Iowa Association of Municipal Utilities Issues Public Comment on FEMA Proposed Rule

WASHINGTON, Feb. 17 -- Alexander J. Cutchey, director for government affairs at the Iowa Association of Municipal Utilities, Ankeny, Iowa, has issued a public comment on the Federal Emergency Management Agency proposed rule entitled "Cost of Assistance Estimates in the Disaster Declaration Process for the Public Assistance Program". The comment was written on Feb. 12, 2021, and posted on Feb. 16, 2021:

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The Iowa Association of Municipal Utilities (IAMU) appreciates the opportunity to submit comments regarding the Federal Emergency Management Agency's (FEMA) Notice of Proposed Rulemaking (NOPR) on the Process for the Public Assistance Program (United States, Federal Emergency Management Agency. "Cost of Assistance Estimate in the Disaster Declaration Process for the Public Assistance Program." 85 Fed. Reg. 80719 (Dec. 14, 2020)).

IAMU is a not-for-profit trade association with the mission to support and strengthen Iowa's municipal utilities. IAMU's members include 754 electric, gas, water, and telecommunication utilities across the state. To support our members in providing reliable service, IAMU regularly assists members with continuity of operations, emergency operations, hazard mitigation, critical asset and infrastructure protection, and disaster response and recovery policy development. As a large number of IAMU's membership are publically owned electric utilities, IAMU is also a member of the American Public Power Association (APPA), a national service organization representing interests of not-for-profit, publicly power utilities throughout the United States.

Iowa municipal electric, gas, and water utilities repeatedly experience damage to distribution infrastructure due to ice storms, tornadoes, and floods. If this damage is severe enough to be declared a disaster by the President of the United States, incurred costs are eligible for reimbursement through FEMA grants. These grants are critical in making communities whole when infrastructure exposed to the natural elements faces the extremes of unforeseeable natural disasters.

IAMU opposes FEMA's proposal to increase the per capita threshold for disaster declarations and adjust that threshold based on each state's wealth as measured in "total taxable resources" because:

- The new thresholds would abruptly and dramatically shift the number and size of disasters for which the state must prepare; and

- The NOPR taken as a whole would shift the responsibility of disaster recovery from the federal government to the state and localities when other existing federal policies are serving to make taking those responsibilities more costly.

These points (and others) are addressed fully within APPA's comment, for which IAMU is supportive and incorporates herein by reference.

Of particular importance for Iowa municipal utilities is that FEMA protect municipal utilities in more rural parts of the state, whose total damage calculation would otherwise fall below the NOPR damage thresholds. Appendix C: PA Disaster Project Amount Comparison of the RIA included with the proposed rulemaking shows that between 2008 through 2017, 22 events hit the FEMA threshold for assistance. With the increased thresholds, four events totaling $21,509,645 would not have been eligible for FEMA disaster assistance. One of the events that would have been removed is the City of Sanborn's 2013 claim for $69,316.50. It is unclear whether one-off events such as Sanborn's 2013 claim would catch the state's attention. IAMU is concerned that removing federal funding makes similar claims more likely to fall through the cracks when trying to receive the necessary disaster assistance. Accordingly, IAMU requests that the proposed rule pay special care and provide sufficient remedies for smaller entities, such as municipal utilities that provide essential services within their communities.

Thank you for the opportunity to submit these comments and their careful consideration.

Respectfully submitted,

Alexander J. Cutchey

Director of Government Affairs

Iowa Association of Municipal Utilities

1735 NE 70th Ave.

Ankeny, IA 50021

515.289.1999

[email protected]

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=FEMA-2020-0038-0001

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