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Is Federal Disaster Relief Funding Distributed Equitably?

APTIM’s disaster recovery and mitigation team addresses potential inequity for underserved communities.

Current Funding Challenges in Underserved Communities

APTIM’s Emergency Management and Disaster Services team constantly faces the question, “Are the approaches to disaster relief and mitigation by the Federal Emergency Management Agency (FEMA) considered equitable?”

According to the Congressional Research Service report, “Defining FEMA’s Approach to Equity and Emergency Management: Policy Considerations,” the answer to that question is “not yet.”  inherent disadvantages faced by lower income communities, which negatively affects the extent and speed of their recovery.

Specifically, they report: “Individuals and communities with fewer financial and social resources often inhabit places that are more physically vulnerable to hazards … resulting in greater risk and losses. Additionally, [they] are often less likely to have access to financial resources (insurance, savings, or safety net through personal loans or gifts), to cover disaster-caused losses, unexpected costs, and local cost-shares.” This results in an enhanced negative impact of natural disasters on these groups.

APTIM’s recovery and mitigation team addresses inequality in disaster recovery funding by supporting hazard mitigation applications for underserved communities. Such funds can financially assist, for example, the construction of culverts along major roadways as evacuation routes preventing road washouts during significant flooding events.

Additionally, FEMA’s mitigation application requires a community to perform a benefit cost analysis, which must produce a value greater than one to ascertain eligibility for funding support. In some instances, the low-population densities of low-income areas prevent this qualification from being met. In that scenario, our team assists municipalities in administering mitigation activities using their own funding sources.

A More Equitable Future for Federal Disaster Relief

Recognizing these issues, FEMA is working to address potential inequality in disaster recovery funding and has established new work units in alignment with this goal. These working groups execute on efforts to promote civil rights, modify agency policies found to result in inequitable outcomes, and solicit policy proposals aimed at improving access to disaster relief programs.

FEMA Administrator Deanne Criswell recently affirmed that “FEMA pursues a comprehensive approach to advancing equity as a critical and foundational part of our mission.” As part of their 2022–2026 Strategic Plan, FEMA acknowledges that some individuals and communities may struggle to understand and participate in their disaster assistance programs. Moving forward, they plan to work with state and local partners and underserved communities to understand their unique challenges.

Legally, both the Stafford Act and FEMA’s regulations prohibit discrimination in the provision of disaster assistance. The Stafford Act’s nondiscrimination provision requires FEMA and other organizations to perform disaster relief operations and provide assistance in an “equitable and impartial manner, without discrimination on the grounds of race, color, religion, nationality, sex, age, disability, English proficiency, or economic status.”

Additionally, federal regulations require that governments receiving FEMA assistance collect data necessary to demonstrate compliance with this requirement as well as other civil rights laws. These regulations will help move the needle on providing relief to those who need it most.

Steps Taken for Non-Discrimination

In order to increase equity across disaster relief operations, FEMA has started implementing federal statutes and regulations on equity, civil rights, and nondiscrimination through a number of means, including:

  • Establishing the External Civil Rights Division within the Office of Equal Rights, which is responsible for compliance and enforcement of federal civil rights authorities, including the nondiscrimination requirement in the Stafford Act, for public-facing programs.
  • Appointing a disability coordinator in 2007, as required by the Post-Katrina Emergency Management Reform Act of 2006, and creating the Office of Disability Integration and Coordination to support the work of the disability coordinator in 2010.
  • Providing accessible, sometimes multilingual, communication in certain FEMA guidance documents and public-facing virtual and in-person meetings.
  • Establishing tribal consultation policy pursuant to Executive Order 13175 for “communicating and collaborating with tribal governments to exchange information, receive input, and consider the views of tribes on actions that have tribal implications.”
  • Developing policies and priorities that incorporate equity-based components in accordance with statutory authorities. For example, FEMA may waive the requirement to recoup assistance provided through the Individuals and Households Program if enforcement of the debt would be against “equity and good conscience.”

FEMA still has a significant road ahead if it is going to equally serve the underserved communities as it does more affluent, densely populated communities. However, these initial policies demonstrate a step in the right direction by acknowledging the disproportionate challenges faced in areas that are more vulnerable to disaster and less likely to obtain funding relief.


Steve Kral
Director of Recovery and Resiliency

APTIM. In Pursuit of Better.

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