Talent Yield Coalition Issues Public Comment on FEMA Notice

WASHINGTON, Aug. 1 -- Eddie Williams, founder and executive director of Talent Yield Coalition Inc., Highlands, Texas, 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 17, 2021, and posted on July 22, 2021:

* * *

Talent Yield Coalition Inc. sponsor of Marcelous-Williams Resource Center appreciates the opportunity to comment regarding the Request for Information on specific FEMA programs, regulations, collections of information, and policies for the agency to consider modifying, streamlining, expanding, or repealing in an effort to further the goals of advancing equity for all, bolstering resilience from the impacts of climate change and environmental justice.

We have seen how the current disaster recovery framework does not provide equitable recovery outcomes.

Change, improvement and collaboration are possible but will take focused leadership in strategic areas to effectively address the injustice of those in the community impacted especially communities of color. Our agency stands ready to assist in any way. We are thankful for this opportunity to share the experience of the survivors and communities that we serve.

The responses to the questions below highlight specific areas where FEMA should focus its efforts when evaluating current agency programs, regulations, and/or policies.

Sincerely,

Eddie Williams

Talent Yield Coalition Inc. sponsor of Marcelous-Williams Resource Center

Eddie Williams

Founder and Executive Director

Email: [email protected] or Phone:( 832) 967-3841

* * *

Talent Yield Coalition Inc. sponsor of Marcelous-Williams Resource Center comments below are outlined as follows:

I. Our Mission, History, and Background

II. Recommendations to improve equity and reduce human bias when delivering disaster assistance services.

III. Responses to relevant FEMA RFI Questions

I. Our Mission, History, and Background

The nonprofit Talent Yield Coalition Inc. founded 30 years ago in Houston, Texas, initially worked with At-Risk Youth throughout the city in all 18 housing units and the known hang outs of street gangs. The follow up for the organization was the establishment of a construction company (Willco and Maintenance) to help the unemployed felons train and attain viable employment. During the early part of 2010, as the organization broaden its scope it acquired a 7-bedroom 4 bath home to create The Marcelous-Williams Homeless Veterans Home with the goal of establishing a viable environment where with proper hand holding and referrals they might move from at risk to stable status for these veterans. With the concentration on eleven homeless veterans, this pilot-program proved to be successful (95 percent of those served attain sustainability).

At this juncture, the organization realize there exists a common need for all clients regardless of station in life, age, gender, disadvantaged, etc..... Where do I go to get assistance? ..... Who can help me weave through the maze of bureaucratic paperwork.? Often being told.... "That's not our area of expertise.... We can't help you"

Hence, the birth of the Marcelous-Williams Resource Center. With the acquisition of existing business property in Rural East Harris County (Highlands, Texas), the site with an existing office building and warehouse, was remodeled in preparation of receiving clients without any restrictions. All our services are FREE to the community. The initial area to be served was Highlands, Texas (where we established the home base for this new project). Today, we serve clients throughout east Harris County; to include Highlands, Baytown, Crosby, Dayton, Liberty, Channelview, Pasadena, McNair, and Barrett Station, many are Communities of Color as well as Chambers County to include Mt. Belview, Anahuac, Hankamer, Double Bayou, and anyone else who reached out or walked through our doors.

To ensure we had the necessary tools to deliver our service, we established as many MOU'S/MOA'S (memorandum of understanding/agreement) with as many agencies on the Federal, State and Local level...to include Churches, Schools Other Nonprofits, Law enforcement etc. as possible. Then we implemented an aggressive outreach effort to inform the communities of our presence and intent. So many social service agencies have excellent programs but the end-user either do not know where or how to connect to them.... we fill the gap as a "One Stop Shop"

As a Resource Center we had some basic principles in which we felt should be in place. First, service needed to be FREE, so that it is accessible to everyone. Next that our partners were reliable and understand that the intensive intake process we developed would screen out fraud and potential duplication of services thus enabling them to minimize their staffs time and utilization of other in-house resources. "Bridging the Gap"

Now, after six years of operation assisting an average of 350 families per year; "We Know What Works and Why". The key factors being:

1. Community Based to reach and serve the client where they are

2. Collaboration and not duplication of social services in our community

3. Development of client trust, follow-up, and advocacy.

With this being said.... having a proven track record, we seek assistance in establishing like Resource Centers in rural and isolated communities with this proven pilot utilizing local volunteers and accessible local agencies.

II. Recommendations to improve equity and reduce human bias when delivering disaster assistance services.

Our agency conducted a project for Upper Texas Gulf Coast Regional Resilience Initiative (UTRI) for the period of January 1, 2020 to June 30, 2020 focusing on: Bridging the Gaps in Disaster Recovery to Ensure an Equity-Centered Resilience Approach

Our program, 'Disaster Recovery Advocacy Program' (DRAP) targeted the low-income minority population communities ie communities of color struggling to receive disaster recovery services. This program was designed to consider cultural significance, unique community characteristics, and trauma. Our organization having been heavily involved in disaster recovery as the result of the numerous clients who were affected by Hurricane Harvey, Tropical Storm Imelda and the San Jacinto River Waste Pits (a Superfund Cite) found themselves in more distressed situations than they were ever before.

After becoming a United Way Baytown Agency in 2018 and having been called upon to assist in recovery efforts after Hurricane Harvey, we found ourselves involved in multiple phases of the process: from Case Management, serving on the Baytown Chambers Disaster Recovery Team, to fulfilling unmet needs to hurricane victims. However, our current efforts were restricted to specific zip codes which we feel resulted in one of many disparities in equity of clients served.

Therefore, our Board took a bold approach to serve any clients that knocked on our doors, but we were required to tracked clients served under the United Way grant dollars.

Disaster survivors could receive assistance from as many as 11 (eleven) different agencies each with its own paperwork and process. The burden of application was placed on the survivor who has just lost everything. Approximately, 80% of the data collected by disaster assistance agencies are (a) the same across various applications or (b) publicly available from other sources including individual tax returns, county records, etc.

During our involvement we have been able to identify many gaps in the process and have witnessed that our efforts serving as" Advocates" for clients have to a large degree eliminated many of the flaws and frustration between the client and recovery agencies.

Requirements were "All Over the Board" ranging from age guidelines, ownership documentation, FEMA # or not, mobile homes versus home on slab or block and beams. When a client comes to us, we determine which of the disaster recovery programs that the client qualifies, explain the process to the client, assist the client in collecting the paperwork and submit to the agency.

We monitor the case and ask the client to keep us informed of any changes or updates directly from their case manager. If advocacy is required, client gives us permission to speak on their behalf. We seek either to negotiate or find an alternative solution to the issue. We have developed working relationships with many members of the Disaster Recovery VOAD (National Voluntary Organizations Active in Disaster). ie. Catholic Charities, Samaritan Purse, United Way Baytown, USDA, Harris County Disaster Recovery, Hope Recovery, etc.

Federal disaster aid must shift from its current reactive cookie-cutter structure to a proactive and adaptable design that provides equitable priorities for communities of color and low-income individuals. Current programs are based on broken systems and faulty assumptions that force a one-size-fits-ALL when the uniqueness of a community should be considered.

Our Community Workers were able to conduct 296 calls to complete the DRAP surveys for the seven zip codes identified in our project........ zip codes included throughout east Harris County; to include Highlands, Baytown, Crosby, Dayton, Liberty, Channelview, Pasadena, McNair, and Barrett Station, many are Communities of Color as well as Chambers County to include Mt. Belview, Anahuac, Hankamer, Double Bayou.

As we explained, the reason for conducting the survey, many individuals experiencing bias stated there needs to be a change for communities of color receiving disaster assistance.

Following recommendations were given:

A. Eligibility criteria for disaster recovery assistance should be the same for all agencies.

B. Documentation requirements should be consistent with all agencies, for example, form of identification requirement is an ID instead of in addition of an ID, a social security card and birth certificates.

C. Case managers should be point of contact for not only repairs but for all unmet needs: all disaster assistance services.

D. If a disaster agency depleted their funding, the client should be contacted without a long wait for services and find out months later funds were depleted.

E. If a disaster agency depleted their funding or do not qualify for their program especially after the application process, the client should be referred to another disaster assistance agency.

F. Agencies should not require the client to obtain contractor's bid but have a qualified contractor to provide the service. Many clients complained some contractors charged for a bid or an elderly/disabled client struggled to find a contractor to fulfil the request of the case manager. There were concerns the bid was inflated.

G. Agencies should be consistent in deciding structural repair/rebuild of a home. Many observed their neighbor have their home rebuilt in the neighborhood versus a home that suffered similar damages was repaired and still had structural or mold problems later on.

H. Some agencies required the client must purchase flood insurance and other agencies many not require flood insurance for a home rebuilt.

III. Responses to relevant FEMA RFI 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?

Concerns: Individuals seeking disaster assistance find the process is too long from filing with FEMA to finally receiving services. The elderly/disabled especially will give up because of the time to file with FEMA, wait on the insurance carrier/inspection if they have insurance, complete or collect documents and follow-up with FEMA who then confuse the client to collect more paperwork. While seeking disaster assistance, individuals and families lived in sub-standard conditions. The amount of assistance has shown in many cases is bias against persons or families of communities of color as well as elderly/disabled individuals.

Recommendation: FEMA should develop a single intake and application process in order to deliver resources and benefits more efficiently and equitably.

FEMA should determine how to bridge the gap regarding racial or equitable concerns to help improve programing and processes but will also help local governments and nonprofits determine how best to use their grant funds.

Concerns: Additionally, the migration of evacuees who are basically renters impact neighboring states seeking housing. Once the funds are exhausted for the renter, FEMA transitional services are not timely or are complex processes and the victim(s) may experience a period of homelessness. the lack of diverse assistance options for renters often impacts some of the most vulnerable members of the community especially people of color.

Recommendations: FEMA should deliver a comprehensive assistance programs to stabilize renters after the impact of a disaster.

#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?

Concern: A six feet black 40-year old male weighing over 400 lbs applied for home repair. He lived in McNair, a community of color, and was a long-time bus driver for the school district. He was on sick leave waiting for knee surgery that now impacted his job. The client owned a 3bedroom home destroyed by the disaster. However, the disaster agency offered a rebuild for a 2-bedroom home without a handicap ramp or even a front porch. The agency claims a 3bedroom home for his mother who lives next door was just built which they felt the client will need to live and support his mother.

The client protested and stated the home is in his name and have nothing to do with his mother's home ownership. Any decision for the welfare of his mother would be a decision by the siblings. The client accepted the offer of the 2-bedroom afraid that he would not have opportunity to have any assistance with his home.

After the home was built, the client asked if the water settling on the property after a rain could be resolved. The disaster agency was not willing initially to address the issue. Our organization advocated and he received several loads of dirt to create runoff away from the house and a concrete driveway. When the damaged home was demolished, the contractor should have made provisions to ensure the ground leveling was sufficient for a block and beam house to be built. This client experience so many bias with no recourse or authority to present the issues.

Recommendation: The disaster agency's program did not bolster resilience to the impacts of climate change despite the fact that many impacted communities are at greater risk to experience additional disasters and experience greater impacts from climate change especially communities of color. FEMA should set targeted resilience standards for its disaster recovery housing assistance program and allow recovery funds to be used to make resilient upgrades that offer greater protection against future disasters.

Concern:

Agency deciding what they believe the client should receive for housing needs is bias. Disaster repairs noted outside communities of color identified homeowners receiving repairs to replace the flooring or other damages comparable to original value of their home which ran into the $10,000 and up costs. Communities of color were judged on socio-status or surrounding conditions to determine what disaster assistance will be provided.

In our efforts to advocate for the client, many case workers cited the internal challenges within the disaster assistance agency they had in assisting clients of color to move their cases forward.

Recommendations:

FEMA should set standards for its disaster recovery based on the structure of the home not the household situation(s) to determine what services the agency will provide.

Recommendations:

FEMA should implement a 'safe' program for homeowners, renters and case workers to address concerns or inequities they experience in receiving disaster assistance service or providing the services. That same agency should offer 'advocacy' and reporting requirements to governmental agencies for the purpose of addressing challenges facing all communities.

#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?

Concern:

In Harris County especially, low-income communities, elderly and/or disabled and communities of color often cannot afford lump sum flood insurance premiums. Great that FEMA provides grants to assist in paying for flood insurance for a period of time. If the premiums were payable monthly, the homeowner's fixed budget could cushion the impact of cost, but this is not given to them as an option.

Many of the homeowners are not only concerned with paying for flood insurance premiums but the added burden of property taxes because their exemptions do not cover the excess value of the home that was repaired. Many investors wait for the opportunity to acquire these properties due to the homeowner is forced to sell even in a buyout program.

There have been recommendations to educate residents about the risk of flooding and the relative affordability of purchasing flood insurance. Education is only a small part of the problem.

Recommendation:

The National Flood Insurance Program should establish policies based on homeowner's income and allow the owner to establish payment plans as an option.

Recommendation:

Disaster Assistance agencies should have a consistent requirement for the 'rebuild' of homes requiring flood insurance for rebuilds. Some agencies required the homeowner purchase flood insurance within 6 months of rebuild which there was no verification process in place. Other agencies had no requirement or agreement in place after rebuilt to purchase flood insurance.

Because there was cross-agencies in a community especially people of color, the criteria were different for a mix of homeowners.

# 4

Are there FEMA programs, regulations, and/or policies that are unnecessarily complicated or could be streamlined to achieve the objectives of equity for all (including people of color and others who have been historically underserved, marginalized, and adversely affected by persistent poverty and inequality), bolstering resilience to climate change, or addressing the disproportionately high and adverse climate-related impacts on disadvantaged communities in more efficient ways? If so, what are they and how can they be made less complicated and/or streamlined?

Concern:

Our agency advocated for persons in the community, ie communities of color still waiting for disaster assistance which in most cases was more than 14 months. We learned quickly the requirements of other disaster assistance program to refer the client for home repair/rebuilds. Disaster Agencies, not having a seamless delivery of services, created wait time, health issues, loss of property, etc. COVID created even more of an impact on the home dwellers that did not have a safe place to go.

Our non-profit agency shares the concern being located in East Harris County in the unincorporated, having no support of social services.

Recommendation:

Establishing a seamless delivery of service processes that can be implemented by local organizations, non-profits and churches is crucial for communities of color, low-income and elderly/disabled. Next step, partner with these same organizations to create public outreach strategies. These entities know their communities and can be value added.

Concern:

Currently, as funds are being depleting, we see clients reaching out to us to advocate....ie case worker cannot be contacted or the case worker was confusing, etc. Many of the clients contacted our agency to share that disaster assistance agency cannot start the rebuild because of permits by the City is pending or pending the contractor's assessment, etc. In the meantime, the client cannot be placed in a hotel or apartment for temporary housing, or the client is still waiting to move belongings to storage. The case worker states the expense for relocation can not start until the house is being rebuilt.

Recommendation:

FEMA should advocate Congress to allocate permanent funds to the CDBG-DR program.

FEMA should address government agencies for example, a City's permit office to provide provisions when the need is disaster assistance.

# 10

What successful approaches to advance equity and climate resilience have been taken by State, local, Tribal, and territorial governments, and in what ways do FEMA's programs present barriers or opportunities to successful implementation of these approaches?

There have been no organizations either on the local, city, county or state level that has addressed equity in communities especially communities of color. There are organizations that claim to overcome barriers and successfully implement effective, efficient, and equitable distribution of private and public funds in partnership with dozens of nonprofit partners.

However, funds were distributed to non-profit 'partners' and not local non-profit organizations that have working relationships with their communities. An example, the East Harris County is not supported with funds awarded in Houston or Harris County.

Organizations such as funded Harvey Home Connect platform is not user friendly for the many diverse individuals in the community to access its service. Connective, another organization has a workable program to text availability of resources in the community, but if the community is not aware of its services, the goal is not successful to direct the community during a disaster situation.

Connective collects recipient information, track progress and share finding with its partner organizations which provides data for long term solutions that agencies can implement change but does not address the immediate need of the person experiencing disaster now. There needs to be an 'advocacy program.'

Recommendation:

FEMA should adopt a similar model implemented by Connective but add an Advocacy Program for the client. The model should be implemented locally in the community with non-profits that can support outreach easier, facilitate data gathering but also implement a defined Advocacy Program.

Our agency supports case management services that promote outreach, intake assessments, development of the client's Plan of Action, identify resources, assist the client to apply based on program requirements, perform follow-ups and lastly advocate if necessary to seek alternative sources or present workarounds. This approach supports community equity and resilience especially in communities of color and offers data to local, city, county, state attempting to change policy or restructure disaster assistance programs even in an ongoing evaluation.

From the 296 surveys conducted for the (DRAP) program in 2020, our agency offered case management services to advocate for 71 of these clients that have not received any disaster assistance services for various reasons. Components, in addition to case management, that can improve any service delivery model is collaboration, outreach and advocacy.

Thank you again for allowing our agency to share information that support the community.

Working for Our Community!

* * *

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

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com