FEMA Responds to NRDC's Petition for Better State Disaster Planning Requirements

NRDC recently received a response from the Federal Emergency Management Agency (FEMA) to a petition that we filed with the agency nearly a year ago.

Last October, we filed a petition with FEMA asking the agency to ensure that states address climate change in their Hazard Mitigation Plans, which are developed to help states prepare for natural disasters. The plans include disaster risk assessments, statewide vulnerability studies, and strategies to reduce the loss of life and property. Every three years, states submit these plans to FEMA for approval. When the plans are approved, states are then eligible to receive certain FEMA grants to help implement on-the-ground strategies to reduce disaster risks. These strategies include activities like relocating structures out of flood-prone areas and windproofing vulnerable buildings.

Because federal taxpayer dollars are at stake, FEMA needs to ensure that states will spend grant funds as effectively as possible. This means adopting strategies that are based on an accurate understanding of risks and vulnerabilities – including the impact that climate change could have on the state. Since climate change will bring more frequent and more intense natural disasters, including extreme heat, wildfires, droughts, floods, and hurricanes, it is critical that states fully understand their climate risks and plan accordingly. President Obama recognized the importance of increasing resilience and preparing for climate change in the Climate Action Plan he announced this summer. Unfortunately, many states either completely omit or barely address climate change in their Hazard Mitigation Plans, instead relying solely on historical disaster data to estimate – and potentially underestimate – future risks. This practice could needlessly put people and property in harm’s way.

To resolve this problem, the petition we filed last year requested that FEMA do three things:

  1. Approve states’ Hazard Mitigation Plans only if climate change is adequately considered;
  2. Amend FEMA regulations to confirm explicitly that climate change must be considered in these plans; and
  3. Develop guidance for states to provide them with advice and resources for addressing climate change in their plans.

For more background on this effort and the relationship between natural disasters and climate change, check out these blogs about filing the petition, the Hurricane Sandy rebuilding strategy, and GAO’s report citing fiscal exposure from climate change.

On September 16, after 11.5 months, we received an official response to our petition.

In response to our request to approve plans only if they adequately address climate change, FEMA’s response is silent.

Regarding our second request to amend regulations, the letter says :

“FEMA has denied the petition because it does not contain adequate legal justification establishing how FEMA’s existing regulations and policies are insufficient. FEMA’s regulations already require State mitigation plans to include an overview of past and future natural hazard events that can affect the State.”

On the bright side, regarding our third request to improve climate guidance, the letter also says:

“All future guidance for State, local and Tribal mitigation planning will incorporate elements of climate change, as appropriate.”

Moving forward, FEMA must follow through on this commitment to improve the guidance it gives to states so that climate change is a required factor in states’ future hazard projections. We hope to see strong, clear guidance on this topic issued in a timely fashion, as well as enforcement of the requirement to consider climate change in plans. We will keep a close eye on FEMA’s progress. Communities around the country are already feeling the impacts of climate change, and FEMA needs to make sure that all 50 states are ready and resilient. More robust disaster planning will help to minimize loss of life, prevent property damage, and protect federal taxpayers.