Comment Submitted by Artanis Capital, LLC

Artanis Capital, LLC, through its emergency housing platform Artanis Emergency Communities, respectfully submits these comments on the President's FEMA Review Council Final Report. We write for one purpose: to ensure Secretary Mullin's directive, that future federal emergency housing be reusable, relocatable, and redeployable from one disaster to the next, is carried from the report's recommendations into their implementation, rather than lost in the process between the two. The Council's Final Report identifies the right structural failures. It documents that FEMA has incurred more than $3.6 billion in administrative costs over the last five years, permitting nearly 25 cents of every disaster dollar to be consumed before a single survivor is housed. It quotes a government official: "FEMA will pay 500 thousand dollars to put a trailer in your yard for a few months when we could have bought the house next door for half that." Florida's Division of Emergency Management Director Kevin Guthrie added: "The amount of money that the federal government is spending on RV trailers, I've heard numbers that are six figures for a five-figure travel trailer. It is insane." The report does not, however, resolve the one question Secretary Mullin placed at the center of the table. It identifies what must end. It does not specify what replaces it. At the May 7 final meeting, the Secretary was explicit: "We're wanting to see housing that's going to be reusable. Something where we can take them from one disaster to the next... I don't want to tear it down. I want to be able to pick it up and move it someplace." That is not a policy aspiration. It is a design specification, and the Final Report does not translate it into a recommendation. The blindspot is this: the Council's FAIR framework transfers emergency sheltering responsibility to state, tribal, and territorial governments and provides federal funding within 30 days of a disaster declaration. Without a corresponding federal asset standard, states will default to the same disposable single-use trailer procurement the Council's own report condemns, recreating the disposal cycle at the state level rather than ending it. Ten months after Hurricane Helene, FEMA had placed only 243 families in mobile homes across all of North Carolina. Changing how fast money reaches states does not change what kind of asset that money procures. Reform without asset standards is a faster path to the same destination. The fiscal argument is straightforward and aligns with the administration's efficiency mandate. A unit procured at $150,000 all-in and recovered at a best-case GSA auction average of $20,000 is a $130,000 taxpayer loss per unit, multiplied across thousands of units per major hurricane season. A redeployable unit amortized across three to five disaster cycles carries only marginal redeployment costs, covering transport, site preparation, and utility reconnection, rather than a full unit cost each time. At end of life, it retains value as workforce housing, military base-camp capacity, or border housing infrastructure, preserved on a government balance sheet rather than lost at auction. These comments request the Council's Final Report, or its transmittal letter to the President and any implementing legislation, incorporate five specific recommendations: (A) minimum redeployability standards for all federally funded emergency housing; (B) a government-owned fleet, federal or state title, managed and deployed by private operators, with state-held assets cross-deployable through existing EMAC mutual aid channels; (C) alignment of emergency housing procurement with the Council's administrative cost reduction mandate through long-term fleet contracts rather than per-disaster re-procurement; (D) consolidation of all federal Individual Assistance program access into a single housing-anchored intake platform; and (E) explicit memorialization of Secretary Mullin's redeployability directive in the transmittal to the President. Artanis Capital, LLC operates Artanis Emergency Communities, a turnkey platform deploying reusable, community-scale emergency housing on domestic steel-frame construction meeting Build America, Buy America requirements. Units are constructed in 8 hours and move-in ready within 24, engineered for lift, transport, and re-installation across multiple disaster cycles, with government title retained at mission conclusion rather than written off at GSA auction. Full substantive comment with specific recommendations is attached.