Public Comment Period on Climate Change and Underserved Populations
From April to July 2021, FEMA sought public comments on how the agency's programs deal with climate change and underserved communities and populations.
Event Details
On April 22, 2021, FEMA issued a Request for Information (RFI) seeking information from the public on how the agency’s programs, regulations, and policies could better advance the goals of equity for all, environmental justice, and bolster resilience to the impacts of climate change. During the 90-day comment period, FEMA hosted two public meetings on June 15 and 16 to gather additional feedback and maximize public participation in the RFI. There were 274 total attendees for both events and 23 of those attendees provided verbal feedback. The comment period closed on July 21, 2021.
Read below the summary report of the RFI or download a PDF of the report.
Summary Report
FEMA received a total of 340 comments in response to the RFI. The 340 comments received include written comments posted to regulations.gov, comments received during the two public meetings, and comments received via fema-regulations@fema.dhs.gov.1 The RFI and supporting documentation, including transcripts from the two public meetings, and public comments can be found on Regulations.gov.
FEMA received comments from a range of stakeholders including individuals, non-profit organizations, industry associations, and State, local, and Tribal governments. The comments ranged in length from one line to 25 plus page letters. Stakeholders provided agency-wide, cross-cutting comments related to equity, climate change, information collection, data sharing, and suggested process improvements. Stakeholders also provided comments directed toward specific FEMA programs and sub-topics within those programs. In short, the comments provided a wealth of feedback addressing hundreds of topic areas.
FEMA is working diligently to review the comments provided and determine how best to address their contents. In particular, the comments will be considered as FEMA develops its 2022-2026 FEMA Strategic Plan. As a threshold matter, FEMA created a high-level summary of the issues and major themes generally and within specific programs which are outlined below. This general summary does not address all comments received.
General Comments
EDUCATION, OUTREACH & TECHNICAL ASSISTANCE
Commenters included numerous suggestions on ways the agency can provide more education, outreach, and technical assistance in its recovery, mitigation, and preparedness grant programs, and in the National Flood Insurance Program. Comments suggest there is a desire for more education, outreach, and technical assistance to support community preparedness activities, mitigation efforts, grant application processes, and floodplain management. The private sector also offered suggestions on how they could assist FEMA with education, outreach, and technical assistance to the public, non-profit organizations, and local governments.
INFORMATION COLLECTION & DATA SHARING
Commenters also focused on information collection and data sharing. Commenters generally supported collecting more information throughout FEMA programs to allow for more in-depth reporting on demographics associated with disaster assistance. To advance equity, some commenters felt the agency must better collect and share data to allow FEMA and its partners to target solutions to meet the needs of those most impacted by disasters. Comments were also focused on the need for data availability and transparency to allow local non-profit and private actors to offer solutions to challenges directly impacting their communities.
PROCESS IMPROVEMENTS
Commenters provided suggestions on ways to improve processes generally and for specific programs. Many commenters raised issues with the complexity of FEMA’s application processes associated for all of its preparedness, recovery, and mitigation grant programs. Commenters proposed solutions involving increased use of technology and improvements in existing technology to generally improve processes while offering specific solutions for programs to reduce the number of steps required in the application processes and make changes to the documentation required for those applications.
Program Specific Comments
RECOVERY GRANT PROGRAMS
FEMA received hundreds of comments related specifically to the FEMA Individual Assistance (IA) and Public Assistance (PA) grant programs. Comments on the IA program generally focused on ways to advance equity within the program, including suggestions to expand eligibility within the program and to improve transparency regarding eligibility requirements to those applying for assistance. Commenters also focused on the complexity of the application process and provided suggestions to streamline it and ways the agency can be more flexible with documentation requirements in a disaster setting to better advance equity. For example, some commenters suggested a single intake and application process for all federal disaster assistance to streamline assistance and advance equity. Other commenters offered suggestions on how FEMA can better assist those with disabilities throughout the disaster assistance process.
Comments on the PA program generally requested that PA prioritize climate resilience and equity when providing assistance and review the cost sharing requirements for communities impacted by disaster. Comments also expressed a desire for more outreach and education, encouraging more engagement directly with local and Tribal governments. Some commenters recommended FEMA work to better encourage building resilient public facilities and promote responsible investment in resilient, nature-based solutions. Commenters also recommended that FEMA expand public assistance eligibility for non-profit organizations.
MITIGATION & PREPAREDNESS GRANT PROGRAMS
FEMA received hundreds of comments focused on its mitigation grant programs, including the Building Resilient Infrastructure and Communities (BRIC), Hazard Mitigation Grant Program (HMGP) and the Flood Mitigation Assistance (FMA) programs, offering suggestions on ways to advance equity and promote resilient solutions for communities through mitigation grant funding. Commenters raised concerns regarding the complexity of the application processes and offered suggestions to provide more education and technical assistance for communities to compete for this funding effectively. Several commenters discussed the benefit cost analysis tool and provided a range of recommendations to make the tool easier to utilize for underserved communities and to make the tool’s analysis more equitable for those communities. Commenters also discussed challenges with completing buyouts under the mitigation grant programs, making several suggestions for improvement to further advance equity for those that wish to relocate after a disaster.
FEMA also received dozens of comments related to FEMA preparedness grant programs. Commenters suggested that FEMA work with Congress to increase funding for all of its preparedness grant programs, increase focus on rural areas, better integrate its preparedness programs with its recovery and mitigation programs, track data on the specific benefits and risk reduction achieved with preparedness grant funding, and increase focus on the psychological impacts of terrorism and traumatic events.
NATIONAL FLOOD INSURANCE PROGRAM (NFIP)
FEMA also received hundreds of comments on the National Flood Insurance Program (NFIP). Comments focused on recommendations for the agency to make flood insurance more accessible to individuals through education, outreach, and affordability initiatives and to communities through education, outreach, and technical assistance on floodplain management and mitigation planning efforts. Commenters generally offered ways to improve the flood mapping process through enhanced technology and scientific advances as well as inter-agency collaborations. Some commenters also offered solutions to floodplain management challenges to improve resilience and mitigate the effects of flooding in an equitable manner.
Conclusion
We recognize that we need to create stronger partnerships to better enable and support communities and underserved populations when it comes to resiliency and climate change. The input we received from this RFI will help us to better deliver on our mission in a manner that will allow us to advance equity for all.