs Director for Climate Resilience, Urban Sustainability Directors Network
Federal disaster aid must shift from its current reactive cookie-cutter structure to a proactive and adaptable design that prioritizes communities of color and low-income individuals’ needs first and foremost. Current programs are based on broken systems and faulty assumptions that force a one-size-fits-all framework onto unique and ever-changing communities. The technological-solutions-based federal programs ignore what is truly important: relationships, connectivity and respect. Social equity, corrective action and pre-disaster funding should be the foundation for federal programming.
In the event of a disruption, federal programs should take a targeted universalism approach and focus time, resources, and funds in frontline communities. Programs should be designed to consider cultural significance, unique community characteristics, historic (and present) racism and prejudice, and trauma. People should be treated with respect and kindness. Response and funding should be connected to local community-based organizations, local faith-based organizations and local-governments who have goals, plans and projects identified by the community, established and trusted relationships with the community, and the ability to maintain and build relationships throughout the recovery process rather than the swooping in and out demonstrated by federal agencies and national organizations. I recommend:
- 50%-75% of all post-disaster funds should be allocated to local community-based organizations, faith-based organizations, local government agencies and local non-governmental organizations that have demonstrated plans with goals, strategies, actions that are proactive, include equity considerations and have been approved by the community.
- Current FEMA Pre-Disaster Mitigation Grants and Building Resilient Infrastructure and Communities money should be prioritized in frontline communities and communities of color for action that builds community adaptive capacity and reduces risk before any disruption.
- All federal funding and federal programs should include climate projections and trend lines and support proactive action for worst-case-scenarios. We must stop implementing projects that are based on lowest possible protections, such as the US Army Corps of Engineers’ post Katrina projects, that are not sufficient for future risks and likely impacts.
- All FEMA employees and federal disaster responders must go through in-depth racial equity training and training on trauma and responding to trauma. This training must be attended twice per year and there must be continuing education requirements as part of this training.
- Local institutions, community-based organizations, and local governments beyond emergency management offices should proactively collaborate with and be partners to manage, support, direct and distribute funds, resources and support. Rejecting the cookie-cutter approach means we need to develop plans that have multiple pathways for success and completion.
- Restructure all federal programs with advisory teams that are primarily made up of people most impacted (frontline communities) and those who have seen firsthand how terribly these programs treat people and communities.
True change requires massive transformation. The “way we have always done it” is not the way we can continue to do it. The federal assistance programs are archaic. Efforts to improve these programs must be efforts to dismantle racism and prejudice institutionalized into these programs while also ensuring that new structures focus on respecting people, prioritizing funding and resources for those who need it most, and working with local partners to respond and recover.
Independent Consultant at DB Advisory Services and Former National Institute of Standards and Technology Community Resilience Fellow
The Disaster Supplemental Nutrition Assistance Program (DSNAP) provides short-term post-disaster food assistance to eligible populations. Due to the demographics of eligibility, examination of the program, its related policies and implementation methods could provide useful information on eligible and ineligible populations’ recovery outcomes. In turn, this information would be useful for pre-disaster planning to improve resiliency and post-disaster services to improve recovery for future disasters.
Analysis of these data may be useful to benchmark the use of other programs for similarly-situated disaster survivors. These may include, but are not limited to, housing, travel, broadband access, health care and, possibly, other social determinants of health criteria. As seen with HUD’s Rapid Rehousing and Homelessness Prevention Program and other homelessness prevention programs, short-term assistance can be a significant stabilization factor for low-income/vulnerable populations.
Cross-eligibility, where a family or individual receiving a public benefit with similar eligibility criteria is permitted another pubic benefit, would save administrative dollars and applicants’ often limited resources. As DSNAP is provided at an inflection point in a household’s recovery, the full analysis of policies, implementation and outcomes is necessary. To that end, I recommend the policy actions:
- Establishing criteria for DSNAP availability by disaster severity, geographic concentrations of poverty or low-income, and regular SNAP receipt, among other potential factors
- Securing better, real-time information on post-disaster food supply chains, retail food stocks and prices, and transportation options to food supplies to better assess a community’s food needs and individual households’ capacity to use DSNAP benefits
- Improving the notices of availability to potential recipients based on analysis of previous successful networks and communications in a post-disaster scenario
- Assessment and change to the appropriate length of the application period to better accommodate hard-to-serve households and chronic nutritional and food supply chain disruptions
- Improved flexibility in the documentation and application process for DSNAP applications, including allowing alternative proof of food hardship based on evidence of past program denials due to documentation alone as well as providing more physical locations and media channels for submission
- Improved technical assistance and case management starting at the point of application rather than receipt to help households produce documentation and complete their applications
- Revising the timeline for eligibility review, approvals or rejections, and appeals to expedite receipt while offering transparent status updates
Better alignment with eligibility criteria for other post-disaster assistance
- Consistent triggers or rules for state decisions to offer DSNAP
Principal Research Associate, Center on Labor, Human Services, and Population, Urban Institute
Homeowners can suffer particularly stressful financial impacts following natural disasters, having to manage mortgage payments along with necessary home repairs on top of any costs associated with temporary housing if their residence is rendered uninhabitable by the disaster. Not surprisingly, research has found that residents of areas affected by natural disasters may be more likely fall behind on mortgage payments or to experience a foreclosure. Findings from Urban Institute research show, for example, that residents affected by Hurricane Sandy saw increases in both mortgage delinquency and foreclosures that were both relatively large and persistent, evident even four years after the storm.
Current policy already provides some forms of protection and relief for mortgage holders in the wake of natural disasters, including forbearance programs, moratoria on foreclosure sales or evictions, and suspensions of credit reporting and the collection of late charges. Yet, this assistance is not consistently offered, its terms consistent from one disaster to the next, and they are not necessarily targeted to the lowest-income homeowners.
Policy changes could consider ways to make these programs more automatic, extended, and uniform. Government-sponsored enterprises (GSEs), including Fannie Mae and Freddie Mac, can require servicers to suspend foreclosure sales or evictions following all disasters of a given severity, such as by absolute numbers of properties severely damaged or numbers of owner-occupied units requesting FEMA Individual Assistance, for example. Currently, the institutions only do so on a case-by-case basis. These, like other protections, could be triggered automatically for declared disasters.
Other elements of these programs could extend for longer periods following the disaster. For example, the Federal Housing Administration (FHA) currently instructs lenders to allow forbearance plans within a declaration region for just 90 days. Finally, the terms, durations, and triggers for such protections could be further harmonized across not only the GSEs, FHA and other agencies, but also with potentially modernized regulations governing loss modification as implemented by the Consumer Financial Protection Bureau (CFPB).
Fair Chance Director & Disaster Unemployment Assistance Lead, National Employment Law Project
Disaster Unemployment Assistance (DUA) is a federal program that provides temporary financial assistance to individuals unemployed as a result of a “major disaster” declared by the president. DUA is administered out of state UI offices.
There are two major requirements for an individual to qualify for DUA: 1) The individual must be out of work as a “direct result” of a major disaster; and 2) The individual does not qualify for regular unemployment insurance (UI) from any state or U.S. territory. Once found to be eligible for DUA, workers must actively look for work and accept suitable work offered them, not unlike UI recipients. In addition, the individual must show that for every week he or she is collecting DUA, his or her unemployment continues to be the direct result of the disaster, not other factors.
Like UI benefits, DUA benefits are paid weekly, once an application is completed, filed and processed. DUA recipients receive the same weekly benefits that they would have been entitled to had they qualified for UI in the state where they were employed for up to 26 weeks. However, at a minimum, DUA benefits cannot be less than one-half of the state’s average weekly UI benefits. The DUA benefits for part-time workers are pro-rated based on the hours they worked as a percent of a 40-hour work week.
Those who may be eligible for DUA and typically could not collect regular state UI benefits include may individuals, such as: self-employed people who lost their business or suffered a substantial interruption of activities as a direct result of a major disaster; workers whose place of employment was damaged due to the disaster and cannot find work as a consequence; workers who cannot reach their employment as a result of the disaster; and workers unemployed as a result of an injury caused as a direct result of the disaster.
The most essential policy change we need is to make sure that eligible claimants know about DUA availability. States should inform residents of the program and, when appropriate, apply for extensions to ensure that every eligible claimant is able to apply for DUA without any unnecessary barriers. In addition, there are several reforms that Congress can enact:
- Removing the federal restriction requiring unemployed families from disaster areas who qualify to collect limited state unemployment benefits rather than federally-funded DUA;
- Establishing a minimum DUA benefit that is 1.5 times the national average state UI benefit (or $531), thus mitigating the economic hardship imposed on workers in Florida and other states that pay especially low benefits relative to the average state wages;
- Extending the maximum period of DUA benefits from 26 weeks under the current law to 52 weeks to account for the severe economic hardship caused by today’s disasters
- Increasing the state administrative funding to cover all the costs incurred in processing DUA benefits during major disasters.
Several additional program rule reforms by the US Department of Labor and state agencies should also be enacted to expand access to the program.
Research Associate, Metropolitan Housing and Communities Policy Center at the Urban Institute
Additional resources are need to help people with utility bills after a disaster. FEMA doesn’t provide direct assistance with utility bills, although some Individual Assistance funds can be used to pay connection fees. States can divert some funding from the Low-Income Home Energy Assistance Program (LIHEAP) to pay for utility replacement or reconnection for households that cannot afford to pay energy bills after a disaster. But, Congress has not allocated additional emergency funds for LIHEAP since FY2011. There are no federal resources available for other utilities such as water, phone, or internet.
Urban Institute research found that utility debt among people in ZIP codes affected by natural disasters rises in each of the four years following the disaster. Four years after medium disasters the share of people with debt in collections was 10 percent higher than in our comparison group. For renters who are displaced, it can take some time to close their old utility accounts. They may find themselves with bills for two residences at once, at a time when they are already in financial distress.
To help these families, FEMA Individual assistance could be expanded to provide households more aid with utility bills. Alternately, Congress could provide additional funding for LIHEAP after disasters and allow LIHEAP funds to be used for water and other utility payments in the period following a disaster. Either program could be extended to support households with disaster-related financial stresses that continue for a year or two after the disaster itself. States and localities could provide protections to families, take steps to revise billing procedures and liability, and strengthen rules around the disconnection of utilities in post-disaster locations.
President and CEO, National Low Income Housing Coalition
Since 2017, NLIHC has led the Disaster Housing Recovery Coalition (DHRC) of more than 800 local, state, and national organizations to help ensure a complete and equitable housing recovery for the lowest-income disaster survivors. While DHRC has issued a comprehensive set of recommendations to Congress, FEMA, and HUD, we recognize that America’s disaster housing recovery framework is broken and in need of major reform.
NLIHC and Fair Share Housing Center of New Jersey are documenting the persistent barriers to an equitable housing recovery. The lowest-income survivors – including people of color, seniors, people with disabilities, people experiencing homelessness, and other individuals – are often hardest hit by disasters and have the fewest resources and face the longest, steepest path to recovery. Despite the clear need, federal efforts frequently leave these survivors without the assistance needed to get back on their feet and their communities less resilient to future disasters. The result is a disaster housing recovery framework that exacerbates and reinforces racial, income, and accessibility inequities at each stage of response and recovery.
To address these systemic challenges, the DHRC recently hosted a policy convening with diverse stakeholders to reimagine a new disaster response and recovery framework that is centered on survivors with the greatest needs and ensures equity among survivors, especially for marginalized people and communities.
In order to accomplish this ambitious goal, any new disaster framework must reflect several core principles: Everyone must be fairly assisted to fully and promptly recover through transparent and accountable programs and strict compliance with civil rights laws, with survivors directing the way assistance is provided. Securing help from government must be accessible, understandable, and timely. Displaced people must have access to all the resources they need – including shelter, temporary housing, and long-term housing assistance – for as long as they need to safely and quickly recover housing, personal property and transportation and to reconnect with family and community.
Survivors – whether homeowners, renters, or people experiencing homelessness – must be able to rebuild or access quality, affordable, and accessible rental homes in safe neighborhoods of their choice. Recovery efforts must ensure that all neighborhoods are free from environmental hazards, have equal quality, accessible public infrastructure, and are safe and resilient. Disaster rebuilding must result in local jobs and contracts for local businesses and workers.
Equity Analyst, Texas Low Income Housing Information Service
FEMA must learn from its own ineligibility data how to prevent avoidable denials among low-income households for the Individual Assistance program. For example, in areas where informal title practices are common, FEMA needs to adopt procedures that accommodate this. Many FEMA applicants in Puerto Rico (following Hurricane Maria) were denied assistance because they could not prove they owned their own homes. This has also caused problems across the Southern US with inherited property. Especially because these informal arrangements are more common among people of color, FEMA needs to recognize this recurring issue and adopt procedures that take it into account.
FEMA’s data also show that low-income applicants were disproportionately denied Individual Assistance after Harvey. Though homeowner applicants making less than $30K a year made up only 28% of applications, they accounted for 48% of denials. The data reveals dramatic disparities that offer some clues to FEMA and disaster recovery advocates. There are some denial codes that disproportionately affect low-income households, such as “Occupancy not Verified” or “Missed Inspection”. If FEMA notices these denials are more common among the lowest-income applicants, this should be a sign that policies need to be examined and more flexible standards may be necessary.
However, because of FEMA’s lack of transparency around their inspection and determination process, we have only vague evidence as to what has gone wrong with each application. There are still open questions about what triggers some of these codes, and therefore, confusion remains over not only how individual applicants can appeal them but also how we can address systemic inequities. Greater transparency is crucial to both the applicant struggling to access recovery funds and those of us who want to see policy changes to create a more equitable disaster recovery process.
YVETTE CHEN and ADAM GORDON
Policy and Planning Analyst and Associate Director and Staff Attorney, Fair Share Housing Center
Natural disasters take place within pre-existing social structures. Communities are shaped by legacies of segregation, disinvestment, and land use policy, so even before a hazardous event, neighborhoods have differential access to resources. To account for these inequalities, Fair Share Housing Center advocates for a fair allocation of recovery funding, release of timely and clear post-disaster data, and adherence to fair housing standards.
Recovery funding should be distributed equitably among survivors. Currently, funding awards and damage assessments based on property values steer assistance toward wealthier homeowners. We saw this firsthand in New Jersey after Superstorm Sandy when renters experienced 43% of the damage, yet were initially targeted to receive only 22% of federal funding. The federal government should require recovery funding to address needs of people that are low-income, people with disabilities, people with limited English proficiency, and other marginalized groups.
FEMA should release post-disaster datasets in a timely manner to promote transparency. Fortunately, FEMA has made more data available after recent disasters, including data on individual assistance applications with information on flood level, demographics, and amounts and duration of assistance. We analyzed an earlier version of these data and found that recovery plans in New Jersey post-Superstorm Sandy discriminated by race and ethnicity. Other communities have used these data to more comprehensively find which neighborhoods need the most help. FEMA should continue working to release timely and comprehensive data.
Recovery must adhere to the Affirmative Furthering Fair Housing requirement in the federal Fair Housing Act. Jurisdictions receiving federal funding must execute disaster recovery plans and allocate funding in compliance with fair housing laws, to address and not further exacerbate racial disparities and segregation.
Lastly, but critically, recovery programs must have a consistent and long-term planned approach. Local authorities are best positioned to engage residents and assess on the ground needs pre- and post-disaster. Mitigation and adaptation projects often go to wealthier communities, whereas communities of color and low-income communities are often located in higher-risk areas. Federal, state, and local governments should promote fairness in both infrastructural investments and relocation options and actively make mitigation and elevation options before disaster strikes.
Executive Director, Environmental Analysis & Communications Group, Edward J. Bloustein School of Planning & Public Policy, Rutgers, The State University of New Jersey
We have heard loud and clear that changing climate conditions tip the scales for individuals and families that are already living on the edge. This includes major storms but it also includes even the smallest climate events such as nuisance flooding which makes it difficult for individuals and families with limited transportation options to get to work or school on time, or back-to-back high heat days that prompt urban residents to not use their air conditioners because they have to choose between paying their electric bills or buying groceries, or torrential rain events that can further damage homes that need basic structural repairs, making them ineligible for federal weatherization assistance dollars.
For policy change to truly benefit low-income households and communities, we need to do three things:
- Adjust our current mental definition of resilience from bouncing back to the conditions that existed prior to a climate event to, instead, define whole communities that are measurably better, namely: healthier, greener, more equitable and more prosperous. The adaptive capacity of any household or community is linked to the underlying integrity of the infrastructure, social systems, economy and other factors in a community. Building strong communities for all means building resilient communities.
- Change how we design and implement policies to make sure that we remove barriers that prevent low-income residents from having a seat at the table where policies are designed and locally implemented. Low-income residents have historically had a limited voice in local, state and federal decision-making processes; new systems are needed to support their involvement and ensure that they have the capacity to be full participants.
- Consider the inherent causes of many low-income households’ and communities’ vulnerabilities to climate change. Low-income households and communities are the result of complex, historic social inequities including community underinvestment, health disparities and segregation. Considering equity implications of recovery policies can be an important tool to ensure that we are not adding temporary patches to broken systems but that we are, instead, building policies that are inherently designed to support strong and resilient households and communities that can recover from climate events regardless of income levels.
Chief Strategy and Innovation Officer, SBP
I recommend three policy changes:
ONEAPP for recovery assistance
Disaster survivors may receive assistance from as many as 19 different agencies – each with its own paperwork and process. The burden of application is placed on the survivor who has just lost everything even though roughly 80% of the data collected are a) the same across various applications and b) publicly available from other sources including individual tax returns. Much confusion could be simplified by creating a single, common application for disaster assistance that is used by all these agencies. Publicly available data could be used to pre-populate the application fields to save time and energy on behalf of disaster survivors.
Improve FEMA damage assessment
FEMA’s method for damage assessment still relies primarily on human inspectors with paper and pen, or tablet devices, to visit impacted homes one at a time to assess damage. This method is slow, inconsistent, and subject to bias and human error. The process for applying, appealing, and advocating for one’s self is anything but clear. Meanwhile, the insurance industry uses satellite imagery, aerial flyovers, drones, predictive analytics and other sources of big data to assess damage more quickly and consistently and pay claims in a matter of hours or days vs. weeks or months. FEMA’s strategic plan includes a goal to reduce the complexity of FEMA – the damage assessment and award process is a great place to begin.
CDBG-DR permanent rules and regulations
State and local housing recovery and repair programs utilize federal (HUD) CDBG-DR funds intended to serve the most vulnerable disaster survivors. The process typically takes at least 14–18 months from the time of disaster to the moment when funds start to reach clients. Still more time is needed to achieve scale and predictability in repair programs. Most take 5+ years to reach all eligible survivors. The most vulnerable homeowners must wait longest, often years, to receive assistance and complete their recovery. The delay and lack of predictability pushes survivors beyond their breaking point and causes irreversible damage to children, families, and seniors who suffer unnecessarily because of this lengthy and unpredictable process. Congress should authorize and require HUD to build standard CDBG-DR rules and regulations that apply regardless of disaster. This would allow state and local governments in affected communities to share what has worked more easily with one another, and to build effective, efficient, and compliant programs more quickly when disasters occur.
MARION MOLLEGEN MCFADDEN and LAURIE SCHOEMAN
Senior Vice President of Public Policy and Senior Advisor for Resilience and Senior National Director for Resilience & Disaster Recovery, Enterprise Community Partners
There are several changes to federal policy that can help low-income households during disaster recovery. Congress should:
- Ensure CDBG-DR becomes a permanently authorized program which will ensure stability, effectiveness and sustainability of federal dollars.
- Identify ways of providing bridge funding to jurisdictions so they can get the cash advance necessary to implement needed infrastructure as immediately as possible.
- Ensure that the AMI reflected in the local jurisdiction reflects the true need of the community with respect to affordable housing needs. Often a disconnect between registered AMI threshold and true need i.e. more households housing insecure because federal poverty levels need to be recalibrated to reflect true cost of living etc.
- Ensure that community participation included in the mitigation planning processes as well as action planning that occurs in communities, with declared disaster, planning for deployment of CDBG-DR and CDBG-DR MIT funding as well as HGMP and BRIC funding. Community participation should be a mandate regarding every federally funded project over a particular to be determined threshold.
- Consider the importance of Technical assistance regarding supporting communities in recovery as well as mitigation/adaptation planning. TA set aside should be available to jurisdictions for community engagement support. This assistance should include templates to jurisdictions that they can use from other jurisdictions and communities around buyouts, rehabilitation and restoration and education and training.
- Consider the importance of rebuilding to include affordable housing to both replace what was lost in event and bring more into community to create wider pool of affordable housing “reserve” particularly in repeated loss communities.
- Ensure that resiliency guidance and standards, such as Enterprise Community Partners’ resilient housing guidance and fact sheets, are included in jurisdictional scoping and programming of federal dollars invested in home rebuilding during the recovery process for relevant regions and related topics.
- Review additional guidance developed by Enterprise and others to review executive level policy changes necessary to improve resilience for low income communities beyond the immediate disaster recovery timeframe.
LORI PEEK and JENNIFER TOBIN
Professor of Sociology and Director of the Natural Hazards Center and Deputy Administrator of the Natural Hazards Center, University of Colorado Boulder
Disasters—worsened by climate change, crumbling infrastructure, and widening economic inequality—imperil our nation’s schools. Nine out of ten children in the United States live in communities that are at risk to flooding, earthquakes, tornadoes, wildfires, or other natural hazards. That risk is exacerbated for low-income and racial minority children who attend segregated and systematically underfunded schools. Children in economically disadvantaged areas cannot fix the state of their schools on their own, yet they are required to attend classes in buildings that could lead to their deaths in a disaster. Fulfilling our moral and ethical obligation to the nation’s most vulnerable school children will require major public and private sector investments in natural hazards mitigation.
The American Society of Civil Engineers recently assigned a D+ to our nation’s rapidly deteriorating school infrastructure and estimated that maintaining school facilities at their current levels will cost $38 billion annually. Because our public schools are funded in large part by property taxes, low-income communities often struggle to meet the basic needs of students and teachers, with no dollars left for building maintenance or improvement.
Political leaders have promised trillions of dollars in infrastructure investments. If associated policies were written with a social justice lens, such investments could help low-income and majority-minority school districts retrofit dangerous unreinforced masonry buildings, build storm shelters, and adequately heat and cool classrooms, among other life-saving strategies. As private sector growth continues, corporations that receive substantial tax breaks and other economic incentives should be required to help mitigate vulnerable school buildings. Their profits should also help pay for the construction of new schools that are often required when large companies move into cities, increasing the demand on our underfunded public education systems.
Beyond ensuring that old and new school buildings are structurally resistant to disaster, there are other ways to improve natural hazard safety in schools. Federal and state school safety regulations should require that school leaders partner with emergency managers to write preparedness, recovery, and educational continuity plans, so that academic progress is not seriously disrupted in the event of a disaster. School safety also needs to be incorporated into the curriculum so that every child receives an education that emphasizes disaster resilience.
Ensuring that all children—regardless of race or social class background—receive a quality education remains one of the great promises of our nation. As young people come of age in this ever more turbulent and unequal world, they must be prepared with the knowledge and capabilities to make it a more just and sustainable place. Helping children to thrive under these conditions will require additional resources and new policy frameworks that prioritize their education, safety, and wellbeing. And that is exactly what our children deserve.
Assistant Professor of Emergency Management, Jacksonville State University
One of the biggest challenges that many low-income households face is the need to prove their deservedness. In practice, this comes down to documentation, a space where some legal aid groups and others have tried to assist. Yet, it also comes down to the inherent penalties for the inability to afford flood insurance or to afford to properly maintain homes. There are many ways to tackle this challenge, but clearly no easy solutions:
- Change contract mechanisms with private contractors, or with non-profits providing case management, to avoid situations where the contractor has financial disincentives for working with more difficult cases. For example, contracts that track the number of applicants as the measure of contractor success create an incentive to only focus on those applicants whose needs require less labor hours. In other words, people with complicated cases languish in appeals, while middle class homeowners are assisted first.
- Consider models where base levels of assistance are provided, without the need for onerous documentation. More money is spent in preventing the misspending of funds, and more trauma created for disaster victims, than is warranted. This is a model being used internationally.
- Improve data sharing between federal and state agencies, as well as insurance agencies, to reduce the direct burden on impacted households in cases where documents have been lost or where a homeowner does not readily have access to information such as tax returns.
- Recognize the existence of historical inequities, such as redlining, that leave some neighborhoods less able to receive federal assistance; and, modify the requirements to assist those residents.
- Explore mechanisms to look at community benefits and costs vis-à-vis individual low-income households. Our current benefit-cost methodologies for investments are inherently limited, and the value of a structure alone does not reflect the value of a family’s ability to remain in a community in which they are embedded.
- Revise the Stafford Act to allow for more flexibility with post-disaster housing assistance, especially for short term housing solutions that can be transitioned to long term solutions, such as the RAPIDO model. The current policy of prohibiting any permanent habitation in short term housing results in tremendous waste as money is spent on trailers that depreciate and are eventually discarded.
- State and local governments should also support the creation of land trusts, co-ops, and other legal entities that will allow communities to interact directly with federal grants as communities, and not just as collections of individuals.
Former Executive Director, Risk Management and Decision Processes Center, Wharton School, The University of Pennsylvania
Disasters can cause financial distress for families. Roughly 44% of Americans do not have $400 in liquid funds for an emergency. With such limited savings, families cannot fund reconstruction post-disaster—which could stretch into the thousands or tens of thousands of dollars—from their bank accounts. As others in this series have highlighted, federal disaster aid programs are often insufficient and delayed. And post-disaster loans, while helpful for some families, are not a panacea as many low-income families do not have qualifying debt to income ratios or credit scores and would be burdened by additional debt. There is thus no substitute for disaster insurance in order to ensure recovery. Yet, the families that need the protection of disaster insurance the most are the least able to afford it.
Flood and earthquake coverage are excluded from standard homeowners policies and very few people purchase these additional policies. For lower income households, the cost can be prohibitive. A report from FEMA finds, for example, that lower income households are less likely to have flood insurance. How can we make disaster insurance available and affordable to these families?
Many stakeholders have examined this question for the case of flood insurance and suggested a means-tested assistance program that would help families with the cost of flood insurance. This could be a voucher program, for example, run by HUD and paid for, not through cross-subsidies in premiums, but from the Treasury. Other program designs have also been considered (see here, here, and here). Means-tested assistance could also be provided for investments in hazard mitigation, which in turn could lower insurance costs.
Absent a federal program, the city of Portland, Oregon found through a pilot program that flood insurance costs could be lowered even without direct payments by helping homeowners obtain elevation certificates (used by the National Flood Insurance Program to better price older homes) and offering one-on-one counseling with a knowledgeable flood insurance agent who could correct errors in their policy and right-size their policy. These consultations lowered insurance costs for the majority of participants, sometimes substantially. Such pilots like this could be scaled around the country. Other cities are experimenting with property tax rebates in lower income areas when households have flood insurance.
Finally, looking beyond public sector assistance, innovative insurance products that have been tested in other parts of the world could be brought to a U.S. context. For example, parametric microinsurance policies could provide needed funding post-disaster for low income families. These policies could be facilitated through an NGO or harness mobile technology to provide funds directly to households. In some places, these may need to be designed as public-private partnership where the premium is cost-shared with a public agency or charitable group.