Federal Emergency Management Agency Review Council; Notice of Meeting

The Reinsurance Association of America (RAA), representing property and casualty reinsurers, supports the Final Report's recommendations for FEMA reform. They advocate for a phased approach that emphasizes public-private partnerships, expands private-sector participation in flood insurance and risk sharing, and maintains federal investment in science-based hazard data and mapping.

Miami-Dade County, Florida, Department of Emergency Management supports the FEMA Review Council's recommendations to reform disaster response and recovery. However, the County emphasizes that any reforms must include sustained funding, technical assistance, and clear definitions of roles to ensure that administrative burdens or significant costs are not shifted onto local governments.

The State of North Carolina, through the Governor’s Recovery Office for Western North Carolina and the NC Department of Public Safety, supports the Council's goals of creating a faster and more flexible disaster system. However, they express specific concerns regarding potential reductions in survivor assistance, the shifting of federal costs to state and local governments, and the need for parametric triggers that account for inland and non-tropical hazards.

Adrian Sevier opposes the Council's recommendations, arguing that the proposed parametric insurance model for public assistance is impractical due to inevitable state challenges over loss valuations. The commenter suggests alternative reforms, such as increasing the per capita indicator, amending the Stafford Act to establish a 50% fixed award, and combining the HMGP and BRIC programs into a state-administered funding stream.

The New Hampshire Department of Safety, Division of Homeland Security and Emergency Management, supports the proposed FEMA reforms but emphasizes the need for a phased approach that accounts for the varying capacities of different states. They argue that reforms must be inclusive of rural and smaller states, advocating for sustained administrative funding and a shift toward proactive disaster preparedness.

The National Association of REALTORS and the National Association of Home Builders submitted joint comments regarding the FEMA Review Council's Final Report. While they support streamlining mitigation funding and simplifying assistance programs, they oppose the proposal to privatize the NFIP through depopulation and express concerns regarding raising disaster declaration thresholds and limiting Individual Assistance.

Ayuda Legal Puerto Rico, a nonprofit public interest organization, opposes the proposed reforms because they would shift disaster costs to states and territories, tie assistance to property values rather than actual needs, and create barriers for survivors with informal ownership. They argue that the proposed changes would disproportionately impact vulnerable populations and jurisdictions with limited economic capacity, like Puerto Rico.

The City and County of San Francisco, joined by the City of Seattle and Snohomish County, opposes several recommendations in the President’s Council report to assess FEMA. They argue that the proposed shifts in responsibility, funding structures, and administrative requirements would impose undue financial and operational burdens on local governments while potentially leaving disaster survivors and communities with inadequate support.

The Environmental Defense Fund (EDF) opposes several recommendations in the FEMA Review Council's Final Report, particularly the push toward privatizing the National Flood Insurance Program and raising federal disaster declaration thresholds. They argue that these changes would undermine community resilience, widen the insurance gap for vulnerable populations, and unfairly shift the financial burden of disaster recovery onto under-resourced state and local governments.

The Maryland Department of Emergency Management (MDEM) supports the FEMA Review Council's efforts to modernize the national emergency management system but urges a phased implementation of its recommendations. They argue that transitioning responsibilities to state and local governments requires sustained federal investment in workforce development, funding, and technical capabilities to avoid fracturing national readiness and placing undue burdens on states.