Fors Marsh Group Issues Public Comment on FEMA Notice

WASHINGTON, July 28 -- Fors Marsh Group LLC, Arlington, Virginia, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on FEMA Programs, Regulations, and Policies". The comment was posted on July 21, 2021:

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Introduction

Fors Marsh Group, LLC (FMG) is pleased to respond to the request for information from the Federal Emergency Management Agency (FEMA) to inform future strategies to achieve FEMA's mission in a manner that furthers the goals of advancing equity for all and bolstering resilience from the impacts of climate change.

Fors Marsh Group is a leading research and evaluation partner with several federal agencies including FEMA's National Assessments and Integration Division and Individual and Community Preparedness Division. In this response we put forward three recommendations for advancing FEMA's equity and climate change resilience goals through improved evaluation and evidence-building activities. These recommendations support not only the Agency's priorities but build on its work over the past several months to reach historically underserved communities with vaccine confidence message as part of FEMA's support to the National Strategy for the COVID-19 Response and Pandemic Preparedness. FMG has been honored to support these efforts, and we believe that tools like the Social Vulnerability Index and the Climate Data Initiative can provide structure and program objective for FEMA's mission.

In this response, FMG provides three recommendations that focus on ways that FEMA's ongoing work to implement the Evidence Act can be leveraged to address equity and climate change priorities. We present these recommendations below, along with corresponding action steps that can be taken in support of these recommendations. We also indicate which General Questions and Specific Questions from the RFI the recommendations address.

Recommendation 1: Embed Equity and Climate Change within FEMA's Evidence Act Response (general questions #1-2, and specific questions #1-5)

The Foundations for Evidence-Based Policymaking Act (Evidence Act) charges federal agencies to be more proactive and transparent in their efforts to build an evidence base and use that evidence to make decisions. The Evidence Act places specific requirements on some federal agencies to name evidence officials and generate evidence products, namely the evidence-building plan, evaluation agenda, and capacity assessment. Researchers at FEMA's NAID and OPPA offices are building a more robust research and evaluation portfolio to inform emergency management decisions. To this end, these offices have begun developing strategic products that align with the prescribed practices of the Evidence Act. This recommendation focuses on way to leverage these strategic products to address the following questions:

* General Question 1: Are there FEMA programs, regulations, and/or policies that perpetuate systemic barriers to opportunities and benefits for people of color and/or other underserved groups as defined in Executive Order 13985 and, if so, what are they? How can those programs, regulations, and/or policies be modified, expanded, streamlined, or repealed to deliver resources and benefits more equitably?

* General Question 2: Are there FEMA programs, regulations, and/or policies that do not bolster resilience to impacts of climate change, particularly for those disproportionately impacted by climate change, and, if so, what are they? How can those programs, regulations, and/or policies be modified, expanded, streamlined, or repealed to bolster resilience to the impacts of climate change?

* Specific Question 1: Individual Assistance: Are there regulations and/or policies that act as a barrier to people of color and others who have been historically underserved, marginalized, and adversely affected by persistent poverty, inequality, and climate change?

* Specific Question 2: Are there measures FEMA could take to more effectively bolster or incentivize resilience to the impacts of climate change?

* Specific Question 3: National Flood Insurance Program: Are there regulations and/or policies that disincentivize purchasing flood insurance, particularly by lower-income communities, communities of color, and Tribal communities? Are there measures FEMA could take to increase nationwide the number of flood-insured homes in the general population and particularly in lower-income communities, communities of color, and Tribal communities?

* Specific Question 4: Are there measures FEMA could take to prioritize funding to mitigate the disproportionate impact climate change has on the most vulnerable in society, particularly lower-income communities, communities of color, and Tribal communities?

* Specific Question 5: Preparedness Grant Programs: Are there measures FEMA could take to improve our Preparedness Grant Programs to ensure the funding provided to our State and local partners and other stakeholders addresses the domestic terrorism threats currently faced, particularly when those threats impact or target groups that have been historically underserved or subjected to discrimination? What should FEMA address beyond the types of activities these grants support the priority areas on which we ask our State, local, and Tribal partners and other stakeholders to should focus; and the risk methodologies to use in determining how to allocate funding?

In order for progress on equity and climate change to be meaningful it must be rooted in evidence-based practices that impact the Agency's desired outcomes. We recommend that FEMA utilize new Evidence Act products to guarantee that equity and climate change resilience are priority areas for research and evaluation and that evidence-based decision-making becomes an integral part of the Agency's equity and climate change agendas. The steps below lay out an action plan for implementing this recommendation.

Step 1: Create a logic model that identifies specific equity and climate change outcomes

FEMA's first step must be to define the equity and climate change outcomes that it hopes to achieve. These high-level, Agency outcomes will serve as the North Star to direct all subsequent directorate- and division-specific goals and activities. Without them, FEMA risks directing conflicting or misaligned efforts throughout the Agency that undermine its success.

Once FEMA has identified the high-level equity and climate change outcomes, we recommend the Agency develop a logic model that captures all of FEMA's operational and programmatic components that will address equity and climate change outcomes. A logic model demonstrates how a program works by identifying the program's assumptions, resources, activities, and outcomes. They can be used to strengthen evaluation activities by identifying research questions, which aspects of a program to evaluate, what information to collect, and measures and data collection methods.

In 2019, under contract with the National Assessments and Integration Division (NAID), FMG developed a logic model for the Homeland Security Grant Program, which has subsequently directed Homeland Security Grant Program (HSGP) research and evaluation activities. In a similar fashion, FEMA can use a logic model to understand the relationship between desired outcomes and its various activities, specifically those related to equity and climate change, which are currently less-well defined.

FEMA should engage a wide variety of stakeholders to inform and validate each component of the logic model. These stakeholders should engage new groups that can speak to equity- and climate- specific components, including the academic community, nongovernmental organizations from underserved communities, climate scientists, and those underserved communities most affected by the affects of climate change.

Step 2: Incorporate equity and climate change objectives in the Agency Learning Agenda, Capacity Assessment, and Annual Evaluation.

The Evidence Act recommends a variety of products to ensure agencies are able to build the necessary infrastructure to use evidence in policy development; facilitate open government data; and integrate with the Federal Data strategy. Using the logic model as a foundation, FEMA can develop these products to be inclusive of its equity and climate change goals. These products include:

1. Learning Agenda: a systematic plan for identifying and addressing policy questions relevant to the programs, policies, and regulations of the agency.

2. Capacity Assessment: gauge an agency's ability and infrastructure to conduct evidence-building activities like foundational fact finding, performance measurement, policy analysis, and program evaluation.

3. Evaluation Plan: describes the evaluation activities an agency plans to conduct that align with the long-term strategy defined in the Learning Agenda.

4. Data Plan: describes how an agency plans to increase open access to data while strengthening privacy and security regulations.

Learning Agenda

Of particular relevance to addressing DEI and climate change is the FEMA learning agenda. The FEMA learning agenda should specify priority research questions that address equity and climate change outcomes and identify methods for answering each research question. Questions should focus on investments and processes that improve DEI and climate outcomes across all mission areas to support the development of a useful evidence base that can drive future policy decisions and investments.

Of course, to answer these questions, FEMA must define how it measures outcomes related to equity and climate change. One way FEMA's learning agenda should address these questions is by considering how modifications or expansions to FEMA's doctrine can support equity and climate change goals. For example, FEMA's current core capability framework does demonstrates how a program works by identifying the program's assumptions, resources, activities, and outcomes. They can be used to strengthen evaluation activities by identifying research questions, which aspects of a program to evaluate, what information to collect, and measures and data collection methods.

In 2019, under contract with the National Assessments and Integration Division (NAID), FMG developed a logic model for the Homeland Security Grant Program, which has subsequently directed Homeland Security Grant Program (HSGP) research and evaluation activities. In a similar fashion, FEMA can use a logic model to understand the relationship between desired outcomes and its various activities, specifically those related to equity and climate change, which are currently less-well defined.

FEMA should engage a wide variety of stakeholders to inform and validate each component of the logic model. These stakeholders should engage new groups that can speak to equity- and climate- specific components, including the academic community, nongovernmental organizations from underserved communities, climate scientists, and those underserved communities most affected by the affects of climate change.

Step 2: Incorporate equity and climate change objectives in the Agency Learning Agenda, Capacity Assessment, and Annual Evaluation.

The Evidence Act recommends a variety of products to ensure agencies are able to build the necessary infrastructure to use evidence in policy development; facilitate open government data; and integrate with the Federal Data strategy. Using the logic model as a foundation, FEMA can develop these products to be inclusive of its equity and climate change goals. These products include:

1. Learning Agenda: a systematic plan for identifying and addressing policy questions relevant to the programs, policies, and regulations of the agency.

2. Capacity Assessment: gauge an agency's ability and infrastructure to conduct evidence-building activities like foundational fact finding, performance measurement, policy analysis, and program evaluation.

3. Evaluation Plan: describes the evaluation activities an agency plans to conduct that align with the long-term strategy defined in the Learning Agenda.

4. Data Plan: describes how an agency plans to increase open access to data while strengthening privacy and security regulations.

Learning Agenda

Of particular relevance to addressing DEI and climate change is the FEMA learning agenda. The FEMA learning agenda should specify priority research questions that address equity and climate change outcomes and identify methods for answering each research question. Questions should focus on investments and processes that improve DEI and climate outcomes across all mission areas to support the development of a useful evidence base that can drive future policy decisions and investments.

Of course, to answer these questions, FEMA must define how it measures outcomes related to equity and climate change. One way FEMA's learning agenda should address these questions is by considering how modifications or expansions to FEMA's doctrine can support equity and climate change goals. For example, FEMA's current core capability framework does not explicitly address equity or climate change. To address equity, FEMA could introduce one or more new core capabilities specific to the equity-focused outcomes identified in the logic model. Additionally, FEMA can leverage existing capabilities to develop a climate-sensitive construct that would support evaluation of climate goals and application of existing data.

In 2020, FMG worked with NAID to develop the HSGP Grant Effectiveness Data Roadmap, which identified specific research questions that address learning priorities and that, when answered, would provide necessary evidence to inform grant investments and improve program outcomes. In addition to the learning agenda, the Roadmap also articulated the ideal state of grant effectiveness evaluation, discussed the associated capacity, cultural, data, and technical challenges associated with achieving it, and proposed solutions to begin addressing those challenges. Similarly, FEMA's learning agenda should go beyond defining specific research questions and methods to also identify foundational frameworks for evaluating FEMA's impact on new equity and climate change priorities.

Capacity Assessment

FEMA should also ensure that it incorporates equity and climate change into the Agency's capacity assessment, which is an important tool for understanding FEMA's ability to reach its evaluation goals. The capacity assessment focuses on how well evidence activities support the needs of different departments and functions within the agency, how appropriate agency methods are to addressing research questions, how well personnel capability and agency infrastructure support research goals, and how equipped the agency is to support staff capacity development.

In addition to assessing the topics listed above, FEMA's capacity assessment should focus on FEMA's current structures, processes, attitudes, and beliefs around equity and climate change in order to better understand how Agency culture should be leveraged or modified to support new goals.

Evaluation Plan

Completion of an equity- and climate change-focused Evidence Act strategy will result in an evaluation plan that explicitly addresses these priorities. Through the consistent evaluation and reporting on equity and climate change goals, FEMA can drive meaningful progress that is evidence-based and transparent.

Recommendation 2: Assess and apply existing data to conduct research on effective practices for advancing equity and promoting climate change resilience.

FEMA cannot hope to achieve its equity and climate change goals without ensuring it has access to appropriate and sufficient data to answer its research questions. In 2020, FMG worked with NAID to create the HSGP Data Landscape, which identified all available data for evaluating the impact of the program, assessed the strengths and weaknesses of each source, and identified gaps in current data through subsequent strategic efforts. We recommend that FEMA conduct a similar, in-depth review of data that is currently available to address equity and climate change resilience.

Assess current data landscape

FEMA should prioritize maximizing awareness, access, usability, and use of extant data to begin addressing its research questions. Using what is already available is both more efficient and expedient than introducing new data collections right away. Through a thorough assessment of the field, FEMA can prioritize its research agenda to begin evaluations on where data currently exists and prioritize data gaps to be sure that Agency resources are having the greatest impact. Specifically, FEMA's equity and climate change data assessment should have five objectives: 1. Assess existing FEMA data for overlap with equity and climate change-relevant concepts

There is currently little FEMA data that can explicitly answer questions about equity or climate change resilience. We recommend that FEMA conduct an in-depth scan of all its data to identify data that may be equity or climate change sensitive. Equity-sensitive and climate-sensitive data would be those that have either conceptual or population overlap with the outcomes identified in the logic model.

2. Scan available datasets across the Federal government for sources that capture equity and climate change-related concepts

Title II of the Evidence Act encourages open sharing of data across the Federal government. By assessing data from other agencies, FEMA can identify potentially useful data and combine its own data with other sources that may capture equity or climate change concepts in a way that is useful to FEMA. For example. FEMA has already started using the Center for Disease Control's Social Vulnerability Index (SVI) to integrate the concept of social vulnerability into assessments of risk and capability.

3. Assess FEMA data for potential integration with other Federal data sources and make recommendations on connections that can be made to capture the elements identified in the FEMA Logic Model

Not all relevant data may be appropriate for use with FEMA data. For successful integration FEMA must be able to connect data in a valid manner, which can be challenging. FEMA should engage with those most familiar with each data source to determine the feasibility of combining data and making recommendations for which data integrations to pursue.

4. Identify gaps in the landscape to inform data collection modifications or new data collections

While we believe FEMA can make significant strides toward its research goals with existing data, FEMA will also need to consider what data is not available and should be collected. Gaps should be prioritized and link directly to a specific research question to ensure relevance and direct resources efficiently. Recommendation 3 below includes a more detailed discussion on incorporating more varied stakeholder input in FEMA data.

5. Determine what FEMA data and analyses can be shared with other agencies and/or the public.

Addressing data sharing is a recommendation aligned with Title II of the Evidence Act and that supports the goals of advancing equity. By ensuring that all non-confidential data is made available to the public, FEMA can empower academics, advocacy groups, and researchers to use data to research their own priority topics, and advance emergency management evidence-building through more varied research.

Apply existing data to conduct research

Once FEMA has assessed available data and its potential for addressing FEMA's goals, it should identify specific analyses that can be conducted to address priority research questions around equity and climate change. For example, Table 1 below includes a list of possible research topics that FEMA could pursue using existing FEMA data and data from the social vulnerability index.

Table 1: Example Analyses Using FEMA and SVI Data

Conduct statistical analysis using the SVI in conjunction with grant activities data to determine whether community demographics are predictive of grant fund allocations.

Combine data from the SVI and grant activities data to identify trends in grant investments and determine to what extent grant dollars are administered to underserved communities.

Combine SVI data with IA and PA data to better understand how disaster funds are allocated to underserved individuals and communities.

Conduct statistical analysis to determine whether demographic characteristics of FEMA disaster aid applicants (particularly income and racial characteristics) are predictive of (1) receipt of aid and/or (2) level of aid

Combine SVI data with FIMA flood insurance data to understand how flood risk affects underserved communities and how flood insurance and other resources reach these communities.

Compare SVI data against publication order data from Ready and ICPD to review how materials are (or are not) reaching the most vulnerable communities, through zip-code level analysis.

Compare SVI data against FEMA course completion (EMI, ICPD's OPEN course) data to identify geographic and community gaps in existing capacity build; task divisions to create outreach plans to address these gaps.

We recommend that in addition to pursuing these research questions, FEMA also follow-up on any relationships found by conducting focus groups and interviews to better understand the causes of such inequities.

FEMA can also build new data tools to make priority data available across the Agency and the Federal government. For example, FEMA can work with other Federal agencies to create a Climate Vulnerability Index to integrate relevant climate and vulnerability data (e.g., SVI, National Risk Index), visualize data in a user-friendly GIS-based data tool, and share publicly and/or with other Federal agencies. Additionally, FEMA can integrate and showcase equity and climate change data by incorporating as a dashboard for the FEMA Daily Operations Briefing, supplementing the current Common Operating Picture data.

Recommendation 3: Incorporate more varied stakeholder input into risk and capability assessments.

Achieving equity in emergency management cannot be limited to equitable distribution of grant dollars. Rather, FEMA must ensure that the use of those grant dollars 1) does not promote practices that disproportionately injure underserved communities, and 2) reflects the disaster-related priorities of the whole community. Measuring these concepts will require new data that capture the priorities and experiences of members of underserved communities. If FEMA is to understand how its investments impact underserved communities, it must engage with underserved communities.

To address these changing hazards, FEMA must expand its network of stakeholders, ensuring that the whole community is represented, and that the risk assessment process is strengthened to allow for greater community input in the process. FEMA should consider how to capture the community's understanding of the key hazards they face, whether weather-based or otherwise, especially those of underserved communities. Current grant effectiveness evaluations draw on risk, capability, and investment data all submitted by emergency management administrators and/or practitioners. While these perspectives are essential, they provide an incomplete picture of all stakeholders in equity and other FEMA outcomes.

One way FEMA can do this is by leveraging the National Household Survey, which reaches millions of American families to assess attitudes, beliefs, and behaviors around preparedness, to understand community member experiences with grant-funded entities, such as state and local emergency management agencies and police and fire departments. These experiences may reveal relationships between FEMA-funded investments and inequitable experiences with emergency response agencies.

For example, FEMA can combine this new data with grant investment data reported in the BSIR to analyze whether there are any grant investments that are predictive of worse experiences for underserved communities. FEMA can also draw on the strength of its community engagement partnerships built through the vaccine confidence efforts, Incorporate climate metrics and projections into the NRI or a companion dataset.

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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0011-0001

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