Habitat for Humanity International Issues Public Comment on FEMA Notice

WASHINGTON, July 31 -- Kristin Wright, director for disaster risk reduction and response at Habitat for Humanity International, Atlanta, Georgia, 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 written on July 21, 2021, and posted on July 22, 2021:

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Habitat for Humanity is a global nonprofit housing organization working in local communities across all 50 states, Guam, Puerto Rico and Washington, D.C. in the United States and in more than 70 countries around the world. Anchored by the conviction that decent and affordable housing places families on a path of new opportunity and increased stability and self-reliance, Habitat has helped more than 35 million people improve their housing conditions through home construction, rehabilitation and repairs, housing finance, housing support services and technical assistance.

Ten percent of our network is located in high-risk regions for at least two hazards. Disaster preparedness, response, and mitigation have long been priorities for Habitat in our mission to build safe homes and resilient communities. Habitat for Humanity has been responding to disasters nationwide over its 40-year history, but especially since Hurricane Katrina, the organization has effectively organized and implemented multiple large-scale recovery efforts to address the affordable housing challenges that face low-income families following a major disaster. Habitat's efforts have assisted hundreds of families to secure decent, affordable housing after their homes were damaged or destroyed.

Our collective disaster recovery work includes short-term response and long-term recovery efforts over many years that supports housing needs through activities such as immediate clean-up, community-wide assessments, family support, new construction, and rehabs and repairs. As indicated in our recent position on climate change,/1 we know that extreme weather events, which are made more intense by climate change, reduce and degrade the affordable housing stock globally. By partnering with families to build stronger, more disaster-resilient and more energy-efficient housing, we have seen how adequate, safe and resilient shelter can contribute to both the immediate security and long-term well-being of families while reducing a home's environmental impact.

While Habitat's work in disaster response, recovery and risk reduction spans the globe, given the time frame we had to submit this comment we chose to focus on the rich examples from our field response in Puerto Rico following Hurricane Maria. Given the nature of Puerto Rico's hazard risk and disaster vulnerabilities, it provides a case study for the rest of the nation regarding the improvements FEMA can make in its service delivery to create equitable outcomes and be better positioned for the realities of climate change. Our responses to both general and specific questions are broken down in the following sections correspondent to the question number in the RFI docket:

General Questions

(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?

FEMA has a one-size-fits-all approach to getting assistance to survivors that does not take into account local contexts, including culture, language, background, architecture, and knowledge, etc. This approach inhibits the individuals who need it most from receiving adequate support. In the bullets below, Habitat field practitioners share suggestions that could enable FEMA to deliver resources and benefits that support equitable outcomes:

* Partner with researchers: Habitat has increased and improved its practice of partnering with researchers who can assess needs to inform program design, and monitor and evaluate programs as they are being implemented so that programs can be more agile and responsive to local needs. Therefore, our first recommendation is one that answers both general questions included in this letter: FEMA should partner and collaborate closely with independent researchers who are skilled in participatory, qualitative, and evaluative research, throughout the emergency cycle. Incorporate iterative data collection, interpretation and translation into use throughout FEMA-led activities. We are confident this will bolster resilience to climate change by those who are disproportionately affected, as well as reduce systemic barriers to benefits and opportunities, as long as vulnerable people and marginalized communities are centered in the research questions, and engaged in co-creation of knowledge.

* Data sharing: Early in recovery, establish data sharing agreements with other actors doing similar work. This would address the overall issue of equity, as many actors visit the same places and whole communities are left out. This causes the amount of funding and rebuilding efforts to not align with areas that were damaged most.

* Choose to partner with local individuals, organizations and companies:

* Language is often a barrier to accessing adequate resources from FEMA. FEMA should prioritize hiring local staff who are multilingual and multicultural. For local individuals who could work for FEMA but have had their own homes damaged, they could also prioritize providing housing assistance to them to enable them to work. For example, staff and volunteers who did not adequately speak Spanish made mistakes on damage assessments in Puerto Rico, which hurt FEMA's reputation on the island and decreased trust with residents.

* Community-based organizations and hardware stores bring a wealth of local knowledge that can improve access to hard-to-reach areas, help prep relevant supplies and materials, and identify commuity members in need of assistance. For example, local hardware stores are a vital resource for local knowledge on housing construction across Puerto Rico because there are many small hardware stores selling housing construction materials to builders within each municipality.

* Local partners will also have a better understanding of the types of residential housing that exist in the affected areas. For example, in Puerto Rico, it is common for two houses, occupied by two generations of the same family to sit on top of each other and have the same address. This means that if both families applied for FEMA funding, the second family that applied would be denied for suspected duplication of benefits. Similarly, in rural areas of Puerto Rico multiple homes could be built on one lot. In these cases, many times, only one home was approved for FEMA funds per lot. Because these types of arrangements are often made in response to poverty or marginalization from formal ownership mechanisms, such policies that uphold the notion of one family, one land title, reduce the potential impact of existing social resilience strategies.

* Revise funding opportunities targeted to organizations to improve accessibility for small and local grassroots organizations. This should include revisiting the communication channels, documentation requirements, number and amounts of grants available, burden of grant writing, reporting and measurements, among other considerations. The organization should aim to be clearly understood and accessible to organizations that are closest to the most marginalized and vulnerable communities, and those that have demonstrated long-term relationships of accountability with such communities. Local organizations may not have the capacity, infrastructure or knowledge to navigate the existing bureaucracy necessary to access federal funding. This does not mean, however, that the same organizations do not have the requisite capacities to effectively and efficiently serve their communities' needs for disaster mitigation, preparedness, response or recovery. The high level of bureaucratic requirements often results in uninintentional prioritization of organizations that are less likely to be led and/or staffed by people who live and work in the most marginalized communities or come from the most vulnerable households, in funding considerations. In light of increasing intensity and frequency of disasters, FEMA should work to identify potential local partners before, as well as during and after, emergency periods.

* Equitable pay: Pay surge staff and volunteers salaries that are on par with the area in which they are working. High salaries inhibit local organizations from hiring their own quality surge staff because they cannot compete with FEMA's high rates.

* Surging staff: Staff should be surged based on need in the affected area. This is especially important when back-to-back disasters occur in different areas. For example, in 2017 many times more surge staff were sent to Florida and Texas, as compared to Puerto Rico, where damage was far greater by any metric used./2

* Stimulating the local economy: FEMA should see their assistance - in the form of grants to homeowners or deployment of surge staff - as an opportunity to reinvigorate the local economy. It should prioritize sourcing local materials and housing staff with local companies. For example, staff was flown to Puerto Rico from mainland U.S., rented cars from major car rental companies, and housed in resorts, none of which were locally owned. All of that money went back to mainland U.S., instead of circulating Puerto Rico's three inhabited islands.

* Provide two-way travel support to evacuated residents who want to return to their homes. For example, some travel support was only available for residents who wanted to leave Puerto Rico, which exacerbated the already high levels of migration off the island. Some individuals wanted to relocate permanently and had the resources to start anew somewhere else, but others lacked those resources, so one-way travel support was an insurmountable barrier to returning.

* Increase accountability of programs to disaster survivors. A starting point for program accountability is to engage with social scientists to design a community-based feedback mechanism. Then FEMA should invest in the mechanism's maintenance and create transparency around its operations. This is especially important for emergency repair programs where the temporary nature of the repair may result in poor quality of the working being completed.

(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?

FEMA's programs are designed to return the state of housing back to where it was prior to the disaster. Returning the state of damaged housing stock back to where it was prior to the event also means a return to the hazard vulnerabilities that damaged the housing in the first place. Below are some opportunities FEMA could explore to reduce risk exacerbated by climate change:

* Improved education on multi-hazard resilient construction practices: This could include guidelines for homeowners on how to self-build housing that is resilient to multiple hazards, and talking points for volunteers, inspectors, or staff who may engage in conversations with homeowners about rebuilding.

* For example, a trend seen in Puerto Rico post-hurricane has been an increase in people wanting to build or rebuild housing informally with reinforced concrete instead of wood. Reinforced concrete houses, however, can be vulnerable to earthquakes when constructed without adherance to building codes or other regulations. It is estimated that more than half of housing in Puerto Rico is constructed informally. Outside organizations must consider the prevalence of this practice in their response. Conversely, after a series of earthquakes in 2019/2020, attitudes shifted and distrust grew for informally constructed reinforced concrete housing that residents saw as vulnerable and dangerous. It is possible to build wooden and concrete homes that are resilient to both hazards. FEMA and supporting agencies should include information promoting hazard resilient construction methodologies for all housing types in a local community./3

* Embrace the true meaning of build back better: Instead of rebuilding infrastructure to the previous standard, provide incentives and funding for renewable sources of energy generation such as solar or wind that have less environmental impact than natural gas, coal or nuclear power plants.

* Incorporate sustainable materials: Blue tarps, used as a temporary measure to secure one's belongings if a home's roof was damaged, deteriorate quickly. Often, they will need to be replaced multiple times before a home can be permanently repaired. The tarps also introduce microplastics into the surrounding area, which damages ecosystems already at risk to climate change. Furthermore, in many parts of Puerto Rico the distribution was delayed due to the requirement that homes be assessed and measured before the tarps were distributed. They were also distributed without training on how to use or dispose of them properly./4

Specific Questions

(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?

FEMA should make it easier for people to access the resources needed to address their recovery needs. FEMA will continue to exacerbate social disparities, particularly in relation to housing, until it reforms the current process and formula for awards and builds a new model driven by equitable outcomes. In the following bullets we have shared some anecdotes around the FEMA Individual Assistance Program and thoughts on building a more equitable model:

* Anecdotally, we have heard from many local Habitat organizations and their partner families about challenges accessing FEMA Individual Assistance. Some were denied assistance altogether. For others, the assistance was not enough to cover all the repairs needed to make their homes safe again./5

* Many local Habitat organizations fill the gap for housing recovery assistance when insurance and FEMA do not meet the need and CDBG-DR resources have yet to be allocated and administered to survivors. Our programs are specifically targeted to serve low-income households. Without program support to fill in the gaps, many of these households would not fully recover.

* Many households are not aware of or do not understand the process to file an appeal claim when they believe the federal disaster assistance package they have received is falling short and they may be owed more. FEMA should reform the appeals process so that it is clearly communicated that households have a right to appeal and provide a variety of methods - online, in-person, via postal mail - to do so. This would help boost FEMA's IA approval ratings so that disaster survivors are getting the resources they need to recover. Additionally, this would allow nonprofit organizations to leverage their resources to more strategically serve households that are in need and outside of IA parameters.

* FEMA should increase its local public communications budget and engage with local organizations to improve its communications efforts. Such communications efforts should specifically seek to inform those who may be eligible for FEMA support, and to receive feedback from those same people (as suggested in the last bullet point of #2 above). An example of this need comes from Puerto Rico. When the equity-improving decision was made to open another round of appeals, in part due to the confusion around ownership documents specific to Puerto Rico's legal system, the decision was not publicly communicated. Therefore, very few households were able to take advantage of the re-opened appeal process. Habitat's program in Puerto Rico had the budget flexibility and communication connections to disseminate information about the re-opened appeal process. Habitat also hired local lawyers to assist families in completing their appeal forms within the new timeframe.

* As FEMA is already aware, multiple news outlets including NPR and the New York Times have reported on the disparities between white households that receive federal disaster assistance and homeowners of color who receive federal disaster assistance. A recent New York Times article, FEMA Disaster Aid Often Widens Racial Disparities,/6 highlights the different experiences of two Hurricane Laura survivors. Despite the similarities in housing type and damage, the white household initially received an Individual and Households Program (IHP) award $10,000 greater than that of their neighbors of color. FEMA's formula for determining IHP awards is perpetuating racial disparities in how property value is calculated. These issues are systemic across the housing sector and the root causes must be identified to implement a more equitable formula for assistance.

* Last year Habitat released a white paper on the role housing policy plays in our nation's racial disparities and what can be done to resolve them: Racial-Disparities-and-Housing-Policy./7

The report details the many ways that racial discrimination has left a legacy of unequal housing conditions, options and opportunities prevalent today including:

* Unequal homeownership attainment and equity gains

* Continued segregation and exclusion from communities of opportunity

* Greater housing cost burdens

* Higher rates of housing instability and threats of eviction

* The compounding effect of COVID-19

If FEMA aims to remove barriers and inequities in the delivery of federal disaster assistance particular to housing recovery, inequities across the housing ecosystem as defined above should be examined in relation to FEMA's fomula for IHP awards. The policy paper also provides housing policy solutions that could have implications for FEMA's reform and delivery of housing recovery programs.

Lastly, Habitat for Humanity commends FEMA for seeking input and collaboration to address two of the largest threats to quality of life in America today: climate change and inequity. We offer continued collaboration and are eager to seek opportunities for partnership in learning so that together we may face and reduce these threats.

Sincerely,

Kristin Wright

Director, Disaster Risk Reduction & Response (US & Canada)

Habitat for Humanity International

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Footnotes:

1/ Habitat for Humanity International. (July 21, 2021). Housing and climate change: Habitat for Humanity International's position. https://www.habitat.org/about/climate-change-position

2/ Willison, Singer, Creary and Greer. 2019. Quantifying inequities in US federal response to hurricane disaster in Texas and Florida compared with Puerto Rico. BMJ Glob Health. Jan 18;4(1). doi: 10.1136/bmjgh-2018-001191

3/ Goldwyn, Javernick-Will and Liel. 2021. Dilemma of the Tropics: Changes to Housing Safety Perceptions, Preferences, and Priorities in Multihazard Environments. Natural Hazards Review (22(3). https://ascelibrary.org/doi/abs/10.1061/(ASCE)NH.1527-6996.

4/ Laura Gorbea, Founding President PR PASS Workshop.

5/ Anecdotes collected from: Habitat for Humanity of Middle Keys, Habitat for Humanity of Collier County, and Habitat for Humanity of Highlands County (Hurricane Irma); Fort Bend Habitat for Humanity and Houston Habitat for Humanity (Hurricane Harvey); and Crystal Coast Habitat for Humanity and Fayetteville Area Habitat for Humanity (Hurricane Florence).

6/ Flavelle, C. (2021, June 7). Why Does Disaster Aid Often Favor White People? The New York Times. https://www.nytimes.com/2021/06/07/climate/FEMA-race-climate.html.

7/ The role of housing policy in causing our nation's racial disparities - and the role it must play in solving them. (2020, August). Habitat for Humanity International. Retrieved July 21, 2020, from https://www.habitat.org/sites/default/files/documents/Racial-Disparities-andHousing-Policy-.pdf

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

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