Comment Submitted by Large Public Power Council
AnonymousOpposeTrade association
Summary: The Large Public Power Council, representing 29 public power utilities, opposes the proposed conversion of the Public Assistance program into a parametric formula grant (RAPID) because it creates "basis risk" where payouts may not match actual restoration costs. They also oppose the reduction of the federal cost share from a 75 percent baseline to a 50 percent floor, arguing it shifts significant, unpredictable costs onto local communities and ratepayers.
To the President's FEMA Review Council:
On behalf of the Large Public Power Council, I am pleased to submit the attached comments on the Final Report of the President's FEMA Review Council, released May 7, 2026. These comments are also being filed through the Federal eRulemaking Portal at regulations.gov under Docket No. DHS-2026-0067.
LPPC represents 29 of the nation's largest public power utilities, operating across 23 states and territories. Our members are state- and locally-owned, not-for-profit electric utilities that serve as first responders in nearly every major disaster, and FEMA's Public Assistance program is central to how they restore service after a storm. LPPC supports the goal of faster, clearer, and more predictable disaster recovery, and our comments address the Final Report's recovery and mitigation recommendations from that perspective.
We appreciate the Council's work and welcome the opportunity to discuss these comments further.
Respectfully submitted,
Large Public Power Council