National Low Income Housing Coalition Issues Public Comment on FEMA Notice

WASHINGTON, July 28 -- Diane Yentel, president and CEO of the National Low Income Housing Coalition, 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 20, 2021, and posted on July 21, 2021:

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I. Introduction

The National Low Income Housing Coalition (NLIHC) is dedicated solely to achieving socially just public policy that ensures people with the lowest incomes in the United States have affordable and decent homes. Our members include state and local housing coalitions, residents of public and assisted housing, nonprofit housing providers, homeless service providers, fair housing organizations, researchers, public housing agencies, private developers and property owners, local and state government agencies, faith-based organizations, and concerned citizens. While our members include the spectrum of housing interests, we do not represent any segment of the housing industry. Rather, we focus on housing policy and funding improvements for extremely low-income people who receive and those who need assistance.

NLIHC leads the Disaster Housing Recovery Coalition (DHRC) of more than 850 national, state, and local organizations, including many working directly with disaster-impacted communities and with first-hand experience recovering after disasters. The DHRC works to ensure that federal disaster recovery efforts reach all the lowest-income and most marginalized survivors.

America's disaster housing recovery framework is broken and in need of major reform. When disasters strike, the lowest-income survivors - including people of color, seniors, people with disabilities, people experiencing homelessness, people with limited English proficiency, and other individuals - are often hardest hit and face the longest, steepest path to recovery./1

Despite the clear need, federal efforts frequently leave these survivors without the assistance needed to fully recover and their communities less resilient to future disasters. As a result, federally led emergency response and recovery programs exacerbate and reinforce racial, income, and accessibility inequities at each stage of response and recovery.

The Federal Emergency Management Agency (FEMA) has requested information on the extent to which agency programs, regulations, and policies 1) perpetuate systemic barriers to opportunities and benefits for people of color and other underserved groups; 2) bolster resilience to the impacts of climate change; and 3) address the disproportionately high and adverse climate-related impacts on disadvantaged communities. FEMA has also requested information about unnecessary or unjustified administrative burdens that may create the systemic barriers.

This comment letter will address the negative impacts that FEMA programs, regulations, and policies have for the lowest-income and most marginalized survivors and how those failures reinforce vulnerabilities to climate change, housing insecurity, and racial segregation.

II. People of color and other underserved groups are disproportionately impacted by low incomes, housing cost-burdens, and homelessness, which magnify the adverse climate impact on disadvantaged communities.

Data collected by the U.S. Census Bureau and analyzed annually by NLIHC show that there are 10.8 million renter households with extremely low incomes - accounting for 25% of all renter households./2

People of color are much more likely than white people to have extremely low incomes; 20% of black households, 18% of American Indian or Alaska Native households, 14% of Latino households, and 10% of Asian American and Pacific Islander households have extremely low incomes. Only 6% of white non-Latino households in the U.S. are extremely low-income renters./3

When looking at households who are housing cost-burdened - defined as households that spend more than 30% of their incomes on rent and utilities - racial disparities persist. While 42% of white households are cost-burdened, 52% of Latino renters, and 54% of Black renters are cost burdened - with over 30% of all Black renters spending more than half of their income on housing./4

Nearly half (48%) of extremely low-income renters have a disability or are seniors./5

These racial disparities are also reflected in data on homelessness. According to the National Alliance to End Homelessness, in 2020, Native American and Black Americans had the highest rate of homelessness among the nation's racial and ethnic groups. Latinos have the second highest homeless rate - still almost double the homelessness rate of white people./6

Racial disparities in housing directly relate to the disproportionately high and adverse climate-related impacts on disadvantaged communities. A community with significant populations of cost-burdened households is a community that is vulnerable to the future effects of climate change./7

By bolstering support for these communities, FEMA can ensure their full recovery while simultaneously bolstering their ability to withstand future climate change impacts. A recently released report from NLIHC, "Taking Stock: Natural Hazards and Federally Assisted Housing" found that one-third of federally assisted housing stock is in areas with very high or relatively high risk of negative impact from natural hazards, and people of color disproportionately make up the population living in these units./8

As a result, housing will play a large role in ensuring that low-income households and their communities can weather the climate change impacts of the coming years.

III. Lack of FEMA leadership, guidance, and technical assistance prevents people of color and other underserved groups from accessing assistance during a disaster.

Emergency planning and disaster response efforts have largely failed to fully recognize and incorporate the needs of the lowest-income and most marginalized survivors, including people of color, seniors, people with disabilities, people experiencing homelessness, people with limited English proficiency, immigrants, and others, resulting in devastating impacts on disaster survivors./9

These challenges date back to beyond the disastrous efforts to evacuate New Orleans in 2005 to the recent stranding of Puerto Ricans without food, water, or shelter after Hurricane Maria in 2017, and the failed evacuation of Paradise, CA during the Camp Fire of 2018.

Without strong oversight by FEMA, local and state emergency managers regularly fail to ensure that people of color and other underserved groups are safe during disasters. As a result, the human toll of a disaster and a community's vulnerability to future climate change impacts is increased. While some jurisdictions have drafted substantially improved accessible emergency plans, others have continued to ignore the problem./10

Without federal standards, emergency disaster response will continue to vary by jurisdiction, leading to increased danger for vulnerable survivors from climate change impacts and communities less able to withstand even greater impacts in the future.

Barriers to Emergency Management Resources

Disaster survivors with low incomes commonly lack access to emergency management resources at the local level.

Localities frequently expect residents to have the resources to acquire food, water, and other necessities to shelter in place for the duration of the storm and emergency response period. Residents are expected to obtain the necessary plywood and nails and have the tools needed to prepare their homes for potential damage. During an evacuation, planners often presume residents have cars or bus fare, the city or region has enough buses, that evacuation staging points are effectively and universally communicated, that state-run information sources are trusted, and that residents will be able to return when they can safely do so. Local governments may assume private companies and businesses will officially close during storms, while many service industry businesses that employ low-income individuals stay open, forcing residents to stay in harm's way despite calls for evacuation. Experience has shown that many of the above expectations are simply not true for many of the lowest-income households who live in under-resourced communities, have a disability or limited English proficiency, or lack access to public information sources.

A recent example of these failures can be found at the federally assisted Sandpiper Cove property in Galveston, TX. In August of 2020, the approaching Hurricane Laura prompted city officials to issue a mandatory evacuation order. Residents of Sandpiper Cove, located in a majority non-white census tract where 58% of individuals fell below the poverty line, were not notified by property management nor city authorities of any official plan for evacuation. Contacted by phone, city emergency management staff only provided vague information about a mass transit evacuation staging location half a mile from the property when directly requested by housing advocates working in the community. Residents were unaware of what personal property to bring with them during evacuation, were unable to walk to the evacuation site, and calls to the local emergency management hotline went unanswered or faced long wait times. Information at the evacuation site was only provided in English and emergency management staff could not confirm the destination of buses being used for evacuation. In line for buses, seniors and children were forced to spend five or six hours outside of a locked air-conditioned community center in 90-degree heat as they waited. Multiple individuals with disabilities were forced to remain behind due to this mismanaged evacuation. While Hurricane Laura subsequently changed paths, returning residents were greeted with notices that they would be removed from their apartments for a renovation project. Neither state or local officials have conducted a debrief or assessment of the evacuation or have reached out to advocates or organizers at the building./11

A substantially similar failure occurred at a care facility where Hurricane Laura struck in Lake Charles, LA. Nearly 80 residents of the majority-black Golden Arms Apartments were forced to wait for assistance for three days after the storm. Residents called authorities 80 different times over the course of the ordeal but received no assistance until passing recovery volunteers were flagged down by residents. Multiple government organizations active in the response to Hurricane Laura refused to accept responsibility for the situation in the aftermath. When asked for comment a FEMA spokesperson said that FEMA does not have a role in investigating the subject./12

Policy Solution

FEMA must use its technical assistance and grant programs to ensure local emergency response resources are accessible to disaster survivors with low incomes.

Although FEMA's role during the initial disaster response is to financially support state and local governments, the agency has an obligation to provide technical assistance to create effective disaster assistance plans and to support training and education programs for comprehensive emergency management./13

FEMA's National Preparedness Directorate and Grant Programs Directorate's Technical Assistance (TA) program currently provides support to states, tribes, territories, and local governments (STTLs) in support of homeland security mission areas - including response./14

FEMA must develop TA expertise in preventing or perpetuating systemic barriers to assistance during emergency response and, using the strongest language available, request or require that STTLs utilize this TA to ensure that instances like those described above do not reoccur.

In addition, FEMA creates the National Response Plan (NRP) and National Disaster Recovery Framework (NDRF), and facilitates the Emergency Management Performance Grant (EMPG), providing funds to assist STLLs in implementing National Preparedness Goals (NPG)./15

As a requirement for the continuing receipt of EMPG funds, FEMA must require a review of all relevant emergency response plans to ensure that STTL emergency managers are adequately anticipating the specific needs of low-income households, individuals and families experiencing homelessness, individuals living with disabilities, individuals with Low English Proficiency, and other underserved groups. STTL plans that do not meet the standards developed by the agency should be required to utilize FEMA TA to rectify the shortcomings as a prerequisite for receiving future EMPG funds.

One of the best ways to ensure that the needs of communities of color and other underserved communities are addressed is to offer them a leading role in developing emergency planning and response plans. This ensures that plans have been created with the cultural competence and knowledge needed to serve all survivors regardless of income, ability, language, or education levels; address communication gaps; and ensure that inadequate information or rumors do not exacerbate the situation. To the greatest extent possible, FEMA must encourage or require STTL officials to engage members of these communities and their networks of trusted relationships to plan for future emergencies and update plans that fail to protect all survivors. Doing so not only serves the purpose of education and information, but also builds trust in communities that have historically been overlooked or mistreated by authorities.

Barriers For People Experiencing Homelessness

Emergency response operations regularly discriminate against individuals and families experiencing homelessness.

Individuals and families experiencing homelessness are among the most vulnerable individuals during a disaster, often relying on nonprofit or informal organizations as a means of accessing information, shelter, food, and water./16

When homeless services or shelter systems are disrupted by a disaster, many individuals and families experiencing homelessness lose ways to access information about emergency assistance or evacuations, and means to access food, water, or shelter. Many may lack telecommunication devices that can receive emergency alerts from government authorities that contain critical information about evacuation staging areas or the location of emergency shelter.

In many areas that have sought to criminalize or otherwise harass individuals and families experiencing homelessness, there may be an adversarial relationship between individuals living in encampments or on the street and local government or police that prevent them from trusting offers of assistance.

Compounding this issue, pre-disaster homeless populations are often excluded from, or face additional barriers to, accessing emergency shelters. During Hurricane Michael, individuals and families experiencing homelessness were not taken to general shelters but were placed in specific shelters that were separate from the general evacuation shelters./17

Following Hurricane Irma, advocates reported that people experiencing homelessness prior to the disaster were forced to wear armbands and were kept separated from other disaster survivors. These actions further stigmatize people experiencing homelessness and often bar them from the resources they need to stay safe during a disaster.

Policy Solution

FEMA should create and enforce national standards and technical assistance materials to ensure equal access to emergency response resources for individuals experiencing pre-disaster homelessness.

FEMA should update the NRP, NDRF, Federal Emergency Support Functions and Federal Interagency Operations plans (FIOPs), and all other applicable federal directives to directly address responsibility for meeting the equal access and needs of individuals and families experiencing homelessness prior to a disaster. In partnership with HUD and the US Interagency Council on Homelessness (USICH), FEMA should create new federal standards and enforce existing standards for interacting with and assisting individuals and families experiencing homelessness during a disaster. These standards must be implemented so that individuals and families experiencing homelessness are able to access shelters and are not isolated in dedicated mass or non-congregate sheltering as has been seen during past disasters. These standards should reflect the civil rights obligations under federal law that must be followed to ensure that a survivor's rights are not being infringed based upon their status as unhoused.

As discussed above, while FEMA does not directly oversee emergency sheltering or evacuations at the local levels, it does have a responsibility to provide appropriate TA to STTLs and otherwise assist the creation of emergency response plans through grant programs such as the EMPG. FEMA must require that STTL emergency response plans include sections dedicated to the evacuation and emergency sheltering of individuals and families experiencing homelessness. This type of TA can be utilized when FEMA identifies an emergency response plan that fails to adequately address the needs of individuals and families experiencing homelessness during emergency response.

FEMA should also encourage emergency managers and emergency shelter partners such as the American Red Cross to work with existing providers of shelter and services to individuals and families experiencing homelessness in their area to ensure that these plans are being developed with and shared both among the homeless assistance sector and the individuals and families experiencing homelessness themselves.

Barriers for Individuals with Disabilities

Emergency response operations often lack access or accommodations for individuals with disabilities.

People with disabilities are twice to four times more likely to die or sustain a critical injury during a disaster than people without disabilities./18

Yet many emergency plans do not sufficiently address how to reach those with disabilities during times of disaster. Instead, many local authorities rely on a neighbors-helping-neighbors approach that is not workable in many areas of the country.

FEMA itself has been slow to roll out training products and other materials to assist local officials in taking care of the needs of individuals with disabilities during disaster emergency response. This lack of response at the federal level can result in local officials making the care of individuals with disabilities during disasters even less of a priority.

While federal law, including the Americans with Disabilities Act and the Rehabilitation Act, prohibits discrimination against individuals with disabilities under any federal program - including those for disaster preparation and response - practice has lagged./19

The Department of Homeland Security (DHS) has published accessibility and inclusion guidelines for state and local disaster planners, but these best practices are often overlooked, ignored or rejected./20

Advocates from impacted areas frequently report that shelters and outreach and application centers are not accessible, available physical and mental health assistance is inadequate, and sign interpreters and other accommodations are not provided. People with disabilities whose only needs are the ability to get into a shelter and use its restrooms are often diverted to "special needs" or "medical shelters," even if they do not require the level of care provided there.

The Department of Health and Human Services consistently issues waivers allowing states to direct people with disabilities to nursing homes, which are not always the safest places of refuge in emergencies, often leading to involuntary institutionalization./21

During Hurricane Harvey, elderly residents in a Galveston, Texas nursing home were photographed with flood waters up to their waists/22 and 14 nursing home residents in the largely unregulated nursing home industry died in 2017 from heat exhaustion when their facility lost power in Hurricane Irma./23

In some areas regularly impacted by disasters, authorities have provided for the pre-registration of persons of limited mobility so they can be evacuated if necessary, and the officials have directed persons with disabilities to specific shelters, separate from general population shelters and away from their families and loved ones. At other times, people with disabilities may be directed away from shelters to hotels or other facilities. In prior iterations of this non-congregate sheltering, residents assigned to hotels may have to buy and prepare their own food, which would otherwise be provided without charge at a large shelter. In addition to the financial challenges this presents, survivors with disabilities may not be physically or otherwise able to access grocery stores, or the markets that once existed may not be available after a disaster./24

Communication of emergencies to the deaf and blind communities is often erratic despite requirements of the law. Emergency broadcasts in some states and localities feature no sign language interpreters or partially obscured interpretation that makes it difficult for a viewer to fully understand what information is being conveyed. In the 2019 storm season, the National Weather Service and National Oceanographic and Atmospheric Administration provided depictions of Hurricane Dorian's projected path in a visual format only, making it impossible for those with vision impairments to understand where the storm was headed./25

Policy Solution

FEMA should create and enforce national standards and technical assistance materials to ensure equal access to emergency response resources for individuals with disabilities.

Due to the failure of STTLs to ensure equal access to emergency response resources for individuals with disabilities, FEMA should update the NRP, NDRF, Federal Emergency Support Functions and FIOPs; and all other applicable federal directives to specifically address the responsibility for meeting the equal access, health maintenance, safety, and independence needs of children and adults with disabilities to prevent institutionalization. The federal standards in these documents should be strictly enforced, requiring communications, shelters, and evacuation strategies that can reach people with disabilities without requiring institutionalization. These standards should include requirements that emergency communication be fully accessible to those within the deaf and blind communities without exception.

Federal funds - such as FEMA EMPG - are required to be spent in compliance with the equal access requirements of the Rehabilitation Act of 1973 and the Americans With Disabilities Act of 1990./26

However, many recipients are, at best, unaware of how to comply with these requirements nor how to interact with people with disabilities without adhering to a medical-model bias that leans towards institutional placement. FEMA must ensure that grantees receiving funding from FEMA are fully aware of their responsibilities when it comes to these and other applicable laws dealing with individuals with disabilities and develop TA and training materials to ensure compliance.

Simultaneously, FEMA must redouble its efforts to work with the disability justice community to ensure that individuals with disabilities are being represented fully on applicable policy making and advisory bodies, that plans and initiatives around disability are met with approval by disaster justice advocates, and that their concerns and recommendations are being fully considered and followed. FEMA should also continue to push STTLs to work with disability justice advocates in their own areas to ensure that such work is occurring at all levels of emergency response. This means meeting directly with disability justice advocates when requested.

Barriers for Immigrant Populations

Emergency response operations often lack access or accommodations for immigrant populations.

Many immigrant communities have a distrust of police and other local authorities due to targeting by immigration authorities both locally and by the DHS. Often, this distrust results in community members only calling for help or assistance as a last resort. This distrust has been further enhanced by the actions of the most recent administration - which moved to dramatically modify the "public charge" rule that would prevent individuals from gaining U.S. citizenship because they received a certain amount of assistance from the federal government. Although disaster and emergency response assistance are not directly impacted, many recent immigrants may become less likely to seek out and utilize emergency disaster response services./27

In addition to this inherent distrust, emergency alerts and instructions are often presented only in English - meaning that immigrant populations and others with Low English Proficiency are unable to clearly understand what they must do during a disaster. There is no requirement that emergency announcements appear in languages other than English./28

However, such access is required for federal- or state-funded programs./29

Translated documents can at times be available but often not in the needed amount.

Policy Solution

FEMA should create technical assistance materials and enforce national standards to ensure equal access to resources for immigrant populations.

FEMA should update the NRP, NDRF, Federal Emergency Support Functions and FIOPs and all other applicable federal directives to specifically address responsibility for meeting the equal access, health maintenance, safety, and other needs of immigrant populations. These national standards should also include ensuring that emergency communications are issued in languages other than English.

To improve access to critical information among immigrant populations, FEMA must encourage emergency planners to seek out ways to decentralize emergency communications and build formal relationships with networks of community-based organizations within those populations to increase reach and credibility. These communications must be accessible to people with Low English Proficiency. This will allow communities of recent immigrants to see and respond to emergency notices and encourage their greater involvement in the emergency planning process.

FEMA must educate and inform immigrant communities and disasters survivors that there is no information exchanged between the agency and U.S. Immigration and Customs Enforcement (ICE) and that individuals who may be undocumented can safely visit DRCs and speak with the agency without risk of deportation. If FEMA does share any such information with ICE, it must immediately cease doing so.

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VI. Conclusion

FEMA has a moral, ethical, and legal obligation to ensure that the lowest-income and most marginalized survivors - who are disproportionately people of color and other underserved groups - are not prevented from accessing the assistance they need to recover after disasters. While the recent history of the agency is rife with examples of how such principles were ignored, we are hopeful that the agency can move beyond these failures and ensure that all disaster survivors are able to fully recover.

Our nation needs a new vision for disaster housing recovery that centers around those with the greatest needs. To undo the racial, income, and accessibility inequities embedded in our current disaster housing recovery framework and to ensure a complete and equitable housing recovery for all survivors, our nation must prioritize robust resident engagement, transparency, full accountability and due process, robust equity and civil rights enforcement, and increased local capacity and benefits. By establishing an anti-racist and equitable disaster response, FEMA can exemplify this new vision and create communities that are not only economically and socially vibrant, but ones with the resources needed to increase their resilience and face the brunt of climate-change driven disasters in the coming years.

View full comment at: https://downloads.regulations.gov/FEMA-2021-0011-0235/attachment_1.pdf

Sincerely,

Diane Yentel

President and CEO

National Low Income Housing Coalition

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Footnotes:

1/ Ratcliffe, C., Congdon, W. J., et. al., (2019). Insult to Injury. Urban Institute.

2/ National Low Income Housing Coalition, The GAP Report, 2021, Available at: https://reports.nlihc.org/sites/default/files/gap/Gap-Report_2021.pdf

3/ Id.

4/ Id.

5/ Id.

6/ National Alliance to End Homelessness, Racial Inequalities in Homelessness, by the Numbers, June 2020, Available at: https://endhomelessness.org/resource/racial-inequalities-homelessness-numbers/

7/ Andreanecia Morris & Lucas Diaz (2019), Reimagining Housing: Affordability Crisis and Its Role in Disaster Resilience and Recovery. in S. Laska (ed.). Louisiana's Response to Extreme Weather (pp. 241-259), Springer.

8/ National Low Income Housing Coalition and the Public and Affordable Housing Research Corporation, Taking Stock: Natural Hazards and Federally Assisted Housing, June 2021, Available at: https://preservationdatabase.org/wp-content/uploads/2021/06/Taking-Stock.pdf

9/ See Ratcliffe, C., Congdon, W. J., et. al., (2019). Insult to Injury. Urban Institute; Guillermo, O., Schultheis, H., et. al., (2019), A Perfect Storm, Center for American Progress; Kathleen Tierney, Disasters: A Sociological Approach, Polity Press, 2019

10/ Liu, Amy, et al., editors. Resilience and Opportunity: Lessons from the U.S. Gulf Coast after Katrina and Rita. Brookings Institution Press, 2011. JSTOR, www.jstor.org/stable/10.7864/jctt127x5f.

11/ See Texas Housers, Close Call With Disaster: Lessons from the Hurricane Laura Evacuation of a HUD Subsidized Apartment in Galveston (2021), Available at: https://texashousers.org/wp-content/uploads/2021/03/Close-Call-With-Disaster-Sandpiper-Cove-v.1.1.pdf

12/ See Sacks, Brianna, "These Seniors Were Left Behind When Hurricane Laura Hit. No One Claimed Responsibility", Buzzfeed News, September 25, 2020, Available at: https://www.buzzfeednews.com/article/briannasacks/seniors-left-behind-hurricane-laura-lake-charles

13/ 44 CFR Sec. 360.1 et seq.

14/ FEMA, NPD TA Factsheet (2011), Available at: https://www.fema.gov/pdf/media/factsheets/2011/npd_ta_factsheet.pdf

15/ FEAM, 2021 Preparedness Grants Manual (2019), Available at: https://www.fema.gov/sites/default/files/documents/FEMA_2021-Preparedness-Grants-Manual_02-19-2021.pdf

16/ June Gin, "Preparing the Whole Community: Including Individuals Experiencing Homelessness in Disaster Planning", October 2020, UC Boulder Natural Hazards Center, Available at: https://hazards.colorado.edu/news/research-counts/preparing-the-whole-community-including-individuals-experiencing-homelessness-in-disaster-planning.

17/ US Department of Housing and Urban Development, "Send Red, Not Blue: The Homeless Resident", 2014, Available at: https://files.hudexchange.info/resources/documents/Send-Red-Not-Blue.pdf

18/ Paul Timmons, "Disaster Preparedness and Response: The Special Needs of Older Americans," Statement for the Record, Special Committee on Aging, U.S. Senate, September 20, 2017, available at https://www.aging.senate.gov/imo/media/doc/SCA_Timmons_09_20_17.pdf.

19/ 29 U.S.C. Sec. 794 et seq.

20/ Department of Homeland Security, Recommendations for Emergency Managers for Improving the Delivery of Disaster Assistance to Disaster Survivors with Disabilities, March 2019, https://www.dhs.gov/sites/default/files/publications/adg-listening-sesssions-reccommendations_english_0.pdf.

21/ National Council on Disability, "Preserving Our Freedom, Ending Institutionalization of People with Disabilities During and After Disasters", May 2019, https://ncd.gov/sites/default/files/NCD_Preserving_Our_Freedom_508.pdf

22/ Galveston Daily News, "Eighteen People Rescued from Flooded Assisted Living Facility", August 27, 2017.

23/ CNN, "Husband and Wife Among 14 Dead After Florida Nursing Home Lost A/C", October 9, 2017.

24/ See National Council on Disability, "The Impact of Hurricanes Katrina and Rita on People with Disabilities: A Look Back and Remaining Challenges" (2006), Available at: https://ncd.gov/publications/2006/aug072006

25/ Shelley Tremain, "Dorian, Disaster Relief, and Disabled People" (2019), Biopolitical Philosophy, Blog, Available at: https://biopoliticalphilosophy.com/2019/09/03/dorian-disaster-relief-and-disabled-people/

26/ FEMA, "Preparedness Grants Manual", page 43, February 2021, Available at: https://www.fema.gov/sites/default/files/documents/FEMA_2021-Preparedness-Grants-Manual_02-19-2021.pdf

27/ Bernstein, H., McTarnaghan, S., Gonzalez, D., "Safety Net Access in the Context of the Public Charge Rule", Urban Institute (August 2019), Available at: https://www.urban.org/sites/default/files/publication/100754/safety_net_access_in_the_context_of_the_public_charge_rule_1.pdf

28/ Martin, C. (2019). Understanding US Housing Data in Relation to the 2017 Disasters. Natural Hazards Review, 20(3), 04019007.

29/ 42 U.S.C. Sec. 2000d and 24 C.F.R. Sec. 1.4

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

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