Comment Submitted by Anonymous

I support efforts to improve post-disaster mitigation funding, but I strongly urge FEMA not to replace the Hazard Mitigation Grant Program with the proposed Refined Risk Reduction Program as currently written. The proposal is too vague, too rigid, and too narrowly focused to serve communities effectively in California. Rather than improving mitigation, it risks making funding less accessible, less equitable, and less responsive to the hazards communities actually face. First, the proposed Phase 1 timeline is not realistic. Providing mitigation funding within 30 days of a disaster declaration may sound efficient, but in practice, communities are still dealing with debris removal, safety inspections, damage assessments, and the early stages of recovery. At that point, most jurisdictions do not have the capacity to identify and scope meaningful mitigation projects, much less complete the documentation and compliance steps required for approval. If FEMA intends this funding for immediate activities, it should clearly limit it to practical uses such as code enforcement, inspections, or temporary permitting support—not traditional mitigation projects. Second, the proposal appears biased toward flood-related residential projects and does not adequately reflect California’s hazard profile. It seems designed around project types that are easier to standardize in flood- and hurricane-prone states, while giving less consideration to wildfire and earthquake risk. In California, wildfire retrofits are harder to streamline, and high housing costs make buyouts and elevations far less practical. A federal mitigation program should not steer funding toward the hazards FEMA finds easiest to process while sidelining the hazards that pose the greatest risk to communities. Third, the proposal is too unclear to evaluate confidently. It does not clearly define what activities are eligible, whether funding applies only to residences or also to infrastructure, or whether Phase 2 can support all hazards or primarily flood-related uses. That level of ambiguity makes planning difficult and creates unnecessary uncertainty for states, local governments, and applicants. I am also concerned that the proposal could weaken the connection between hazard mitigation planning and post-disaster funding. In California, requiring detailed project information in state or local mitigation plans could create conflicts with CEQA review requirements and complicate plan approval. Mitigation plans should remain strategic planning tools, not become project-level implementation repositories. The proposed cost-share structure is another serious concern. Tying the federal share to undefined performance metrics would make it harder for applicants to know what match they are responsible for and could discourage participation, especially among lower-capacity jurisdictions. Many communities already struggle to meet the current cost share. A less predictable system would only make that problem worse. The proposal also appears to expand state responsibilities significantly without identifying how those added duties will be supported. Maintaining project pipelines, tracking high-risk properties, validating systems, and managing accelerated timelines would require substantial staff capacity and administrative funding. Without that support, the burden on states and local jurisdictions could become unmanageable. I am also concerned that the new funding structure could reduce support available to Enhanced States like California, particularly if the new two-phase allocation does not preserve funding levels comparable to the current HMGP framework. That would limit the state’s ability to pursue large-scale and high-cost mitigation projects, including wildfire resilience and major infrastructure investments. Finally, I urge FEMA not to retroactively convert legacy disasters into a new program model or impose a rigid eight-year deadline with no extensions. Existing delays are often caused by FEMA review timelines, staffing shortages, and administrative complexity—not by local applicants alone. A hard deadline with no flexibility would discourage more ambitious, multi-benefit projects and push communities toward smaller, less effective investments. In short, this proposal needs substantial revision before it should move forward. Any replacement for HMGP should be clear, flexible, all-hazard in design, and grounded in the real conditions communities face after disasters. It should expand access to mitigation, not narrow it. As currently written, I do not believe R3P meets that standard.