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NLIHC leads the
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.
This comment letter will address the negative impacts that
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
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
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
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,
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
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
Without strong oversight by
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
A substantially similar failure occurred at a care facility where Hurricane Laura struck in
As a requirement for the continuing receipt of 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,
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.
As discussed above, while
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.
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
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.
During Hurricane Harvey, elderly residents in a
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
Due to the failure of STTLs to ensure equal access to emergency response resources for individuals with disabilities,
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.
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
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.
To improve access to critical information among immigrant populations,
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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,
View full comment at: https://downloads.regulations.gov/FEMA-2021-0011-0235/attachment_1.pdf
President and CEO
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1/ Ratcliffe, C., Congdon, W. J., et. al., (2019). Insult to Injury.
7/ Andreanecia Morris &
9/ See Ratcliffe, C., Congdon, W. J., et. al., (2019). Insult to Injury.
10/ Liu, Amy, et al., editors. Resilience and Opportunity: Lessons from the
11/ See Texas Housers, Close Call With Disaster: Lessons from the Hurricane Laura Evacuation of a
12/ See Sacks, Brianna, "These Seniors Were Left Behind When Hurricane Laura Hit. No One Claimed Responsibility",
13/ 44 CFR Sec. 360.1 et seq.
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
19/ 29 U.S.C. Sec. 794 et seq.
27/ Bernstein, H., McTarnaghan, S., Gonzalez, D., "Safety
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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