The Road to Resilience?
It’s hard to argue against the goal of becoming a more resilient nation, as is a policy priority of the Biden administration. For floodplain managers, that means being much more resilient to the hazard of flooding, and to do that we not only need the data from our science agencies like NOAA and USGS to inform decision making and design standards, but we also need a FEMA that understands the issues and science of climate change so that resilience can be built into every directorate, division, program, and office in the agency, while maintaining the essential capacity to perform its core public safety and emergency management roles of preparedness, protection, response, recovery, and mitigation.
Clearly, climate change resilience is a priority for FEMA right now, as evidenced by its strategic plan. Goal #2 of the 2022-2026 plan is titled “Lead the Whole of Community in Climate Resilience” with stated actions such as “FEMA will take a people first approach to increase climate literacy, develop tools, and allocate resources informed by future risk estimates to target investments to create a more equitable and resilient nation.” Again, it’s hard to argue against that, and we’re not.
However, unfortunately after nearly 20 years, FEMA is feeling the need to reorganize by dissolving the Federal Insurance and Mitigation Administration (FIMA) and combining what is FIMA and preparedness into a new “resilience” organization. Apparently, this effort has been underway since this past spring and most disappointingly, none of the organizations who are FEMA’s partners in implementing hazard mitigation programs were made aware of the plan or approached for feedback. It only came to light in October when two of our partner organizations that represent the emergency management community had briefings —which was less than a month before FEMA Administrator Criswell was to make a determination whether to proceed with the reorganization. Based on the most recent information we have, the new resilience organization would have six directorates: Business management, federal insurance, grants management, risk information and community preparedness, resilience operations, and resilience strategy.
Some of you are probably thinking, “Why should I care about FEMA’s organizational structure?”
It is a fair question, and unless you have ever studied or endured state or federal government bureaucracy, this might even sound like a logical approach. However, in thinking about this, several red flags immediately came to my mind:
- What is the impact in combining preparedness and mitigation grants into one big grants directorate? Will the grants be disconnected from the respective program managers? Each grant program is usually authorized by Congress and has its own unique set of priorities, rules, restrictions, etc.
- Where will floodplain management land? Currently, and after decades of hard work, floodplain management is a division within the FIMA’s mitigation directorate. However, a decade ago, floodplain management was a branch, which is smaller and less important in terms of organizational structure. Being at the higher, divisional level brings recognition and resources. Certainly, this administration can’t be considering “demoting” floodplain management when flooding remains the nation’s most frequent and costly weather-related hazard and while thousands of people are still piecing their lives back together in the aftermath of Hurricane Ian?
- What resources will the new resilience bureaucracy take from FIMA? Upon becoming a part of the Department of Homeland Security, FEMA and FIMA lost several SES positions (executive management positions just below the top Presidential appointees). Several of those positions were regained in the past decade. How many will be lost to the new resilience organization which, by definition, will result in fewer leadership positions managing crucial mitigation programs (since the new resilience organization includes both preparedness and FIMA)? Also, what about financial resources? It is widely known that FEMA continues to pay a “DHS Tax” in which DHS takes resources off the top of programs to fund the DHS bureaucracy. For those of us who have labored for many years, if not decades, for funding of key programs, a “resilience tax” is not an appealing idea. Also what about staff positions — how many will be reprogrammed away from the NFIP, floodplain management, or other important mitigation programs to the new resilience organization?
- Can we be sure that FEMA’s Risk Analysis Division (currently) will be sufficiently focused on implementing the vision of the National Flood Mapping Program in the new organization where clearly the focus will be on risk assessment and preparedness for all hazards? Keep in mind we haven’t completed the job in providing flood mapping for the entire nation as Congress had envisioned in the National Flood Mapping Program. Can we be certain that more than $400 million annually in funding (when you combine the budget derived from fee money and appropriated money and for which ASFPM has spent decades advocating for support in Congress) will not be diverted for other uses?
- What happens when there is a new FEMA Administrator? We presently have capable leadership in FIMA. David Maurstad has experience and expertise in working with Congress on NFIP issues, and is the “tip of the spear” as the single executive in charge of all four phases of the NFIP. Under a new FEMA Administrator, especially under a new President that has different priorities, it would not surprise me at all that this new individual would be geared much more towards the very important preparedness function of emergency management. If that is the case, who speaks for the NFIP comprehensively since the program will be in at least three or four different directorates? What priority or focus will the legacy mitigation programs have when competing with preparedness among the new executives?
The biggest struggle in writing this column is just limiting the concerns to just these five points I’ve outlined here. There’s a myriad of potentially negative consequences that could occur with the restructuring, and it could take years to recoup the gains we made in the past decade.
FIMA has done well over the past several years in taking specific actions to change its programs to realize a larger resilience vision, including creating a plan for the future of flood risk data that includes not only future conditions (which, incidentally, has been required by law for 10 years now), but also providing a base layer of information nationwide to finally move closer to “getting the job done” of mapping the country; initiating the process for finally evaluating the NFIP minimum building and land use standards; tweaking the benefit-cost analysis approach for mitigation projects to better achieve resilience and equity outcomes; and developing a more resilient framework for pricing flood insurance by taking advantage of financial risk management tools and Risk Rating 2.0. If anything, the current organization showcases how a federal agency can meet these resilience goals by taking informed, concrete actions.
What is most disappointing to me though, is the absolute lack of partner engagement or participation in this process. Although in this process we’re called “customers” not “partners,” it seems we’re neither in light of one of the primary stated reasons for this reorganization is to be more customer-centric by “placing an emphasis on the customer journey and the customer’s point of view.” FEMA, I am saying this directly to you — you have not engaged a single “customer” that is a floodplain manager — and ASFPM alone has thousands of your “customers” as members. In fact, this is a frustration felt by the emergency managers too. It is disingenuous to believe you can reorganize to be more customer-centric when you haven’t even talked to us. And we do not want “check the box” engagement, but true engagement which leads to mutual understanding and actually influences the process.
The core functions of preparedness, response, recovery, and mitigation being carried out by FEMA are rooted in public health and safety. We have and will always continue to need a robust and capable FEMA and the agency’s hardworking staff. I have read quotes from others hoping or pushing FEMA to move from being a response agency to a resilience agency. This is a 100% false choice. Our nation needs a dependable and strong emergency management agency that can also achieve both the climate resilience and equity goals of the current administration. Reorganizing in a way that seems to erase and substitute the discipline of hazard mitigation for resilience and combining it with preparedness just to be able to say you have a resilience organization makes no sense, especially in light of the need to build resilience in all of FEMA’s directorates and divisions.
To that point, even FEMA’s own National Advisory Council, in its recent November 2022 report, makes an insightful recommendation on resilience related to response — focusing on workforce resilience to address the emotional and psychological impacts of working on so many disasters back-to-back leading to burnout, retirements, and resignations. Indeed, it is not unnoticed by us that nearly half of the senior managers of FIMA have recently left for other opportunities and others are concerned about an uncertain future. There are many paths for an agency to become a successful resilience agency and I am not remotely convinced that this approach is one of them. Becoming a resilient nation — especially in the face of climate change — is not only a whole-of-agency need, it is a whole-of-government need.
ASFPM wrote a letter to Administrator Criswell on Oct. 14 expressing our concerns, and we have since discussed the matter further with Victoria Salinas, FEMA’s acting deputy administrator. We will continue to push for a more inclusive engagement process in any future conversations and decisions that will impact floodplain managers and the communities we serve.
Your partner in loss reduction,
