AECOM Issues Public Comment on FEMA Proposed Rule
* * *
The comments and suggestions provided herein are founded on all levels of governmental disaster management experience covering all types of hazard events. Further, our guiding principle is built upon the primary lesson learned over our decades of support and experience, which is the inherent value of reducing the complexity and improving the timely delivery of government disaster recovery aid to disaster survivors.
Summary of AECOM Comments
Our responses to the
2.The proposed methodology will likely benefit large urban jurisdictions and affluent communities with high levels of TTR more than economically distressed small- andmedium-sized communities and rural areas.
1. Incentivize SLTT capacity building and commitment for resilience: Generally, disasters affect SLTTs differently based on two post-disaster capability proficiencies--response and recovery. If the federal government invests in preparedness and mitigation, that investment will ultimately help decrease the severity of damage experienced by SLTTs, resulting in fewer disaster events that require federal assistance and, for those that do, decreased costs of federal assistance.
To achieve this improved resilience for those SLTTs that demonstrate strong disaster management capacity and capabilities, building code enforcement, and a clear commitment to increasing resilience and adapting to climate change, we recommend increasing the federal cost share above 75% or lowering the disaster declaration threshold.
By increasing the federal share or adjusting the threshold, investments in building SLTT's resilience and capacity can be expected to result in a reduction of catastrophic disaster impacts and consequences.
2. Use a tiered approach to delegate disaster management responsibilities: We propose a tiered approach, described below, that would provide SLTTs with federal support and grants on a tiered scale based on the disaster impacts to their communities.
In recent years, the frequency of disasters and severity of disaster impacts have overwhelmed federal resources. Further, the current all-or-nothing methodology used in responding to Presidentially declared disasters has disincentivized SLTTs to adequately invest in capability and capacity building and explore new and innovative financial tools, such as parametric insurance and climate bonds.
A tiered approach would decrease reliance on federal resources by requiring SLTTs to build capacity and take on more disaster management tasks. This approach would allow the federal government to put more focus on large-scale disasters and let states respond to moderate events with their own resources and be reimbursed the eligible response and reconstruction costs later. In order to promote disaster management capacity and capability building for SLTTs, we propose the federal government share responsibilities with SLTTs as described below.
* Tier 3 (Full-Scale Disaster) - For a major Presidential disaster declaration over a certain threshold, the federal government would provide full-scale disaster assistance to impacted SLTTs within the declared state, to include both financial as well as other disaster management and response assistance.
* Tier 2 (Moderate-Sized Disaster) - For moderate-sized Presidential disaster declarations under a certain threshold, similar to
To obtain financial assistance for the disaster, we recommend the federal government require the submittal of an Action Plan outlining the use of the federal funding to include damage assessments, recovery activities, major milestones, and compliance requirements.
* Tier 1 (Small-Sized Disasters) - For small disasters resulting in damages under a certain threshold, such as the existing
If a tiered approach is adopted, the private sector may prove to be a critical resource for supporting states and territories in managing disasters. In this case,
3. Improve equity and fairness of the proposed TTR approach: We support continuing to evaluate the impact of any disaster at the county and local government level, as well as at the American Indian and Alaskan Native Tribal Government levels. However, using the approach outlined in the proposed rule, which is a quantitative methodology based on TTR, is biased against small and economically vulnerable communities with low levels of TTR. If a disaster occurs across small communities or a tribal nation, receiving a Presidential disaster declaration will be extremely difficult as compared to one that occurs in areas of higher TTR such as urban centers with expensive infrastructure, higher wages, and higher rates of taxation. To counteract this bias, we support weighting the TTR bias using objective socio-economic status data at the county level. Such an approach would be consistent with other federal agencies such as the
Implementation Considerations
Our country needs to work together to build a resilient nation; our approach outlined in Suggestion No. 1 would provide SLTTs with an incentive to improve resiliency and disaster management response by having the option of increasing the federal share if they enact various hazard mitigation and resilience measures. Such measures might include adopting modern building codes, improving floodplain management, procuring private sector contracts, demonstrating progress toward Enhanced State Mitigation Plan status, disaster resilient land use planning, adopting climate resilient practices, and using innovative financial tools such as parametric insurance to avoid and reduce disaster impacts and consequences and provide rapid-infusion of capital immediately after an event.
As described above,
Implementing the proposed rule fairly and equitably across the country should be a
Conclusion
We thank you for the opportunity to provide feedback on
* * *
The proposed rule can be viewed at: https://www.regulations.gov/document?D=FEMA-2020-0038-0001
TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact
Artificial Intelligence and Machine Learning for Insurance Technology from Johnson Controls Available on the Ocean Tomo Bid-Askā¢ Market
County commission holds meeting
Advisor News
Annuity News
Health/Employee Benefits News
Life Insurance News